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Handloaded Ammunition Declaration: MoD Ranges


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53 minutes ago, Brillo said:

As one of those involved in organising the Birmingham Bisley, there was some initial concern about the declaration, but it is nothing onerous and it does not ask for specifics. Therefore, any load data remains in the privy to the person signing the declaration.

All it asks is that the shooter specifies which calibre is being used and which source the load data came from. For example, I stated .308 and the data source was Quickload and the Berger reloading manual. 

Next they will be asking when your scales were last calibrated at a UKAS accredited calibration facility. 

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Really? That’s a bit of a vacuous statement. All they are asking is for you, the shooter, to confirm that you have followed safe reloading procedures. That is not an unreasonable thing to ask.

If anyone on here has seen or completed the declaration you would not object to it.

 It’s no more onerous than signing on a range and providing your FAC number.

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40 minutes ago, Brillo said:

Really? That’s a bit of a vacuous statement. All they are asking is for you, the shooter, to confirm that you have followed safe reloading procedures. That is not an unreasonable thing to ask.

 

I quite agree. This comes back to the MoD's / Landmarc's legal obligations under Health & Safety at Work legislation. Let's just hope we never have some idiot with a grossly overloaded cartridge and/or loaded with a quite unsuitable powder/bullet combination kill or seriously injure somebody else on the firing point. Personal tragedy aside, handloads would be doubtless banned within days with the possible exception of those holding some sort of handloading competence certificate as per the Safe Shooter certification only more onerous.  

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Indeed. Unfortunately it take just one person to take it jet that little bit too far, which results in an incident, that will then make it very difficult for the rest of us.

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1 hour ago, Laurie said:

 

I quite agree. This comes back to the MoD's / Landmarc's legal obligations under Health & Safety at Work legislation. Let's just hope we never have some idiot with a grossly overloaded cartridge and/or loaded with a quite unsuitable powder/bullet combination kill or seriously injure somebody else on the firing point. Personal tragedy aside, handloads would be doubtless banned within days with the possible exception of those holding some sort of handloading competence certificate as per the Safe Shooter certification only more onerous.  

Do checks properly or don't do them at all. When some idiot blows his firearm up on a MoD Range even though he used 'recognised/approved/validated' (by what SEQP Body I might ask) data, but when looked into further, used his partners kitchen scales to measure the amount of 'recognised/approved/validated' propellent powder to use. Worse still the idiot who mixed Pistol Powder with Rifle Powder. These 'administrative safeguards' are not worth the paper they are written on. H&S at Work Act is for the work place, if you are not in a work place, in most instances the regulations don't apply, that's why so many people are allowed to fall off totally unsuitable ladders at home and not get prosecuted. Trying to put something in place that cannot be properly audited and checked and which relies on an individuals self declaration will not stand up to scrutiny when something does go wrong. 

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21 minutes ago, John MH said:

Do checks properly or don't do them at all. When some idiot blows his firearm up on a MoD Range even though he used 'recognised/approved/validated' (by what SEQP Body I might ask) data, but when looked into further, used his partners kitchen scales to measure the amount of 'recognised/approved/validated' propellent powder to use. Worse still the idiot who mixed Pistol Powder with Rifle Powder. These 'administrative safeguards' are not worth the paper they are written on. H&S at Work Act is for the work place, if you are not in a work place, in most instances the regulations don't apply, that's why so many people are allowed to fall off totally unsuitable ladders at home and not get prosecuted. Trying to put something in place that cannot be properly audited and checked and which relies on an individuals self declaration will not stand up to scrutiny when something does go wrong. 

I agree in part.  It seems like a weak attempt at regulation as there's no audit (yet).  If a shooter can't be trusted to make up good, safe rounds, then how likely is he/she likely to alter their behaviours when confronted by a declaration to sign?  Having said that what's the real alternative other than to chrono and/or pull rounds for inspection?

I recall a conversation with an F Class shooter who was extremely blasé about overloading rounds "we start load development after maximum loads in the manuals" and this was "advice" being given to a small group of club shooters.   A Dangerous Pr1ck.

A self declaration is not likely to carry much weight in court when some poor third party is seriously injured or worse.  At best a declaration may, just may encourage people to seek advice and take safety a bit more seriously.

