As other installments in this series show, there were already significant issues with the first few iterations of the new prototype “Small Arms of the 1980s” (SA80) family of weapons. From an initial concept in 1971, these had seen 8 years of development by the time they emerged from NATO ammunition trials in 1979. At this time, the initial emphasis on building these weapons in a new British caliber, the 4.85x49mm cartridge, shifted, and the 5.56x45mm chambering came to be accepted. The internal project name became “Enfield Weapon System,” rather than the earlier “485 Weapon System,” in a tacit recognition that 4.85mm was effectively dead. The caliber was not the only casualty, however, as the weapon itself was about to be radically redesigned. RSAF Enfield lacked experience in the design and especially the manufacture of contemporary firearms, and the definitive XL64E5 IW (rifle) and XL65E4 LSW (LMG) had shown serious problems with functioning and excessive barrel wear. They had been expected to achieve a mean rounds between failure (MRBF) rate of 2500 MRBF for the IW and 8000 for the LSW. The early figure after the NATO trial was exceptionally low, at just 97—indicating weapons unfit for military service.

Tackling the Issues

The issues which resulted in this poor performance could no doubt have been resolved; these were, after all, prototype designs that had yet to pass through Ordnance Board, “user” and troop trials. The coincidence of the NATO ammunition trials was unfortunate timing in that it interrupted development, but at the same time it was an opportunity to spot serious issues early on and rectify them before formal British trials began. The design was promising enough, and the need for a new British rifle and machine gun urgent enough, that it was decided to move ahead with the next developmental iteration. Unfortunately, before any individual issues with the original design could be tackled, the cost of production was deemed to be too high and a second round of “value engineering” (VE) was demanded. This was supposed to be a refining of an already proven and functional design to make it more economical to produce. The first VE study had changed minor details like the shape of controls or individual contours of the receiver. Yet only 4 years after the original weapon system had been launched, the findings of this new study resulted in a substantial and visually obvious redesign; practically a new gun (the subject of this piece). This “reset button” approach only compounded the factory’s existing difficulties, with the original targeted in-service date (ISD) of 1983 just a few years away.

Embracing Feedback

Embodying the value engineering feedback, another short run of prototypes was produced; this time just three rifles with serials prefixed “PR” for “Production Rifle.” The new design was much bulkier and more wedge-shaped compared to the svelte XL60 (superficially it is very close to the final SA80 design). As a result, weight increased; unfortunately, due to the VE focus on cost-saving, quality did not. In fact, with limited experience of pressing and weld-ing, and morale increasingly an issue, quality control was variable from this point until the closure of the Enfield factory in 1988.

Nonetheless, the design itself had issues beyond this. The new pressings were thin and easily distorted, despite the new rifle weigh-ing a full kilogram more than the XL64E5. The new trigger mechanism housing (TMH) was also found to be insufficiently strong to support a loaded magazine. The TMH mag-azine well was a short, lipped design just a few millimeters tall. The trigger mechanism was also substantially redesigned, and the safety reverted to a cross-bolt type in an effort to minimize inadvertent operation by left-handed users. This allegedly became critical much later on when the final L85A1 was in service, as the polymer catch—chosen on cost-saving grounds—swelled with envi-ronmental changes and became difficult to operate. The SUSAT, still in prototype stage, was given a new mount, operated by a single throw lever. For now, these guns carried over the existing mechanical design of the XL60 series, with the exception of a new bolt design incorporating double ejectors and a more conventional (longer and narrower) AR-style extractor, no doubt both attempts to improve the weapon’s reliability. More changes were to come in the definitive XL70 series, however.

Design Changes

The most obvious change in this next, much longer production run of prototypes was the incorporation of a longer, separate external magazine well assembly. This was seam-welded onto the bottom of the existing TMH. A thick and heavy piece of sheet metal was introduced to contain the trigger group as a drop-in assembly. This had a vertically ribbed reinforcement at its front which served as a guide for the rear aspect of an inserted magazine (i.e., it formed the back of the magazine well). A sheet metal hammer stop was welded to this new trigger group assembly. The bolt carrier was of yet another new pattern, being substantially wider and sporting simplified lightening cuts on both sides. Apparently bolt bounce had been addressed in some way, because the inertia pellet was eliminated; its channel being enlarged and bored clear through in order to accommodate the new guide rod. Contrary to claims in Steve Raw’s The Last Enfield, the dual ejectors on the “PR” bolt were deleted and never seen again.

