Affordable, legal alternatives to BP for ejection charges?

In this pic you can see the installed igniters for both charges. On top (left) the canister for the drogue/nosecone charge (0,25 gram), and the 30 mm body tube contains the 70 cm main chute (and 0,2 gram flash cotton). The entire module fits into a 2 1/4" LOC body tube.

Bat-mite said:

Hi, all. So far, from what I gather, the alternatives for doing BP ejection charges are:

1. Buy BP from a gun store and lie about having a muzzle loader.
2. Buy a cheap old muzzle loader and buy BP from a gun store and tell the truth about having a muzzle loader.
3. Buy BP from a gun store and get a LEUP.

So, supposing I had an aversion to lying, and didn't want to buy a muzzle loader, and didn't want to pay for a LEUP, are there any legal, affordable alternatives to BP that people are using?

I saw that Apogee has some kind of CO2 ejection, but it looks rediculously expensive. Thanks!

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I reckon you could make a workable enough one of those (one of those being a typical pyro actuated CO2 deployment device) with not much more than a drill press, hacksaw and bench grinder ... with a bit of ingenuity. Provided you can find some dowel rod that closely matched a CO2 bulb's diameter.

Troy

BenAlbers said:

In this pic you can see the installed igniters for both charges. On top (left) the canister for the drogue/nosecone charge (0,25 gram), and the 30 mm body tube contains the 70 cm main chute (and 0,2 gram flash cotton). The entire module fits into a 2 1/4" LOC body tube.

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Thanks of the pictures,looks like a great system.

wfcook said:

The federal regulations only allow possession, transport, use, etc. of BP for use in antique weapons. All Of the above-cited exemption, yearly allowances, etc do not apply in rocketry. This is not a Maryland thing, although I am not necessarily defending the regulatory environment in Maryland.

Note that the ATF has recently clarified it's position on BP substitutes and they treat them exactly the same as BP...

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You are incorrect about BP substitutes now being regulated the same as black powder. There are two 'explosives' lists: one that requires an ATFE license and one that adds additional penalties if you commit a crime using something on the list.

This post explains why I say this:

https://www.rocketryforum.com/showt...ple-7-FFFG-Black-Powder&p=1582221#post1582221

The ATF now says the if you blow something up using a black powder substitute they can charge you under the 18 U.S. Code § 844 - Penalties section of the law. It does not mean that you now have to have a FFL to use a BP substitute. If you read the list you are referring to you'll see there are many other items listed that do not require an ATF permit such as smokeless powder (which is specifically exempt from ATF regulation via federal law).

but the TL;DR version is this: you can get in extra big trouble if you use black powder substitutes in a crime but you they are NOT regulated the same as black powder and you do not need a permit.


Tony
ps: and you can use BP legally in any weapon made for it, it does not have to be an antique. There are many modern firearms designed for black powder that allow you to use BP exempt from BATFE regulation.

BenAlbers said:

In this pic you can see the installed igniters for both charges. On top (left) the canister for the drogue/nosecone charge (0,25 gram), and the 30 mm body tube contains the 70 cm main chute (and 0,2 gram flash cotton). The entire module fits into a 2 1/4" LOC body tube.

Click to expand...

It may work fine, but compared to BP its extremely expensive and is definitely hazardous to ship (which is why its shipped wet,) a 300g (wet package weight, not sure what the dry weight is after liquid is allowed to evaporate) is about $24 for the one seller I saw that will ship to the US. BP on the other hand is $20-$25 depending on where you buy it here in the US per pound (453g, of which that is dry usable weight). I get using something like flash cotton if BP is not available in certain countries or locations.

The whole " used solely for sporting, recreational, or cultural purposes in antique firearms" is up for interpretation. I've read posts where people have posted that their LEUP inspector told them that rocketry falls under the "recreational" term and BP used for that is exempt. Then people have posted that their LEUP inspector told them that any use must be in "antique firearms" to be exempt. That tells me that even the ATF doesn't know how to interpret the law/regulations.

Now for my OPINION! We all know what Opinions are worth, but this is mine. I think that if you are using BP for ejection charges for your model rocket there isn't an ATF agent that is going to say a thing about it, much less charge you with anything. I believe the only way you would ever get charged by any law enforcement agency for the use of BP in rocketry is if you also intentionally used BP to commit a serious crime. It would be one of the many additional charges the would be loaded up with the initial charge. I really believe any law enforcement officer that would charge you solely with the use of BP in your rockets would have a hard time keeping his job because there are so many more serious offences he can pursue. Kind of like a traffic cop that spends a lot of time catching people going 1 or 2 mph over the limit, he isn't going to be working long. Then you have the prosecutors that have to try a case like that. If you push back at all, they are going to drop it as not worth their time or money since they have so many more serious crimes to prosecute.

With all that said, there is no guarantee that someone won't be charged with an explosive violation for using BP in a rocket. If that happens to be me, I'm going to push back as far as I can because only a court ruling will finally sort out exactly what "used solely for sporting, recreational, or cultural purposes in antique firearms" really means.

