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Posted: 4/17/2008 8:11:00 AM EDT
Link Posted: 4/17/2008 8:37:52 AM EDT
[Last Edit: 4/17/2008 8:44:15 AM EDT by RenegadeX]
What is the source of this document? It is dated today (thus only a few hours old) and is on DOJ letterhead but is unsigned.

Never mind, I see it is hosted on the ATF web site.
Link Posted: 4/17/2008 9:04:35 AM EDT



haven't seen this on that silencer site yet...



Link Posted: 4/17/2008 11:07:48 AM EDT
Well, this is an interesting development.
~Dg84
Link Posted: 4/17/2008 12:23:29 PM EDT
[Last Edit: 4/17/2008 12:27:31 PM EDT by Green0]
Link Posted: 4/17/2008 1:16:44 PM EDT

Originally Posted By Green0:

I mean from what I read they are suggesting people get new stamps for the same serial in the event of damaged tubes in need of replacement.


So, what you're saying Green0 is one manufacturer can't "repair/rebuild" another manufacturer's silencer by simply stamping a new can with all the info and serial number from the old can? That's what I find interesting...

In the end I agree, it's the customer that gets the shaft.
~Dg84
Link Posted: 4/17/2008 1:22:27 PM EDT
Link Posted: 4/17/2008 1:31:13 PM EDT
[Last Edit: 4/17/2008 1:31:27 PM EDT by doorgunner84]

Originally Posted By Green0:

I think they are saying NO-one. Not even the original manufacturer can repair such a product, but can only replace it with an entirely new unit, on the same serial, and re-conduct the taxed transfer for another $200 stamp on the same serial #.

It's the new transfer of the essentially same product to the same person that seems contradictory and flawed.


Roger...
~Dg84
Link Posted: 4/17/2008 1:33:41 PM EDT
[Last Edit: 4/17/2008 1:35:11 PM EDT by 444]
Maybe I am missing something but, I don't see the point of having to pay another $200 tax to replace the tube other than a way to collect another $200.
I could see if they were trying to prevent having two suppressors with the same serial number but It doesn't say anything about having to prove that the original tube was destroyed.

I guess it just removes the incentive of trying to get away with owning two suppressors with the same serial number and only one tax stamp ??
Link Posted: 4/17/2008 3:28:17 PM EDT
So who did ALL owners of a can "this nice favor " by asking atf for a letter like that
who has the greatest benefit of that letter
That is really "a nice customer service ",,now people has to pay $200 extra for a repair

Link Posted: 4/17/2008 4:15:26 PM EDT
It would be interesting to know who asked for this letter.

So basically because of this if some malfunction destroys my suppressor I will be out $200?
Link Posted: 4/17/2008 4:21:02 PM EDT

Originally Posted By jmarkma:
It would be interesting to know who asked for this letter.

So basically because of this if some malfunction destroys my suppressor I will be out $200?


The cost of the repair PLUS $200.
Link Posted: 4/17/2008 4:30:36 PM EDT
well from now on the manufactures should put the serial number on the mounting endcap
just to make sure the customer later can have the can repaired without paying the extra pirat tax ,,,, easy enough

those who dont ,,,would take away this option from the customer
Link Posted: 4/17/2008 4:31:44 PM EDT
Actually, it sounds like lifetime warranties just got a lot more expensive for suppressors manufacturers.
Link Posted: 4/17/2008 4:31:45 PM EDT
ps who needs anti gunners ,,when some force trough a letter like that
Link Posted: 4/17/2008 4:32:15 PM EDT

Originally Posted By kel:
This Q&A document clarifying the existing legal abilities of manufacturers to modify and repair silencers was brought on by some recent actions noted by BATF of questionable "repairing" of suppressors - it will probably be of interest to the forum to read and discuss.

BATFE SILENCER FAQ / Q&A

Regards all,

Kel


Someone must have written a letter requesting a ruling.... is Eric Larson lurking around?
Link Posted: 4/17/2008 4:39:12 PM EDT
Oh Joy.

Someone prodded the ATF till they issued anothe rarbitrary ruling that makes our collective lives suck just a little bit more.

