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Digging into the ATF's M855 Proposal & Why It's Wrong
Posted on 3/1/15 at 12:32 pm
Posted on 3/1/15 at 12:32 pm
This will be a lengthy post with pictures and math. Those of you that can't brain too good might want to go look up cat pictures... 
Starting with the ATF's proposal itself:
LINK
The ATF has essentially decided that it now needs to be consistent in its policy with regards to "sporting purposes" exemptions vs. protection of LEO's under the LEOPA. It has deemed that with the not-so-recent advent of pistol-type AR's a part of the GCA that defines "armor piercing" ammunition was triggered. Remember last year that this same line of thought was used by the ATF to ban civilian sales and importation on 5.45mm 7N6 Russian steel core ammunition. 7N6 does seem to fit the material definition of the applicable law (18 USC 921(a)(17)(B)) which states:
I put in bold the section that the ATF is trying to leverage in this proposal. 7N6 was perfectly fine until a handgun that could accept it as ammunition was manufactured for sale though civilian channels. Now AR-type handguns are nothing new and from what I can tell have been around almost as long as this law. Their popularity has certainly increased in recent years which I will get into as a possible reason why the ATF has decided to change its position on M855 later.
Now going to post some technical drawings of M855 and M193.
M855
M193
Starting with the ATF's proposal itself:
LINK
The ATF has essentially decided that it now needs to be consistent in its policy with regards to "sporting purposes" exemptions vs. protection of LEO's under the LEOPA. It has deemed that with the not-so-recent advent of pistol-type AR's a part of the GCA that defines "armor piercing" ammunition was triggered. Remember last year that this same line of thought was used by the ATF to ban civilian sales and importation on 5.45mm 7N6 Russian steel core ammunition. 7N6 does seem to fit the material definition of the applicable law (18 USC 921(a)(17)(B)) which states:
quote:
(B) The term “armor piercing ammunition” means—
(i) a projectile or projectile core which may be used in a handgun and which is constructed entirely (excluding the presence of traces of other substances) from one or a combination of tungsten alloys, steel, iron, brass, bronze, beryllium copper, or depleted uranium; or
(ii) a full jacketed projectile larger than .22 caliber designed and intended for use in a handgun and whose jacket has a weight of more than 25 percent of the total weight of the projectile.
I put in bold the section that the ATF is trying to leverage in this proposal. 7N6 was perfectly fine until a handgun that could accept it as ammunition was manufactured for sale though civilian channels. Now AR-type handguns are nothing new and from what I can tell have been around almost as long as this law. Their popularity has certainly increased in recent years which I will get into as a possible reason why the ATF has decided to change its position on M855 later.
Now going to post some technical drawings of M855 and M193.
M855
M193
2
Posted on 3/1/15 at 12:49 pm to Clames
Con't.
Plainly seen is that the M855's core is made of two materials, mild steel and a lead alloy. As the law is written, this two-part core would seem to disqualify it as armor-piercing since the law specifically uses the word "entirely" with respect to the construction of the projectile or the projectile core. From the ATF's proposal:
It seems they are under the impression that M855's core is entirely made of steel. It also appears this impression was developed without ever consulting the TDP's of M855 ammunition. If they did then M855 should not have required an exemption in the first place. I guess the ATF has decided that since an exemption was granted then they should withdraw the exemption with the intent to banning M855 rather than examining why M855 needed to be considered for exemption in the first place. Mention is made of granting M2AP a sporting purposes exemption on the grounds that is used for target shooting. That is true, at the time the law was drafted M2AP was preferred by Service Rifle competitors at Camp Perry because it was more accurate than standard M2 Ball. I'll allude to this again when bringing M855A1 EPR into the discussion.
