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ATF Hotline number (Joint Support Operations Center): +1 (800) 800-3855

Note:  Several hyperlinks on this page were broken.  We have tried to repair them all during the update to this page on 8/24/2015.  If you discover broken hyperlinks, please tell us which ones you've discovered in an email to atf@corelab.com.  Please include the phrase "OCS ATF page broken hyperlinks" in the subject line of your email.

Topics (click a topic to read more):

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Attorney General Ends Justice Department's (DOJ) Practice of Regulation by Guidance (12/19/2017) (updated 1/18/2018)

1/18/2018 Update:  Reportedly, ATF has been instructed to respond, as normal, to all variances, determinations, classifications, etc. from individual businesses.  IME is still working with DOJ on how to address responses to association (like IME, SAAMI, COSTHA, APA, etc.) inquiries.

On November 16, 20171, "...  in an action to further uphold the rule of law in the executive branch, Attorney General Jeff Sessions issued a memo prohibiting the Department of Justice from issuing guidance documents that have the effect of adopting new regulatory requirements or amending the law. The memo prevents the Department of Justice from evading required rulemaking processes by using guidance memos to create de facto regulations."  This prohibition impacts the Bureau of Alcohol, Tobacco, Firearms, and Explosives (ATF), a component of the DOJ and could hamper ATF's ability to issue variances and rulings and to provide helpful guidance to the regulated community in the form of interpretations.  Exactly how this will impact communications between ATF and the regulated community is yet to be seen.  Owen Oil Tools is a member of the Institute of Makers of Explosives that has engaged ATF leadership and has taken the lead in forming a coalition of industry groups to advise DOJ of the unintended negative impact on the regulated industries and request relief.

Additional information will be posted here as it develops.

Resources:

1 DOJ Memorandum, Prohibition on Improper Guidance Documents, November 16. 2017

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ATF Open Letter about 9/11 Anniversary  (8/24/2011)

ATF has published an open letter on its website requesting that all explosives licensees and permittees review their storage and security procedures and be extra vigilant during the coming weeks as we approach the 10th anniversary of the 9/11 attacks.  ATF advises that it has no specific threat intelligence but cautions that we should all remain on alert and not be complacent about the potential of attacks during this anniversary period.

You can obtain a PDF copy of the letter by clicking here or by visiting the ATF website at:
http://www.atf.gov/press/releases/2011/08/081911-open-letter-to-fels-september-11th-anniversary.html 

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ATF Advisory about Explosives Thefts in Mexico  (2/26/2009)

ATF has issued an advisory to the explosives industry regarding a series of armed thefts of explosives from storage sites in Mexico along the southwest U.S. border.  The advisory is a precaution and not due to any criminal intelligence and it provides links to ATF information on enhancing explosives storage site security. The advisory can be obtained by clicking the either of the following hyperlinks:

You can obtain a PDF copy of the letter by clicking here.

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Acceptability of Signatures on Copies of Licenses & Permits
Copies of Licenses & Permits and of Scanned, Faxed, or E-mailed Copies of Licenses & Permits 
(updated 7/19/2009)

Update 7/19/2009 -- The interim guidance describe below is now formal.  ATF has published this guidance on page 8 of it's latest (June 2009) newsletter.  See the "Newsletter" link below to download a copy.

Original notice (2/3/2009) -- ATF has issued interim guidance in response to an inquiry from OCS regarding acceptability of signatures on copies of licenses and permits.  In this interim guidance, ATF also addresses the issue regarding what types of copies of licenses & permits are acceptable.  ATF advises that formal guidance will be announced soon.  Copies of the OCS inquiry and the ATF interim guidance can be obtained by clicking the following hyperlinks:

OCS inquiry
ATF interim guidance 
Notification to Owen Oil Tools 
ATF June 2009 Newsletter

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Ammonium Perchlorate Composite Propellant  (7/19/2009)

A U.S. District Court has reversed ATF's ruling that ammonium perchlorate composite propellant (APCP) is an explosive.  APCP is no longer regulated under ATF and is not subject to that agency's licensing, recordkeeping, storage, and other regulatory requirements.  Although APCP is no longer regulated under ATF's storage requirements, ATF encourages storage of APCP in explosives magazines for security purposes.  ATF will allow APCP to be stored in magazines with igniters or other regulated explosives products and will not consider the weight of APCP materials in calculating separation distance requirements for magazines.

