BATF Annual Inspections: Storage Letters

BATF Annual Inspections: Storage Letters

Post by Curtis Schol » Thu, 21 Sep 2000 04:00:00



Hi there all you (NON) Storage LEUP holders:

   With my latest inspection about 3 weeks ago, the subject came up about
letters from people/companies willing to allow one to store temporarily
one's class "B" purchases. It seems the BATF wants to insure that all LEUP
holders have some sort of storage arrangement whether at the house/property
or in another's storage area. Call it what you want, the "non-storage" LEUP
has become or has always been a storage "arrangement". John Cato has been
shouting this 'til he is blue in the face that it has always been about
storage.

   I was first told about the letter when I got my initial 1 year LEUP.  The
agent I was coordinating with asked me to get it. Luckily, Ross D. at Magnum
granted me that letter. This was at least 3 years ago.

   A friend of mine that lives close to me also has his LEUP. He got his a
little before me. He was not informed of the letter in his initial round.
His recent inspection has made him scramble for a letter or get his
magazine. He has elected to get his magazine together.

   How many of you out there have been caught flat footed about this
requirement with the latest round of annual inspections?

   If you have not received notice that your local agent wants to inspect
your facilities, now is the time to prepare. Try to make an arrangement with
anyone you can that has storage and have that person write you a letter
allowing you to store. It's either the letter or buy/build that magazine.

   Just trying to inform all you BHM (Big Honkin' Motor) users.

Curtis Scholl
TRA 3976
NAR 72953
RRS

 
 
 

BATF Annual Inspections: Storage Letters

Post by Cochran T » Thu, 21 Sep 2000 04:00:00



Quote:

>Hi there all you (NON) Storage LEUP holders:

>   With my latest inspection about 3 weeks ago, the subject came up about
>letters from people/companies willing to allow one to store temporarily
>one's class "B" purchases. It seems the BATF wants to insure that all LEUP
>holders have some sort of storage arrangement whether at the house/property
>or in another's storage area. Call it what you want, the "non-storage" LEUP
>has become or has always been a storage "arrangement". John Cato has been
>shouting this 'til he is blue in the face that it has always been about
>storage.

...
>   If you have not received notice that your local agent wants to inspect
>your facilities, now is the time to prepare. Try to make an arrangement with
>anyone you can that has storage and have that person write you a letter
>allowing you to store. It's either the letter or buy/build that magazine.

Note that it may not be quite that easy, since a magazine typically also
requires local AHJ approval and/or license. Some people have been unable
to get that, even if they fully comply with BATF Regs (hence the
lawsuit).  Leave plenty of time.

I wonder if the BATF would accept, in lieu of a storage letter, an
affidavit that you will burn all motors on the day you get them (by static
firing if necessary) thus obviating the need for storage?

--tc

My opinions only.

 
 
 

BATF Annual Inspections: Storage Letters

Post by Bill Baldwi » Thu, 21 Sep 2000 04:00:00


This is interesting.....
I asked my agent about a "non-storage" LEUP,  and was told there is no
such thing.....hmmmmmmm  I know fliers that have non storage LEUP
I already had the magazine...
The agent was more interested in the storage magazine (as far as Orange
Book requirements)  than location...
However,, I did apply for the "attached garage" variance. and was
denied.....reason....   I have an attached car port (with double
lockable 5 tumble locks).......
I did have a steel building in the back yard that was
acceptable.....but, it is not located within the distance table as shown
in Orange book......
The steel building is 12 X 20' and it does not have wood interior as O
Book required....
Hmmmmmmm
Seems LEUP is granted per agent instead of "by law".....
I was told anything above 62.5g had to be stored....
The key word is "assembled"   and ATF does not differentiate between
single use and reloadable motors...    key word    assembled..
G38's are more than 62.5g        
You know, the ones on the wall rack in hobby shops....
Left in plain view.....

Bill

Quote:

> Hi there all you (NON) Storage LEUP holders:

>    With my latest inspection about 3 weeks ago, the subject came up about
> letters from people/companies willing to allow one to store temporarily
> one's class "B" purchases. It seems the BATF wants to insure that all LEUP
> holders have some sort of storage arrangement whether at the house/property
> or in another's storage area. Call it what you want, the "non-storage" LEUP
> has become or has always been a storage "arrangement". John Cato has been
> shouting this 'til he is blue in the face that it has always been about
> storage.

>    I was first told about the letter when I got my initial 1 year LEUP.  The
> agent I was coordinating with asked me to get it. Luckily, Ross D. at Magnum
> granted me that letter. This was at least 3 years ago.

>    A friend of mine that lives close to me also has his LEUP. He got his a
> little before me. He was not informed of the letter in his initial round.
> His recent inspection has made him scramble for a letter or get his
> magazine. He has elected to get his magazine together.