So you all have to decide for yourself what the use of BP in rocketry really means to you and are you going to use it. Is it exempt under the "recreational" phrase, is it like driving 1 mph over the speed limit and never enforced or is it like blowing up a mail box and going to be a federal case.

Tune in to this thread, many past threads, and I'm sure many future threads to hash over the legality of using BP in rockets over and over with no definitive conclusion. It's one of the things that keeps TRF going!

Handeman said:

The whole " used solely for sporting, recreational, or cultural purposes in antique firearms" is up for interpretation. I've read posts where people have posted that their LEUP inspector told them that rocketry falls under the "recreational" term and BP used for that is exempt...

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The only exemption for 'recreational' use is IN A FIREARM. For example, from 18 U.S. Code § 921 - Definitions:

"or is a rifle which the owner intends to use solely for sporting, recreational or cultural purposes."

It is clear from the above the 'recreational' applies solely to a use of a firearm and is not independent. Arguing that the exemption for black powder means something different is fraught with peril.

I do have a black powder flintlock that I keep with my BP. I have an FFL so I can not take any chances with how an ATF agent decides to interpret the law.

On the other hand, I am worried that the ATF will show up at a rocket launch and start arresting folks for using BP in rockets? No. But I do think that it is important to understand what the law and ATFE really mean.


Tony

and no, I am not a lawyer nor do I play one on TV

I agree, the law and clear, and we do not fall under it. I also agree the ATF isn't likely to be raiding a launch any time soon.

But if you have a launch go badly, and in the investigation it comes out that BP was used, and it caused say, a fire.... you're f'd.

Not saying don't do it..... but be prepared for that possibility.

I think something is being missed here..........

How can AT ship loose BP with their reloads for ejection charges if it is not legal??

Are you saying every AT reload is illegal??

Lowpuller said:

I think something is being missed here..........

How can AT ship loose BP with their reloads for ejection charges if it is not legal??

Are you saying every AT reload is illegal??

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No one is suggesting that. The ATF sees a difference between products that include BP (such as ammunition, nail gun cartridges, and Aerotech reloads) and sales of loose BP.

-- Roger

The flash cotton I buy is sold per 20gr, indeed wet, and as long as it is stored a little moist it is very safe. This 20 gr is enough for 40 launches so no need to buy large amounts. Buying BP in the Netherlands is difficult, and flash cotton is freely available. But most of all: the extremely clean burn keeps my rockets in great shape. I sometimes even replace the black powder of LP motors by this stuff.

Maybe somebody (AT perhaps) should start selling ejection charge reloads.

Lowpuller said:

Maybe somebody (AT perhaps) should start selling ejection charge reloads.

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They already do.
https://www.rocketmotorparts.com/Initiators_and_Ejection_Charges/cat1577810_3473815.aspx


Steve Shannon

jadebox said:

No one is suggesting that. The ATF sees a difference between products that include BP (such as ammunition, nail gun cartridges, and Aerotech reloads) and sales of loose BP.

-- Roger

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I think they also see a difference in use. Sale of loose BP isn't the same as use of BP. You have to remember there are a few pages of "law" as passed by congress and reams of regulations created by the ATF. That is what got the ATF in trouble at the start of the lawsuit in 2000. Judge Walton set aside all of the regulation the ATF created by sending a letter to AT in 1994 because they didn't use the correct public comment periods and methods of creating the regulations. Of course they went through the "correct" process and totally ignored all public comments and made the regulations exactly like they wanted.

If you really want to see how regulation creation and public comments are supposed to work, look at what the FAA did when they got rid of Model Rocket, Large Model Rocket, High Powered Rockets and went with the new class 1, 2, & 3 methods. They accepted many of the comments as valid and modified the proposed regulation to account for those comments and idea. Many of us don't believe they got everything right, but it was much better for almost everyone involved.

Sorry Tony but you and your AFT agent's opinions don't matter. Neither does mine. The only opinions that count come from the AFT legal Department and appellate court decisions!

But in my job I had to deal with local, state and federal explosives compliance issues for more than 2 decades before I retired and I have a real good knowledge on explosives laws. I build and got both ATF and DDESB approval for our Type 1 explosives magazine, had all the necessary Federal explosive use and manufacturing permits, and the DOT special permits to ship explosives. I was paid to know what the regulations were and where they were applicable.

The small arms components exemption is spelled out in the Orange Book. It only applies for small arms and ammunition and the last time I checked, hobby rockets are not classified as small arms or ammunitions, nor are the recognized by the AFT as such. Both NAR and TRA recognize ATF's position and as far as the hobby is concerned we really don't have to go any further.

• Do some of the ATF regulations make any sense? No.
• Do most hobbyists use BP for ejection charges? Probably yes.
• Does ATF really care? Probably not.
• Could ATF enforce their regulations if they felt like it? Absolutely.

