Further implications of reclassification of wipes as suppressor parts.

[grampajack]

I posted this earlier but was informed by the staff that I didn't provide enough information and needed links. As most are aware, the ATF has reclassified disposable/perishable wipes as "suppressor parts."

http://www.thefirearmblog.com/blog/2017/03/20/wipes-silencer-parts/
http://www.thetruthaboutguns.com/20...r-wipes-baffles-may-make-old-designs-illegal/
https://modernrifleman.net/2017/03/20/atf-reverses-position-on-silencer-wipes/

My question is, Where does this leave oil filters as used in conjunction with registered thread adapters? Since the thread adapter is the actual silencer, doesn't this put oil filters intended to be used as silencers in danger of being reclassified? As such, would it not then be illegal to simply purchase an oil filter at Auto Zone and put it on your registered thread adapter? Would a person not be required to buy the oil filter from a licensed manufacturer and have an FFL "install" it?

 

[JohnKSa]

As such, would it not then be illegal to simply purchase an oil filter at Auto Zone and put it on your registered thread adapter?

I believe it already is.

https://cadizgunworks.com/store/index.php?route=product/category&path=20_26_69

If or when you need to change the filter out, the ATF/NFA rules says it needs to come back to the original manufacture, which Cadiz Gun Works is.​

 

[grampajack]

Well that answers that. What is the advantage now then when you can get .22 suppressors for, what, 400 or so? Doesn't seem to me you would be saving much money if you had to send the blasted thing to the manufacturer every time you needed a fresh filter. Heck, even if they replaced the filters for free I would gladly pay the extra 300 just to avoid the hassle, not to mention be able to use it on my pistol and still see the blanking target through my sights.

 

[JohnKSa]

Initial cost is $85. At $25 for replacement filters it takes 13 replacements before the cumulative cost exceeds the cost of a traditional rimfire suppressor.

Also, no cleaning required...

 

[Odd Job]

Initial cost is $85. At $25 for replacement filters it takes 13 replacements before the cumulative cost exceeds the cost of a traditional rimfire suppressor.

Also, no cleaning required...

My advice to the OP is to get a quality suppressor instead. Some of you may be aware that I am currently testing a suppressor to destruction. It is an A-TEC CMM4 with 6 baffles and it costs £84 retail here in the UK. I don't know how much that would cost in the US or even if you can get it there, but I am confident you could get a similar one, at least in terms of performance.

This is my A-TEC CMM4(6), on a Thompson Center R55 Benchmark. I had the rifle threaded 1/2 x 28 because I had a SIG522 I was using with that suppressor in the early stages of testing.

Here you can see the first two parts of a three part article I am writing about this suppressor, and the way I am testing it:

https://www.linkedin.com/pulse/lead-deposition-a-tec-cmm46-rimfire-suppressor-part-1-bertolli
https://www.linkedin.com/pulse/lead-deposition-a-tec-cmm46-rimfire-suppressor-part-2-bertolli

I am shooting the hell out of this suppressor and I am not cleaning it at all, not even a spray of gun cleaner. Yesterday at the range this suppressor reached the 18,000 round mark. The ammunition I use is Eley Sport, RWS target Rifle and in the early days I also used CCI Minimag. I've used that suppressor on three different rifles.

I've had a grand total of 4 flyers in all that time. One was bad, more than an inch drop at 25 yards, and the other three were off target by less than half an inch. Sound suppression is still good, I've not noticed any degradation although I concede I haven't had it tested professionally. Accuracy is still excellent, I have no complaints at all.

The suppressor has picked up around 60g of residues. It started out weighing 130g and now weighs around 190g. I use the word "around" because it has reached a point of equilibrium. When I reach a round count of 20,000 I will publish part three of the article.

It seems to me that the requirement to clean a suppressor such as this is perhaps overstated.
I don't know if I will get similar results with other designs but I intend to find out. I've purchased several other cans for another test.