>    How many of you out there have been caught flat footed about this
> requirement with the latest round of annual inspections?

>    If you have not received notice that your local agent wants to inspect
> your facilities, now is the time to prepare. Try to make an arrangement with
> anyone you can that has storage and have that person write you a letter
> allowing you to store. It's either the letter or buy/build that magazine.

>    Just trying to inform all you BHM (Big Honkin' Motor) users.

> Curtis Scholl
> TRA 3976
> NAR 72953
> RRS

 
 
 

BATF Annual Inspections: Storage Letters

Post by Cochran T » Thu, 21 Sep 2000 04:00:00



Quote:

>This is interesting.....
>I asked my agent about a "non-storage" LEUP,  and was told there is no
>such thing.....hmmmmmmm  I know fliers that have non storage LEUP
>I already had the magazine...
>The agent was more interested in the storage magazine (as far as Orange
>Book requirements)  than location...
>However,, I did apply for the "attached garage" variance. and was
>denied.....reason....   I have an attached car port (with double
>lockable 5 tumble locks).......
>I did have a steel building in the back yard that was
>acceptable.....but, it is not located within the distance table as shown
>in Orange book......
>The steel building is 12 X 20' and it does not have wood interior as O
>Book required....

Distance tables do not apply to indoor magazines.  So, if you can get them
to accept the steel building as a structure and put your existing magazine
(double locks, non sparking interior) into that, you can store up to 50
lbs.

--tc

My opinions only.

 
 
 

BATF Annual Inspections: Storage Letters

Post by Bob Kapl » Fri, 22 Sep 2000 04:00:00


Quote:

> I was told anything above 62.5g had to be stored....
> The key word is "assembled"   and ATF does not differentiate between
> single use and reloadable motors...    key word    assembled..

I keep hearing this, but have yet to see any change to the regs to support
this change.

Quote:
> G38's are more than 62.5g        

Nope. 55g IIRC.

        Bob Kaplow      NAR # 18L       TRA # Whitewash





 
 
 

BATF Annual Inspections: Storage Letters

Post by Richard Pitzerus » Fri, 22 Sep 2000 04:00:00


Quote:

> Distance tables do not apply to indoor magazines.  So, if you can get them
> to accept the steel building as a structure and put your existing magazine
> (double locks, non sparking interior) into that, you can store up to 50
> lbs.

It's funny how different BATF agents read the orange book differently.
My local agent told me the distance table was in effect for an indoor
magazine (such as inside a backyard shed, or detached garage).

-Rich
--
---------------------------------------------------------------
Richard Pitzeruse               x-3711
Photographer

Syracuse University             http://rmpitzer.syr.edu
---------------------------------------------------------------

 
 
 

BATF Annual Inspections: Storage Letters

Post by markwsimp.. » Fri, 22 Sep 2000 04:00:00


Curtis,
At my visit on Tuesday, the agent had it listed in her records that I
had a magazine, that's how poorly things are communicated within the
BATF.
I've also heard lately that there's an impression that the BATF is
inspecting rocketfolk as a payback for the lawsuit.  That surely wasn't
the reason that I had my visit.  The inspector said that every year a
percentage of all LEUP holders gets auditted and I was just one of the
lucky ones.  She said that I probably wouldn't see another agent for 3-
4 years.  I guess that once they audit you, they take you off the list
for a while, otherwise, I have the same chance of being auditted next
year as I did this year.
When asked if I stored any motors, I replied that I didn't store any
motors >62.5g of propellant per slug.
She wrote down "no storage" IIRC and moved to the next question on her
standard audit survey form.
I asked her if she felt that it was a waste of time to visit rocket
people and she said that they didn't make any distinction between LEUP
holders, they had to visit those that came up on the random list.

Mark Simpson
NAR 71503 Level II



Quote:
> Hi there all you (NON) Storage LEUP holders:

>    With my latest inspection about 3 weeks ago, the subject came up
about
> letters from people/companies willing to allow one to store
temporarily
> one's class "B" purchases. It seems the BATF wants to insure that all
LEUP
> holders have some sort of storage arrangement whether at the
house/property
> or in another's storage area. Call it what you want, the "non-
storage" LEUP
> has become or has always been a storage "arrangement". John Cato has
been
> shouting this 'til he is blue in the face that it has always been
about
> storage.

>    I was first told about the letter when I got my initial 1 year
LEUP.  The
> agent I was coordinating with asked me to get it. Luckily, Ross D. at
Magnum
> granted me that letter. This was at least 3 years ago.

>    A friend of mine that lives close to me also has his LEUP. He got
his a
> little before me. He was not informed of the letter in his initial
round.
> His recent inspection has made him scramble for a letter or get his
> magazine. He has elected to get his magazine together.

>    How many of you out there have been caught flat footed about this
> requirement with the latest round of annual inspections?