I quote from the ATF .pdf
-----------------------------

Repairs may not be done if they result in removal, obliteration, or alteration of the serial number,

The replacement of the outer tube is so significant an event that it amounts to the "making" of a new silencer.

Increasing the length of the outer tube significantly affects the performance of the silencer and results in the "making" of a new silencer.

A damaged outer tube may be repaired by any Federal firearms licensee qualified to perform gunsmithing or by the registered owner. ... The repair may not be performed if it results in the removal, obliteration, or alteration of the serial number,

Q4: If the outer tube is destroyed or damaged beyond repair, may it be replaced?
A: Unless the outer tube is replaced by the manufacturer prior to its removal from the manufacturing premises for purposes of sale or distribution (see Q6), the replacement of the outer tube amounts to the making of a new silencer.

-----------------------------

So, if you have a tube that has suffered wall damage, you're SOL to the tune of no less than $200 PLUS any costs and hassles related to getting another F4 approved. All that is over and above any repair cost the manufacturer might charge.

I guess this means I'll have to buy the heaviest duty, military grade cans I can from here on out.
Link Posted: 4/17/2008 4:42:26 PM EDT
[Last Edit: 4/17/2008 4:43:09 PM EDT by Amish_Bill]

Originally Posted By Wolfdk:
well from now on the manufactures should put the serial number on the mounting endcap
just to make sure the customer later can have the can repaired without paying the extra pirat tax ,,,, easy enough

those who dont ,,,would take away this option from the customer


They cover such logical steps too...

-----------------------------
ATF strongly recommends that manufacturers place all required markings on the outer tube of the silencer, as this is the accepted industry standard. Moreover, this practice eliminates the need to remark in the event an end cap bearing the markings is damaged and requires replacement.

Repairs may not be done if they result in removal, obliteration, or alteration of the serial number,
-----------------------------
Link Posted: 4/17/2008 4:46:57 PM EDT
The FAQ seems to apply to worn or damaged components. What's up with basically changing a new can (nothing worn or damaged) to another manufacturers baffle stack because the customer bought a loud can and doesn't like it? Do you think this FAQ applies to that circumstance?
Link Posted: 4/17/2008 4:49:16 PM EDT
The ATF and their unknown partners in screwing us ARE magnanimous despots... they allow ONE option of modifying the tube pursuant to a repair.

Towards the end, they also show us that they are experts in the design and assembly of suppressors by stating that all the original parts can be used in a tube that is now shorter. Color me confused if you will, but I can understand how 5 pounds of fecal matter can fit in a 10 pound bag, but I'm a little shy on how you can make 5 pounds fit in a bag any smaller than 5 pounds....

------------------------
In addition, the repair may result in a minimal reduction in the length of the outer tube due to rethreading, but repair may not increase the length of the outer tube. Increasing the length of the outer tube significantly affects the performance of the silencer and results in the "making" of a new silencer. ... Reducing the length of the tube by a minimal amount in order to repair a silencer is often necessary to replace damaged end caps, as the tube must be rethreaded. Such minimal reduction of the length of the tube uses all of the original parts, does not significantly affect performance of the silencer, and may be done as part of a repair process without making a new silencer.

------------------------
Link Posted: 4/17/2008 4:52:15 PM EDT

Originally Posted By olephart:
The FAQ seems to apply to worn or damaged components. What's up with basically changing a new can (nothing worn or damaged) to another manufacturers baffle stack because the customer bought a loud can and doesn't like it? Do you think this FAQ applies to that circumstance?