ATF issued an open letter explaining this change on July 17, 2009.  A copy may be obtained at one of the links provided below.

Open Letter to Industry Regarding APCP 
ATF Special Notices & Open Letters 

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Disaster Preparation (9/8/2008)

ATF has issued an open letter to all explosives licensees and permittees addressing the subject of preparing for natural disasters.  ATF is providing suggestions on pre-disaster planning and also advising how to deal with lost, stolen, and/or damaged explosives.  You can obtain a copy of the letter at any of the following locations:

OCS website
ATF website

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Payments to ATF (1/30/2008)

ATF is changing how it will process all payments made to the agency, including license and permit fees.  They will be switching to electronic funds processing which means that when they process your payment, it will be directly debited by them from your bank account rather than following normal check processing procedures.  This procedure is scheduled to start within 30 days of January 25, 2008.  You can obtain a PDF copy of the letter by clicking here.

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Bullet-resistance Requirements for Indoor Magazines.  (updated 8/27/2009)  (see note)

Update 8/27/2009 -- ATF has published an article on this topic on page 10 of the June 2009 ATF Explosives Industry NewsletterClick here to download a copy.

Original notice (3/27/2007) -- 27 CFR 555.208(b)(1) states that indoor magazines do not have to be bullet-resistant if they are located in buildings that provide protection from bullet penetration.  However, if buildings containing indoor magazines do not provide protection from bullet penetration, then the magazine must be bullet-resistant.  For indoor magazines, bullet-resistant means that the magazine is constructed of not less than 1/4" steel and lined with at least 2" of hardwood (27 CFR 555.208(a)(2)).  ATF also provides alternative construction specifications that meet it's bullet-resistance requirements in ATF Rul. 76-18.

ATF I/O Investigators are now checking indoor magazines to ensure compliance with these requirements and have found that typical metal-siding buildings do not provide protection from bullet penetration.  Licensees and permittees are advised to check their indoor magazines and the buildings that house them now to determine if these requirements have been met.  If the requirements are not currently met, modifications should be made to the magazine or the building now to ensure that compliance is achieved as soon as possible. 

If modifications to the magazine are required to make it comply with these bullet-resistance requirements, licensees and permittees are reminded that:

  • Such a modification is a "change in construction" and is subject to the notification requirements of 27 CFR 555.63 and 555.201
  • Explosives must be removed from the magazine before making modifications to the interior of the magazine (27 CFR 555.216)
  • ATF states in ATF Rul. 76-18 that "All steel and wood dimensions are actual thicknesses"; therefore, actual dimensions, and not lumber sizes, should be used to achieve the thicknesses indicated. 

Note:  This topic discusses ATF's bullet-resistance requirements for indoor magazines.  The provisions of 27 CFR 555.208(b)(1) impose similar requirements regarding weather-resistance as well.

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Bullet-resistance Requirements for Type 2 Outdoor Magazine Roofs.  (3/27/2007)  (see note)

27 CFR 555.208(a)(1) states that Type 2 outdoor magazines must be bullet-resistant, fire-resistant, weather-resistant, theft-resistant, and ventilated.  Licensees and permittees reminded that these requirements apply to all sides of a Type 2 outdoor magazine, including the roof.  Bullet-resistant means that the magazine (including the roof) is constructed of not less than 1/4" steel and lined with at least 2" of hardwood (27 CFR 555.208(a)(2)).  ATF also provides alternative construction specifications that meet it's bullet-resistance requirements in ATF Rul. 76-18.

ATF I/O Investigators are now checking Type 2 outdoor magazines for compliance with these requirements and have found that the roofs of many Type 2 outdoor magazines do not meet these requirements.  Licensees and permittees are advised to check their Type 2  outdoor magazines now to determine if these requirements have been met.  If the requirements are not currently met, modifications should be made to the magazine to ensure that compliance is achieved as soon as possible. 

