Shooters Powder & The Laws

It has been a while since we looked at the rules and regs surrounding the acquisition and storage of propellants, otherwise referred to as ‘Shooters Powders’. The term refers to both black powder (gun powder) and all the nitro-based smokeless types. However, whilst all smokeless materials are free from any form of licence, an Explosives Certificate giving authority to Acquire and Keep must be held by those wishing to use black powder for any purpose in connection with their firearms or shotguns. The current rules also embrace the holding of percussion caps, primers and ammunition.

Tick the right boxes

Form ER4A for the GRANT of a COER Explosives Certificate appears deceptively simple, but it has a dual application. For our purpose, we need to both Acquire and Keep black powder, hence the need to complete Parts A, C and D of the document. A downloadable pdf can be found at https:// www.essex.police.uk/contact-us/firearmsapplication/ application-forms/ Note that the 2014 revisions have extended the previous 3 year ‘date to date’ life of the Certificate, to allow coterminous renewal with your FAC and SGC. Since 2012, the Recipient Competent Authority (RCA) document that permits you to TRANSPORT your newly acquired black powder has been supplied with your certificate. The full name for the RCA is the POMSTER, the acronym for Placing On the Market and Supervision of Transfers of Explosives Regulations 1993. You’ll be required to show these documents whenever you make a purchase of black powder for transportation to your storage location, or if you are transporting material for use on the range.

You must give careful consideration to the precise design and location of your storage, mindful of the fact that your black powder must now be stored in a particular type of container/box – sample structural specifications for which can be found on the Interweb at; http://www.reloading.org.uk/ powder_storage.htm It is also recommended, but NOT a requirement, that all smokeless propellants are stored in a similar manner

Your storage box design

Your box must be of a fire retarding plywood (i.e. Fire Retardant Birch Plywood - Euro Class ‘B’) construction with an external wall thickness of at least 18 mm and internal partitions of not less than 6mm thickness. There must be an individual compartment for each container, with at least 30% air space above it. There is no maximum for the number of compartments other than a practical limit on the ease with which the fully laden box could be moved. The lid must have an intumescent (fire retarding) gasket around its border. No bare metal must intrude into the storage space. Advice on markings for the box are contradictory, as an ‘Explosives’ warning sticker would benefit a firefighter but would also alert the attention of a burglar.

The powder must be kept in containers with no more than 550 grams (approx. one pound) of powder per container. The containers must be constructed in such a way that; in the event of a fire they do not provide additional containment that will increase the explosive force of any deflagration. Normally, plastic/polythene or paper/cloth containers will be suitable for this purpose. Metal containers with a screw cap, or a push-in lid (i.e. similar to a paint tin lid) must not be used. The placement of the box(s) will be subject to close-scrutiny. If located within the house, then they must not be in any area which forms part of an escape route in the event of fire. Storage in an outbuilding such as a garage will be an issue, with regard to both security and other fire hazards, especially if there are flammables, such as petrol and paints, in the same location.

Weights and measures

I’ve always been confused by the fact that I can hold twice as much black powder as smokeless powder… but then, that’s the rules! The following is the actual wording of the notes in Explosive Regulations 2014, regulation 7(2)(a).

Notes:

(a) Limits in ER2014 regulation 7(2)(a):- 10 kilograms of black powder and 5 kilograms comprising one of the following options

(i) Shooters powder (black powder or smokeless powder) or

(ii) any hazard type 3 or 4 explosive, or desensitised explosive, which is not a relevant explosive, or a combination of hazard type 3 or 4 explosives, or desensitised explosives, which are not relevant explosives; or

(iii) a combination of shooters’ powder and any hazard type 3 or 4 explosives, or desensitised explosives, which are not relevant explosives; and 15 kilograms of percussion caps or small arms ammunition or a mixture of them(b)

Précis of Storage Requirements:-

• Powder must be in containers with no more than 550 grams per container.
• The containers must not be metal. Plastic/polythene or paper/cloth are suitable. Care is required to ensure where plastic is used that it does not induce static electricity.
• The containers must be kept in a box constructed of plywood with a minimum thickness of 18 mm, or a material of equal or greater fire and physical resistance to attack.
• The box must be constructed to provide 30% additional height between the top of the container and the inside of the lid.
• If the box is to hold more than one container of powder, the interior must be divided by 6mm wooden partitions securely fixed to the walls of the box.
• It is a good idea to fit an intumescent strip around the lid.
• The box must not be stored in any box, drawer, locker or cupboard made of metal.
• Locating the box for storage –
• The box should not be stored on or under any means of access or escape
• The box should not be kept in the same room as flammable liquids or in any areas where there is a risk of fire
• Security of the box –
• The box must be kept in either a secured room or other suitably secured place
• Where not kept under the above provisions the box should meet certain minimum requirements
• Have securely fixed robust hinges
• A secure hasp using a security grade padlock

The and “15Kg of percussion caps or ammunition or a mixture of them” is rather disingenuous. To prove the point, I needed to trawl the guidance notes of several Police Firearms Departments before finding what I was looking for on the Leicestershire site… Sic “You may keep up to 15 kg* of small arms ammunition or percussion caps (*net explosive content) without the need for registration or licensing of the storage premises.” The key words are ‘net explosive content’, i.e. the weight of only the primers and propellant contained within the small arms ammunition. But that leads me to consider my shotgun ammunition. I reload many of the lesser gauges and bulk-buy my various recipes of 12ga. Four or five 250 round cases of 12ga could account for almost 4Kg of my 15kg limit. I know of a number of syndicates who buy huge batches of 12ga, in order to get best discounts and wonder if their purchaser has considered ‘net explosive content’?

Read them for free!

One of the essential pieces of bedtime reading is the HSE publication ‘Explosives Regulations 2014’ ISBN: 9780717665518, Series Code L150. You can either spend £20.00 on a printed copy (with free postage!) or download it for free from the HSE website, link; http://www.hse.gov.uk/ pubns/books/l150.htm well, that’s a no-brainer. Alongside that leaflet is the companion document, ‘Explosives Regulations 2014 L151, Guidance on Regulations – Security provisions’ ISBN 9780717666386, available for the bargain price of £18.00, post free or again, downloadable for free from the Interweb. If you seek further info on this topic from the Interweb, take great care to check the date of the material and then verify it from second and third sources. There’s a lot of B/S out there!