FCP Conference and Reloading

Vegeta

So going by Sparks' post here it seems that reloading permission is possible

So does anyone actually know how to apply for "permission to reload"?

I don't even know the first step, that's probably why only one person has applied.

I want to reload, so how do I go about it legally? Can someone please shed some light on this, who to contact, what's needed on the paper work front

I'm moving into a new house at the moment so if I am going to do this now is the time to put in any required extra security or features.

Veg

It wasn't me!

I was under the impression that it went via your local Super, but in conversation with IRLConor recently he was of the impression that it was your local fire department you'd be dealing with as well for approval.

My suggestion is a written, detailed request to your local Superintendent. If they're the right person to be dealing with, they'll tell you what forms to get and fill out, who to talk to about approving your storage facilities and the like. If they're not the right person, they can probably point you in the right direction, and they'll need to be appraised of your desire in any case.

I intend buying a 6mm BR at some point, and when I do, I'll be applying for permission to store powder and primers as well, both for economy and to guarantee supply, as it's not a common calibre. It'll be a few years for me, but if people are going down this route meanwhile, I'd really like to hear about it so I know roughly what to expect and what my storage requirements will be broadly in line with.

sfakiaman

About a year ago I think, there was a picture of an expolsives licence in the Irish Shooters Digest with permission for powder and primers. I don't have my copy now but someone might.

Vegeta

Ya see from my own ignorant thoughts I believe they class primers ad powder as explosives so is it a license to store and handle explosives I would be after then as opposed to anything firearms related?

I just don't know

Also I'd like to get as much info here before I go to my Super as I don't want to present a half arsed case

It wasn't me!

Vegeta wrote: »

Ya see from my own ignorant thoughts I believe they class primers ad powder as explosives so is it a license to store and handle explosives I would be after then as opposed to anything firearms related?

Yeah, but personally I'd be making it very clear what my intention was for them and the small quantities of a relatively harmless propellant substance involved.

I just don't know

Also I'd like to get as much info here before I go to my Super as I don't want to present a half arsed case

Agreed. It's difficult to accumulate the material when there's so little clarity on the matter. Best of luck though, hope it goes well and hope you'll keep us all abreast of the situation.

milkerman

There is a piece of legislation called the 'Dangerous Substances Act' of 1955 that I think may apply here. It is administered through the local City or County Council. If I remember rightly the cost of the licence was 25 new pence. I think firearms dealers also had to get the licence because of the explosive content of ammunition. There were also limits applied below which you didnt have to get a licence. So, a lot might depend on the volumes that you purchase of ball powder - Is this stuff supplied by the .5 kilo tub or 10kg?

One other thought strikes me. The Gardai would probably like this stuff to be locked away in a safe or cabinet for security. A fireman would prefer it to be stored in a more open container to lessen its explosive force in the event of a fire- who will get their way?

It wasn't me!

milkerman wrote: »

There is a piece of legislation called the 'Dangerous Substances Act' of 1955 that I think may apply here. It is administered through the local City or County Council. If I remember rightly the cost of the licence was 25 new pence. I think firearms dealers also had to get the licence because of the explosive content of ammunition. There were also limits applied below which you didnt have to get a licence. So, a lot might depend on the volumes that you purchase of ball powder - Is this stuff supplied by the .5 kilo tub or 10kg?

One other thought strikes me. The Gardai would probably like this stuff to be locked away in a safe or cabinet for security. A fireman would prefer it to be stored in a more open container to lessen its explosive force in the event of a fire- who will get their way?

A well-ventilated secure cabinet is the answer I expect.

Sparks

Vegeta wrote: »

So going by Sparks' post here it seems that reloading permission is possible

Um, is that the wrong link Veg?

Vegeta

Sparks wrote: »

Um, is that the wrong link Veg?

Noooooooo

What edit?

Sparks

Cool
I should also crosspost this:

Posting this here as well, following email with John Guinane today.

John clarified that what he meant at the seminar (about the number of reloading submissions received) was that the DoJ had received only one "substantial" submission. Legally, reloading is complicated by propellant being classified as an explosive (even through in reality it isn't), which drags in the Explosives Act (which is now being redrafted in its entirety). (As an aside, that came up in the seminar as well - John's not saying propellant is an explosive, just that that's what the law defines it as and he has to work within that framework.) He confirmed that they have received other representations on the subject, both through TD's and from individuals, but without any substantial detail that they could use while re-drafting the Explosives Legislation.

In his own words:

Any submissions, in whatever form, will be considered in the re-drafting process.