The slender twin guide rods and springs taken from the AR-18 were replaced by a stronger (and therefore heavier) triple rod design. This replaced the twin springs with a single spring fitted to the larger central rod, leaving the two outer rods to function simply as bolt carrier guides. This allowed the internal guide channel in the body (upper receiver) to be reduced to a simple ledge—serving only to keep the cam pin in the down and unlocked position until the bolt was in battery—and the corresponding guide peg on the bolt carrier to be eliminated, simplifying the design. The cocking handle was slightly altered into what would become the standard A1 pattern. In an example of detailed value engineering, the machined orienting/locating lug on the handle was replaced with a simple roll-pin (a simple and effective arrangement that persisted into service).

The gas system components were slightly redesigned to reduce the complexity of machining operations. The spigot formerly machined into the gas cylinder was eliminated, as was the hollowed nose of the operating rod. Instead, the gas cylinder was hollowed at both ends to accept the piston/gas plug at the front and the rod to the rear. This raises another interesting divergence from the AR-18. The XL60 had already simplified the ArmaLite four-piece gas system to three components, without a connecting link (still to be found in other derivatives, including the German Heckler & Koch G36 design). This link was deemed superfluous, having apparently been included simply to ease disassembly. The XL70 took the design another step further from the original, employing a simple tubular gas cylinder. Finally, the design also returned to a rear sling loop mounted on the rear of the body. The flash-hider was now standardized on both variants but altered to use radial lines of circular ports (three in each row) rather than slots.

A wholly new set of dark green polymer furniture was designed, of essentially the same pattern as would eventually enter service. The handguard was fully developed with a polymer cover over the sheet metal upper guard and a metal heat-shield liner in the lower. The buttplate was now polymer, with a steel sling loop inserted. The plate wrapped around the toe of the butt as per the A1, but here it was of hard polymer rather than rubber. The pistol grip shape changed slightly, retaining a storage compartment. A new cheekpiece was, as before, simply glued directly onto the receiver. The new bolt release catch and the action dust cover were in matching green polymer (and are as per the A1 in design), but strangely the hold-open catch is black.

The SUSAT was also redesigned by this time and had received the designation XL9E1. This version eliminated the auxiliary grenade sight bracket from the body casting, no doubt to reduce the weight of this hefty optic design. Another new mount, operated by means of two wing bolts and a spring catch, was carried through onto the in-service rifle.

Common Traits

As before, the LSW shared much in common with the IW aside from its heavy barrel and bipod. It retained open-bolt operation but, in another attempt to simplify things, the engineering team did away with the Stoner 63-style main and auxiliary sears, and the gun now operated in open-bolt fashion regardless of semi-au-tomatic or automatic mode. This slam-fire, fixed firing pin design required that a safe position be added to the change lever (fire selector) to prevent accidental discharge if dropped with the bolt carrier locked to the rear ready to fire (regardless of the trigger safety). There being no closed-bolt mode of operation, the safety (auto) sear was deleted from the trigger group. This decision ran counter to the idea of maximum commonality of parts, since this version therefore required a unique carrier design not interchangeable with the rifle variant. The hold-open catch was also flipped around.

Early examples in the XL70 series, like the XL73E2 LSW (pictured), feature a set of black polymer furniture, including an XL60 pistol grip, an unusual cheekpiece that conforms to the shape of the receiver (rather than being smooth) and a buttplate of a unique oval pattern not found on either the XL60 series or the later XL80. Early IW handguards were as per the XL70E3 shown here, but in black. The equivalent XL73E2 handguard is roughly the same shape as the service version, being shorter and with a hand-stop moulded in at the front. It also has a heat shield; however, the prototype form shown here is roughly made and lacks the thin finger-stop of the rifle equivalent. The bipod is non-adjustable and, as currently installed, no longer unfolds. These early guns look and feel more like prototypes than those in the green furniture. Inside, parts of the trigger mechanism look hand-finished, and the trigger pull on this open-bolt-only gun is abysmal.