If modifications to the magazine are required to make it comply with these bullet-resistance requirements, licensees and permittees are reminded that:

  • Such a modification is a "change in construction" and is subject to the notification requirements of 27 CFR 555.63 and 555.201
  • Explosives must be removed from the magazine before making modifications to the interior of the magazine (27 CFR 555.216)
  • ATF states in ATF Rul. 76-18 that "All steel and wood dimensions are actual thicknesses"; therefore, actual dimensions, and not lumber sizes, should be used to achieve the thicknesses indicated. 

Note:  This requirement also applies to Type 1 magazines; however, there is an exception for Type 1 magazine roofs.  This exception is not available for Type 2 magazine roofs -- all Type 2 outdoor magazine roofs must be bullet-resistant.

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Changes in Business.    (updated 8/27/2009)  

Update 8/27/2009 -- ATF has published an article on this topic on page 7 of the June 2009 ATF Explosives Industry NewsletterClick here to download a copy.

Original notice (3/28/2007) -- Many businesses change their form (sole proprietorship, partnership, LP, LLC, Inc., etc.) at some time during their business life.  This may be to reflect changes in the way the company has grown over the years, or it may be to take advantage of some tax provision, liability provision, and so forth.  When this occurs, many licensees and permittees assume, incorrectly, that a mere change in the initials at the end of their company name (for example a change from Inc. to LP) is simply a change in trade name or a change in control and attempt to comply with ATF's notification requirements in 27 CFR 555.56 or 555.57.  

However, this most often is not the case, and licensees and permittees are reminded that such a change is, most often, a change of ownership that must be handled under the requirements of 27 CFR 555.41(b).  These requirements require submission of an application for a new license or permit for the new entity.  This takes time, and one should plan accordingly and submit the application well in advance of the planned change.  It is recommended that this type of activity be coordinated closely with the staff of the ATF Federal Explosives Licensing Center (FELC).

"How do I know if my change is a 'change in ownership'?"  This is often a complex legal question, and assistance should be sought from the FELC staff.  However, there is one simple test that provides the correct answer in most instances -- if a new EIN (employer identification number) will be issued, then, in nearly all instances, a change in ownership will take place and must be addressed under 27 CFR 555.41(b).

For more information on this subject, please contact the FELC at:

Federal Explosives Licensing Center
244 Needy Rd.
Martinsburg, WV 25405
(304) 616-4400

e-mail:  FELC@atf.gov.

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Storage of Loaded Perforating Guns.  (updated 8/24/2015) The information provided below has been superseded by ATF Ruling 2010-7.  Please review the information located here for up-to-date information regarding storage of loaded perforating guns.

The following discussion is provided for historical purposes only:

(1/24/2006 & Updated 3/7/2006)  At the request of the Oilfield Services Subcommittee of IME's Safety & Health Committee, ATF has issued guidance on outdoor storage of loaded perforating guns.  This guidance, outlined in their letter of January 18, 2006, to IME provides for non-magazine storage of loaded perforating guns if the following conditions are met:

  1. A variance must be obtained by each company wishing to store loaded perforating guns in outside, non-magazine storage.

  2. If guns contain detonators or other initiating devices, a detonator interrupter device must be used.

  3. No more than 200 loaded perforating guns may be kept outside of an approved magazine.

  4. Total explosive weight of loaded perforating guns kept outside of approved magazines cannot exceed 2500 lbs.

  5. Perforating guns may be stored in covered or uncovered areas that are secured with a fence with a locked gate.  3/7/06 -- On 2/16/06, IME provided additional information on this topic.  See the note on the bottom of page 2 of the ATF letter for details.

  6. Perforating guns must be stored in a manner that prevents accidental movement or discharge, such as:

    • stored flat on a concrete or paved floor

    • stored flat on offshore tool pallets

    • secured to permanently mounted racks

    3/7/06 -- On 2/16/06, IME provided additional information on this topic.  See the note on the bottom of page 2 of the ATF letter for details.

  7. Perforating guns may be stored on a motor vehicle or trailer if the vehicle/trailer is locked and immobilized by a standard kingpin locking device or a steering wheel locking device.  The vehicles keys must be removed from the vehicle and the brakes set.

  8. The fire safety authority having jurisdiction must be notified in writing and a copy of the notification kept with the variance approval (condition #1).