Plainly seen is that the M855's core is made of two materials, mild steel and a lead alloy. As the law is written, this two-part core would seem to disqualify it as armor-piercing since the law specifically uses the word "entirely" with respect to the construction of the projectile or the projectile core. From the ATF's proposal:
quote:
In 1986, ATF exempted 5.56 mm (.223) SS109 and M855 “green tip” ammunition containing a steel core
It seems they are under the impression that M855's core is entirely made of steel. It also appears this impression was developed without ever consulting the TDP's of M855 ammunition. If they did then M855 should not have required an exemption in the first place. I guess the ATF has decided that since an exemption was granted then they should withdraw the exemption with the intent to banning M855 rather than examining why M855 needed to be considered for exemption in the first place. Mention is made of granting M2AP a sporting purposes exemption on the grounds that is used for target shooting. That is true, at the time the law was drafted M2AP was preferred by Service Rifle competitors at Camp Perry because it was more accurate than standard M2 Ball. I'll allude to this again when bringing M855A1 EPR into the discussion.
Posted on 3/1/15 at 12:53 pm to Clames
I like your evaluation. Hopefully someone will convince ATF (threat of lawsuit) to drop their charade.
Posted on 3/1/15 at 1:11 pm to Clames
Con't...
Some commenters on the ATF's proposal have cited the second paragraph of 921(a)(17)(B) as a possible reason for the ATF's decision. On the face of it, M855's jacket does exceed the 25% threshold stated in the law. Also stated is that the ammunition has to be designed and intended for use in a handgun. M855 was adopted from the Belgian SS109 which was developed out testing of the FN Minimi machine gun (later adopted as the M249 SAW by the US Army) in the 1970's. So it was "designed and intended" for use in a light machine gun to aid in its performance against the standard NATO helmet at the 600 meter range. Contrary to the popular belief that it had anything to do with the M16 though the SS109 is almost an exact duplicate of 5.56mm ammunition developed to improve the 55gr M193 in the late 1960's. The Army standardized on the SS109 because their work was already done for them, how convenient. So it's pretty clear that the second definition cannot apply to M855 even though it's jacket weight is more than 30% of the total projectile weight (20gr/62gr = 32.3%). To reinforce this point, the ATF makes this statement in footnote 7 of page 15 in their proposal:
That would imply 55gr M193 is perfectly safe (assholes currently stocking up should pay special attention here) with respect to the first definition. This footnote is also why I don't consider refutations of the ATF's proposal based on the 25% threshold standard valid. M193's jacket can make up 29% - 32% of the total projectile weight based on the above cited specifications. So either the ATF doesn't consider the M855 to be larger than .22 caliber rimfire (which would be consistent with SAMMI specifications) or they are adhering to the "intent" part of this definition. Either position is inconsistent with their stated reasons for wanting to consistently enforce the "sporting purposes" framework of the GCA.
Some commenters on the ATF's proposal have cited the second paragraph of 921(a)(17)(B) as a possible reason for the ATF's decision. On the face of it, M855's jacket does exceed the 25% threshold stated in the law. Also stated is that the ammunition has to be designed and intended for use in a handgun. M855 was adopted from the Belgian SS109 which was developed out testing of the FN Minimi machine gun (later adopted as the M249 SAW by the US Army) in the 1970's. So it was "designed and intended" for use in a light machine gun to aid in its performance against the standard NATO helmet at the 600 meter range. Contrary to the popular belief that it had anything to do with the M16 though the SS109 is almost an exact duplicate of 5.56mm ammunition developed to improve the 55gr M193 in the late 1960's. The Army standardized on the SS109 because their work was already done for them, how convenient. So it's pretty clear that the second definition cannot apply to M855 even though it's jacket weight is more than 30% of the total projectile weight (20gr/62gr = 32.3%). To reinforce this point, the ATF makes this statement in footnote 7 of page 15 in their proposal:
quote:
Projectiles of this caliber loaded into these cartridges made from other metals, e.g., lead or copper, is not armor piercing to begin with, and will not be effected by the withdrawal of this exemption.
That would imply 55gr M193 is perfectly safe (assholes currently stocking up should pay special attention here) with respect to the first definition. This footnote is also why I don't consider refutations of the ATF's proposal based on the 25% threshold standard valid. M193's jacket can make up 29% - 32% of the total projectile weight based on the above cited specifications. So either the ATF doesn't consider the M855 to be larger than .22 caliber rimfire (which would be consistent with SAMMI specifications) or they are adhering to the "intent" part of this definition. Either position is inconsistent with their stated reasons for wanting to consistently enforce the "sporting purposes" framework of the GCA.
