-----Original Message-----
From: ‘Harmless Harry Handloader’
Sent: Tuesday November 8, 2005 2:16 PM
To: Watson, Christopher; Breitkreuz, Garry - Assistant 1
Subject: Re: FW: Proposed Changes to Reloading Regulations

CHIEF INSPECTOR OF EXPLOSIVES QUOTE #1: Secondly, explosive products and technology have changed a lot over the years, also necessitating changes to the regulations.
HARMLESS HARRY’S COMMENT: As someone who has been reloading for about 30 years, I can not think of any significant changes in the nature of propellants or primers or their containment which would require changes in the laws governing their use and storage. Some tins have changed to plastic containers, the actual manufacturers or the brand names have changed but the basic range of products remains more or less identical. In fact the only change I can think of is the withdrawal from sale of a WWII surplus powder which had a reputation for being unstable. Perhaps you could be more specific about what changes in the products have raised this concern.

CHIEF INSPECTOR OF EXPLOSIVES QUOTE #2: Moreover, you will appreciate that there is increasing public sensitivity to safety issues that must be taken into account.
HARMLESS HARRY’S COMMENT: I am aware that the general public has minimal knowledge of firearms let alone reloading of ammunition. As specifically applies to reloading components I doubt that the general public is even aware they exist. Have you had some specific complaints from knowledgeable members of the public?

CHIEF INSPECTOR OF EXPLOSIVES QUOTE #3: At the same time, I would like to make it clear that the current review of handloading regulations is not sparked by any rash of accidents or fear of them, which is an important factor to consider in the review of the regulations.
HARMLESS HARRY’S COMMENT: Again --- if it ain't broke don't fix it

CHIEF INSPECTOR OF EXPLOSIVES QUOTE #4: Indeed, the Explosives Branch maintains close links with many stakeholder associations. It has always been their practice to consult fully with stakeholders before changing any of their regulations.
HARMLESS HARRY’S COMMENT: I would hope that you would recognize that Allan Rock and the Dept of Justice gave us such a line of BS (in my opinion) under the guise of consulting with the stakeholders (and ignoring all) that virtually no one amongst the recreational shooters trusts any government branch anymore. While I appreciate receiving the CD ROM and appreciate your reply, please remember your department also has the legacy of Allan Rock and firearms registration to overcome.

CHIEF INSPECTOR OF EXPLOSIVES QUOTE #5: The video you saw may have been of a test we performed on a popular shotshell powder in a mock-up of a room.
HARMLESS HARRY’S COMMENT: I appreciate your further description of the test with shotgun powder. I certainly found it potentially interesting. Obviously there is a concern but so is there with many other products stored in basements (eg barbecue propane). My main point however re the video, is that rather than simply showing a mock up room in a snowy field going Kabloom, the demonstration should have been more fully documented. The inside of the building should have been displayed, the container displayed plus the specific powder (bullseye, or green dot etc) named, the method of ignition shown and of course followed by Kabloom :>) During my working life I was employed as a research technician and in preparing scientific papers and reports it was imperative that this sort of information was reported on. We could not simply go out and say we caught lots of fish (or no fish) --- what kind of gear did we use, when did we fish and so forth so that people could judge that the result was repeatable and not an artifact of the method. In the case of the explosion, what I am suggesting could be easily recorded on the same video camera used in the display and more than easily contained in a CD ROM etc.

CHIEF INSPECTOR OF EXPLOSIVES QUOTE #6: If changes to the regulations are required, our goal will be to balance the desire of handloaders to continue to practice their hobby unimpeded with the need to ensure public safety and security.
HARMLESS HARRY’S COMMENT: I would think if any changes are needed, it would be less in the form of regulation than as advisory pamphlets on proper powder storage or the construction of extreme fire proof containers. Examples would be underground storage outside the building or a box of multiple layers of gyprock capable of withstanding a house fire for say 3 hours.

Thanks Harry

------------------------------------------------------------

-----Original Message-----
From: Watson, Christopher [mailto:cwatson@NRCan.gc.ca]
Sent: Monday November 7, 2005 9:09 AM
To: 'Harmless Harry Handloader’
Cc: Kasemets, Juri
Subject: FW: Proposed Changes to Reloading Regulations

Dear Mr. Handloader,

Thank you for your e-mail dated November 5, 2005, expressing your concerns over proposed changes to regulations under the Explosives Act relating to the handloading of ammunition.

We are currently reviewing all of our regulations, for a number of reasons. Firstly, newer legislation has rendered some parts of the Explosives Act obsolete, e.g. the Transportation of Dangerous Goods Act now covers much of explosives transportation. Secondly, explosive products and technology have changed a lot over the years, also necessitating changes to the regulations. Moreover, you will appreciate that there is increasing public sensitivity to safety issues that must be taken into account.

While we recognise that handloading properly practiced is a safe activity, government has the duty to maintain up-to-date, appropriate regulations, thereby maintaining the confidence of the public that government is acting in a responsible manner. At the same time, I would like to make it clear that the current review of handloading regulations is not sparked by any rash of accidents or fear of them, which is an important factor to consider in the review of the regulations.

The Explosives Act prohibits the manufacture of explosives (including ammunition) anywhere except in a licensed factory - unless exempted by regulations. In the past, we have worked with the reloading community to put in place regulations to exempt handloaders from this prohibition. Indeed, the Explosives Branch maintains close links with many stakeholder associations, including the blasting explosives manufacturers, fireworks importers and users and other industry groups. It has always been their practice to consult fully with stakeholders before changing any of their regulations.