And Then There Were Three

At this stage, the requirement for a left-handed LSW was dropped, reducing the number of variants in the family to three. The three PR weapons (all IWs) were chambered in 4.85x49mm, but the decision had already been made to move to 5.56x45mm, and the first of the true XL70 guns were fitted with 1/12 twist barrels and chambered for US M193 ammunition. Nonetheless, the need to move to 1/7 to suit the SS109 cartridge was already anticipated. Whereas the PR guns had been left without “XL” designations, these new weapons were named as follows:

XL70E3—Individual Weapon
XL78E1—Individual Weapon (left-handed) XL73E2—Light Support Weapon
NB, in terms of nomenclature, “rifle” and

“machine gun” persisted in use alongside “IW” and “LSW.” The term “PW” (personal weapon) was also used, in place of IW.

Trials of the XL70 series began in earnest the following year (1981), in an effort to keep the project on schedule. Enfield had suspected in 1972 that it might take until 1984 for full-rate production to be achieved, yet in 1975 they agreed to an ISD of 1983. In an effort to meet this, it is alleged that corners were cut and standards kept artificially low during the trials process. In particular, it is claimed that chicanery played a part in the weapons being seen to meet the required MRBF. Certainly, the new design had inherited some existing issues, along with all-new problems (such as failure to lock open on an empty magazine). The XL60 series had suffered from excessive barrel wear due to a combination of poor metallurgy and a lack of chrome lining (incidentally, this marked the first time that the German firm of Heckler & Koch would be consulted, more than 20 years before the A2 programme). However, metallurgy and inadequate heat-treating continued to plague the weapon, with cracked bolt carriers and even a split barrel revealing serious defects in the manufacturing processes. These catastrophic issues were resolved following Phase A of the User Trials but were a worrying sign at this advanced stage. Prior problems with feed, ejection and trigger reset that had been experienced with the XL60 series remained evident, as did the LSW-specific problem of split groups. This was specific to automatic fire with the LSW, wherein the weapon would produce two discrete groups—the first shot exhibiting a distinctly different point of impact than the remaining shots in a string. This would be the subject of significant work in future iterations of the LSW (stay tuned for more on this issue—Ed.).

As User and Ordnance Board trials continued in parallel, the weapon was able to reach the target 2500 MRBF figure despite these problems. If this seems low by today’s standards, it is important to note that at this period, U.S. military rifles might only be expected to reach 500 rounds more (i.e., 3000 MRBF) than the SA80 IW target for the equivalent failure category. It is essential to point out that, in the British trials, the only categories of failure included were those that involved a malfunction requiring user replacement of parts. Other commonly tested failure modes, namely malfunctions that could be solved with more intensive user intervention (but not parts replacement) and those remedied by immediate action alone (sometimes referred to as “mean rounds between stoppages,” or MRBS) were—according to Steve Raw—ignored. On the other hand, the contemporary U.S. military demanded an MRBS figure of 500, whereas the XL70 SA80 achieved only 95 MRBS. In other words, the weapon on average would malfunction after only three full magazines. Even if the weapon achieved its set MRBF target, an MRBS rate such as this could not possibly be acceptable in service. This worrying situation led to yet another build standard and yet another designation, which we will deal with in the next installment of this series.

Special thanks to the National Firearms Centre at the Royal Armouries, who graciously allowed us access to their world-class collection.
This is Part 3 in a series of articles examining the developmental history of the United Kingdom’s SA80 family of firearms. Part 2 appeared without designation in Small Arms Review, Vol. 23, No. 3.
See armamentresearch.com for further original content.
(This article is adapted from a chapter in Mr. Ferguson’s forthcoming book on British bullpup rifles, which will be published by Headstamp Publishing in 2019. HeadstampPublishing.com)

This author remembers in the late 1990s devouring a fledgling publication that was discovered in the guns section at Borders: Small Arms Review. Twenty years later he’s convinced Small Arms Review is the perfect vehicle in which to “educate” gun lovers everywhere.

