New Ruling on Wetted Nitrocellulose

[Risasi]

What's up with this?

http://www.ammoland.com/2016/08/atf-...#axzz4IlcTAb1e

[Bartholomew Roberts]

That's the Chicago way. The current Administration and its designated successor are going to do everything they can to make legal gun ownership unpleasant and difficult via regulation outside Congress. If that fails, they'll do their best to make selling ammunition and firearms unprofitable via regulation.

Surrender to the Administration's gun control goals or else.

[Risasi]

I was afraid someone would confirm my deep set fear it meant what I thought it means.

Sounds like I better go out and pick up a few pounds of powder tomorrow, eh? I got a feeling it's going from about $25 to $40 here soon...

[SPEMack618]

So this affects reloading powder too? I'm a bit confused.

[Risasi]

Perhaps this will shed some light. From the article:

III. Impact of ATF Reclassification

Manufacturers and importers of smokeless propellant have relied on ATF private letter rulings issued prior to 2016 stating that nitrocellulose wetted with water not less than 25 percent by mass is not subject to regulation under the federal explosives laws. Accordingly, the manufacturers have set up their logistics, storage and operations consistent with nitrocellulose not being regulated as an explosive. Manufacturers and importers may not have adequate storage facilities or record keeping systems to comply with the law. Licensed manufacturers also rely on private, unlicensed vendors to store wetted nitrocellulose in facilities that do not comply with storage requirements. A number of manufacturers also report an adverse impact on their contracts to supply smokeless propellant and finished rounds of ammunition to the Department of Defense.

Publication of the change in classification in an industry newsletter without advance notice has left manufacturers scrambling to determine what standards ATF will allow for alternate storage and record keeping and to obtain permits for unlicensed storage vendors. In the meantime, manufacturers and importers are violating federal law, as ATF allowed no grace period for coming into compliance. We note that ATF has authorized such periods in the past when changing agency positions. For example, see ATF’s November 12, 2010 Open Letter regarding explosive pest control devices.

I'm sure it doesn't affect all of the powder manufacturers, but some of them are very likely to get burned. Just like when the EO was floated a couple of months ago to redefine gunsmithing procedures, like dovetails and accuracy modifications as "manufacturing". Thus requiring another couple grand in licensing. That will destroy the small business gunsmith.

I see nothing good coming of this one either. It will likely affect ammunition manufacturers and reloaders.

[mag1911]

When the ITAR/gunsmithing thing started up a while back I was afraid something like this would be next:

http://thefiringline.com/forums/show...21#post6335121

I'm guessing we're going to see a blizzard of these regulation "enhancements" before the election. I see it as the administration's effort to divert gun-rights attention by focusing our bandwith on this stuff and away from the election.

What I'm really afraid of is they're saving their "best stuff" for last.

[thallub]

It's more misinformation from that purveyor of trash, Ammoland. They have the link to the BATFE document on their site. They are betting that very few pro-gunners will bother to vet their sensational trash.

ATF was recently asked about the status of nitrocellulose under the Federal explosives laws and regulations. “Nitrocellulose explosive” is on ATF’s List of Explosive Materials. ATF has determined that nitrocellulose containing greater than 12.6 percent nitrogen is a high explosive under 27 CFR, Part 555 (nitrocellulose containing 12.6 percent or less nitrogen is generally not an explosive material under Part 555). Therefore, it must be stored in a type 1 or type 2 magazine. We are aware that the U.S. Department of Transportation may assign a nonexplosive classification to nitrocellulose when it has been wetted with water or alcohol. This is based, in part, on the diminished likelihood of explosion in a transportation accident. Because the nitrocellulose retains its explosive characteristics when the water or alcohol is removed, the wetted nitrocellulose remains a nitrocellulose explosive, subject to the licensing, safety and security requirements of the Federal explosives regulations. However, based upon the diminished likelihood of wetted nitrocellulose exploding, ATF will consider variance requests to store the wetted material under an alternative arrangement.

https://www.atf.gov/file/106536/download

BTW: Nitrocellulose in higher concentration is also called guncotton. Two of my friends were burned to death when they laid out wetted guncotton prior to burning. In order to speed up the drying process they raked it, causing a conflagration that cost their lives.

