The Bureau of Alcohol, Tobacco, Firearms, and Explosives (ATF) recently published a notice of proposed rulemaking (NPRM) to remove the reference to an outdated guidance document in an explanatory note following the table of separation distances (TSD) of ammonium nitrate (AN) and blasting agents from explosives or blasting agents. ATF also proposed amending that note to clarify that those separation distance requirements apply to all AN.
The big question in everyone’s mind should be: what exactly does ATF consider “all AN” to include? Does this include Class 5 AN emulsions (ANE)? Does it include AN solution (ANSol)? These questions are not addressed in the NPRM and will surely be the crux of many public comments. Application of the TSD to ANE and ANSol could have profound and costly impacts to operators. If the TSD will apply only to dry AN prill or crystals, then there will be practically no impact.