>    If you have not received notice that your local agent wants to
inspect
> your facilities, now is the time to prepare. Try to make an
arrangement with
> anyone you can that has storage and have that person write you a
letter
> allowing you to store. It's either the letter or buy/build that
magazine.

>    Just trying to inform all you BHM (Big Honkin' Motor) users.

> Curtis Scholl
> TRA 3976
> NAR 72953
> RRS

Sent via Deja.com http://www.deja.com/
Before you buy.
 
 
 

BATF Annual Inspections: Storage Letters

Post by Bob Kapl » Fri, 22 Sep 2000 04:00:00


Quote:


>> Distance tables do not apply to indoor magazines.  So, if you can get them
>> to accept the steel building as a structure and put your existing magazine
>> (double locks, non sparking interior) into that, you can store up to 50
>> lbs.

> It's funny how different BATF agents read the orange book differently.

Actually, it's not funny at all. It's disgusting. It's part of the problem,

Quote:
> My local agent told me the distance table was in effect for an indoor
> magazine (such as inside a backyard shed, or detached garage).

That's what my local agent told me. And it wasn't the only thing she told me
that was incorrect.

Based on that, I asked for TWO variances, one for attached garage storage,
and one because one corner of my garage (not where the magazine would go)
was less than 75' from my neighbors attached garage. The DC office granted
my request for the attached garage storage, and told me that distance
requirements did not apply to indoor storage. I have that in writing in the
letter that grants me my variance. But I've never found it in the orange
book or any where else.

        Bob Kaplow      NAR # 18L       TRA # Whitewash





 
 
 

BATF Annual Inspections: Storage Letters

Post by Bob Kapl » Fri, 22 Sep 2000 04:00:00


Quote:

> Distance tables do not apply to indoor magazines.  So, if you can get them
> to accept the steel building as a structure and put your existing magazine
> (double locks, non sparking interior) into that, you can store up to 50
> lbs.

Indoor magazines do not require double locks or security hasps over the
shackle. That *IS* in the orange book.

        Bob Kaplow      NAR # 18L       TRA # Whitewash





 
 
 

BATF Annual Inspections: Storage Letters

Post by Cochran T » Fri, 22 Sep 2000 04:00:00



Quote:




>>> Distance tables do not apply to indoor magazines.  So, if you can get them
>>> to accept the steel building as a structure and put your existing magazine
>>> (double locks, non sparking interior) into that, you can store up to 50
>>> lbs.

>> It's funny how different BATF agents read the orange book differently.

>Actually, it's not funny at all. It's disgusting. It's part of the problem,

>> My local agent told me the distance table was in effect for an indoor
>> magazine (such as inside a backyard shed, or detached garage).

>That's what my local agent told me. And it wasn't the only thing she told me
>that was incorrect.

>Based on that, I asked for TWO variances, one for attached garage storage,
>and one because one corner of my garage (not where the magazine would go)
>was less than 75' from my neighbors attached garage. The DC office granted
>my request for the attached garage storage, and told me that distance
>requirements did not apply to indoor storage. I have that in writing in the
>letter that grants me my variance. But I've never found it in the orange
>book or any where else.

NFPA may be more specific (I don't have a copy here), but the Orange Book isn't.

The Orange book explicitly says that outdoor magazines shall comply with
distance tables, in every place that it talks about outdoor magazines.  It
does not say that indoor magazines have to, in any place that it talks
about indoor magazines. But that's ok--if it isn't required, then it isn't
required! People need to be assertive with BATF agents who want to make
you do things that are not required in regulations or law! [Ditto with
e.g., record keeping, such as asking people to keep original receipts for
all transactions].  

Logically speaking, (and I know, that's a silly thing to be saying here)
it's hard to imagine why there would be a category for indoor magazines at
all, and that there would be a limit of 50# for them, if outdoor magazine
distance limits applied.

--tc

My opinions only.

 
 
 

BATF Annual Inspections: Storage Letters

Post by Cochran T » Fri, 22 Sep 2000 04:00:00



Quote:


>> Distance tables do not apply to indoor magazines.  So, if you can get them
>> to accept the steel building as a structure and put your existing magazine
>> (double locks, non sparking interior) into that, you can store up to 50
>> lbs.

>Indoor magazines do not require double locks or security hasps over the
>shackle. That *IS* in the orange book.

You're right, provided the building provides equivalent security, whatever
that means :-).

-tc

My opinions only.

 
 
 

BATF Annual Inspections: Storage Letters

Post by John H. Cato, Jr » Fri, 22 Sep 2000 04:00:00


tc:

Quote:
>>>> Distance tables do not apply to indoor magazines

Pitzeruse:

Quote:
>>> It's funny how different BATF agents read the orange book differently.

tc:

Quote:
>NFPA may be more specific (I don't have a copy here), but the
> Orange Book isn't.