Having acquired more than a passing knowledge of firearms and weapons in general, the author had never heard of Robert Kent or his Battery. The writer’s “education” commenced after purchasing Item #117–Tools & Hardware CMPTS: at a government auction located at DRMO, Fort Belvoir, VA, in August 1992. This lot of “tools & hardware” was jammed into a 4x4x3-foot wooden crate. Back in his warehouse (used machinery dealer) over the next couple of weeks he emptied the crate and discovered a variety of fasteners, hardware and a hodge-podge of related stuff. But lying at the bottom of the crate was a 55-pound 3ftx1ftx 7in object wrapped in five or six layers of banded cardboard. How often does a 46-year-old man experience the thrill of unwrapping that special present on Christmas morning? Ta-Da! Robert Kent’s Kent Battery. The “genius” that he is, the writer knew it was a Kent Battery because screwed to the lid of an olive, drably painted wooden box was an engraved tag: “KENT BATTERY Ballistics Research Laboratories Aberdeen Proving Ground Maryland!”

Contents of the Find

Kneeling in the cast-off cardboard in front of the box, unlatching and opening the lid and peering in prompted a dumbstruck look to gradually appear on this writer’s face, and, yes, while scratching his head, he muttered, “What in the Hell’s this?” The case contained the strangest looking 03 Springfield rifle he’d ever seen. The rifle buttstock (a machined piece of 1 ½-inch round aluminum bar stock) was hinged to one end of an engine-turned-aluminum-plate with the barrel supported by a spring-type clamp at the other end. The same “KENT BATTERY” tag was riveted to the buttstock end. Two fabricated brass lift handles were attached to this base plate, facilitating removal from the box. The firearm could then be raised and supported at an approximate 30-degree angle with an aluminum rod. This rod was also hinged to the plate and fastened (3/8-inch diameter x 4-inch long brass rod brazed to a section of an Allen wrench brazed to a ¼-inch Allen head bolt) to a stainless steel compression clamp surrounding the barrel. There was no trigger guard, and the bolt handle had been modified. Threaded into the receiver was a 2 ½-inch long piece of solid stock, replacing the original Springfield barrel. Then appeared a 1½-inch long, stainless adaptor that married a 9½-inch long section of 1½-inch diameter brass tube to the dewatted barrel. The tube displayed a strange looking 2 groove rifled 1-inch bore. The crown was stamped, “1 in 10” and “1 in 15.” The Springfield’s serial #3275540 suggested, and later verified, that the Battery was assembled in 1942.

Nestled around the Springfield he found five projectiles: 1) 43/8-inch long aluminum body with a steel point; 2) 3½-inch long projectile with an initial ¾-inch steel base and the remaining aluminum; 3) 6-inch long projectile with an initial 15/8-inch Plexiglas base, then 2½-inches of aluminum and finally a 1¾-inch steel point; 4) 9¼-inch long Plexiglas body with a 3½-foot steel point; 5) The coolest of all—a 10¼-inch long aluminum rocket “look-a-like” with shaped fins that would induce spin. The “rocket” would be slipped over the barrel instead of inserted. The first 4 rounds presented lugs or tabs, engaging the riffling and inducing spin.

The wooden case had a hinged top and pair of lift handles. Two stainless steel rods, found with the projectiles, would be placed into pockets routed in the sides of the case allowing the Battery to rest flush with the top of the case when open. The Kent Battery rested on the rods in firing position.