Submissions should be sent directly to:

Crime 4,
Department of Justice, Equality and Law Reform,
92-94 St Stephen's Green,
Dublin 2,
Ireland

Sikamick

Correct me if I'm wrong but the submissions that John Guinane was talking was re peoples interest in reloading and to give reasons as to why it should be allowed, submission are not applications for a reloading licenses.

Sikamick

Sparks

He was looking for suggestions - in detail - on how the Explosives Act might be redrafted to allow reloading, not applications for licences, yes.

IRLConor

It wasn't me! wrote: »

I was under the impression that it went via your local Super, but in conversation with IRLConor recently he was of the impression that it was your local fire department you'd be dealing with as well for approval.

I think the DoJ issue the import permits (I have no citation for this, although I think it's somewhere in the laws governing the transport of hazardous substances). The "local authority" is the body that issues licenses for stores of powder. Here's how I traced its definition through the laws:

First, the local authority was defined in Section 116 of the Explosives Act 1875

The local authority for the purposes of this Act shall be—

1. In the city of Dublin, the Lord Mayor, aldermen, and burgesses acting by the town council:
2. In any urban sanitary district in which the powers, jurisdictions, and authorities of the grand jury of the county in which such district is situate are vested and exerciseable by the urban sanitary authority, except as hereafter in this section mentioned, the urban sanitary authority:
3. In any harbour within the jurisdiction of a harbour authority, whether situate or not within the jurisdiction of any local authority, before in this section mentioned, the harbour authority, to the exclusion of any other local authority:
4. In any place in which there is no local authority as before in this section defined, the justices in petty sessions assembled.

The expressions "urban sanitary authority" and "urban sanitary district" have the same meanings respectively as in the Public Health, Ireland, Act, 1874.

Then The Explosives Act 1875, Adaptation Order, 1926 adapted the 1875 act to Irish law without changing the definition of local authority.

Then the Dangerous Substances Act, 1972 repealed almost all of the Explosives Act 1875 but the bits that covered that repeal were never commenced. In terms of explosives law, the 1972 act was a bit of a waste of time.

Then, in 1981, the functions of a "local authority" were transferred to the fire authorities by Sections 9 & 11 of the Fire Services Act, 1981:

1. ...
2. ...
3. ...
4. ...
5. ...
6. ...
7. ...
8. ...
9. —
   1. Each of the following local authorities shall be a fire authority for the purposes of this Act—
      1. the council of a county,
      2. the corporation of a county borough,
      3. the Corporation of Dun Laoghaire,
      4. subject to subsection (2), the corporation of any other borough and the council of any urban district which has established and is maintaining a fire brigade at the commencement of this section.
   2. Where the Minister by order provides that subsection (1) ( d ) shall cease to apply to a particular corporation or council that body shall cease to be a fire authority on the day specified in that behalf in the order.
   3. The functional area of a fire authority shall be—
      1. in the case of the council of a county, the administrative county, excluding any borough or urban district, the corporation or council of which is for the time being a fire authority;
      2. in the case of any other local authority, its administrative area.
   4. References in any enactment to a fire brigade authority, as defined in the Fire Brigades Act, 1940 , shall be construed as references to a fire authority.
   
   
10. ...
11. —
    1. The functions of a local authority under the following enactments shall be functions of a fire authority within its functional area—
       1. the Dangerous Substances Act, 1972 ,
       2. the Explosives Act, 1875,
       3. such provisions of any other enactment as are specified by the Minister by order.

In 1993, Dun Laoghaire was removed as a fire authority by the Local Government (Dublin) Act, 1993 (the one that split up the county council into Fingal, South Dublin and Dun Laoghaire-Rathdown).

Other than that, I see no modifications to the definition of "local authority" for the purposes of the Explosives Act, 1875. If anyone does know, I'd be delighted to find out.

So, in short (!) it's not quite the local fire brigade, it's the county council or corporation which runs your local fire brigade.

Sparks

...and if anyone ever wants to know why the explosives act rewrite isn't simple, that post is probably one of the better explanations!

IRLConor

Sparks wrote: »

He was looking for suggestions - in detail - on how the Explosives Act might be redrafted to allow reloading, not applications for licences, yes.

I was under the impression that the Explosives Act didn't need to be redrafted to allow reloading, since Section 41 of it already exempts it:

Explosives Act, 1875, Section 41 wrote:

Nothing in this Act shall apply to the filling or conveying, for private use and not for sale, of any safety cartridges to the amount allowed by this Act to be kept for private use.

I always thought that the restriction on reloading was accomplished by controls on the importation, transport and/or storage of the propellent.

