Exclusive: Not UnSafe
Inside A California Independent
Handgun Test Laboratory
By Mac Scott
A decade ago the State of California enacted a law mandating virtually any handgun model sold in the state must undergo testing by an Independent Handgun Test Laboratory before it would be allowed on the market. This is the story of one of those laboratories.
The 1990s saw a rise of gun-related legislation at the municipal and county level throughout California. “Enlightened” politicians passed ordinances banning the sale of “Saturday Night Specials” within their jurisdictions. While varied and confusing to the extreme, these laws all had something in common: they tried banning something that couldn’t be adequately described. Analogous to the 1964 pornography opinion issued by Justice Stewart (“I don’t know how to define it, but I know it when I see it.”), even the most gun-savvy were unable to come up with a workable definition of “Saturday Night Special.”
The problem grew to a point where the state legislature stepped in and enacted SB15, calling for mandatory testing of almost every handgun model sold in California. With a rigorous procedure including massive firing and drop testing, lawmakers figured that those guns they “knew” would ultimately qualify as “SNS” would fail the tests and ultimately be banned from sale in the state. Sounded good to the politicians and liberals.
In a tribute to legalese, those guns successfully tested would be reported to DOJ as being “Not Unsafe.” My guess is that no politicians anywhere would ever want their names associated with anything that would claim a firearm was “Safe.” The semantics of politics never fail to boggle the mind.
SB15 was passed in the late 90s, with an implementation date of January 1, 2000. The California DOJ, Bureau of Firearms, was tasked with establishing criteria for the licensing of Independent Handgun Test Laboratories. My business partner, Doug McDougall, and I studied the laboratory rules and decided we actually fit this criteria: we had a shooting facility at our disposal, a better than working knowledge of firearms and a secure and alarmed building.
We bought a gunsafe with the requisite rating for secure firearms storage. Ammo storage only required a locked container, so we bought a Rubbermaid cabinet and put a padlock on its door. One importer sent us a trio of 1911 clones for testing, just in case we became licensed. We put these three pistols in the safe, the accompanying 2,000 rounds of ammo in the locked plastic cabinet and advised DOJ we were ready for inspection.
Shortly a small army of suits invaded and checked out our facility. (All DOJ people I dealt with were, in truth, very pleasant and professional.) They observed us shoot and drop the one model we had on hand, apparently decided we weren’t a hazard to ourselves or others, and issued us Handgun Test Laboratory License #3. I, as the contact guy, began soliciting manufacturers for their handgun testing business.
I’m not sure if we were naïve, short-sighted or just plain stupid. Both the state inspectors and us thought we had all our bases covered for receiving test guns into our shop, doing our thing with them and shipping completed guns back to the manufacturer and DOJ. All would fit into our little safe and cabinet, right? Wrong!
A selection of handguns and ammo on their way to the range for testing.
Soon a huge truck pulled up in front of our gunshop. The operators got out, removed a forklift and offloaded pallet after pallet of boxed guns and ammunition to the sidewalk. Something like 300 new in the box handguns, and over 100,000 rounds of ammunition, and this just for Ruger. We later received test guns from, among others, Heckler & Koch, Beretta, Taurus, Charles Daly, Wilson Combat, Kahr Arms, North American Arms and Kimber. So much for the capacities of our safe and ammo locker.
Initially overwhelmed, we soon got to work converting two unused areas in our office space to “safe” rooms, with solid doors and alarm systems. As guns and ammo continued to flow our way, these rooms began to fill rapidly, but they ultimately held all the to-be and have-been tested stuff. And, of course, the ammo depleted itself rapidly.
The State mandated that three samples of each tested model receive 600 rounds of full-power ammo, a total of 1,800 rounds per model. No malfunctions (other than provable ammo failure) were allowed in the first 20 rounds per sample; no more than 6 gun-caused malfunctions total were allowed per sample (18 malfunctions per model). Each handgun had to be allowed to cool after 50 rounds, then inspected for loose screws, etc., every hundred rounds. Guns were to be periodically cleaned and lubed according to manufacturer recommendations.