Heck - let me post the full text in the forum -- give me one minute...
------------------------
In the event that identical replacement parts for a silencer are not available, new and different component parts may be used as long as the silencer retains the same dimensions and caliber.
------------------------
Link Posted: 4/17/2008 5:05:10 PM EDT
Yep I sure do wonder how this all came about. Somebody is hurting EVERYONE just becaue they got pissed off. Thanks
Link Posted: 4/17/2008 5:07:19 PM EDT
[Last Edit: 4/17/2008 5:08:17 PM EDT by chromeluv]

Originally Posted By kel:
noted by BATF of questionable "repairing" of suppressors
Kel



Who/what company asked for a ruling on this?
Link Posted: 4/17/2008 5:10:21 PM EDT

Originally Posted By Amish_Bill:

Originally Posted By Wolfdk:
well from now on the manufactures should put the serial number on the mounting endcap
just to make sure the customer later can have the can repaired without paying the extra pirat tax ,,,, easy enough

those who dont ,,,would take away this option from the customer


They cover such logical steps too...

-----------------------------
ATF strongly recommends that manufacturers place all required markings on the outer tube of the silencer, as this is the accepted industry standard. Moreover, this practice eliminates the need to remark in the event an end cap bearing the markings is damaged and requires replacement.

Repairs may not be done if they result in removal, obliteration, or alteration of the serial number,
-----------------------------


they only recommends it ,,you dont have to ,,and working according there logic ( that for us is non understandable ) isnt needed

see they use the fact that then you dont have to remark in the event an end cap bearing the markings is damaged and requires replacement.

but i rather have to remark than pay $200

there logic plain sucks ,,,but what would you expect from a agency that dosnt have to pay ,,but is used to having YOU pay for every thing they do (tax money paid )
Link Posted: 4/17/2008 5:21:13 PM EDT

Originally Posted By Wolfdk:

Originally Posted By Amish_Bill:
They cover such logical steps too...

-----------------------------
ATF strongly recommends that manufacturers place all required markings on the outer tube of the silencer, as this is the accepted industry standard. Moreover, this practice eliminates the need to remark in the event an end cap bearing the markings is damaged and requires replacement.

Repairs may not be done if they result in removal, obliteration, or alteration of the serial number,
-----------------------------


they only recommends it ,,you dont have to ,,and working according there logic ( that for us is non understandable ) isnt needed

see they use the fact that then you dont have to remark in the event an end cap bearing the markings is damaged and requires replacement.

but i rather have to remark than pay $200

there logic plain sucks ,,,but what would you expect from a agency that dosnt have to pay ,,but is used to having YOU pay for every thing they do (tax money paid )


If the endcap is serialized, it may not be replaced. (see red above) This is based on the assumption that removing an end cap 'removes' the serial number from the can.

Now, if you serialize a heavy duty plug in the muzzle end that has replaceable inserts for the important parts.... but, you still don't get around the prohibition on replacing the tube. You just make it much, much harder to prove.
Link Posted: 4/17/2008 5:21:31 PM EDT
You've got to be kidding me. I can't believe people still ask the BATFE to verify things anymore. This is just another PITA to worry about in buying a silencer now.

WHO ASKED? I guarantee I will boycott any MFG that did this, if it was, in fact, a MFG.

Link Posted: 4/17/2008 5:24:19 PM EDT

Originally Posted By chromeluv:

Originally Posted By kel:
noted by BATF of questionable "repairing" of suppressors
Kel



Who/what company asked for a ruling on this?


I dont know how it is in the us ,,But here in DK you can have access to papers like that,sins it Does concern everybody

write the Atf and ask as a us citizen they should have everything ip address and so on it ,,its public matter ( tax money you know ) you should have the right to know ,,they for sure just did stab you( as a owner of a can) in the back


This must really be a nightmare for 1928 ,if he during a test ruins a can ,,he can not have it rebuild ,,this might be the end of the( heavy duty ) testing

Who ever did this letter writing really did harm the whole can community

i really hope people will remember this until the back stabber is found
Link Posted: 4/17/2008 5:30:14 PM EDT
[Last Edit: 4/17/2008 5:30:37 PM EDT by kavik]
We should just mark the serial numer on the rear, tube and front. Then a "original serial number" will always remain intact no matter what the repair.
Link Posted: 4/17/2008 6:09:39 PM EDT

Originally Posted By chromeluv:

Originally Posted By kel:
noted by BATF of questionable "repairing" of suppressors
Kel



Who/what company asked for a ruling on this?