Either way, the reloading clauses in the new Explosives Act should be something like:

1. In this section -
   • "component parts of ammunition" means any part of ammunition for a firearm including but not limited to bullets, pellets, shot, propellant powder, casings, primer and percussion caps.
   • "round of ammunition" means one unit of ammunition or such component parts of ammunition which, if assembled, would constitute one unit of ammunition
2. The holder of a firearm certificate may -
   1. Possess the component parts of ammunition for the firearm specified on said firearm certificate.
   2. Deconstruct or dismantle any such round of ammunition into its component parts.
   3. Subject to a permit as set out in section 3, construct ammunition from component parts of ammunition.
   provided that they do not possess at any time more rounds of ammunition than permitted by said certificate.
3. The issuer of a firearm certificate may issue a permit allowing the holder of that certificate to construct ammunition subject to the following conditions:
   1. the holder of the permit can be permitted to construct ammunition without danger to the public, the peace or security
      and
   2. the holder of the permit will store ammunition and the component parts of ammunition without danger to the public, the peace or security

civdef

All the local fire authority has is a register of explosives stores under the 1875 act, no licence issued by them or anything, though the DoJ insists that all firearms dealers etc are listed on the local authority register. The fire service likes knowing in advance which buildings containg exciting substances.

Sandy22

Sparks wrote: »

...and if anyone ever wants to know why the explosives act rewrite isn't simple, that post is probably one of the better explanations!

But in the next post, #15, he goes on to show nicely that with the application of a modicum of time and intelligence it needn't be that complicated either.

There are two other alternatives. One would be to resurrect Section 14 of the Dangerous Substances Act of 1972 and deal with reloading in the firearms legislation. The other, the one usually adopted in practice, is to copy the English. Their regime, except in some minor areas, seems to work quite well and safely for both shooters and the authorities.

My concern is that our authorities see reloading too as an "anathema to Irish shooting sports culture" and will exploit the regulatory complexities to suppress it. Bear in mind the FRI comes from a military background where ammunition is only made in an arsenal and issued in exactly sufficient quantities on the firing line. The idea of shooters selecting their own ammo, stockpiling it and/or, God forbid, fabricating it themselves, may well be an anathema to him.

Sparks

Can't agree with you on military backgrounds Sandy, too many shooters who want to reload have military backgrounds.

Sandy22

Sparks wrote: »

Can't agree with you on military backgrounds Sandy, too many shooters who want to reload have military backgrounds.

That's because they're shooters, not because they are/were soldiers. Is the FRI a shooter? Does he want to handload? Why does he think you need to ask the range operator every time you want to use handloads? Do Englishmen and Germans have to ask, and if they don't, how often are they being blown up?

Sparks

If it only matters that they are shooters Sandy, then their military background is immaterial and the only thing is whether or not the FRI is a shooter. If you think his military background matters, then it matters for other shooters as well.

Why does he think you need to ask the range operator every time you want to use handloads?

The other questions are valid Sandy, but that one isn't - range operators in Ireland have far dafter rules than that, several won't let you even use factory loads unless you buy them from them.

Look, I think we should have reloading. I don't see what all the fuss is about over it. I really don't. But I also know that just walking up to them and saying "we want this" isn't going to work unless we have 51% of the electorate standing there agreeing with us. And I don't think the FRI has the freedom of expression that we have out here - he's a civil servant under the Minister for Justice. Anyone who thinks that he's got the ability to tell the Minister to get bent isn't quite thinking it through carefully enough.

It wasn't me!

Interestingly, it does seem almost pitifully simple to write in Conor's few clauses to an act in order to permit reloading in a useful, clear, coherent way, with a solid, reasonable mechanism to be designated in another act, with a body specified for the certification of those practitioners of it. I for one would love to reload. I really do like the idea of tailoring ammunition to my rifles for accuracy and efficacy's sake. It's a whole art and pursuit in and if itself, separate to shooting but for most countries, integral to it. It's something we should have clearer mechanisms for (I mean, until the other day, half the population of this forum was of the impression that it was absolutely illegal to do so, when that's not the case) and I sincerely believe that we're no less competent than our counterparts in other countries who practise reloading and that it's not a move that will cause undue problems for anyone.

Grizzly 45

Do Englishmen and Germans have to ask, and if they don't, how often are they being blown up?