An “Ah-Ha” Moment

When the Kent Battery was removed from the case for the first time the “Ah-Ha” moment arrived. Laying underneath the base plate was the paperwork:

 1) A mimeographed copy of a letter from Lt. Col. Donovan F. Burton to Col. Charles Ostrom. The letter was dated December 9, 1965. Col. Donovan, an Associate Professor at the Department of Ordnance United States Military Academy West Point, New York, requested information. Twice a year the Col. operated “an in-flight ballistics demonstrator called the Kent Battery to illustrate projectile stability” for the cadets. He sought “design parameters of the gun tubes to insure that we do not exceed the design stresses.” Col. Ostrom was assigned to the Ballistic Research Laboratories Aberdeen Proving Ground, Maryland.

2) A seven-page mimeographed copy of a letter from the Ballistic Research Laboratories to Col. Burton. The letter is dated December 20, 1965. It contained a wealth of information regarding the history of the Battery, its practical application and a lesson plan titled, “Exterior Ballistics Kent Battery Demonstration Dept. of Ordnance Lesson No. 34.”

3) An October 21, 1982, eight-page pamphlet designating the Aerodynamics Range at Aberdeen a National Historic Mechanical Engineering Landmark. Robert Kent and Dr. Alexander C. Charters “developed the technology which laid the groundwork for the design of the Aerodynamics Range.” “The Range is recognized as the prototype for similar installations within the United States and abroad.”

The writer considered this “find” moderately interesting, but since Google didn’t exist in 1992, and since he was no machinist and couldn’t fire the Battery due to the lack of a functioning barrel, his interest waned and ultimately ceased. The case was unceremoniously shoved under a section of pallet racking in the shipping area of his shop. Over the next 10 years or so it languished there; although more than once pulled out, serving as a stepping stool.

Eureka!

Somewhere in the late 90s the writer was on the phone with Mike (who manufactured custom barrels). Mike was discussing the purchase of a Gorton milling machine. The conversation drifted to a cannon barrel bore scope that Mike had bought and then on to the great stuff at the Aberdeen Proving Ground Museum. The writer began describing the odd looking rifle in the box with the neat projectiles, when Mike blurted out, “You have a Kent Battery?” “Yep. How did you know?” Mike had studied Robert Kent and the Kent Battery in a ballistics course at school.

Time passed. The writer moved to an adjoining state. Google was invented. He discovered information on Robert Kent, but the Kent Battery? Forget about it. “Robert Kent developed the Kent Battery.” No description, no history, no photo or even a drawing. He begins to realize that this box that had resided under the pallet rack probably contained something of importance.

In 2010 the writer contacted Ron, a friend of a friend. Ron worked at Aberdeen from the late 60s to his retirement in the early 2000s (“The best job a guy could ever have”). Ron was familiar with the Kent Batteries. Aberdeen owned about a half dozen, each displaying a different rate of twist. A couple sported the original wooden buttstocks, and others were mounted on aluminum plates (not engine-turned), but all were “crude” compared to the West Point Battery. Ron assumed that he was aware of all that existed but admitted that he had never seen the West Point Battery. He asked the writer if the bore looked strange, and he received an, “It sure does.” “Each barrel was machined with two different rates of twist—the West Point: 1 in 10 and 1 in 15.” Ron reminisced about firing various banks of batteries in projectile flight demonstrations up until the mid-1970s … about blanks misfiring causing the projectile to “plop out” and travel 10 feet … about using a cartridge containing the incorrect charge causing the projectile to travel twice as far as it should …  about filing nicks and removing dents when a projectile landed where it shouldn’t. “It was great fun,” Ron said. The demonstrations ceased, and the batteries disappeared. Only a couple of people had ever seen the Kent Battery in person.

A Trip to the Gun Store In 2016, this writer met Bud, a gun collector in his late 70s who ran a great gun store nearby. Having never met Bud beforehand, the writer walked in cold off the street and asked him if he would like to see something really neat. Bud thought at first, because of size of the case, that it contained some type of LAW launcher. The case was opened, the Battery was lifted out and placed in the firing position. The projectiles were arranged in front, and the documents produced. You’ve all seen it, and we’ve all done it. Bud examined Kent’s creation, cycled the action and held and admired each projectile. He scanned the documentation in order to understand what was before him. His son was then called and told to “get over here now!” The same procedure repeated. With a gleam in his eye, Bud then telephoned a good friend and began the conversation with, “I’m looking at the most beautiful firearm that I’ve ever seen.” Later during the visit Bud murmured, “What in the world could this be worth? $3000, $30,000, $300,000, $3,000,000. Who knows?”

