The making of a monocore on manual machines

MachIVshooter said:

I certainly do enjoy making things, seeing what I can come up with, but bear in mind that this is ultimately R&D for a commercial venture. I'm spending a great deal of money on materials and many hours on machines to build something that I then go and deliberately beat the snot out of, and do it all over again with slight changes in design, different materials, etc. in the quest to develop a marketable item. I've blown up several already, units that would have been cared for and used for many, many years if they were personal form 1 builds, but are getting screwed onto machine guns and run to failure because I need to find out just how durable they are (or aren't).

For example, this one? I took basically the same design and carved it out of 6/4 Ti, just an inch shorter and with a little thicker sleeve to be a more durable version of this. It's heavier than I want it to be, and the suppression is not satisfactory, which could be due to the slightly reduced volume, the minor changes in baffle geometry, or the material. So I get to take another $100 worth of Ti and try again. And again. And again, With 8-10 hours on the machines and several smoked tool bits for each iteration.

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pintler said:

I certainly do enjoy making things, seeing what I can come up with, but bear in mind that this is ultimately R&D for a commercial venture.

FWIW, I took pdsmith's comment as pointing out that non-SOT folks building on a Form 1 don't have the luxury of trial and error. If I take my new Form 1 can to the range and don't like the sound or the tube bulges or whatever, I can't change the design, or even repair it without paying another $200 and waiting however many months. If I could pay $200 for the right to have exactly 1 can at a time serial numbered pintler001, but could destroy the old, or make new baffles as long as the serialized part was unchanged, or whatever, then I'd be tinkering like mad. Since I can't, there is a strong tendency to not try anything out of the ordinary or push any edges; better a working can that's a couple of ounces heavier or a couple DB louder than a featherweight $200+ paperweight.

If the HPA ever passes ....

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MachIVshooter said:

True.

That said, with a form 1 can, you are the manufacturer, so you may repair it, just as a licensed manufacturer would. You just can't alter the dimensions on your form 1 or keep spare parts around. If it's an 8" long .30 caliber rifle can, you can't crush it and recycle that serial number onto a 7" .223 cal suppressor.

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MachIVshooter said:

I'm not familiar with this (opinion letter? FTB determination? Official ruling? Moron agent running his mouth quote?). In strict interpretation of actual statutes, there is no distinction between maker and manufacturer. As far as parts are concerned, a repair part would be a spare part if the part it is meant to replace still exists. My interpretation is that you would need to destroy the damaged part completely before making the new one in order to not be in possession of spare parts, but it can't be a "spare" if it is the only one. Tubes/sleeves are the exception.

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DEPARTMENT OF THE TREASURY
BUREAU OF ALCOHOL, TOBACCO AND FIREARMS
WASHINGTON, DC 20226

AUG 23 1999

901040:GS
5320/99-0115

Dear Mr. Bardwell:

This is in response to your letter of June 28, 1999, regarding the
repair of a silencer by an individual owner. You ask "whether it
is lawful for the owner of a lawfully possessed silencer ... to
repair that silencer himself, by replacing unserialized internal
components with new components of his own making." You cited the
replacement of a worn out plastic "wipe" or damaged baffle as an
example.

As you are aware, 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. Thus,
certain internal components, intended only for use in a silencer,
are silencers as defined.

If an individual made one of these parts, even for use as a
replacement part, the individual would be making a silencer. Under
the provisions of the National Firearms Act, any person must apply
for and receive permission to make a silencer and pay the making
tax for each silencer made. This would require the individual
owner to file an ATF Form 1 application for each silencer part to
be made with the payment of $200.00 for each application prior to
making any replacement part.

In regard to the two parts in your cited example, we consider a
baffle to be a silencer, but a wipe, which is usually nothing more
than a rubber or plastic disc with a hole in it, is generally not
considered to be a silencer. Thus an individual owner could
replace a wipe.

- 2 -

Mr. Bardwell

For the replacement of a part or parts that meet the definition of
a silencer, the individual owner would need to arrange for the
transfer of the silencer to a Federal firearms licensee who is
qualified to manufacture silencers.

If you have questions about the classification of other silencer
components, please provide us with a description of them or should
any additional information be needed, please contact Gary Schiable
at (202) 927-8330.


Sincerely yours,

[signed]
Kent M. Cousins
Chief, National Firearms Act Branch

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there is no distinction between maker and manufacturer.

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