[/QUOTE]

Dont know about the English,but Germany yes you do need to ask a lot of questions and end up filling in alot of paperwork and answering 98% of exam questions on explosive laws,and 2% on actual handloading procedures . Now,if by some freak chance the Gubmint decide to trust us with explosives for reloading[thats what they are classified as by them,so there is no point in arguing the difference].How easy do you think they will make it for us to reload??Despite there being more explosive components in your medicine cabinet,kitchen,and garden shed.Having one 1kg can of nitro powder will proably require your house to have a concrete blockhouse out in the back garden,regular inspections by Gardai,Fire Dept and HSE,etc.It will become a paperwork nightmare in so much red tape that in an Irish solution to an Irish problem,reloading will be legal here just impossible to actually carry out.
How often do German handloaders get blown up PA....0% last decade ASFIK.Wether thats up to knowing the explosive laws in and out or by simply purchasing and reading the reloading manuals and being ccareful..I cant say.

Vegeta

Grizzly45 wrote:

Dont know about the English,but Germany yes you do need to ask a lot of questions and end up filling in alot of paperwork and answering 98% of exam questions on explosive laws,and 2% on actual handloading procedures . Now,if by some freak chance the Gubmint decide to trust us with explosives for reloading[thats what they are classified as by them,so there is no point in arguing the difference].How easy do you think they will make it for us to reload??Despite there being more explosive components in your medicine cabinet,kitchen,and garden shed.Having one 1kg can of nitro powder will proably require your house to have a concrete blockhouse out in the back garden,regular inspections by Gardai,Fire Dept and HSE,etc.It will become a paperwork nightmare in so much red tape that in an Irish solution to an Irish problem,reloading will be legal here just impossible to actually carry out.

Thing is Grizz, on the exterior (looking at explosives, dangerous substances and firearms acts) it currently looks to be completely above board, very convoluted of course but doable all the same. There were even a few guys doing it legitimately.

Grizzly 45

So maybe we might be better off continuing under the old convoluted legislation???

civdef

From what I've heard, the new explosives licensing system will involve fire service inspections anyway.

It wasn't me!

Grizzly 45 wrote: »

So maybe we might be better off continuing under the old convoluted legislation???

There are provisions for it under the old legislation, true enough, but until someone gets off their arse and applies to do it and comes back here and says "Yeah, I applied; here's all the information I've gained in the process with regard to what they wanted from me in terms of storage, who I had to apply to and deal with, and my experiences of the application process and the result I had from it" very few people are going to go ahead and actually do it, so it takes some pioneer to forge the way. As I understand it, the rewrite that's going on is more to clarify procedures with regard to reloading and to make it a firearms oriented issue rather than an explosives one in the sense that it's for sporting purposes, rather than say quarrying. It would be absolutely brilliant to see the explosives act rewritten in a clear fashion for the modern nation, with deferrence to the firearms act with regard to possession of propellant powder for reloading with a clause inserted in the Misc. Bill to amend the firearms act and insert the clauses Conor offered. Actually, what would people's opinions be if the definition of explosives governed by the explosives act were amended to exclude propellant powder, which would be dealt with only by the firearms act; is that feasible?

Currently, I don't shoot a fullbore rifle, but I do intend to own some in the future, and if I get, as I propose to do, and ISSF 300m rifle, it's pretty certainly going to be in a calibre which for both supply and financial reasons will necessitate reloading (6BR, 6.5x47 etc.) so I do have a distinct interest in seeing this clarified and provided for.

jwshooter

what would make a bigger hole in the ground a kg of reloader 19 ,or the gas cylinder at the back of every ones house.
more jobs for the boys .only retired cops need apply.

It wasn't me!

jwshooter wrote: »

what would make a bigger hole in the ground a kg of reloader 19 ,or the gas cylinder at the back of every ones house.
more jobs for the boys .only retired cops need apply.

That's a very good point actually.

Sparks

It is, but aren't there a host of standards that apply to the calor gas cylinders we use, and even more to those with piped gas?
Hell, they won't even let us shoot with our air cylinders now if they're more than a decade old, and the scuba tanks we refill from have to be visually inspected annually and hydroscopically inspected every five years.

Me, I've no problem with there being sensible regulations in place, no more than I'd have a problem with having to have a gun cabinet. I'd much rather have to have the fire brigade inspect my home than than risk being the eejit standing in the ashes of his house coming to terms with the realisation that because he caused the fire, his insurance was void...

Vegeta

Sparks wrote: »

It is, but aren't there a host of standards that apply to the calor gas cylinders we use, and even more to those with piped gas?
Hell, they won't even let us shoot with our air cylinders now if they're more than a decade old, and the scuba tanks we refill from have to be visually inspected annually and hydroscopically inspected every five years.

Me, I've no problem with there being sensible regulations in place, no more than I'd have a problem with having to have a gun cabinet. I'd much rather have to have the fire brigade inspect my home than than risk being the eejit standing in the ashes of his house coming to terms with the realisation that because he caused the fire, his insurance was void...

