Reports of Mass Disapprovals of eForm 1 Silencers

[traveller]

The way you write it, its so clear cut. If its that clear, why has it taken them years to enforce the law? Who should get fired for allowing all these illegal suppressor to be sold?
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I have no doubt that internally the ATF always looked at the 'solvent traps' as a premade silencer. In a different time and under different leadership , they decided not to press the issue and allowed their sale under the 'if it has any other legitimate purpose' interpretation.

Just because the cop lets 10 cars going 15 over pass before he finishes his donut and pulls you over the speeding law isn't suddenly invalid.

 

[IMBLITZVT]

I have no doubt that internally the ATF always looked at the 'solvent traps' as a premade silencer. In a different time and under different leadership , they decided not to press the issue and allowed their sale under the 'if it has any other legitimate purpose' interpretation.

Just because the cop lets 10 cars going 15 over pass before he finishes his donut and pulls you over the speeding law isn't suddenly invalid.

I think solvent traps were out long before Trump.

I don't see the ATF letting 10 people build Machine guns illegally and only going after the 11th that happens along. I see your point but I don't think it holds in this situation. Its not like they let 10 people build one using a solvent trap, its like the let 10,000 build using a solvent trap. At best its more like when the cop give you a ticket in Baltimore for J-Walking. I bet you would be pretty pissed with that.

The problem with malum prohibitum law is that there is no natural "bad" to guide you. Its simply bad because ATF (hopefully using some crappy law) says its bad. So if the ATF is not saying its bad, then its only natural to assume its ok and good as that is the natural state of the world before they developed some statute saying the opposite. We view the world as a naturally free place with only the laws of God and Man to restrict us. We do not need permission to do something but we are restricted from doing certain things spelled out by law. In this case, there is no natural or moral reason to think taking a device and making it into another device is bad. The only guide we have is the ATF. If they do not stop it, and its clearly a known practice, then we must assume its ok, as its naturally ok and not immoral. The problem is when they then suddenly change and are now willing to toss you in jail for 10 years for something that all but sanctioned (by issuing previous form 1s when they knew it was happening) not long before. We expect the the rules to be fair and consistent. Its annoying when they are seeming changed at the whim of the ruler. That is how the ATF is acting and why so many are upset and IMO rightfully so.

 

[Trigger Time]

I tried to buy a Napa 4003 fuel filter from Amazon several years ago when the Form 1 thread was still active. A couple days after the sale UPS tracking said it was delivered to an address in the Bronx NY, it said signed for buy ATF. So I suspect they have been watching that stuff for a while.
I had to use a different brand of filter for my tractor.

 

[theNOTORIOUSmo]

As an update to my situation,

I just got my form 1 approved and so did 2 other people I know personally.

 

[traveller]

As an update to my situation,

I just got my form 1 approved and so did 2 other people I know personally.

After you responded to their RFI ?

 

[theNOTORIOUSmo]

After you responded to their RFI ?

Correct. I went overkill and sent pictures of my equipment. Buddy who also got approved said he will just be using machine tools and that materials will be purchased dependant on the approval of the form 1.

Before this BS happened I was going to purchase a tube and endcap and machine all the baffles myself. Looks like I will be doing everything now seeing as it's a little questionable for vendors to even sell tubes or endcaps now...

 

[teratos]

Correct. I went overkill and sent pictures of my equipment. Buddy who also got approved said he will just be using machine tools and that materials will be purchased dependant on the approval of the form 1.

Before this BS happened I was going to purchase a tube and endcap and machine all the baffles myself. Looks like I will be doing everything now seeing as it's a little questionable for vendors to even sell tubes or endcaps now...

I would seriously recommend you shroud your barrel.

https://sdtacticalarms.com/product/barrel-shroud/

 

[theNOTORIOUSmo]

For some reason i thought they stopped selling too like every one else. that's good to know that i can still make sure i can keep a carbon fiber barrel from getting banged up.

 

[teratos]

For some reason i thought they stopped selling too like every one else. that's good to know that i can still make sure i can keep a carbon fiber barrel from getting banged up.

Indeed. I have several and they really do a good job. All of my barrels look factory new.

 

[traveller]

Correct. I went overkill and sent pictures of my equipment. Buddy who also got approved said he will just be using machine tools and that materials will be purchased dependant on the approval of the form 1.

The approvals suggest that this was not some nefarious scheme to outlaw all homemade silencers but an attempt to bring that business in line with how they regulate commercial silencer manufacturers.

Before this BS happened I was going to purchase a tube and endcap and machine all the baffles myself. Looks like I will be doing everything now seeing as it's a little questionable for vendors to even sell tubes or endcaps now...

I would expect that after the dust settles, those machine shops will go through the paperwork with the agency to sell 'silencer parts'. If you provide a copy of your form1, they will then sell you a 'silencer end cup' or a 'silencer tube assembly' and everything a-ok.

 

[theNOTORIOUSmo]

I would expect that after the dust settles, those machine shops will go through the paperwork with the agency to sell 'silencer parts'. If you provide a copy of your form1, they will then sell you a 'silencer end cup' or a 'silencer tube assembly' and everything a-ok.

