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Posted: 12/12/2013 8:39:07 AM EDT
At this point this is a hypothetical question.  No parts made or forms approved.  

That said, let’s assume that one has an approved form 1(s) and can manufacture a suppressor.

By law at what point during the process is a suppressor manufactured?  When does it go from a pile of parts to a suppressor?
It is my understanding that as a machinist or fabricator, once an approved form is in hand, can make a suppressor and even repair it so long as replace parts are destroyed to only allow for the single suppressor.  However what if I am not a machinist or fabricator?  Can I have a machinist make any of, or all of the parts necessary to assemble a suppressor?

Example
I have a design for a suppressor that is made up of 4 parts.  1x tube, 2x endcaps, and 1x baffle.  I contact Acme machine shop that agrees to make parts based off my design.  As parts is this legal?  What if I have Acme make the tube only?  I receive the tube and engrave my form 1 info and place it in my safe.  Next I have Acme make my baffle as a single part.  (legal?)  Next one or both end caps (?).  I assume that if I had all the parts and my form I can assemble the suppressor.  

What about 4 different shops each making one part; would that be legal?

What are your thoughts?    
Link Posted: 12/12/2013 9:09:17 AM EDT
[#1]
parts of a suppressor ARE a suppressor, so the stamp holder must make each part.

Now, when does a freeze plug become a baffle, or a tube become a body, i dunno....
Link Posted: 12/12/2013 9:11:25 AM EDT
[#2]
You have to make everything yourself.



Link Posted: 12/12/2013 9:37:06 AM EDT
[#3]
I do not know the law, is it clearly stated that parts must be made by the form holder?   I certainly can’t argue the law as I do not know it.   Where would I look to see what is codified?

While I know the ultimate purpose of a piece of tubing at what point is it a suppressor body vs a piece of tubing?  Would the Acme machinist be libel for my use of a piece of tubing?  In the example posted they are making parts not suppressor parts.

How is this different form having a shop cut and thread a barrel for an SBR?
Link Posted: 12/12/2013 10:13:57 AM EDT
[#4]
Discussion ForumsJump to Quoted PostQuote History
Quoted:  How is this different form having a shop cut and thread a barrel for an SBR?
View Quote


A short barrel can be used on both a SBR and on a legal pistol.
Link Posted: 12/12/2013 10:42:27 AM EDT
[#5]
Quoted:
At this point this is a hypothetical question.  No parts made or forms approved.  

That said, let’s assume that one has an approved form 1(s) and can manufacture a suppressor.

By law at what point during the process is a suppressor manufactured?  When does it go from a pile of parts to a suppressor?
It is my understanding that as a machinist or fabricator, once an approved form is in hand, can make a suppressor and even repair it so long as replace parts are destroyed to only allow for the single suppressor.  However what if I am not a machinist or fabricator?  Can I have a machinist make any of, or all of the parts necessary to assemble a suppressor?

Example
I have a design for a suppressor that is made up of 4 parts.  1x tube, 2x endcaps, and 1x baffle.  I contact Acme machine shop that agrees to make parts based off my design.  As parts is this legal?  What if I have Acme make the tube only?  I receive the tube and engrave my form 1 info and place it in my safe.  Next I have Acme make my baffle as a single part.  (legal?)  Next one or both end caps (?).  I assume that if I had all the parts and my form I can assemble the suppressor.  

What about 4 different shops each making one part; would that be legal?

What are your thoughts?    
View Quote


'can make a suppressor and even repair it so long as replace parts are destroyed to only allow for the single suppressor. '
I don't believe that you are allowed to repair a form one suppressor yourself.  You may want to give ATF a call or better yet right them a letter.

You also can not start to make any parts before the form 1 is approved.  Unlike an SBR you won't be engraving anything before the form is approved.

Hope this helps

Edit:  I just re read you question 'Next I have Acme make my baffle as a single part. (legal?)'  This is another one.  Acme can make your entire suppressor as long as you are present with approved form 1 in hand.  No one can make a baffle for you if you are not present.  It basically comes down to you having to make it yourself but you can have help.
Link Posted: 12/12/2013 11:19:35 AM EDT
[#6]
Discussion ForumsJump to Quoted PostQuote History
Quoted:
You have to make everything yourself.



