By Dave Goetzinger of Handgun Safe Research
USA – -(Ammoland.com)- Bulldog Cases & Vaults markets a line of Chinese-made safes that share a keypad allowing the safes to be compromised with a piece of wire.
At least two manufacturers in China make safes using this fitting, Suzhou Shuaima Metal Products Co. Ltd, producing the model SM-S-170), and Ningbo Lifang Metal Products Co., Ltd, producing the model 25ED. These are intended as light-duty office safes where security needs are minimal.
They aren’t gun safes.
But any U.S. importer is free to seek California Department of Justice (DOJ) approval for devices like these, and if a light-duty office safe gets California DOJ approval it can end up in your local sporting goods store in the gun department. The packaging will suggest the device is rugged and ideal for your home-defense needs, though the Chinese manufacturer who built it had no idea what use the device might be put to in the U.S.
When I began investigating the handgun safe industry—a six-month investigation starting in March of 2015—one of my first findings was that none of the safes I examined were made in the U.S.. Several companies claimed their products were designed in the U.S., but everything was thrown together on Chinese assembly lines. Another early finding I made was that the majority of the handgun safes on the market are advertised as being approved by California’s DOJ, meaning they meet California Firearms Safety Device Standards as set down in Section 4094 of California’s Penal Code, Title 11, Division 5, Chapter 6. The emphasis of the statute is on gunlocks, though a firearms safety device (FSD) is defined to include what the statute calls a “lockbox.” In the list of key-term definitions under Section 4082, an FSD is defined thus:
(l) “Firearms safety device” means a device that locks and is designed to prevent children and unauthorized users from firing a firearm. The device may be installed on a firearm, be incorporated into the design of a firearm, or prevent access to the firearm.
The phrase “prevent access to the firearm” gives the lockbox its place among FSDs. A lockbox is designed to prevent access, so it also satisfies key-term definition (y), which states that a lockbox is “a firearms safety device that fully contains and encloses the firearm(s).” Where this gets confusing for anyone trying to understand why California’s DOJ has failed so utterly in its approval process is in sorting out the difference between two statutory concepts, the firearms safety device and the gun safe.
California’s Gun Safe Standards comprise Section 4100 of Chapter 6. The standards are divided into two parts—part (a), which describes material and construction standards, and part (b), an alternative standard.
None of the lockboxes I’ve examined meets the standards of part (a).
The devices lack most of the required attributes, like having three separate 1/2-inch locking bolts. However, a safe can be called a gun safe if it satisfies the requirements of the alternative: “(b) A gun safe that is able to fully contain firearms and provide for their secure storage, and is certified to/listed as meeting Underwriters Laboratories Residential Security Container rating standards by a Nationally Recognized Testing Laboratory (NRTL).” At first glance, this alternative standard seems to describe a lockbox. Yet, none of the lockboxes I’ve examined meets the standards of an Underwriters Laboratories Residential Security Container (RSC). None of them has had the appropriate label inside indicating that they are UL 1037 Section 54 Residential Security Containers.
What this means is that a lockbox is not a gun safe, by either definition. A lockbox is firearms safety device, like a trigger lock.
The fundamental problem with California’s conceptual device—the firearms safety device—is that lawmakers were attempting to devise a single comprehensive testing process adequate to evaluate too many products, including cable-styled gunlocks, lockboxes, gun cabinets, trigger locks, and more. Gunlocks are relatively straightforward to address with a set of testing procedures, but a lockbox is composed of more than a keyed lock. A lockbox will often have a separate locking mechanism proper for the device, the mechanism composed of both mechanical and electrical components, with a small processor controlling the electronics. A lockbox will also have a container with structural issues of its own.
Despite these realities, lockboxes need to meet only minimal standards in order to receive California DOJ approval. The FSD must be designed to prevent deactivation except by use of a key, or combination, or other method intended by the manufacturer. Combination locking mechanisms must permit at least 1,000 different combinations. The lockbox must prevent removal of or access to the enclosed firearm, and it needs to be capable of repeated use. Finally, a lockbox must pass the testing procedures described in the regulations.