This post was edited on 3/1/15 at 1:15 pm
Posted on 3/1/15 at 1:51 pm to Clames
Con't...
Going into the .30-06 (7.62x63mm) M2AP sporting purposes exemption (I'm just going to say SPE from here on out), it is cited in the ATF's proposal:
Very well documented, anyone who has studied the development of the M1 Garand would know that in the years preceding WW2 and the doctrinal changes resulting from experiences in WW1 that it was expected that the infantry rifleman would be issued a combat load of M2AP specifically due to it's superior accuracy and ability to penetrate lightly armored vehicles and personnel at extended ranges. Standard M2 Ball was developed out of the fact that National Guard firing ranges where not large enough to contain all M2AP entirely within the designated impact zones. M2 Ball was not intended for the battle field but production shortages along with other logistical requirements basically forced its issue. Anything is better than nothing in that case. I can see an analogous situation developing with M855 and M855A1 in the coming years which nicely segues into the discussion of why the ATF is apparently ignoring the demonstrated sporting purposes of M855.
M855A1 EPR next to M855.
M855A1 uses a nominal 19gr steel penetrator tip over a solid copper slug and reverse-drawn copper jacket. The steel tip in M855A1 is larger and much harder than the mild steel slug in M855. This is a harder hitting round (mostly owning to the feed characteristics of the steel penetrator and increased operating pressure) and more accurate due to better in-flight stability. Part of my suspicions for why the ATF is considering this proposal against M855 is due to the fact that at some point M855A1 will be commercially available. Lake City is already producing more of it than M855 and M855A1 would be similarly exempt from being defined as armor piercing in both material and intent. If citing that it is unsuitable for sporting purposes it will have to keep in mind that the Army Marksmanship Unit (AMU) has been using M855A1 in Service Rifle competition as a demonstration of its improved accuracy.
AMU Using M855A1
Exempting M855A1 under the same guidelines as M2AP would be entirely consistent with the ATF's stated desire of uniformly applying the sporting purposes framework under the GCA. My concern is that if it decides to ban M855A1 in the face of obvious documented use as a sporting cartridge, could it also re-examine M2AP in the light of commercially available M1 Garand Match ammunition and projectiles?
Going into the .30-06 (7.62x63mm) M2AP sporting purposes exemption (I'm just going to say SPE from here on out), it is cited in the ATF's proposal:
quote:
Further, in 1992, ATF held that 30-06 M2AP cartridges were also exempt. In each case, ATF found that, “it is well documented” that the respective ammunition “has been recognized as being suitable for target shooting with rifles due to its accuracy.” Id.
These cartridges were originally produced for the military and were only later adopted by civilians for sporting purposes.
Very well documented, anyone who has studied the development of the M1 Garand would know that in the years preceding WW2 and the doctrinal changes resulting from experiences in WW1 that it was expected that the infantry rifleman would be issued a combat load of M2AP specifically due to it's superior accuracy and ability to penetrate lightly armored vehicles and personnel at extended ranges. Standard M2 Ball was developed out of the fact that National Guard firing ranges where not large enough to contain all M2AP entirely within the designated impact zones. M2 Ball was not intended for the battle field but production shortages along with other logistical requirements basically forced its issue. Anything is better than nothing in that case. I can see an analogous situation developing with M855 and M855A1 in the coming years which nicely segues into the discussion of why the ATF is apparently ignoring the demonstrated sporting purposes of M855.
M855A1 EPR next to M855.
M855A1 uses a nominal 19gr steel penetrator tip over a solid copper slug and reverse-drawn copper jacket. The steel tip in M855A1 is larger and much harder than the mild steel slug in M855. This is a harder hitting round (mostly owning to the feed characteristics of the steel penetrator and increased operating pressure) and more accurate due to better in-flight stability. Part of my suspicions for why the ATF is considering this proposal against M855 is due to the fact that at some point M855A1 will be commercially available. Lake City is already producing more of it than M855 and M855A1 would be similarly exempt from being defined as armor piercing in both material and intent. If citing that it is unsuitable for sporting purposes it will have to keep in mind that the Army Marksmanship Unit (AMU) has been using M855A1 in Service Rifle competition as a demonstration of its improved accuracy.