View Quote



a machinist can help but you must be there with form 1 and take it with you if not finished also


so I learned on silencer talk
Link Posted: 12/12/2013 1:59:23 PM EDT
[#7]
Ok after reading these two links what is the difference between a SOT manufacture and form 1 manufacture?  Besides the need for the SOT to register all the items that are constructed.
Is the form1 manufacturer a qualified manufacturer for the single item?

I can not make out Legaleze

Thanks

ATF FAQ

Code of Federal Regulations

Link Posted: 12/12/2013 2:10:41 PM EDT
[#8]
Discussion ForumsJump to Quoted PostQuote History
Quoted:
Ok after reading these two links what is the difference between a SOT manufacture and form 1 manufacture?  Besides the need for the SOT to register all the items that are constructed.
Is the form1 manufacturer a qualified manufacturer for the single item?

I can not make out Legaleze

Thanks

ATF FAQ

Code of Federal Regulations

View Quote


Your starting to loose me bro.  I think your making things a lot complicated than they actually are.  Basically your not going to out lawyer the ATF lawyers. LOL  It might help if you stop using the term manufacture.  a form 1 is a one time Permission.  And by one time I mean 1 time!  no do overs no repairing, changes and absolutely no Testing!  Get it!

I've lost site of what it is your trying to do now.
Link Posted: 12/12/2013 2:17:34 PM EDT
[#9]
Discussion ForumsJump to Quoted PostQuote History
Quoted:
Ok after reading these two links what is the difference between a SOT manufacture and form 1 manufacture?  Besides the need for the SOT to register all the items that are constructed.
Is the form1 manufacturer a qualified manufacturer for the single item?

I can not make out Legaleze

Thanks

ATF FAQ

Code of Federal Regulations

View Quote


Form 1 is used to build a single can for yourself. SOT is a FFL/Manufacturer that makes them to sell them.
Link Posted: 12/12/2013 4:12:50 PM EDT
[#10]
Quoted:
let’s assume that one has an approved form 1(s) and can manufacture a suppressor.

By law at what point during the process is a suppressor manufactured?
View Quote


The "law" is vague and essentially how pissed the ATF is at you.  At a minimum, when a part can provide suppression or is threaded with a through hole, it is considered a suppressor part.

Quoted:
It is my understanding that as a machinist or fabricator, once an approved form is in hand, can make a suppressor
View Quote


Yes.

Quoted:
It is my understanding that as a machinist or fabricator can make a suppressor and even repair it so long as replace parts are destroyed to only allow for the single suppressor
View Quote


Unless that machinist or fabricator is an 07/02, No.  Repair work can only be done by manufacturers.

Quoted:
Can I have a machinist make any of, or all of the parts necessary to assemble a suppressor?
View Quote


Yes, provided you are physically there with approved Form 1 or they are an 07/02

Quoted:
I contact Acme machine shop that agrees to make parts based off my design.  As parts is this legal?

What if I have Acme make the tube only?  

I receive the tube and engrave my form 1 info and place it in my safe.  Next I have Acme make my baffle as a single part.  (legal?)  Next one or both end caps (?).  I assume that if I had all the parts and my form I can assemble the suppressor.  

What about 4 different shops each making one part; would that be legal?  
View Quote


Again, you have to be there with said approved Form 1 or they must be 07/02s
Link Posted: 12/12/2013 4:36:09 PM EDT
[#11]
The way I heard it explained was that a manufacturer is a buisness with an FFL. If you get a form 1 approved, you are a maker. As such, you aren't allowed to repair, or replace anything on the suppressor after it is made. I have heard of people wit trusts putting the machine shop making their can on the trust temporarily and giving them copys of all the paperwork while they make it, if your doing it on a trust.
Link Posted: 12/12/2013 5:16:19 PM EDT
[#12]
Im going to just ASSUME that every part becomes a suppressor part once you get your permission slip back
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