At the invitation of the National Firearms Association (NFA), I attended a world sport shooting advisory board at their annual meeting in March, and have met with officials from a number of shooting associations and gun clubs to discuss this issue. Be assured that no proposals to modify the regulations affecting handloading will be made before full consultations have been completed with all involved.

The video you saw may have been of a test we performed on a popular shotshell powder in a mock-up of a room. 8lb of powder was contained in a plastic bottle which was then exposed to a fire. The bottle was not the original container; but we subsequently obtained similar results in original packaging. The video has not been released to anyone except officials of shooting associations, and the propellants industry.
Discussions with reloaders indicate that many people prefer to purchase in larger containers (8 or 12 lb) for economy and store indoors to avoid temperature and humidity cycling. Our testing indicates that outdoor storage should not be a problem, and that indoor storage will not have effects outside the building. The area of most concern is the reaction in a fire of a large container in an enclosed space. The overpressure generated could significantly damage the building. The solution may be in storing in smaller containers in a suitable cabinet.

If changes to the regulations are required, our goal will be to balance the desire of handloaders to continue to practice their hobby unimpeded with the need to ensure public safety and security. Again, please be assured that we will not change anything in the current regulations until all interested parties have had the opportunity to provide their input.

Thank you for taking the time to write and share your thoughts.

Yours sincerely,

C.G. (Chris) Watson, Ph.D.
Chief Inspector of Explosives
Director, Explosives Branch
Minerals and Metal Sector
Tel: (613) 948-5170 / Fax:
(613) 948-5195
E-mail: cwatson@nrcan.gc.ca

-------------------------------------------------------------------------

-----Original Message-----
From: ‘Harmless Harry Handloader’
Sent: November 5, 2005 3:14 PM
To: jkasemet@NRCan.gc.ca; mhkouri@nrcan.c.ca; Breitkreuz, Garry - Assistant 1;
Subject: Proposed Changes to Reloading Regulations

Nov. 5, 2005

Dear Mr. Kasemets;

I am writing to you because I am concerned about your proposal to change the regulations regarding the possession and use of reloading components (for sporting ammunition). Like virtually all reloaders in Canada and unequivocably all that I personally know (as a recreational and competitive shooter) I feel that the regulations are quite adequate in their current form.
While I recognize that you are probably being told what to do by the

Liberal politicians in Ottawa, I also think it is important to create some credibility for government departments. We have the Canadian Wildlife Service recommending a ban on lead sinkers for all of Canada based on the death of 4 loons per year. This agency has the remarkable ability to use these 4 dead birds to declare it is the principle cause of the 15-20,000 loon deaths in Canada annually.
We further have the Justice department making regular claims of crime reduction by the gun registry, while bullets whiz by like never before in cities like Toronto and Vancouver.
Even your own department does not appear to be blameless; last summer I received a CD ROM of 3 kg of some sort of explosive being set off in a mock up building. This video appears to have been produced for sensationalism exclusively --- there is no indication of what specific powder was used nor how it was contained and both of these factors, particularly the latter would have a dramatic effect of the nature of the resulting burn/explosion. I know from experience of disposing of unwanted powder (without such effects), that the explosive must have been contained somehow.
I also have received the results of a FOI request by Garry Breitkreuz for information concerning explosions and injuries related to reloading supplies. There appear to be only 2 such cases on record and at least one, perhaps both appear to be a result of activities outside existing regulations as well as involving a surplus powder condemned several years ago for instability and apparently still being sold by an unscrupulous dealer.
In short it seems remarkable how safe reloaders are and reloading is.
To have hundreds of thousands, perhaps millions of rounds loaded annually across Canada and virtually no significant injuries over a long time speaks very loudly to the lack of need for change.

Thank you, Harmless Harry Handloader

_____________________________________________________________________________

New Drafts - Plain Language Regulations - Explosives Regulations Project
http://www.nrcan-rncan.gc.ca/mms/explosif/over/noticeboard_e.htm

We began a pilot project to make the sections of the Explosives Regulations covering family fireworks more reader-friendly some time ago. We drafted plain language Consumer Fireworks Regulations and tested them with retailers and consumers to see if the requirements were clear and easy to understand.

The Explosives Regulations project builds on that pilot project. We are now looking at the regulations as a whole and trying to write modernized regulations that reflect existing regulations, policies, practices, and changes in technology.

Explosives Regulations Project
Welcome!

Thank you for your interest in the Explosives Regulations project.

http://www.nrcan-rncan.gc.ca/mms/explosif/over/plmain_e.htm

Information about the Explosives Regulations project
We are seeking comments on the following Parts:
Part 1, Definitions, interpretation and scope of these regulations (pdf)
Part 3, Authorization and classification of explosives (pdf)
Part 4, Importing explosives (pdf)
Part 5, Making or manufacturing explosives (pdf) New!
Part 7, Industrial explosives (pdf)
Part 8, Ammunition and propellant powder and percussion caps for use in small arms and industrial tools (pdf) New!
Part 10, Model and high-power rocket motors (pdf)
Part 11, Entertainment industry pyrotechnics (pdf)
Part 12, Consumer fireworks (pdf)
Part 13, Display fireworks (pdf)
Part 14, Magazine licences and storage in a magazine (pdf)
Part 15, Licences, permits and certificates (pdf)

NATURAL RESOURCES CANADA
Explosives Regulatory Division
http://www.nrcan-rncan.gc.ca/mms/explosif/over/over_e.htm