AMU Using M855A1
Exempting M855A1 under the same guidelines as M2AP would be entirely consistent with the ATF's stated desire of uniformly applying the sporting purposes framework under the GCA. My concern is that if it decides to ban M855A1 in the face of obvious documented use as a sporting cartridge, could it also re-examine M2AP in the light of commercially available M1 Garand Match ammunition and projectiles?
Posted on 3/1/15 at 2:42 pm to Clames
It appears to me that they really don't have much ground to stand on.
I think a court case would easily defeat their "re-interpretation" of M855.
If they want to do this correctly, there should be a vote in Congress to change or rewrite the law, not this bureaucratic fiat.
LC
I think a court case would easily defeat their "re-interpretation" of M855.
If they want to do this correctly, there should be a vote in Congress to change or rewrite the law, not this bureaucratic fiat.
LC
Posted on 3/1/15 at 3:07 pm to LongueCarabine
They don't and it's obvious they are either very confused about the composition of the current M855, they don't really care, or both. The Army at one time planned a lead-free version of the M855 and part of it is mentioned in the first drawing I posted. It called for a tungsten-based slug in place of the lead one. That would fit the material definition for armor piercing but as far as I know it never went into production beyond a few testing lots and is not available for commercial purchase.
Posted on 3/1/15 at 3:54 pm to Clames
quote:
They don't and it's obvious they are either very confused about the composition of the current M855, they don't really care, or both.
Posted on 3/1/15 at 5:28 pm to Clames
good writeup, as usual
Posted on 3/1/15 at 7:24 pm to Clames
quote:
Going into the .30-06 (7.62x63mm) M2AP sporting purposes exemption
I was going to say lets all just build 30-06 handguns.
Hopefully, the 62gr can get this or some other exemption as well, since this is bs to begin with.
Posted on 3/1/15 at 7:32 pm to Carson123987
quote:
good writeup, as usual
+1
Posted on 3/1/15 at 8:21 pm to kengel2
That's kind of the problem. M855 already has the exemption and the ATF wants to withdraw it. M855 should have even needed to be exempt according to the written definition of armor piercing ammo in the law.
Posted on 3/1/15 at 8:47 pm to Clames
I agree with you but this is pure politics.
Posted on 3/1/15 at 9:23 pm to TutHillTiger
Which is part of my point. There is no technical reason for the ATF to do this, it certainly has no interest in correctly interpreting the law as it is written. It's definitely trying to see how far it can go with stretching the legal bounds.
Posted on 3/1/15 at 10:00 pm to Clames
You got it, they were called by the Administration and told do this and now trying to find a way and then defend it.
Posted on 3/1/15 at 10:16 pm to TutHillTiger
I really would like to see what other types of ammo where submitted for SPE's. It's mentioned in the proposal but nothing else is cited.
Posted on 3/2/15 at 7:14 am to TutHillTiger
Which leads to the next question, why do we still need a ATF? They just seem like a whole division of wasteful spending
Posted on 3/2/15 at 7:23 am to GeauxWrek
quote:
why do we still need a ATF? They just seem like a whole division of wasteful spending
this X1000
It would be a great day if the ATF was abolished
Posted on 3/2/15 at 8:41 am to Clames
Great write-up. Is the M855 the most prevalent round for sale on the civilian market? Are there other rounds generally available? Anything specifically designed for hunting, like with a quality bullet, Nosler, Barnes, etc.?
Posted on 3/2/15 at 9:15 am to Mung
quote:
Is the M855 the most prevalent round for sale on the civilian market?
Fairly close with the 193 (the old U.S. GI issue) for FMJ rounds.
Most straight up 5.56mm will be either SS109/M855, M193, or derived from either of those rounds because of NATO standardization.
quote:
Anything specifically designed for hunting, like with a quality bullet, Nosler, Barnes, etc.?
Almost all of these will be chambered in .223 Remington and will work in AR-15s, despite not being technically chambered for the round. The reason being, the military is not allowed to use hollow point ammunition because of various conventions, Geneva, Hague, etc.
And many of them will be too expensive for plinking, of course, although there are some .223 FMJ plinking rounds as well.
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