Click here for a copy (copy updated 3/7/06) of ATF's letter to IME.  For additional information on how to obtain a variance, please call Debbie Payne at (817) 551-0660 or send an e-mail to atf@corelab.com

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Certifications required by ATF  (2/21/2017)

OCS is the regulatory compliance programs administrator for Owen Oil Tools LP, manufacturer and distributor of specialty explosives including perforators, cutters, severing tools, detonators, and power charges. Explosives licensees like OOT are regulated by the Bureau of Alcohol, Tobacco, Firearms, and Explosives (ATF) and, as of May 24, 2003, will be required to provide the following information to each vendor from which they purchase explosives:

  1. A certified copy of the non-expired ATF license
  2. A certified statement of intended use of explosives
  3. A list of persons authorized to take delivery of explosives on behalf of the company (authorized receivers list)

We make available a combined certification (updated 02/15/2019) that meets all 3 requirements listed above.  Click here to obtain a copy of the combined certification.

Click here to obtain a copy of the initial notification from 4/7/2003 that includes an explanation of the new requirements under the Safe Explosives Act.

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Computerized Recordkeeping (1/22/2007)

On January 18, 2007, ATF issued ATF Ruling 2007-1 to clarify that the use of computerized recordkeeping, without first obtaining a variance, is acceptable under specified conditions.  Click here for details.

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Reporting Magazine Changes (7/25/2006)  

OCS has received a letter from ATF clarifying the meaning of its "magazine changes" reporting requirements.

In 27 CFR 555.63 and 555.201, ATF requires reporting of 4 "magazine change" events:

  1. Before making changes in construction to an existing magazine (27 CFR 555.63(a)(4), 555.63(c), and 555.021(c)),
  2. Before constructing a new magazine  (27 CFR 555.63(a)(4), 555.63(d), and 555.021(c)),
  3. Before using a reconstructed magazine (27 CFR 555.63(a)(4), 555.63(c), and 555.021(c)), and
  4. Before using a newly added (acquired) magazine (27 CFR 555.63(a)(4), 555.63(d), and 555.021(c)).

While 27 CFR 555.63 uses very specific language when describing changes that are to be reported (i.e., "changes in magazine construction", 27 CFR 555.201(c) is not so clear.  This has led to the assumption that "changes" to magazines might include such events as:

  • relocating an existing magazine,
  • repairing a magazine (even though the repairs don't require a change in construction), or 
  • painting a magazine.

Such interpretations could lead to issues with local ATF investigators during compliance inspections; therefore, OCS sought clarification of the issue with a letter to ATF and they replied that events like those described above do not require notification to ATF.  

Click here for a copy of the ATF letter and the OCS inquiry.

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Meaning of the term "Inhabited Building" (11/29/2005)    

On November 25, 2005, ATF issued ATF Ruling 2005-3 to clarify the meaning of the term "Inhabited Building".  This ruling should put to rest issues such as shared property, occasional visits to structures, occupation by single persons, etc.  Click here for details.

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Export Broker Licensing (7/16/2005)  

In reply to an inquiry from OCS, ATF has provided guidance on the subject of licensing of export brokers.  This guidance was received in an e-mail communication from Assistant Director Lew Raden.  In the e-mail, Mr. Raden states:

These persons at a minimum will need a permit issued through ATF. If by "paying for explosives" they take title to the explosives and then distribute explosives to someone else, they would need a license through ATF. If the "broker" simply acts as a service, completing paperwork, facilitating but not directing the transaction or shipping of the explosives and receiving a fee for services, then no license or permit is required. ATF is working on a ruling pertaining to the scenarios that you presented, and we hope to issue it soon. It is partly due to the complexity of the legal analysis of factors that has delayed issuance of the ruling and getting you a response.

A copy of the inquiry from OCS may be obtained by clicking here.

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New Explosives Marking Requirements (7/16/2005)  

On May 27, 2005, ATF published new requirements (70 FR 30626) addressing the subject of identification markings to be placed on explosive materials.  These new requirements, which become effective on July 26, 2005 expand the previous marking requirements of 27 CFR 555.109 to include explosives imported into the USA.  Previously, the marking requirements only applied to explosives manufactured in the USA.  

The following summarizes the new marking requirements.  There are additional provisions regarding method of marking and exceptions not discussed below.  Please see the Final Rule for details.  A copy of the Final Rule can be obtained by clicking here.