I don't think anyone is against regulations Sparks, even tough ones, as long as it is actually accessible. The point is any Joe Soap can buy a gas cylinder but reloading on the other hand......

Sparks

I know what you're saying Veg, but my point was that any Joe Soap can buy a gas cylinder because the gas cylinder manufacturers, retailers, refillers, inspectors and servicers all have more onerous regulations to comply with; and when it comes to reloading, the law seems to think of us more as manufacturers than consumers.

Vegeta

Sparks wrote: »

I know what you're saying Veg, but my point was that any Joe Soap can buy a gas cylinder because the gas cylinder manufacturers, retailers, refillers, inspectors and servicers all have more onerous regulations to comply with; and when it comes to reloading, the law seems to think of us more as manufacturers than consumers.

I wont argue on that point as you're right

Strict manufacture regulations do not negate post purchase mischief or potential for said mischief.

In other words strict manufacture regulations do not prevent the misuse of a gas barrel after its been bought, and anyone can buy a large barrel of gas!

Lets face it, its the misuse of powder the DoJ must be worried about, which is understandable

Dvs

Sparks wrote: »

I know what you're saying Veg, but my point was that any Joe Soap can buy a gas cylinder because the gas cylinder manufacturers, retailers, refillers, inspectors and servicers all have more onerous regulations to comply with; and when it comes to reloading, the law seems to think of us more as manufacturers than consumers.

Hello Sparks,
the regulations that relate to the bulk storage of gas,
the regulations for re fillers of gas cylinders and the regulations for transport of large quantities of gas cylinders by road and regulations for retailers of gas cylinders are not applied to consumers.

who purchase a few gas cylinders from their local retailer,
one for their gas cooker, one for the gas heater and one for using with the gas gun for the torch on felt they are putting on the extension on their granny's house, guidelines for best practice exist and it is left to the individual to apply and abide by them for their own safety.

In other jurisdictions the individual reloader is exempt from the regulations for storage, transport and of large quantities of propellant that importers, transporters and retailers are regulated by, because the commonsense approach is taken that, they are a consumer that buys a few tubs of propellant and primers, guidelines for best practice exist and it is left to the individual to apply and abide by them for their own safety.
as an individual in the same way as they do with other potentially flammable compounds in their home.

Is this such an alien concept for Ireland?
is it not the case that this same commonsense approach has been applied to the Irish consumers buying gas cylinders, petrol, diesel, fuel oil and it has proved workable, consumers are even permitted to reload their own vehicles fuel tank without special training or certification in a public filling station,
they can even fill a petrol can and bring a few litres home to reload the lawnmower in the comfort of their own garage.

Dvs.

Sparks

They sure can Dvs, if they use an approved can...

Look, I'm not saying I think they're right here - I think they're off-base quite a bit. I'm just saying it's not as libertarian-simple as folks think.

Kryten

02:41, Sparks up late on a school night The issue as I see it is that the end result is ammunition for firearms, and they are bad :( (according to the minister)

Yes there are more dangerous substances and use of these substances can lead to a greater explosion risk. But the authorities just cannot get past the whole firearms thing

Sparks

Kryten wrote: »

the authorities just cannot get past the whole firearms thing

Y'know, I just can't get behind that generalisation. The Minister, for example, doesn't hate firearms. He, so far as I can tell, doesn't give a tuppenny bleep about them. They only popped up on his radar when they began to affect his job rating and re-election prospects. That's not being anti-firearm, that's being highly cynical. Equally unpleasant, but not the same. As to the civil servants in the DoJ, to be honest, I think they privately support target shooting and the other legitimate uses of firearms. These guys aren't stupid - they can see the statistics as well as we can. They can't say much publicly - civil servants are not permitted to represent themselves publicly (which is why you won't hear from the DoF mandarins over the current contraversy in the DoF about who read what report). But if you look at what they have done over the past few years, and compare it to what their predecessors did, and compare it to the course of action that would have resulted in the least amount of work for them, and you compare it to the behaviour of certain other groups of civil servants our sport comes into contact with; well, you get a nicer impression of the firearms unit.

The Gardai.... well, I don't have enough contact with the FPU to give a solid impression, but I've a fair amount of leeway for Gardai most of the time - but the 'no evidence' statement from last week has been eating away at that since I heard it and I'm increasingly unhappy about it. But there are lots of Gardai who are supporters of us (feck's sake, some of the Gardai there on Friday are shooters themselves). So I'm not about to light the torch and pick up my pitchfork just yet (well, not for them anyway. Some of the slow readers in the DoF, now, that's for another forum).

lordarpad

OK, how do I make a reply to the MOJ on this subject?