I'm no fanboy... not in any respect. But I've got a good idea. At least I've narrowed down the companies I'll be dealing with in the future.

Kel, thanks for posting this...

~Dg84
Link Posted: 4/17/2008 7:01:31 PM EDT
Think correspondence on this topic could be released under a FOIA request?
Link Posted: 4/17/2008 7:11:09 PM EDT

In addition, the repair may result in a minimal reduction in the length of the outer tube due to rethreading, but repair may not increase the length of the outer tube. Increasing the length of the outer tube significantly affects the performance of the silencer and results in the "making" of a new silencer. ... Reducing the length of the tube by a minimal amount in order to repair a silencer is often necessary to replace damaged end caps, as the tube must be rethreaded. Such minimal reduction of the length of the tube uses all of the original parts, does not significantly affect performance of the silencer, and may be done as part of a repair process without making a new silencer.


I like how shortening the tube doesn't seem to have an effect on it's performance, but lengthening ( even "minimal") does.

You can cut it down "minimally", rethread and you're ok. 'Course, then you'll either have to machine a baffle to fit or get all new internals.

But, if you cut off the end of the damaged tube, re-weld a new tube section and rethread and it's even a nanometer longer than the original you're hosed.
Link Posted: 4/17/2008 7:23:17 PM EDT
Great Everyone Might have This Effect them by Confusing rulings Haphazardly made by BATFE

Link Posted: 4/17/2008 7:38:14 PM EDT
Sounds like someone needs to go after the ATF.

Too bad no one has the resources.
Link Posted: 4/17/2008 7:45:06 PM EDT

Originally Posted By SC-Texas:
Sounds like someone needs to go after the ATF.

Too bad no one has the resources.


The Pope was just here, but I don't think his work visa will let him stay long enough. Other than him, who?
Link Posted: 4/17/2008 8:05:49 PM EDT
Not surprised a CERTAIN company was involved in this.

maybe they need some cheese with their whine.

we are our worst enemy.


always has and always will be
Link Posted: 4/17/2008 8:05:54 PM EDT
[Last Edit: 4/17/2008 8:30:40 PM EDT by TaylorWSO]

Originally Posted By kel:
This Q&A document clarifying the existing legal abilities of manufacturers to modify and repair silencers was brought on by some recent actions noted by BATF of questionable "repairing" of suppressors - it will probably be of interest to the forum to read and discuss.

BATFE SILENCER FAQ / Q&A

Regards all,


Kel



Did Gemtech ask for this? What a way to stir up a shit storm. If my Gemtech breaks and is found defective will Gemtech cover the cost of the stamp?


BTW I don't think its wrong to ask the ATF questions, you should know that they will end up screwing you over in the end. This was a bad fucking move to say the least.


If Gemtech is the one that actually ask for this I will never purchase another damn thing from them.

ETA its Gemtech- Oh well I'm sure they will find other business.
Link Posted: 4/17/2008 8:28:30 PM EDT
From what I recall, AAC got a letter saying they could replace, Gemtech got a letter saying they couldn't replace and asked for clarification. That was 2 years ago though, IIRC. Not sure if they were involved in the current declaration or not.

It really seems like someone should be able to sue over things like this. You can sue if McDonalds coffee is too hot, but not when ATF decides "changing a caliber" somehow makes it a new silencer, that's just crazy.
Link Posted: 4/17/2008 8:32:04 PM EDT
man thats bullshit
Im not real concerned with the tax or even the bullshit of getting photos prints etc
but if you get a new sheriff/ chief that is a dick you cannot get a cleo sign off and you are screwed or have to go to a trust or LLC
Link Posted: 4/17/2008 8:35:28 PM EDT

Originally Posted By doorgunner84:

Originally Posted By chromeluv:

Originally Posted By kel:
noted by BATF of questionable "repairing" of suppressors
Kel



Who/what company asked for a ruling on this?


I'm no fanboy... not in any respect. But I've got a good idea. At least I've narrowed down the companies I'll be dealing with in the future.

Kel, thanks for posting this...