Explosives manufactured in the USA:

  1. Marks must be applied by the licensed manufacturer on explosives manufactured for sale or distribution.  Marks do not have to be placed on explosives manufactured for the manufacturer's own use.

  2. Marks must be applied at the time of manufacture.

  3. Marks must include:
  • name of manufacturer,
  • location of manufacture,
  • date of manufacture, and 
  • shift of manufacture (unless there is only 1 manufacturing shift).

Explosives imported into the USA:

  1. Marks must be applied by the licensed importer on explosives imported for sale or distribution.  Marks do not have to be placed on explosives imported for the importer's own use.

  2. Marks must be applied prior to distribution or shipment for use, and in no event, later than 15 days after release of the explosives from Customs custody.

  3. Marks must include:
  • name and address (city & state) of importer,
  • location of manufacture (city & country),
  • date of manufacture, and 
  • shift of manufacture (unless there is only 1 manufacturing shift).

Requirements applying to all markings (whether USA manufactured or imported into USA):

  1. Marks must be permanent and legible.

  2. Marks must be in English using Roman letters and Arabic numerals.

  3. Marks must be on each cartridge (device), bag, intermediate container, and on the outside of the container used for packaging the explosive materials.

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Qualification to be Listed as an "Authorized Receiver"  (7/16/2005)  

ATF requires licensees and permittees to furnish to suppliers lists of persons authorized to receive explosives on their behalf.  We have recently received questions regarding the qualifications of persons who can be listed on an "Authorized Receivers List."  Specifically, we have been asked if authorized receivers can only be those persons who have fingerprints on file with ATF or who have been identified as "Responsible Persons" by the licensee or permittee.  The answer is, "no".  Authorized receivers can be either "employee possessors" or "responsible persons", but they are not required to be "responsible persons".  Also, since "employee possessors" do not routinely have fingerprints on file with ATF (exceptions exist for those who have been granted relief from explosive possession disabilities), the statement that only those persons with fingerprints on file with ATF can be "authorized receivers" is also incorrect.

ATF confirmed this opinion in the June 2005 ATF Explosives Industry Newsletter where, in the last sentence of the left-hand column on page 6, they state, "Please note, the persons on the certified list must also be listed on the license/permit as an employee possessor or a responsible person."  A copy of this newsletter is available by clicking here.  

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Receiver Verification (when using common/contract carrier) (10/25/2004)  

OCS has received a letter from ATF providing additional guidance regarding receiver verification requirements when a common or contract carrier is used to deliver explosives.  In the letter (copy to be posted next week), ATF confirms that:

  1. When a common or contract carrier is not used (i.e., customer pick up or delivery by you):

    1. You must examine an identification document of the receiver and 
    2. You must confirm that the receiver is on the distributee's Authorized Receivers List.

  2. When a common or contract carrier is used for delivery to holders of a license/permit:   

    1. You and/or the carrier are not required to examine an identification document of the receiver,
    2. You and/or the carrier are not required to confirm that the receiver is on the distributee's Authorized Receivers List,
    3. You are required to examine the valid, unexpired driver's license of the person accepting possession of explosives for the common/contract carrier, and
    4. You are required to note the name of the carrier and the driver's full name in your permanent records.

  3. When a common or contract carrier is used for delivery to holders of a limited permit, you must:

    1. Follow the requirements of 27 CFR 555.105(b)(6)(iii) or
    2. Follow the requirements of ATF Ruling 2003-5.

    27 CFR 555.105(b)(6)(iii) requires that a common or contract carrier hired by a licensee or permittee verify the identity of the person accepting delivery on behalf of the distributee, note the type and number of the identification document, and provide this information to the distributor.

    ATF Ruling 2003-5 allows you to contact the distributee within 3 business days of shipment to confirm receipt of explosives (click here for details).

