What are rules concerning igniters?

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TWRackers

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Okay, maybe I've missed something in all the discussions about igniters, so bear with me.

Item 1: New rules regarding APCP spell out numbers about how much APCP can be stored, what permits are required, etc. etc.

Item 2: The relevant law as written includes igniters along with other items as "explosives" or "low explosives" or whatever, and therefore they are "regulated".

Item 3: It appears that manufacturing igniters requires a LEMP, and selling them requires a LEDP.

Question 1: Does possession of igniters require a LEUP?

Question 2: What are the limits regarding igniters? Rules have hard numbers to them; less than this much is okay, more than this much requires storage or permits or whatever. So what are the regulations (quantities, storage means, etc.) regarding igniters?

The only thing I've heard so far is that igniters probably should be stored in a magazine like the motors/reloads are, and possibly a separate magazine, depending whom you ask. I don't remember seeing anything about numbers of grams or numbers of igniters or anything else. Or have the regulations which "regulate" igniters not been written (yet)?

This is NOT a discussion about whether igniters or motors or APCP or anything else should be regulated, just a query as to what the regulations or rules are for igniters. This is also NOT a discussion concerning HAZMAT fees, LEMPs, or selling or shipping igniters; I'm only talking about possession of igniters.

Please try to post replies that address the questions asked without getting into those debates that get threads either partially or completely deleted. I'd really like to get some facts here.
 
Thomas,

There are no hard and fast regulations regarding ignitors. From what I've been able to gather this is the situation as it now obtains:

1. E-matches

The BATFE has been regulating standard e-matches as explosives for a year or more. Most dealers will not sell them to a consumer unless that person has a LEUP.

2. Ignitors

The BATFE seems to be opening a new front in their war on model rocketry by trampling on ignitor manufacturers. There are no hard and fast regulations regarding ignitors, but from anecdotal comments here and on other forums it appears that ignitors supplied with motors/reloads are considered part of said motor/reload. Replacement ignitors sold as replacement parts for motors/reloads by the orginal manufacturer are probably also not of concern. Third party ignitors are probably going to require a LEUP to buy or possess. Home made ignitors have not been addressed by the BATFE recently but will probably need a LEUP for transport off of the owner's property.

Ken Holloway
NAR #78336, L_II
 
ken: the solution is to "make and use" igniters onsite at the launch......

or as the BATFe Q&A sceanrio points out, assuming a LEUP is needed, have a person who owns the igniter provide one for use onsite (asuming of course you do not fall in the prohibited persons category)

The above is allowed for HPR motors that require a LEUp: so I am speculating that what is good for motors would also be good for igniters.

terry dean
nar 16158
 
Terry,

I don't believe that making ignitors at a launch would get around the BATFE's contention that ignitors are a regulated explosive. Making them at home on your own property would probably not be prohibited but making them at a location not "owned" by you would probably require a LEMP.

On the other hand your point about a LEUP holder supplying an ignitor to a non-LEUP holder at a launch is probably valid. Its just that things are going to get awfully complicated if that's the only way to get one.

Ken Holloway
NAR #78336, L-II
 
Originally posted by TWRackers
Okay, maybe I've missed something in all the discussions about igniters, so bear with me.

Item 1: New rules regarding APCP spell out numbers about how much APCP can be stored, what permits are required, etc. etc.

Item 2: The relevant law as written includes igniters along with other items as "explosives" or "low explosives" or whatever, and therefore they are "regulated".

Item 3: It appears that manufacturing igniters requires a LEMP, and selling them requires a LEDP.

Question 1: Does possession of igniters require a LEUP?

Question 2: What are the limits regarding igniters? Rules have hard numbers to them; less than this much is okay, more than this much requires storage or permits or whatever. So what are the regulations (quantities, storage means, etc.) regarding igniters?

The only thing I've heard so far is that igniters probably should be stored in a magazine like the motors/reloads are, and possibly a separate magazine, depending whom you ask. I don't remember seeing anything about numbers of grams or numbers of igniters or anything else. Or have the regulations which "regulate" igniters not been written (yet)?

This is NOT a discussion about whether igniters or motors or APCP or anything else should be regulated, just a query as to what the regulations or rules are for igniters. This is also NOT a discussion concerning HAZMAT fees, LEMPs, or selling or shipping igniters; I'm only talking about possession of igniters.

Please try to post replies that address the questions asked without getting into those debates that get threads either partially or completely deleted. I'd really like to get some facts here.

Item 3: It appears that manufacturing igniters requires a LEMP, and selling them requires a LEDP.
1.) A LEMP allows you to manufacturer and distribute. If you have a LEMP you don't need a LEDP to sell.

Question 1: Does possession of igniters require a LEUP?
Yes .... unless.
1.) Igniters that come with exempt motors are exempt, along with their black powder ejection charges.
2.) The igniter you possess has been proven not to be an explosive.
3.) It was self manufactured for your own use.
4.) Contrary to popular belief, the 62.5 gram limit does not apply to igniters, it applies only to APCP.
5.) Igniters must be stored in approved magazines. They must be in a separate magazine from APCP or any other explosive. I'm supposing the upper weight limit is 50 lbs.

If you ask 6 different ATF agents across the country you will get 6 different answers. I'd guess that most will say you must have a LEUP or better to use or own an igniter.
 
Other info is that the word Ignitors is on the explosives list so it all just depends on what the ATF or your agent classifies as an Explosive see davids explanation above of the 6 different answers...
 
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