Assuming all three samples passed the firing test, the guns were then dropped onto a concrete pad from a height of 39.4″. A primed case was placed in the chamber and the gun was made ready in its easiest-to-fire state (eg: hammer at full-cock on D/A revolvers and 1911-types, safeties off, etc.). Each sample was dropped six times from six different positions, to land on muzzle, top, bottom, butt, one side and hammer (if present). No incidents of drop-induced discharge were allowed. If one pistol went “pop” the whole test was out the window; the manufacturer would have to submit three new handguns and more ammo for a complete new test.
So there we were, multiple guns and ammo on rollaway carts, spending endless hours on the range blasting away. At first we took it as an opportunity to hone skills, performing speed and accuracy drills. It didn’t take long, however, to figure out that was not particularly time-effective. With ultimately well over a thousand handgun samples to test, each requiring 600 rounds, it became a matter of getting as many rounds through the guns in as expeditious a manner possible.
The State allowed us to use outside “testers” to fire these guns under our direction. Each tester was vetted, their names submitted to the State for their records. We put the word out to our local IPSC club, to our better customers, and local law enforcement. At first we had no end of people who thought it was “just too cool” to be able to shoot all these new guns with all that free ammo. It didn’t take long, however, for the coolness factor to wear off. Guys would wheel out three guns and two full cases of ammo with big smiles on their faces; they’d return several hours later holding their wrists, putting bandages on trigger fingers, coughing like chain smokers and shaking their heads like wet dogs. While a handful of our volunteers kept coming back for more, very few lasted more than one model. Some didn’t even make it that far. Doug and I ended up testing about 90 percent of the guns ourselves.
A Taurus “Raging Hornet” leaving the drop fixture
holder, en-route to striking the concrete floor.
A primed case rests under the cocked hammer.
In this case, we caught the Taurus bouncing
back up. Note the hammer had fallen due to
the hit, but the primed case did not fire due to their safeties.
Putting about 2,000 rounds of ammo through three handguns in a short period of time takes a lot of effort and exacts a personal toll. Semi-autos were the simplest: emptying the mags was no huge problem. It was getting them loaded, over and over again, that caused pain, abraded skin and raised blisters. The real time-consumers were the revolvers. We tried speedloaders, but they actually slowed down the process, essentially requiring the ammo be handled twice. Ultimately the old tried and true method of revolver loading worked out the best. With all that practice, of course, some of us started approaching almost Miculek-like speed, but pretty soon the carpal tunnel gods got the best of us. At the end of some revolver sessions we actually had to manually straighten our curled, gnarled fingers.
What guns were the easiest and hardest to test? Being a 1911-kinda guy, that type was always my first choice. I could complete a shooting test on a 1911, including loading all mags myself, in about 1 ½ hours. That was made possible by having one of our gunsmiths dedicated to checking and cleaning each gun, as necessary, during its cool-down period. Drop-testing added another half-hour or more and wasn’t done in conjunction with the live-fire testing, for obvious safety reasons.
The most punishing guns, surprisingly, weren’t the various .44 Magnums, .454 Casulls and .480 Rugers, although running a couple thousand rounds through any of those at a sitting was no simple pleasure. Nope, the hardest-kicking guns by far were the little Ruger SP-101 .357 Magnum 5-shots. Ruger furnished us with scads of .357 158 grain JSP Winchester ammo and they just plain hurt. Small DAO pistols also took their toll on trigger fingers with their tough pulls and sharp edges.
I admit that drop-testing was the toughest on me emotionally. Intentionally destroying fine handguns went against the grain. It was interesting, however, to see how different guns physically fared in the tests. Smaller, lighter guns came away with little to no damage save for some scuffing. Larger, heavier guns, particularly the big revolvers, were often rendered useless by test’s end. Sights would be missing, grips cracked, cranes bent, hammers broken, but they still wouldn’t drop-fire. One manufacturer’s guns proved so tough it was hard to discern any drop-testing had even taken place on them.