The closest thing I have to an oil filter is the Hogan "Decimeater" which has a three chambered design with an outer air space packed with a felt wadding similar to a Brillo pad. It may well turn out that this design doesn't stand up to that degree of fouling.
I have to consider the possibility it does not.
If that's the case, how do I clean it? It may well be that the felt liner can't be cleaned and has to be replaced.

Anyway I thought you would find it interesting. For reference the Hogan is the at the far left in the image below:

This is what it looks like when X-rayed:

These are the internals:

I would be pretty annoyed if the felt wadding deteriorated and I couldn't replace it without sending it back to the distributor! It seems very fragile, even minor handling results in fibres coming off in my hands.

 

[dogtown tom]

I posted this earlier but was informed by the staff that I didn't provide enough information and needed links. As most are aware, the ATF has reclassified disposable/perishable wipes as "suppressor parts."

Not exactly. Since 1986, Federal law has stated that any part of a silencer is by itself regulated. Many folks assumed that a 1999 ATF opinion letter (saying replaceable wipes were not "generally" silencer parts) applied to everyone: http://www.titleii.com/bardwell/atf_letter66.txt Therein lies the problem.....opinion letters are not law, not regulation and generally only apply to the person they are addressed to.

My question is, Where does this leave oil filters as used in conjunction with registered thread adapters?

They remain a silencer part and only replaceable by a licensed dealer or manufacturer. Nothing has changed since 1986.

Since the thread adapter is the actual silencer, doesn't this put oil filters intended to be used as silencers in danger of being reclassified?

Whoever told you that only "the thread adapter is the actual silencer" was wholly ignorant of Federal law. While the thread adaptor may have a serial number, the entire silencer is a silencer and regulated by the NFA.

As such, would it not then be illegal to simply purchase an oil filter at Auto Zone and put it on your registered thread adapter?

Yes, and doing so has been illegal since 1986.

Would a person not be required to buy the oil filter from a licensed manufacturer and have an FFL "install" it?

There is no requirement to buy the oil filter from a manufacturer or have a manufacturer replace the filter. Any licensed dealer can do it.

What is the advantage now then when you can get .22 suppressors for, what, 400 or so?

There are several manufacturers who sell rimfire silencer for less than $200.

Doesn't seem to me you would be saving much money if you had to send the blasted thing to the manufacturer every time you needed a fresh filter. Heck, even if they replaced the filters for free I would gladly pay the extra 300 just to avoid the hassle, not to mention be able to use it on my pistol and still see the blanking target through my sights.

Which is why I shake my head every time someone mentions oil can suppressor.

 

[dogtown tom]

Initial cost is $85. At $25 for replacement filters it takes 13 replacements before the cumulative cost exceeds the cost of a traditional rimfire suppressor.

Uh...........no.
Several companies sell sub $200 rimfire silencers. The most inexpensive is Rebel Silencer out of El Paso who has one for $99. From day one it beats the pants off any oil can.
The sub $250 market has dozens of excellent rimfire silencers.

Also, no cleaning required...

Well, that's because you'll be buying a new oil can every time I'll be cleaning my factory silencer.
My factory silencer will remain quiet, your oil can will degrade over time.
My factory silencer was a one time purchase. Your oil can requires regular replacement. A cost that will never end.

 

[grampajack]

So basically everyone with those oil filter suppressors has been breaking the law this entire time. Good to know! I thought it might be nice to have one, but not under those circumstances. I also did not realize that .22 suppressors have gotten so cheap. The last time I shopped for one they were in the 400 range. I think the cheapest one I could find was in the mid 300s.

 

[JohnKSa]

Several companies sell sub $200 rimfire silencers.

That's what I get for not doing more careful research. I looked at a number of manufacturers but I must have gotten unlucky and not found the more reasonably priced silencers.

Well, that's because you'll be buying a new oil can every time I'll be cleaning my factory silencer.

If I had one that would be correct. Not only do I not have one, I do not intend to buy one.

So basically everyone with those oil filter suppressors has been breaking the law this entire time.

Only if they're replacing the filters themselves. Which, to be fair, probably many are.