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20 minutes ago, John MH said:

These 'administrative safeguards' are not worth the paper they are written on. H&S at Work Act is for the work place, if you are not in a work place, in most instances the regulations don't apply, that's why so many people are allowed to fall off totally unsuitable ladders at home and not get prosecuted. Trying to put something in place that cannot be properly audited and checked and which relies on an individuals self declaration will not stand up to scrutiny when something does go wrong. 

 

I couldn't agree more! However, that's the world we inhabit now. After a fatal incident, the inevitable Monday-morning quarterback investigation will pose the rhetorical question. "You're telling me that you allowed people on your range to fire ammunition they'd created at home for high-power rifles with no checks at all on their competence, or even asked them what data they used?"

 

I have a direct parallel experience here, many many years ago on a private commercial range, not an MoD one. Most times I went there, there was a guy with a repro Winchester 1866 'Yellow Boy' levergun in 44-40WCF. As I had a passing interest in the cartridge, I asked him about components and loads and got some bullshit replies. Then, he came clean and it turned out that he'd NO knowledge at all about his loads. A mate had set him up with a Lee Turret press and dies complete with the Auto-Disk measure and had set everything up for him and chosen the components and loads. All the owner had to do was to feed in primers to its magazine, pour powder into the Auto-Disk hopper, and finger-seat bullets while pulling the handle to size cases and work the  primer and measure. I had (in my own head) mixed views on this, but decided in the end that it seemed to work, but nevertheless I'd be far happier if he'd read a manual or two and knew what he was doing. Long after I'd stopped going there, I mentioned this fellow to another shooter who knew the range in question. 'Oh, he blew that rifle up very comprehensively was the response!'

 

Every day almost, I read posts and see questions asked on forums supposed to be populated by experts that simply wouldn't be there if the poster had done even minimum basic research and/or read any of the bullet company manuals. The degree of ignorance revealed is sometimes breathtaking especially when injected into a discussion that is contingent on the use of rifles with non-standard chambers and freebores which have a considerable effect on pressures, or loads require employment of particular cases. 

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Anyone that's been shooting for a few years and meets up with club members will have unfortunate tales of reloading cock-ups.  Arrogance and ignorance in large measures.

We had a member load a .223 based on an overheard conversation where the other chap talking was making a joke 'one teaspoon' of powder xxx.    I kid you not.  He is still alive and in one piece thankfully.  I'm not sure how much he actually learned from the experience either...  Then there's the chap with five bullets stuck up his barrel....    I despair

As a club sec I'm reluctant to advocate for reloading training in house as we don't have 'credentials' that would stand up in court should something go wrong down the line.  I will personally help individuals 1 to 1 but I'm very particular about who I will help - I must trust that they will act sensibly.

This forum is generally populated by sensible types but there's still a small but disturbing amount of a casual disregard for safety first in offering load advice for unknown rifles

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3 hours ago, John MH said:

H&S at Work Act is for the work place, if you are not in a work place, in most instances the regulations don't apply

Afraid that particular act does apply, it’s freely available and I would recommend that anyone acting as an officer of a constituted club acquires a copy and digests the obligations within.

Reasonableness is the name of the game and being able to evidence that “you” have done all that you can so far as is reasonably practicable to mitigate risk might well prove valuable post incident. It is that desire to produce evidence that is likely to be the motivation behind asking what to me seems a reasonable question.

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7 hours ago, SMLE said:

Afraid that particular act does apply, it’s freely available and I would recommend that anyone acting as an officer of a constituted club acquires a copy and digests the obligations within.

Wrong in part, see here: https://www.hse.gov.uk/entertainment/leisure/basics.htm and here https://www.hse.gov.uk/entertainment/leisure/amateur-sports-club.htm

In particular: 

Quote

However, anyone (including volunteers) with control of non-domestic premises like a school or community hall has legal responsibilities under health and safety law to make the premises and any equipment or substances provided for their use there, safe, so far as is 'reasonably practicable'.