~Dg84


You do realize Gemtech wrote this and Kel works for Gemtech- I betcha you're even more happy about the can purchase now.
Link Posted: 4/17/2008 9:09:56 PM EDT
I really hope that everyone here understands that Gemtech wrote this letter not for "clarification", but rather to "get back" at AAC for rebuilding and vastly improving some of their greatly lacking suppressors. Those that deny this fact or try to make excuses are either delusional or have sustained a massive head injury.

In the end, not only did Gemtech end up screwing all manufacturers, but all customers as well.
Link Posted: 4/17/2008 9:16:41 PM EDT

Originally Posted By TaylorWSO:

You do realize Gemtech wrote this and Kel works for Gemtech- I betcha you're even more happy about the can purchase now.


Yes, and yes...
~Dg84
Link Posted: 4/17/2008 9:19:26 PM EDT

Originally Posted By volmed10:
I really hope that everyone here understands that Gemtech wrote this letter not for "clarification", but rather to "get back" at AAC for rebuilding and vastly improving some of their greatly lacking suppressors. Those that deny this fact or try to make excuses are either delusional or have sustained a massive head injury.

In the end, not only did Gemtech end up screwing all manufacturers, but all customers as well.


That is the way I am seeing it too.

I don't have a dog in the gemtech vs. AAC fiasco, I don't own cans from either company. But unless there is something else behind this, I won't ever buy a can from one of those companies, and it's not hard to guess which.
Link Posted: 4/17/2008 10:37:31 PM EDT
[Last Edit: 4/18/2008 4:30:21 AM EDT by mpallett]

.edited - personal attack.


Another strike aginst the american gun owner... Chalk one more up for the GOV.
Link Posted: 4/17/2008 10:39:07 PM EDT
Link Posted: 4/17/2008 10:53:26 PM EDT
height=8
Originally Posted By kel:
All,

we keep our heads down, do our work, and continue to make and deliver cans, not internet rivalries.

Kel



Lately it seems more like 'we keep our heads down, do our research, and continue to copy the latest and best developments from our rivals'
Link Posted: 4/18/2008 2:53:44 AM EDT
Kel wrote "We don't ask questions that would lead to hinder our own business".Do you ask questions that would hinder the business of anyone else?
Link Posted: 4/18/2008 4:12:01 AM EDT
Originally Posted By kel:
All,


The first I heard about this was yesterday from my attorney. He contacted me to inform me that BATFE was releasing the pdf I referenced, and to discuss the new data and how it affects the way the industry does business. This morning, the first official knowledge of this is when I received an email from BATFE telling me that this document was going public and a link to the pdf.


ok ,,,did ATF send such a mail to ALL can manufactures,,or did they only send one to special selected ones ,,if only to you ,,,why only you
Link Posted: 4/18/2008 4:26:34 AM EDT

Originally Posted By kel:
All,
Last time I was up at Tech Branch, I saw there were copies of Shotgun News and other magazines open on desks, with advertisements circled - anyone that doesn't think the BATFE doesn't also look on these websites is quite foolish. It's their job to be aware of what's been going on -- and no one had to bring it to their attention.

Do you come there so often that they let YOU see things they are investigating,,is it that what you are telling us
are you and ATF that familiar ??



Think about it: The people that caused this are the ones making continual noise and bringing it upon us all -- not the ones keeping a low profile.

So when a customer ask you if you can fix his can,,and you tell him no ..you blame this (your ) customer that he did try to get it fixt by another company
Then when this customer is happy and does show the fix (that you should have done ) on the net you blame him for telling this ??


You wear your shame like a crown.yep ,,but some has no shame in life



Kel
Link Posted: 4/18/2008 4:26:39 AM EDT
Link Posted: 4/18/2008 4:29:33 AM EDT
Link Posted: 4/18/2008 5:07:27 AM EDT

Originally Posted By Wolfdk:
So who did ALL owners of a can "this nice favor " by asking atf for a letter like that
who has the greatest benefit of that letter
That is really "a nice customer service ",,now people has to pay $200 extra for a repair


One word Gemtech i have several cans and they are not to far from me, NEVER will i buy from them
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