A company seeking California DOJ approval for one of its lockboxes, either imported or U.S.-made, must submit four of a given model to one of California’s Certified FSD Laboratories for testing. The manufacturer must also provide the name and model number of the device, a description of the device, a description of the product’s intended use, including a description of safe operation, and the type, make, or model of firearm(s) the device is designed for. Testing procedures are outlined in Section 4095. All tests are intended to replicate forces exerted through the use of common household tools for approximately ten minutes.
In addition to describing the conditions under which tests are performed (at temperatures between 16 and 27 degrees Celsius, with a primed case installed in a locked firearm, etc.), Section 4095 describes a long series of tests to be performed on gunlocks. Only subsection (e) of Section 4095 describes a test specifically for what it calls “lock box type devices.” Lockboxes are dropped onto a concrete slab. They are dropped from a height of one meter and one centimeter with the locking mechanism facing up and with the locking mechanism facing down.
Nowhere in the statute is there any mention of how to go about examining a lockbox’s construction.
The parts of a typical lockbox—the container, the locking mechanism proper, its mechanical and electrical components, the processor, and bypass lock—are never described. Therefore no reason exists for tests of these components. Therefore the design weaknesses in a lockbox will go unnoticed unless one of the statutory gunlock tests accidentally uncovers a design problem.
Which leads back to the other glaring problem with the whole process. Certified FSD Laboratories are set up to test gunlocks, not lockboxes.
Whereas tests performed on gunlocks are done to specific purpose (like manipulating lock cylinders to determine how resistant they are to picking), lockboxes are dropped on a concrete slab to no specific purpose. A lockbox is simply deemed to have failed the test if it is disabled or if the firearm discharges the primed case during the test. “Disabled,” according to the statute, means the firearm can be accessed and fired. As for guns discharging when dropped, a modern striker-fired handgun will not discharge when dropped from a height of one meter and one centimeter.
Which raises the question of what kinds of guns are used in these tests. Subsection (b) (12) of Section 4095 explains that guns used in testing shall be “no greater than 5 inches (L) x 3 inches (H) x 1 1/4 inches (W) in size.” These are the dimensions of a typical five-shot, snub-nosed revolver. Nowhere in Section 4095, or anywhere else in the language of Chapter 6, is there any mention of the different kinds of handguns one might keep in a lockbox.
Once testing is completed, the lab submits test results to California’s DOJ, which performs no additional tests. Approved devices are then listed on California’s Roster of Approved Firearms Safety Devices.
But just because a device is listed on the roster doesn’t mean it was tested.
Subsection (c) of Section 4093 allows the DOJ discretion to approve an FSD without requiring any testing. If a product is like another product already marketed by the same importer and differs only in minor ways immaterial to the locking mechanism, the lockbox can be approved. Design defects in one device that go undetected by a Certified FSD Laboratory will be incorporated into other devices in a line of products.
And still, Certified FSD Laboratories blindly carry out their duties and send test results to California’s DOJ. By being certified through California’s DOJ to do testing, the Certified FSD Laboratories are represented to the public as having the competence to evaluate the efficacy of lockboxes. By approving the devices, California’s DOJ represents itself as having the statutory machinery in place to make pronouncements on lockboxes. But it doesn’t. Certified FSD Laboratories are entirely unable to assess lockboxes, and California’s DOJ remains ignorant of design flaws in the products it’s approving.
About Dave Goetzinger
I began while writing a piece of investigative journalism titled “Safe Cracking Is Too Easy,” published in the September 2015, issue of American Shooting Journal. The piece looked at defectively designed handgun safes, and was first posted online at ASJ on July 21, 2015, under the title “It’s Too Easy To Crack Your Gun Safe.”
About Handgun Safe Research
This site exposes the design defects and security vulnerabilities of popular handgun safes. Visit : www.handgunsaferesearch.com