Click here for a copy of the ATF letter
Click here for a copy of the OCS inquiry

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ATF Security Checklist.  (7/26/2004)  

Gary Bangs; Chief, Explosives Industry Programs Branch; Arson and Explosives Division; Bureau of Alcohol, Tobacco, Firearms, and Explosives has advised that ATF has developed a checklist that ATF inspectors will be using when visiting proprietors. Mr. Bangs stresses that this assessment is VOLUNTARY and that inspectors may also utilize questionnaires of key employees to evaluate internal controls that may present potential weak links, thereby increasing the risk of criminal use of explosives. This internal control evaluation is also voluntary.  ATF's hope is that, by examining a facility from an outside perspective, simple things that may be overlooked could be pointed out and corrected, with little increased cost to the proprietor. Other items on the checklist may certainly increase costs, but ATF wanted to include as much as possible to ensure that we all constantly think about security. ATF knows that security is everyone's concern, but it is always best to have an outside look. The closer you are to something, the easier something may be missed.

Mr. Bangs has provided the checklist before it goes into actual use so that industry will be aware of its coming use and not be surprised and to, hopefully, avoid miscommunication or misunderstanding during implementation. In addition, ATF hopes that industry will embrace this as a good thing, to everyone's benefit, and that it will be publicized as much as possible. 

You can review the ATF security check list by clicking one of these links:  MSWord    Acrobat PDF

In addition, ATF is examining their overall explosives risk assessment procedures to make improvements where possible. Therefore, they have posted a special notice to all explosives licensees/permittees from Director Truscott. They also have posted an open letter to all Federal firearms licensees encouraging voluntary safeguards and reporting of suspicious activities regarding explosives that they handle, such as black and smokeless powder. Finally, the next explosives newsletter will be coming out soon. You can review the two letters mentioned above on the ATF website by clicking here.

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5400.8 Form Eliminated.  (9/11/2003)  

ATF has issued an Interim Final Rule (68 FR 53509 - 53513) that eliminates the requirement to use ATF From 5400.8, Explosives Delivery Record.  This interim final rule "removes the procedures set forth in 27 CFR 555.103(b)(3) and 555.105(b)(6)(iii) and (iv), which require transactions ... involving delivery ... by a common or contract carrier" to be documented on form 5400.8.  In the place of collecting form 5400.8, ATF now requires that distributors verify the identity of the person accepting possession of explosives for the common or contract carrier by examining that person's valid driver's license (issued by any State, Canada, or Mexico).  Additionally, distributors must record in their permanent records the name of the common or contract carrier and the full name of the driver.   

5400.8 forms collected prior to the effective date of the IFR, must be maintained as part of the distributor's permanent record in compliance with 27 CFR 555.121.

For more information, please review the Interim Final Rule (click here).

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Receiver Verification.  (5/27/2003)

ATF has issued Ruling 2003-5 which will relieve common/contract carriers from the requirement that they verify the identity of persons taking possession of explosives when delivering to holders of limited permits.  In the ruling, ATF provides an alternate procedure for compliance with the requirements of 27 CFR 555.105(b)(6)(iii).  The alternate procedure is:

The distributor shall, no later than three business days after shipment of the explosive materials, contact the distributee by telephone, facsimile, e-mail or any other means to ensure that the shipment has been received.  The distributor shall make a notation on ATF Form 5400.4 indicating whether the shipment was received and the date and time of the contact with the distributee.

As noted, this alternate procedure only applies to instances of delivery by common or contract carrier to holders of limited permit.  It is our opinion that the shipment verification by phone, fax, e-mail, etc. described above would also meet the verification requirements of 27 CFR 555.103(b)(2) & (b)(3).  We have received informal confirmation that ATF shares this opinion and that additional guidance on this issue is forthcoming from them (updated information available, please see the compliance update of 10/25/2004).

Click here (ATF website) or click here (OCS website) to review ATF Ruling 2003-5.

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Storage of Explosives(3/27/2007)

ATF requirements regarding storage of explosives are found in Subpart K of the Commerce in Explosives Regulations (27 CFR 555.201 - 555.224).   The following is a brief summary of those requirements:

