1995 Congressional HearingsIntelligence and Security
1995 Congressional Hearings
SPORTING ARMS AND AMMUNITION MANUFACTURERS' INSTITUTE, INC.
June 13, 1995
ORAL STATEMENT OF ROBERT T. DELFAY
EXECUTIVE DIRECTOR
SPORTING ARMS AND AMMUNITION MANUFACTURERS' INSTITUTE
Concerning H.R. 1710, The Comprehensive
Anti-Terrorism Act of 1995
GOOD MORNING. MY NAME IS ROBERT DELFAY. I AM THE
EXECUTIVE DIRECTOR OF THE SPORTING ARMS AND AMMUNITION
MANUFACTURERS' INSTITUTE (SAAMI).
SAAMI, FOUNDED IN 1926 AT THE REQUEST OF THE FEDERAL
GOVERNMENT, CONDUCTS A NUMBER OF ONGOING STANDARDS AND
SAFETY PROGRAMS THAT HELP ASSURE THAT U.S.-PRODUCED
SPORTING FIREARMS AND AMMUNITION ARE BUILT TO SAFE AND
UNIFORM STANDARDS AND THAT THESE PRODUCTS ARE USED IN A
SAFE AND RESPONSIBLE MANNER.
THE 19 MEMBERS OF SAAMI INCLUDE THE NATION'S LEADING
MANUFACTURERS OF SPORTING FIREARMS, AMMUNITION AND
SMOKELESS PROPELLANT POWDERS. A MEMBERSHIP LIST IS ATTACHED
TO OUR WRITTEN STATEMENT, AND I REQUEST THAT BOTH BE
SUBMITTED FOR THE RECORD.
H.R. 1710--THE COMPREHENSIVE ANTI-TERRORISM ACT OF
1995-WOULD DIRECT THE ATTORNEY GENERAL TO CONDUCT A STUDY
TO DETERMINE THE FEASIBILITY AND LAW ENFORCEMENT
USEFULNESS OF PUTTING DETECTION AND TRACER TAGGANTS
INTO EXPLOSIVE MATERIALS.
SAAMI SUPPORTS THIS PROPOSED STUDY. THOSE SAAMI
MEMBERS WHICH MANUFACTURE SMOKELESS POWDERS ARE
COMMITTED TO ASSISTING IN THE STUDY DESIGN AND
IMPLEMENTATION AND IN PROVIDING SUCH TECHNICAL INFORMATION
AS MAY BE HELPFUL AND APPROPRIATE. SAAMI MEMBERS HAVE
ASSISTED GOVERNMENT AGENCIES IN SIMILAR STUDIES IN THE PAST,
AND IT IS URGED THAT ANY NEW STUDIES WOULD NOT DUPLICATE
THE EXTENSIVE AND AUTHORITATIVE TESTING ALREADY CONDUCTED
AND THAT THEY BE DESIGNED TO ALLOW FULL AND REALISTIC
ASSESSMENT OF THE SAFETY AND THE COST-EFFECTIVENESS OF
TAGGANT TECHNOLOGIES.
THE MEMBERS OF SAAMI SUGGEST THAT SIGNIFICANT SAFETY,
MANUFACTURING, AND DISTRIBUTION ISSUES MUST BE RESOLVED
BEFORE CONSIDERATION CAN BE GIVEN TO ESTABLISHMENT OF A
PROGRAM REQUIRING THE USE OF IDENTIFICATION TAGGANTS IN
SMOKELESS POWDERS, USED IN SPORTING AND LAW ENFORCEMENT
AMMUNITION.
THE FIRST OF THESE ISSUES IS SAFETY. PAST STUDIES HAVE
DEMONSTRATED THAT THE ADDITION OF IDENTIFICATION TAGGANTS
TO SMOKELESS POWDERS POSES SERIOUS SAFETY RISKS.
IN 1979 AND 1980, SAAMI MEMBERS PARTICIPATED IN AN
EXTENSIVE TESTING PROGRAM DESIGNED BY A BUREAU OF ALCOHOL,
TOBACCO AND FIREARMS CONTRACTOR. THE TEST RESULTS WERE
EVALUATED BY THE OFFICE OF TECHNOLOGY ASSESSMENT.
TESTING SHOWED, AND OTA CONCURRED, THAT THERE WAS A
"SIGNIFICANT DECREASE IN STABILITY" OF THE TAGGED MATERIAL
DUE TO AN INCOMPATIBILITY BETWEEN THE SMOKELESS POWDER AND
THE TAGGANT. THE DESTABILIZING EFFECT OF THE TAGGANT WAS
CONFIRMED BY FURTHER TESTS AT TWO GOVERNMENT
LABORATORIES. OTA CONCLUDED THAT A "DEMONSTRATION OF
SAFETY WOULD HAVE TO BE QUIRE CONVINCING TO OVERCOME THE
CURRENTLY PERCEIVED INCOMPATIBILITY."
IN ANOTHER SERIES OF TESTS, THE TAGGANTS CAUSED LOW
FIRING PRESSURE. THE OTA REPORT STATED THAT "SIGNIFICANTLY
REDUCED BALLISTIC PERFORMANCE, ... AND EVIDENCE OF IMPROPER
IGNITION OCCURRED" AND THAT "IMPROPER IGNITION WOULD
CONSTITUTE A SAFETY HAZARD AS THE ROUND MIGHT NOT CLEAR
THE BARREL." FIRING THE NEXT SHOT MIGHT DESTROY THE FIREARM
AND CAUSE SERIOUS INJURY TO THE SHOOTER OR BYSTANDANDERS.