What the ATF Regulations are and what ATF has to say about them.

https://www.atf.gov/file/60711/download The 2016 ATF Explosives List. Black powder substitutes are on the list. Crimson Powder is an ascorbic acid based black powder substitute,

https://www.atf.gov/explosives/docs...ves-laws-and-regulations-atf-p-54007/download Orange Book 2012 pg. 100
Black Powder TransactionsPublic Law 93-639 (1975) allows nonlicensees/nonpermittees to purchase commercially manufactured black powder, in quantities of 50 pounds or less, solely for sporting, recreational or cultural purposes for use in antique firearms or antique devices. A nonlicensee or nonpermittee purchasing black powder under the exemption need not be a resident of the State in which the dealer is located. Also, the categories of persons to whom the distribution of explosive materials is prohibited do not apply to black powder transactions made under the exemption. Acquisitions of black powder not qualifying under this exemption are subject to the same regulatory requirements that govern any other low explosive.All persons who distribute black powder, regardless of quantity, must be licensed as explosives dealers and, among other things, must provide adequate storage.

https://www.atf.gov/file/106536/download June 2016 ruling on nitrated cellulose being a high explosive. Page 2!

Nitrated Cellulose is what makes glossy paper glossy. It is what ping pong balls are made from.
Are either high explosives? No.
Is wetted nitrocellulose explosive? No. It's been tested by DOT and shown not to be.
Does the AFT ruling make sense? No.

Maybe the Donald will appoint Wayne LaPierre as Head of the ATF. That would solve everyone's problem.

But until that time, we have to deal with a bunch of dumb unenforced regulations that are still on the books and that can be enforced at the whim of an agent or the agency.

My dual deployment in action (Leviathan). Main chute at 300 ft

Snipped for brevity

bobkrech said:

Sorry Tony but you and your AFT agent's opinions don't matter. Neither does mine. The only opinions that count come from the AFT legal Department and appellate court decisions!...

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Bob,

You make a single, fundamental error in your conclusions. The regs you cite apply to manufacturers, importers, and dealers. Not to the end user.

The addition of black powder substitutes is for the purposes of commerce, not use. Your experience in industry is not the same as my experience as a consumer. Further, the list of explosives published that you refer to is also used for:

18 U.S. Code § 844 - Penalties

which does not impact our use.

Here's an example of what I mean, from ATF book you link to (all emphasis is mine):

"81. Is smokeless powder designed for use in small arms ammunition subject to the explosives storage requirements?
Smokeless propellants designed for use in small arms ammunition are exempt from regulation under 18 U.S.C. Chapter 40 and the regulations in 27 CFR Part 555. However, it should be noted that persons engaged in the business of importing or manufacturing smokeless propellants must have a Federal explosives license. Additionally, smokeless propellant designed for use other than small arms ammunition is not exempt. Therefore, explosives products such as squibs, fireworks, theatrical special effects, or other articles that may be utilizing smokeless propellants are regulated and must be stored accordingly."

https://www.atf.gov/explosives/docs...ves-laws-and-regulations-atf-p-54007/download page 69

In your case as a manufacturer you were under the purview of the law. In fact I am working right now with a manufacturer of military ammo so I am also familiar with many of the ATFE rules and regs regarding smokeless powders. Note though that it only applies to manufacturers, not dealers. But as a consumer of smokeless powder I am exempt unless I use them in a criminal activity, in which case I fall under section 844. Note that the the italicized text refers to design, not use. It does not say 'smokeless propellant designed for small arms ammunition but used otherwise is not exempt'. It is very clear. The same exemption is not afforded to black powder, it is ONLY exempt when used in a suitable firearm.

I'll end with a final example. If you are in the business of selling firearms, you are subject to federal ATFE laws and regs. However, as a private individual, if I decide to sell you a firearm in non-interstate commerce, I am exempt from such. Much of the same applies to the explosives regulations.

I'll leave you this challenge: please provide a link to an ATF document that says consumer purchases and use of smokeless powder or black powder substitutes requires a permit or license, or that it's use in a manner not intended to cause harm constitutes a violation of explosives laws. If I'm wrong, I'm wrong. As familiar as you seem to be I'm sure you'll find a link that shows our use of smokeless powder or bp substitutes is regulated. But so far I have not seen it.


Tony

ps: at the end of the day we all make our own decisions on what to do or not to do, it is not my intention to induce anyone to do something they feel may be against regulations

As a person who does not manufacture, modify, import, or even own much in the way of firearms, explosives, ammunition, or BP substitutes; I -really- appreciate this informed & informative discussion.

manixFan said:

"81. Is smokeless powder designed for use in small arms ammunition subject to the explosives storage requirements?
Smokeless propellants designed for use in small arms ammunition are exempt from regulation under 18 U.S.C. Chapter 40 and the regulations in 27 CFR Part 555. However, it should be noted that persons engaged in the business of importing or manufacturing smokeless propellants must have a Federal explosives license. Additionally, smokeless propellant designed for use other than small arms ammunition is not exempt. Therefore, explosives products such as squibs, fireworks, theatrical special effects, or other articles that may be utilizing smokeless propellants are regulated and must be stored accordingly."

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I'm betting using smokeless in a rocket is going to get tripped up by this. I do not believe you have some bulletproof loophole here. Sorry.