  • Notifications (ATF) -- required before acquiring/constructing new magazines and before making changes in construction to existing magazines (27 CFR 555.201(c))
  • Notification (local fire authority) -- required orally by close of business the day storage begins and in writing within 48 hours of beginning storage (27 CFR 555.201(f)).
  • Inspections -- at least once every 7 days (27 CFR 555.204). 
  • When must explosives be in magazines? -- Explosives must be kept in locked magazines, unless the explosives are being manufactured, used, transported, or being prepared for use/transport (27 CFR 555.205).
  • Location of (high explosives) Magazines -- Magazines used to store high explosives must be located in accordance with the American Table of Distances (27 CFR 555.206 and 555.218).
  • Construction Requirements -- Magazines must be constructed to meet ATF requirements for magazine type (27 CFR 555.207 - 555.211).  Alternate construction requirements are provided in ATF Rul. 76-18.
  • Smoking, matches, open flames, or spark producing devices -- are not allowed in magazines, within 50 feet of outdoor magazines, or in rooms containing indoor magazines (27 CFR 555.212).
  • Detonators -- cannot be stored with other explosives in most cases (27 CFR 555.213).  See also "Detonator storage".
  • Storage against walls -- prohibited (27 CFR 555.214(a)).
  • Arrangement of containers -- marks must be visible and stocks must be arranged so that they can be easily counted and checked upon inspection (27 CFR 555.214(b)).
  • Opening/closing containers -- containers must be closed while stored.  Except for fiberboard and other nonmetal containers, containers cannot be opened in magazines or within 50' of magazines (27 CFR 555.214(c)).
  • Tools -- must be made of nonsparking materials (27 CFR 555.214(d)).  Some exceptions exist.
  • Housekeeping (27 CFR 555.215):
    • Magazines must be clean, dry and free of grit, paper, trash, and empty packagings
    • Floors must be swept regularly
    • Brooms and other cleaning utensils must have no spark-producing metal parts
    • Floors stained by explosives leaks must be cleaned
    • Deteriorated explosives are to be destroyed per manufacturer's advice
    • Area within 25' of magazines is to be kept clear of rubbish, brush, dry grass, or trees (trees taller than 10' are allowed)
    • Volatile materials are to be kept at least 50' from magazines
  • Repairs (27 CFR 555.216):
    • Magazine interiors -- 
      • Explosives must be removed from magazine
      • Magazine must be cleaned of explosive resideu
    • Magazine exteriors -- explosives must be removed if repairs could produce sparks or flames
    • Explosives removed from magazines being repaired must be:
      • placed in other magazines or
      • placed a safe distance from the magazine(s) being repaired and guarded and protected until repairs are complete and explosives have been returned to magazines
  • Lighting -- see 27 CFR 555.217

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Detonator storage(3/27/2007)

ATF allows most explosives to be stored in one magazine; however, in most cases, detonators must be stored in a separate magazine (27 CFR 555.213(b)).  Probably most confusing is the storage of OOT power charge igniters, which many users mistakenly think are "detonators".  ATF defines a "detonator" as follows:

Detonator.  Any device containing a detonating charge that is used for initiating detonation in an explosive. The term includes, but is not limited to, electric blasting caps of instantaneous and delay types, blasting caps for use with safety fuses, detonating-cord delay connectors, and nonelectric instantaneous and delay blasting caps.

OOT power charge igniters (DET-5306-074) are not detonators.  They contain only black powder, which is not a "detonating charge".  They are not used for initiating detonation, they are used for igniting a flammable mixture in the power charge.  Finally, OOT power charge igniters are not classified by DOT as detonators.  Unless prohibited by state or local regulation, OOT power charge igniters may be stored in the same magazine as other high explosives (perforators, cutters, detcord, bi-directional boosters, power charges, etc.) or (per 27 CFR 55.213(b)(2)) in the same type 1 or type 2 magazine as detonators.

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Bi-directional booster storage(3/27/2007)

Bi-directional boosters are shells containing 1 gram or less of RDX, HMX, HNS, PYX, NONA, or CP. They are explosive components used to transmit an explosive train from a donor to a receptor. The donor may be a detonator, detonating cord, or another bi-directional booster and the receptor is detonating cord, another bi-directional booster, or a shaped charge. Bi-directional boosters are classified by the U.S. Department of Transportation as "Components, Explosive Train, n.o.s., 1.4S"

Bi-di/detcord assemblies are lengths of detonating cord with a bi-directional booster affixed to one or both ends.