You will find a lot of this in the model Fire Codes (that the state's adopt).

Example:

ATF says "metal covered wood" or "fabricated metal".  No real talk of what
*thickness* of metal (a question I've seen come up time and again).

When you whip out the Standard Fire Prevention Code, you now see a far more
*specific* situation... to wit...

(this for indoor magazines)

"1902.4.10.3  Indoor magazines constructed of wood shall have sides, bottoms,
and lids or doors constructed of 2 inch (51mm) wood and shall be well braced
at corners.  The magazines shall be covered on the exterior with sheet metal
of not less than 0.0179 inch (0.45mm).
"1902.4.10.4 Indoor magazines constructed of metal shal have sides, bottoms,
and lids or doors constructed of at least 0.1046 inchd (2.66mm) metal and
shall be lined with a minimum of 1/2 inch (13mm) of nonsparking material."
                        --- Standard Fire Prevention Code - 1994 edition
                            (current in the St. of GA)

It's also here where the distance requirements are spelled out (maybe??) a
little more clearly -- "No... in a residense or dwelling," etc.

Of course, that Table of Distances for Low Explosives also has a column for
"From Inhabited Building" -- which is general enough to cover ANY storage and
ANY building (that is inhabited).

-- john.

 
 
 

BATF Annual Inspections: Storage Letters

Post by ....E » Fri, 22 Sep 2000 04:00:00


Here we go again with the less than 62.5g per slug v/s total motor weight...
....Ed


Quote:
> Curtis,
> At my visit on Tuesday, the agent had it listed in her records that I
> had a magazine, that's how poorly things are communicated within the
> BATF.
> I've also heard lately that there's an impression that the BATF is
> inspecting rocketfolk as a payback for the lawsuit.  That surely wasn't
> the reason that I had my visit.  The inspector said that every year a
> percentage of all LEUP holders gets auditted and I was just one of the
> lucky ones.  She said that I probably wouldn't see another agent for 3-
> 4 years.  I guess that once they audit you, they take you off the list
> for a while, otherwise, I have the same chance of being auditted next
> year as I did this year.
> When asked if I stored any motors, I replied that I didn't store any
> motors >62.5g of propellant per slug.
> She wrote down "no storage" IIRC and moved to the next question on her
> standard audit survey form.
> I asked her if she felt that it was a waste of time to visit rocket
> people and she said that they didn't make any distinction between LEUP
> holders, they had to visit those that came up on the random list.

> Mark Simpson
> NAR 71503 Level II

 
 
 

BATF Annual Inspections: Storage Letters

Post by markwsimp.. » Sat, 23 Sep 2000 04:00:00




Quote:
> Here we go again with the less than 62.5g per slug v/s total motor
weight...
> ....Ed

Ed,
No debate necessary. I told my agent that I didn't store any motors
with grains >62.5g and she was satisfied with my answer. She didn't say
that all of my reloads that are >62.5g are included in the regulation,
she accepted my answer that I didn't store any restricted motors. End
of story.

Mark Simpson
NAR 71503 Level II

Sent via Deja.com http://www.deja.com/
Before you buy.

 
 
 

BATF Annual Inspections: Storage Letters

Post by Fre » Sun, 24 Sep 2000 04:24:39


Curtis,

Try this letter, it is what I used when I first applied for a LEUP without
storage. It was excepted by our local ATF.

Fred

Quote:

> Hi there all you (NON) Storage LEUP holders:

>    With my latest inspection about 3 weeks ago, the subject came up about
> letters from people/companies willing to allow one to store temporarily
> one's class "B" purchases. It seems the BATF wants to insure that all LEUP
> holders have some sort of storage arrangement whether at the house/property
> or in another's storage area. Call it what you want, the "non-storage" LEUP
> has become or has always been a storage "arrangement". John Cato has been
> shouting this 'til he is blue in the face that it has always been about
> storage.

>    I was first told about the letter when I got my initial 1 year LEUP.  The
> agent I was coordinating with asked me to get it. Luckily, Ross D. at Magnum
> granted me that letter. This was at least 3 years ago.

>    A friend of mine that lives close to me also has his LEUP. He got his a
> little before me. He was not informed of the letter in his initial round.
> His recent inspection has made him scramble for a letter or get his
> magazine. He has elected to get his magazine together.

>    How many of you out there have been caught flat footed about this
> requirement with the latest round of annual inspections?

>    If you have not received notice that your local agent wants to inspect
> your facilities, now is the time to prepare. Try to make an arrangement with
> anyone you can that has storage and have that person write you a letter
> allowing you to store. It's either the letter or buy/build that magazine.

>    Just trying to inform all you BHM (Big Honkin' Motor) users.

> Curtis Scholl
> TRA 3976
> NAR 72953
> RRS

--
MZ

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