I may be mistaken, but for that would require them to change their definition of what is a silencer is for them to do that. Currently the way it is written with my understanding is that each "silencer part" you buy would require a transfer on a form 4. And for the machine shops to manufacture these "silencer parts", they would need an 07 FFL and get their class 2 SOT.

 

[teratos]

I may be mistaken, but for that would require them to change their definition of what is a silencer is for them to do that. Currently the way it is written with my understanding is that each "silencer part" you buy would require a transfer on a form 4. And for the machine shops to manufacture these "silencer parts", they would need an 07 FFL and get their class 2 SOT.

I call shenanigans. You can buy mounts and end-caps all day long.

 

[theNOTORIOUSmo]

i was more referring to them being called "silencer parts" and going through the paperwork with the ATF to manufacture "silencer parts".

on the endcap issue though. still makes me wonder why none of form 1 people would sell endcaps separate from tubes with the hole in them. if dead air and SiCo can get away with it with no issue, why couldn't they?

 

[teratos]

i was more referring to them being called "silencer parts" and going through the paperwork with the ATF to manufacture "silencer parts".

on the endcap issue though. still makes me wonder why none of form 1 people would sell endcaps separate from tubes with the hole in them. if dead air and SiCo can get away with it with no issue, why couldn't they?

A mounted tube without baffles is a suppressor. Not a very efficient one, but a suppressor nonetheless. If they sold drilled endcaps, technically one could order a screw together suppressor. Endcap, tube, mount. Done.

 

[theNOTORIOUSmo]

A mounted tube without baffles is a suppressor. Not a very efficient one, but a suppressor nonetheless. If they sold drilled endcaps, technically one could order a screw together suppressor. Endcap, tube, mount. Done.

not arguing that at all. all im getting at is that any tube can be threaded ASR on one end, 1.422-24 on the other. then they can sell one of the many commercial front caps that are threaded in that and a plethora of mounts. All they manufacture is a tube, the rest is on the end user to obey all applicable laws.

Now the selling of the sauce cups, dividers or whatever people want to call them always seemed like a very gray area to me. but when quietbore and whoever their 07/02 parent company made that backdoor deal with the atf to allow their kits to still be sold set the precedent that it was ok to purchase kits and manufacture a suppressor from them as long as you have an submitted form 1 beforehand. Hell, they would even ship them before it was approved as i know someone who got there 22 kit before their form 1 was approved.


I'm sure we could go down a huge rabbit hole as to what is and is not a suppressor part, but that would probably be a conversation better had in messages, beers seeing as you are probably less than 15 mins away or at the range actually doing something more enjoyable. because this topic can get this thread so off topic trying to gauge what the ATF does and does not consider a suppressor when they can change their mind on a whim.

 

[redsandman6]

A mounted tube without baffles is a suppressor. Not a very efficient one, but a suppressor nonetheless. If they sold drilled endcaps, technically one could order a screw together suppressor. Endcap, tube, mount. Done.

so whats the difference between this and a linear comp or flash cans that are sold just because they don't have end caps?. this is the problem they keep moving the goal posts

 

[lazarus]

so whats the difference between this and a linear comp or flash cans that are sold just because they don't have end caps?. this is the problem they keep moving the goal posts

Because a flash can or linear comp you’d have to machine to turn it in to a suppressor. And likely would involve a fair amount of work for a not very good suppressor.

A solvent trap is ready made to be converted to a suppressor. A linear comp or flash can isn’t.

 

[RRomig]

Because a flash can or linear comp you’d have to machine to turn it in to a suppressor. And likely would involve a fair amount of work for a not very good suppressor.

A solvent trap is ready made to be converted to a suppressor. A linear comp or flash can isn’t.

But they are a start if we’re going down that road. I agree that the solvent traps are the 80% equivalent of the lowers if not more so. But they Are Not suppressor parts. Converted , machined , finished etc is something that spells out it’s not a part for anything. It’s a start. So at what point is that line drawn. Many people have used Maglight. Do we ban those. So they have known this all along and allowed it because it was legal ( not lax about enforcement) but now they want to change the rules.

 

[alucard0822]

But they are a start if we’re going down that road. I agree that the solvent traps are the 80% equivalent of the lowers if not more so. But they Are Not suppressor parts. Converted , machined , finished etc is something that spells out it’s not a part for anything. It’s a start. So at what point is that line drawn. Many people have used Maglight. Do we ban those. So they have known this all along and allowed it because it was legal ( not lax about enforcement) but now they want to change the rules.

This is true, the legal definition aka "who belongs in a cage for posessing a metal tube without permission" is a moving target depending on who is in office, that is a dangerous precedent.

9221(a) (24)=

(24) The terms “firearm silencer” and “firearm muffler” mean any device for silencing, muffling, or diminishing the report of a portable firearm, including any combination of parts, designed or redesigned, and intended for use in assembling or fabricating a firearm silencer or firearm muffler, and any part intended only for use in such assembly or fabrication.

the "any part intended only for use in such assembly or fabrication" is where we have an issue, a freeze plug, maglite tube or block of metal does not meet the definition. Undrilled baffles even mounts and tubes produced by a form1 buisness seem to meet it. It's a crap definition that is overly broad, and will take a court case to limit, or hopefully a law or case to strike the unconstitutional mess that is the 34NFA down.