According to ATF, neither bi-directional boosters nor bi-di/detcord assemblies are considered "detonators".  Therefore, these devices should not be stored in the same magazine as detonators; however, they may be stored with other high explosives (perforators, detcord, cutters, etc.).  This position has been formally reviewed by ATF, by the Louisiana Department of Public Safety and Corrections and Natural Resources Canada, Explosives Regulatory Division and all three authorities concur (click the name for a copy of the document).

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Owen Explosive Storage Compatibility Chart
(5/19/2015)

“Detonator” magazine

“Charge” (non-detonator) magazine

Not allowed to be stored in Magazines

DETONATING FUZES
ELECTRIC DETONATORS
IGNITERS [1]
NON-ELECTRIC DETONATORS
PRIMERS, CAP TYPE

BI-DIRECTIONAL (Bi-DI) BOOSTERS
BI-DI/DETCORD ASSEMBLIES
BULK EXPLOSIVES [2]
CUTTERS
DETONATING CORD
EXPLOSIVE CARTRIDGES & PELLETS
IGNITERS
[1]
KODIAK PELLETS (added 5/19/2015)
LINEAR SHAPED CHARGES
PERFORATING GUNS
PERFORATORS
POWER CHARGES
SHAPED CHARGES

WellStim / StimGun products [3]
Non-explosive hazardous materials (DOT classes 2 - 9)
Non-explosive items
Metal tools
Cleaning utensils with spark-producing metal parts
Anything that is not an explosive


[1] Igniters may be stored in either the “detonator” magazine or the “charge” magazine (27 CFR 55.213(b)(2))

[2] Such as RDX, HMX, HNS, PYX, etc.

[3] USA only.  Other countries may require storage of these items in magazines.  Consult with national authority in other countries regarding storage of these items.

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ATF Guidance on Suspicious Packages and Bomb Threats (added 6/20/2016) 

ATF has published a pamphlet providing guidance on responding to suspicious packages and bomb threats.  This guidance is available:

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ATF Explosives Industry Newsletter (updated 7/31/2017)    

Note:  ATF has published its July 2017 newsletter.  All of the newsletter topics are important to explosives licensees and permittees; however, we've highlighted a few below that may be of particular interest.

Click here for ATF July 2017 Explosives Industry Newsletter

July 2017 newsletter topics: 

  • Updated Safety & Security Publication (see updated ATF P 5400.15 for more details)

  • Structures Used for Indoor Storage

  • Firework Processes and Manufacturing

  • Distribution Dates

  • Identification of Explosive Materials

  • Q&As

  • How to read an Explosives License or Permit Number

Click here for ATF July 2017 Explosives Industry Newsletter

For a complete listing of all all ATF Explosives Industry Newsletters, please see:
ATF Explosives Industry Newsletter Webpage

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ATF Reference Section

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Safety and Security Information For Federal Explosives Licensees and Permittees (ATF publication ATF P 5400.15) -- added 7/31/2017

ATF has updated its publication, ATF P 5400.15, Safety and Security Information for Federal Explosives Licensees and Permittees. The update to this very important and informative booklet, developed in partnership with the Institute of Makers of Explosives (IME) and the International Society of Explosives Engineers (ISEE) includes information on:

  • ATF Office/Hotline Telephone Numbers and Addresses

  • Security Reminder

  • What Is ATF Doing to Support the Explosives Industry in Keeping Explosives Secure?

  • ISEE’s and IME’s Commitment to the Promotion of Explosives Safety and Security

  • Voluntary Security Checklist

  • Disaster Preparedness

  • Procedures to Follow When an Explosives Theft is Discovered

  • Procedures to Follow When Explosives Are Missing/Lost (including those lost during shipment to you)

  • Incidents Outside of the United States

  • Federal Explosives Law and Regulations Regarding Stolen Explosives

  • Regulatory Program Provisions (27 CFR, Part 555)

  • Licensee/Permittee Responsibility

  • Responsible Persons vs. Employee Possessors

  • Identification of Explosives in Records

  • Recordkeeping Requirements

  • Explosives Storage Requirements

  • Binary Explosives

  • Chemical Safety and Security

  • Guide to Recording Suspicious Person Description

Every licensee and permittee should obtain and refer often to this updated publication.  ATF P 5400.15 can be downloaded here by clicking here or from the ATF Explosives webpage (select "Explosives Publications" from the index on the left side of the page):
https://www.atf.gov/explosives

 

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