If the Club or Range operator has to provided the ammunition then they have a responsibility to ensure its safe, if Range users (the Public/Club Member doing a leisure activity in this scenario) provide their own ammunition then the club cannot be responsible if it is unsafe. However, it is probably reasonable to ask the person shooting hand loaded ammunition if they used 'approve/accredited/recognised' data but if it all goes Pete Tong and someone is hurt when the questioned by the court was all done that was reasonably practical to mitigate the risk i.e  elimination, substitution, engineering controls, administrative controls and personal protective equipment, then the answer would probably be no. If there is a perceived risk that hand loaded ammunition could be dangerous then the easiest mitigation is to 'eliminate' the risk i.e ban the use of home loaded ammunition (a bit severe and not something I would like to see).

Take this example, a company provides a Zip Wire Experience where whilst undertaking the activity the customers are exposed to the risk of a fall from height. They mandate that only harnesses provided by them can be used by customers, these harnesses are serial numbered and regularly safety checked/tested and replaced with new at regular intervals (life expired). A customer turns up and asked can they use the harness they made themselves, it was made at home to recognised industry specifications so should be safe; what do you think the Zip Wire Experience company are going to say, 'sign this certificate to say you made it to recognised data' and you are good to go, I don't think so.

Most HSE Regulation/Law is legally complex and often difficult to understand, as a result they provide an 'Approved Code of Practice' to allow employers and employees (including self employed) to navigate the HSE Regulation/Law, if you can demonstrate that you followed the ACOP and something goes wrong you should at least be offered some protection from the full weight of the law in court. Demonstrating means being able to 'demonstrate' (provide evidence) that the controls you put in place are being used and are effective and that there is a auditable trail. What I see from the 'declaration' approach is that whilst it may be auditable (We have a chit where Fred signed to say his home loads were assembled using 'recognised' data) it's not effective in preventing an idiot blowing up his firearm.

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There is no practical way of overseeing the safety of home loaded ammunition - it's founded on trust that the individuals have knowledge, experience and diligence in assembly.

The value of a declaration is at least the subject of safety has been raised - I would agree that a piece of paper alone is of dubious value but if the declaration is part of a general raising of awareness and education as to risks (as our club) then it does provide some evidence of addressing the issue.

I support the occasional audit at the range whether it be Q&A on paper or a physical test of rounds.  Of course we're all safe and sensible but those others maybe dangerous knobheads that need controlling !

A Safe Shooters Competence Card for reloading, requiring a test of knowledge and skills ?  Of course it wouldn't stop some fools but neither does a Driving License always ensure safe driving.

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I'm afraid the world we live in seems these days to be full of box ticking exercises more to demonstrate compliance with procedural matters than to be substantively reliable.  I do share Laurie and Brillo's views but John MH has made a good point about the validity of some of the information, because there are no checks and balances (pardon the pun) other than on trust.  Whilst it's no great hardship and no bother to complete a form if asked to do so (after all, it may be a condition of the range operator at whose pleasure we enjoy shooting at). it won't be of much help except to cover Landmarc (or whoever) in the event of an unfortunate incident happening.  Even then it will inevitably be a case of strengthening procedures "to ensure nothing like this can happen again".  I think such statements are worth about as much as the info on the paper they're written on but safety has to rely largely on the trust of the individuals we place it in.

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  • 2 weeks later...

It appears, according to the latest NRA Journal, that the NRA are going to add a 'Hand Loading' competency to a Shooter's Certification Card on the nod of your Club Chairman. Who carries the can when some 'Certified' shooter blows up their firearm is not clear. I expect the NRA will be more than happy to charge shooters for 'Certifying' them but I'm not sure they could reasonably be considered a 'Suitably Qualified and Experienced' body to perform such certification.

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2 hours ago, John MH said:

It appears, according to the latest NRA Journal, that the NRA are going to add a 'Hand Loading' competency to a Shooter's Certification Card on the nod of your Club Chairman. Who carries the can when some 'Certified' shooter blows up their firearm is not clear. I expect the NRA will be more than happy to charge shooters for 'Certifying' them but I'm not sure they could reasonably be considered a 'Suitably Qualified and Experienced' body to perform such certification.

