Round up to nearest whole pound: BATF and BP inspection?

[jcsquire]

I *know* I remember reading on this forum about 3 years ago that the BATFE issued a newsletter saying inventory measurements of black powder should be rounded up to the nearest whole pound. Does someone recall which newsletter? Since I typically use 15 grams at a time, my inventory sheet looks like

-15 g for rocket launch 1 lb remaining
-15 g for rocket launch 1 lb remaining
-15 g for rocket launch 1 lb remaining
-15 g for rocket launch 1 lb remaining
-15 g for rocket launch 1 lb remaining

Today I had an inspector who said he had not heard of that rule, and he said it didn't make sense that the records should show an unchanging amount...that I should be posting the actual remaining amount. What he says makes sense to me; 15 g is about 0.5 oz. But I'm almost sure that contradicts what I read in a post here on the Forum about a past newsletter. The orange book doesn't specify, meaning Federal Statue is silent on this, but some faceless administrator QC'ing the agent's work can still refuse to process the request if it doesn't comply with the technical bulletins. I've tried Googling, Googling:rocketryforum.com, and searching the BATF newsletters, but nothing.

Does someone here remember the post? (Please don't let this devolve into ad-hominem attacks on the inspector, or the idiocy of the law. It is what it is.)

 

[cobra1336]

To start, I have never had any problems with batf inspections and their agents. Never heard of logging bp usage. We are talking ejection charge powder, right. Where I live you don't need to put it on your log. It can sit on the shelf in the garage. I still put it in my magazine just in case. Yeah, yeah I know, motors are declassified but I still keep to the old rules. There's that igniter, starter question.

 

[jcsquire]

@cobra,

Right, we're talking how to enter the amount used for black powder ejection charges. Be careful of saying "where I live it can sit on the shelf in the garage"; since the ATF regs were re-written in 2002, BP must be transported in a Type 3 magazine and stored in a Type 4 (section 555.203) unless your use falls under the NRA exemption of 2006 (section 555.141).

Pretty much all I've seen the ATF agents do every 3 year visit is to check that the magazine is clean and that the inventory records are current. Section 555.121 says we have to keep both per-use and annual inventories of all explosive materials, where the word "explosive materials" is defined in Section 841 to include black powder. But they're not used to checking for such minuscule amounts, so don't know what to do with sub-pound levels. I don't know if I would bother with all this if not for the fact I'm a teacher, so want to be perfectly legal when advising my students...