Gunslinger TWFing, does this work?

[Terronus]

A player in my campaign has been using TWF in an unusual way:
He begins his turn with an empty hand and pistol; fires two iterative shots from his pistol (with rapid reload + paper cartridges), drops his pistol and draws a second one, doing the same routine.

He makes sure he is using the TWF penalties properly, but I'm uncertain if one can TWF this way... the combat section says you need to be wielding two weapons to two-weapon fight... but perhaps I'm being overly analytical?

Your thoughts are appreciated!

[Marthian]

unless he's got Quick Draw, I just can't see it.

He might want to look into actually TWF with pistols (such as using the pepperbox, multi-classing into alchemist for vestigal arm, or witch with prehensile hair.)

[8 Red Wizards]

Two weapon fighting with Crossbows are the same as a guns, but if he doesn't have quick draw it's a move action to pull his first or second set of guns. Also a free action can be taken at anytime in and out of your turn unless specifically noted.

[Terronus]

He does indeed have Quick Draw. But it seems like a strange loop hole... by the same mechanics someone could perhaps even use two-handed weapons by drawing and dropping during the attack? Or I might just be confusing myself even more, heh. >.<

[Maxximilius]

He could also be using a glove of storing or weapon cords, and bam.