[Risasi]

I hope you're right, and it is just a "sky is falling" garbage article.

[Bartholomew Roberts]

Originally Posted by thallub

hey have the link to the BATFE document on their site. They are betting that very few pro-gunners will bother to vet their sensational trash.

Speaking of vetting, did you notice they included the entire text of the ATF letter in the actual article in addition to the link? That seems an odd step to take if you are trying to sell sensational trash.

Since you hold yourseld to be in a position to evaluate this claim, which of the specific claims are sensationalistic in your view? Has ATF issued private letter rulings that wetted nitrocelluose of less than 25% nitrogen is not an explosive requiring an explosive magazine? If ATF has done this, how many manufacturers were relying on that ruling in their daily operation? Did ATF just change thus ruling with no advance notice or comment period?

Which of those claims are sensationalistic?

[thallub]

That seems an odd step to take if you are trying to sell sensational trash.

Not really. First of all the BATFE did not reclassify nitrocellulose. Wetted nitrocellulose has been classified as an explosive material for decades. This sensationalistic headline from Ammoland is a lie:

ATF Reclassifies Wetted Nitrocellulose as Explosive Materials Under Federal Laws

Many on these boards seldom read anything. Ammoland is counting on folks to parrot their trash. Ammoland and other purveyors of guns and ammo have a vested interest in keeping the "Obama will take your guns" panic alive because it makes them a lot of money.

Has ATF issued private letter rulings that wetted nitrocellulose of less than 25%nitrogen is not an explosive requiring an explosive magazine?

Not that i'm aware of.

From a friend in the know: "I just got off the phone with Chris Hodgdon and Chris stated that at this time there are NO implications that this will have on the U.S. market at this time. Chris stated that this new regulation was purely for controlling the transport and storage of raw form nitrocellulose and should NOT have an impact on the consumer market."

https://www.ar-15.co/threads/158199-...osive-Material

[steve4102]

. I'm sure it doesn't affect all of the powder manufacturers, but some of them are very likely to get burned.

How many smokeless powder manufacturers in the US?

General Dynamics and who else?

[Bartholomew Roberts]

Not that I'm aware of

And how many private letter rulings are you aware of on any topic?

From a friend in the know:

So.... Ammoland is sensationalistic trash because random guy in an Internet thread says a friend of a friend told him... I mean, I'm open to the argument this is sensationalistic; but it seems your standard of skepticism varies a bit.

It seems the key elements to determining this are:

1) How many smokeless powder manufacturers are using nitrocelluose in excess of 12.6% nitrogen.

2) Of those, how many are relying on an earlier private letter ruling or variance saying such nitrocelluose is not an explosive when wetted 25% by volume for either storage or logistics?

Without knowing that information, I'm not sure how you can assess the impact.

[Jim Watson]

I saw last night on another board that the letter was "in error" and that it will be business as usual in the powder business. We shall see if that is so.

Any road, there are only two manufacturers of smokeless powder in the USA and surely they handle nitrocellulose properly.

Also, the redesignation applied only to nitrocellulose containing more than 12.6% nitrogen. A powder MSDS I recently looked up called for NC of 12.6% N, so that intermediate would not be affected.

I have seen an old description of powder manufacture that said the desired degree of nitration was produced by blending, so if they still do that, they are handling something stronger that could be restricted, if that regulation went through. It would still be internal to the powder mill and the end user probably would not see any change... except higher prices like our friends in the shipping business have given us with Hazmat charges.

[Bartholomew Roberts]

How many smokeless powder manufacturers in the US?

Hogdon, Alliant, Accurate. There are a few others I'm aware of (Winchester, IMR) that have some subsidiary relationship to Hogdon. It seems though that if those manufacturers were being adversely affected to a major degree we'd be hearing about it from them (or NSSF or NRA in the event that wasn't politically expedient for the manufacturer).

[thallub]

With the exception of Alliant, most commercial gun powder is made overseas and packaged the USA. Most of the IMR powders are made in Canada. Most of the Hodgdon branded powders are made in Australia.