OTA CONCLUDED THAT "AS A RESULT OF THIS UNCERTAINTY,
NOT EVEN PRELIMINARY INDICATIONS OF SAFETY ARE POSSIBLE AT
THIS TIME, MUCH LESS THE DEMONSTRATIONS NECESSARY BEFORE A
TAGGANT PROPOSAL COULD SAFELY BE IMPLEMENTED."
ASSUMING THAT THE SAFETY ISSUE COULD BE RESOLVED, THERE
ARE SIGNIFICANT OTHER ISSUES AS TO THE PRODUCTION TECHNOLOGY
FOR AND COST OF ADDING IDENTIFICATION TAGGANTS TO SMOKELESS
POWDERS IN THE MANUFACTURING PROCESS.
THERE ARE NECESSARILY DOZENS OF SIZES, SHAPES AND BULK
DENSITIES OF SMOKELESS POWDER GRAINS USED FOR SHOTSHELLS
AND THE VARIOUS RIFLE AND PISTOL CARTRIDGES. FOR EXAMPLE,
POWDER GRAINS MAY BE SPHERES, FLAKES, OR PERFORATED
CYLINDERS. SPHERES CAN VARY IN DIAMETER FROM ABOUT 1/1000
TO 3/1000 OF AN INCH; FLAKES, FROM ABOUT 9/1000 TO 1/10 OF AN
INCH; AND CYLINDERS, FROM 2/100 TO 5/100 OF AN INCH .
TO BE EFFECTIVE, AN IDENTIFICATION TAGGANT MUST "MATCH"
THE PHYSICAL CHARACTERISTICS OF THE PARTICULAR POWDER OR
POWDER BLEND. IF IT DOES NOT, SCREENING OF THE BLENDED
POWDER IN THE MANUFACTURING PROCESS WOULD REMOVE ANY
TAGGANTS NOT OF THE SAME SIZE OR SHAPE AS THE POWDER.
SIMILARLY, TO PREVENT A TERRORIST FROM REMOVING TAGGANTS BY
SCREENING, BY VIBRATION SETTLING, OR BY POURING THE POWDER
THROUGH AN AIRSTREAM, THE TAGGANT MUST BE A GOOD MATCH TO
THE SIZE AND DENSITY OF THE POWDER.
APART FROM INVITING REMOVAL BY A TERRORIST, FAILURE TO
MATCH THE TAGGANT WITH THE POWDER COULD RESULT IN
STRATIFICATION OF THE TAGGANT IN CANISTERS DURING SHIPPING
AND STORAGE. STRATIFICATION OF TAGGANTS COULD ALLOW USE OF
POWDER THOUGHT TO BE TAGGED WITHOUT TAGGANTS ACTUALLY
BEING IN THE POWDER OR COULD LEAD TO SERIOUS SAFETY PROBLEMS
IF A PORTION OF THE POWDER INCLUDED AN EXTRAORDINARY
CONCENTRATION OF TAGGANTS.
AN IDENTIFICATION TAGGANT PROGRAM WOULD REQUIRE A
NEW, VAST AND COSTLY RECORDKEEPING SYSTEM TO LINK A SPECIFIC
LOT OF SMOKELESS POWDER MANUFACTURED WITH A PARTICULAR
TAGGANT AND THE LAST LEGAL PURCHASERS OF THE CANISTERS
PACKED FROM THAT LOT A PRODUCTION LOT OF SMOKELESS POWDER
IS TYPICALLY BETWEEN 10,000 AND 20,000 POUNDS, WITH A RANGE OF
5,000 TO 50,000 POUNDS. SINCE THE HANDLOADER NORMALLY BUYS A
1/2 POUND OR 1 POUND CANISTER OF POWDER, THE LAST RECORDED
PURCHASERS OF A GIVEN LOT OF POWDER WOULD NORMALLY BE IN
THE RANGE OF 15,000 TO 30,000.
IT IS DIFFICULT TO CONCEIVE WHAT BENEFIT LAW
ENFORCEMENT PERSONNEL COULD OBTAIN FROM EXPENDING THE
RESOURCES NECESSARY TO COMPOSE LISTS OF THE 15,000 TO 30,000
SUSPECTS, MUCH LESS TO CONDUCT A MEANINGFUL INVESTIGATION
OF EACH.
IN ADDITION, CRIMINAL AND TERRORIST MISUSE OF EXPLOSIVES
OCCURS FREQUENTLY AS A RESULT OF THEFTS. A TAGGING PROGRAM
OPERATING AT OPTIMUM EFFICIENCY WILL ONLY LEAD
INVESTIGATORS TO THE LAST LEGAL PURCHASERS.
IN SUMMARY, AS MANUFACTURERS, SMMI MEMBERS ARE
CONCERNED FIRST AND FOREMOST ABOUT THE SAFETY OF THEIR
PRODUCTS. THERE ALSO ARE MAJOR QUESTIONS AS TO THE TECHNICAL
FEASIBILITY AND COST OF ADDING IDENTIFICATION TAGGANTS TO
SMOKELESS POWDERS. SMMI URGES THAT THESE CONSIDERATIONS BE
FULLY EXPLORED IN THE STUDY CALLED FOR BY THIS LEGISLATION
AND, AGAIN, VOLUNTEERS ITS TECHNICAL ASSISTANCE IN THE
PLANNING AND IMPLEMENTATION OF THE STUDY.
THANK YOU.