I did think this was inevitable.  I agree that it just opens another can of worms regarding responsibility - I don't think anyone is 'certifying' but I do think we (club officers) will need to take this responsibility seriously with some evidence of how and why the approval was made for individuals.  We do this for shooting skills at our club, it's not perfect but it does show due process and not just a nod-through.

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3 hours ago, John MH said:

It appears, according to the latest NRA Journal, that the NRA are going to add a 'Hand Loading' competency to a Shooter's Certification Card on the nod of your Club Chairman. Who carries the can when some 'Certified' shooter blows up their firearm is not clear. I expect the NRA will be more than happy to charge shooters for 'Certifying' them but I'm not sure they could reasonably be considered a 'Suitably Qualified and Experienced' body to perform such certification.

Despite the fact that I teach reloading at a local gunshop I dread the day when this becomes a mandatory 'qualification'.......  at cost no doubt!

There are so many variables, opinions and methods that I can't see how it can be formularised to the extent of an exam.

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The August and November reloading courses at Bisley are fully booked. 

I have joined the que to obtain a place on the next available course whenever that may be . 

I attended a course initially at the Rifleman's in Hambridge . Have been loading for 308 , 6.5CM and recently 303 .

I don't believe we have a club official at CRPC who is qualified to approve members and probably wouldn't want the responsibility anyway .

Therefore the easiest route for me personally is to undergo the NRA course .

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Will the the NRA course 'teach' loading to the 'book' data only, if so how many target shooters (especially F-class shooters), actually load within the recommended load data? 

For example: Rifle reloading data | Handloading | Rifle calibers | Centerfire Rifle bullets | Reload your own ammo - Vihtavuori

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Teach the principles, equipment, techniques, sources of data, safety considerations and selection of materials etc.   If a person chooses to then go their own direction that's on them.

If I speed in my car they don't prosecute my driving instructor.  

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On 5/29/2022 at 12:15 PM, Richiew said:

Very secretive with loads regarding club comps mate . Don’t want us newcomers beating the old hands ???? . Took me a lot of persuading to get info re what’s a good starting point . Happy with my loads now 7 years later  . It’s just how it is with clubs . Cheers 

Actually never found this , exact opposite in fact people, both this and other side of pond,, have always been very open with loads and tips/tricks. Found this very helpful when taking up BPCR.

Would suggest if this is prevalent in you current club then join a different club!

Brds Terry

ps personally anyone who can only win by having a tech advantage as opposed to being a better shot is deceiving themselves 

 

 

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11 hours ago, geek said:

Will the the NRA course 'teach' loading to the 'book' data only, if so how many target shooters (especially F-class shooters), actually load within the recommended load data? 

For example: Rifle reloading data | Handloading | Rifle calibers | Centerfire Rifle bullets | Reload your own ammo - Vihtavuori

I know most of the competitive f class shooters in the UK and their probaly some of the best reloaders around.

My f open guns are competitive and i don't run on the edge as they don't need too..

An extra 50fps plus will see just a few millimetres gain so there's no point.

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I have long expected the day when "certification" of shooters would come as far as home reloading is concerned.  What puzzles me is on what basis other then being petrified of litigation, has this decision to up the anti by the NRA been based upon?  Is it the number of related incidents at ranges in the UK each year?  I have yet to personally witness any accident due to home  loaded ammunition in donkey's years of shooting at ranges, although there may have been the odd few.  Surely risk assessment is based on the need and need has to have some basis in real terms (ie incidents occurring) other than "it's a risky business so we need paperwork to prove that someone is "certified"".  It sounds like the thin end of a  long wedge which may yet result in this spreading to disciplines outside ranges...deer stalking for example?  Just another nail in the coffin of freedoms of (mainly) responsible people.  The ramifications if the NRA go down this route seem quite serious for the whole shooting scene.

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IIRC questionnaire the NRA put out was the initial response to concerns raised by the MOD after there had been incidents involving reloaded ammunition. 
Once the concern has been raised the NRA has to do something, gathering information will no doubt guide what happens next.

Much like the HME rules we now have, concerns were raised and a procedure devised that satisfied those concerns and allowed things to continue. ( you need HME on your SSC and do an HME card each time you visit the range). 
 

Surely much better that its the NRA that puts something in place than have the MOD make a decision.

 

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