[P5 Guy]

St. Marks FL is the winchester powder factory still there?

[steve4102]

. Hogdon, Alliant, Accurate. There are a few others I'm aware of (Winchester, IMR) that have some subsidiary relationship to Hogdon. It seems though

These are distributors of the finished product.

That do not manufacture any smokeless powder

[thallub]

St. Marks FL is the winchester powder factory still there?

i forgot about Winchester. It's now owned by General Dynamics:

http://www.gd-ots.com/commercial_powder.html

[Jim Watson]

SOME Alliant powders are made in Radford VA where ATK runs the military ammo plant.

ALL Winchester Ball powders and Hodgdon Spherical powders are made at St Marks, FL, plant now owned by General Dynamics.

That is it, as far as US powder makers.

Western Powder (Ramshot and Accurate) comes from all over, St Marks and foreign. The Alliant Reloder line comes from Sweden and Switzerland.

Hodgdon is kind of a mess, they have grabbed the distributorship for a lot of stuff, Winchester, IMR, and Vihtavuori that I know of.

Their own stuff, Spherical from St Marks, extruded from ADI Australia and IMR Canada, flake from ADI, IMR, and Alliant. They also own Goex and make Pyrodex or have it toll manufactured by a contractor.

[Bartholomew Roberts]

In that case, I'd say sensationalistic then. BATFE won't be winning any battles with ATK or General Dynamics.

[H.W. French]

Hey Jim! I think you meant Radford, VA.

[Jim Watson]

Well, yes I did.
No excuse, I've been there.

[Risasi]

Well, I'm a little more relieved. I guess I'll hold off on buying a couple more lbs of powder. I knew if I posted this here it would get vetted properly.

[Slamfire]

ATF Reclassifies Wetted Nitrocellulose as Explosive Materials Under Federal Laws

http://www.ammoland.com/2016/08/atf-...ederal-laws/?-

At the point the nitrocellulose is incorporated into smokeless powder or a complete round of ammunition, it is exempt from the requirements of the record keeping, storage, and other requirements of federal law and regulations.

I am aware that old deteriorated Navy cannon powder was stored under water in storage pools, prior to reclamation. Water absorbs the nitric acid gas that comes out of deteriorating nitrocellulose and keeps the mix cool. The shooting community is generally not aware that nitrocellulose is highly dangerous as it deteriorates, and as it deteriorates, it heats up, causing auto combustion.

ROLE OF DIPHENYLAMINE AS A STABILIZER IN PROPELLANTS; ANALYTICAL CHEMISTRY OF DIPHENYLAMINE IN PROPELLANTS

Nitrocellulose-base propellants are essentially unstable materials that decompose on aging with the evolution of oxides of nitrogen. The decomposition is autocatalytic and can lead to failure of the ammunition or disastrous explosions.

http://www.dtic.mil/dtic/tr/fulltext/u2/783499.pdf


Gunpowder is a mixture of nitrocellulose and stabilizers, plus 11 herbs and spices. If nitrocellulose dries out there is no reason to assume that it won't ignite. After reading the above listed post, I am going to say it is probably that due to lack of oversight, some wetted nitrocellulose did dry out and went kaboom or almost went kaboom. So the ATF is probably requiring manufacturers to now pay more attention to the stuff.

[Jim Watson]

We can calm down, now.
https://www.atf.gov/file/109341/download

ATF’s June 2016 Explosives Industry Newsletter included a brief discussion of Nitrocellulose, and attempted to clarify the circumstances under which wetted Nitrocellulose is considered a high explosive under 27 CFR, Part 555. As with all explosives, ATF’s focus is on the potential public safety risks associated with materials that can be misused or diverted to unlawful purposes. Subsequent contact from industry members who import, transport, store or employ wetted Nitrocellulose in the production of ammunition, however, has brought to our attention issues that were not fully addressed in the Newsletter and require further consultation and consideration with the industry. Accordingly, ATF has and will conduct further industry outreach concerning wetted Nitrocellulose. In the interim, previously authorized industry practices concerning wetted Nitrocellulose will not be affected.