The (now defunct) range we used was next to our shop, but not owned or operated by us. A decent facility initially, it ultimately succumbed to shoddy or no maintenance. Its bullet traps became occluded and dangerous; its exhaust systems were a joke. Ducking pieces of rebounding lead and hacking like Welsh coal miners became the norm. We tried paper masks, then switched to canister filtration systems, the latter working fairly well. Best was a fireman’s SCBA bottle unit, but its bulk ultimately excluded its use, as did the dirty looks from the range owner when we wore it. Probably thought it implied something about the inadequacies of his range. It did.
We tried many different methods of controlling felt recoil and reducing personal damage. Dual hearing protection was a must, as was adequate eye gear, often full face shields, and shooting gloves. As the problems with the range became more pronounced, Kevlar vests became daily wear.
Rear sight damage to the “Raging Hornet” from drop tests. Note that rest of gun,
save for a few scrapes, is undamaged, a testament to this revolver’s construction.
So what did this all accomplish? Well, aside from creating yet another bloated government bureaucracy and costing manufacturers a huge bundle of loot which they, of necessity, passed on to the ultimate consumer, not much of anything was accomplished. Those handguns sought to be banned by local governments somehow passed the testing procedures and were certified for sale in California. A huge percentage of the guns tested were of high quality and from known, big-name manufacturers and importers. That they passed was not surprising in the least.
We were lucky in that those guns we tested, for the most part, fell within the “major manufacturer” parameter; we received nothing but quality guns to test. In all the hundreds of models we tested, none failed the firing portion and only one failed the drop test. That model was subsequently redesigned with a different set of springs and resubmitted by the manufacturer, at which time it passed.
That fact, however, could never be gleaned from any information available from DOJ, for they kept no record of failed handguns. Laboratories were, in fact, forbidden from reporting test failures to the State: only “Not Unsafe” guns, duly tested, were required to be reported.
In addition to the fees of Handgun Test Laboratories, which ranged from $1,000 to $1,800 per test, the manufacturer had to spring for three samples and two full cases of ammo per model, plus freight to and from our shop. In addition to this cost is the fee charged by the State for the privilege of having a model listed on their “Not Unsafe” gun list. That fee is $200 per model — renewable annually!
Although it’s difficult to accurately figure an average ammo cost (.22 LR being much cheaper than, say, .480 Ruger), and equally difficult to know what any particular firearm costs to manufacture, the following is probably a fair guess as to what initial testing cost the manufacturer.
Test Lab Fee: $1,500
Cost of 3 guns: $1,000
Freight (2 ways): $100
1 Year DOJ License: $200
Approximate Total: $3,400
At this writing there are 1,343 handguns on California’s “Not Unsafe” list. There have been 361 models recently removed from that list (manufacturers regularly purge listed guns that aren’t selling well), giving an immediate total of 1,704 tested handguns. More have been submitted during the past ten or so years, but DOJ has remained close-mouthed as to the actual total.
So, if we take my average test price of $3,400 and multiply it by 1,704 models tested, we get a total of $5,793,600. Let’s say six million bucks — and I have a feeling this number is on the low side. It also doesn’t reflect annual renewal of handguns on the DOJ list by the manufacturer, which currently would be about $280,000 per year. Any guesses as to what this has added to the cost of that new handgun you’re about to buy?
The question always arises as to “why we did it?” Why did we become a test lab? The simple answer is that we could, and that we figured it’d be better if actual “gun people” were involved in the testing. As it turned out we made a myriad of friends in the industry, gained national recognition and accomplished a purpose, albeit a questionable one.
In 2004 Doug McDougall died of lymphoma, all too young at age 40. I transferred the test lab license to Oregon, continued testing through 2006, then resigned the license and ended one of the more interesting eras of my life. As I’m fond of saying, “It was quite a ride.”
And ask me if I’m glad to have escaped California.
Mac Scott may be contacted via Email at firstname.lastname@example.org.