I have visited many military museums around the world, but Belgrade Military Museum is one of the best. With 52 rooms it covers 2,000 years of history, and it presents a large variety of articles of a high patrimonial value.

Some Serbian History

The people came to Serbia 8,000 years ago, and nomads from Russia arrived in the country 3,500 years before Christ. Later Celtics disembarked (300 B.C.). Romans were established in the Balkan countries 300 years later, ruling the east and west. In 395, Imperator Theodosius died, and the empire was divided between east and west; Serbia chose to join the Byzantine group.

A first principality was created in Serbia in the 9^th century, and the Orthodox Church extended between the Danube River and Adriatic Sea. Middle-Ages Serbia was conquered and became a part of the Ottoman Empire (Turkish Empire) for four centuries. A slight inclination for independence came in 1804. In 1830, Serbia obtained self-governance and became a constitutional monarchy, but independence was obtained only in 1878, after a war between Serbia (allied with Bulgaria) and Turkey.

Several wars happened between Serbia and other Balkan countries: Bulgaria in 1885, Turkey in 1912 and Bulgaria again in 1913; the assassination of the Austrian Archduke in Sarajevo is credited as the start of WWI.

In 1915, Germany, Austria and Bulgaria attacked Serbia, and after some success, Serbian troops retreated. Recovered by the French Orient Army, under General Franchet d’Esperey’s command, the Serbian Army regained the offensive and marched to Belgrade and Vienna. At the end of WWI, south Slavic countries joined Serbia to become the Serbian, Croatian and Slovenian Kingdom, later becoming Yugoslavia in 1929. Then in 1934, King Alexander I encountered agitation from Croatian independents and was killed in Marseille, France.

In 1941, Croatia became dissident and facilitated the arrival of the Germans with their allies: Italy, Hungary and Bulgaria. The Regent had an agreement with its occupiers, but patriots denounced it. The Resistance was organized between Draza Mihailovic (nationalist) and Marshal Tito (communist).

At the end of the war, Tito was the winner, and he organized Yugoslavia into a socialist republic with several federated districts: Bosnia-Herzegovina, Croatia, Slovenia, Macedonia, Montenegro, Serbia and two provinces: Vojvodina and Kosovo-Metohija. Under Tito, Yugoslavia became a communist republic, but he veered far from Moscow and joined the Neutral countries.

After Tito’s death in 1980, the relationship between the Yugoslavian areas became damaged, by 1989 it was evident Yugoslavia was coming apart and a civil war occurred between 1991 and 1995. All former Yugoslavian countries became independent. But the situation declined, and NATO intervened by aircraft bombing Serbia in 1999. In 2003 the last of the former Yugoslavia became Serbia-Montenegro, but they separated in 2008.

A Museum Born with the Country

In 1878, Serbia became an independent country. A law regarding the organization of the army was adopted and stipulated that all guns or materials regarding the military history of the country had to be kept for scientific and memory purposes. The War Ministry was responsible for this organization, and the museum was founded as a celebration of Serbia’s independence.

In May 1879, the military museum project began. First, Turkish and Serbian arms and flags used during the Independence War were consolidated, and later with uniforms, horse-drawn trucks and cannons. The collection became more significant at the end of the 19th Century.

The first permanent museum display was established in 1904, in a small octagonal 17-yard diameter room in the Kalemagdan fortress in Belgrade. It displayed a lot of information about the history of Serbia, and people were invited to give military souvenirs to the museum.

The establishment took part at the Balkan Exhibition in London in 1907. But due to a lack of interest, it closed in 1912-1913 during the war. When WWI began, bombs fell on Belgrade, and many buildings including the museum were destroyed. The Austro-Hungarians arrived, and many pieces were sent to Vienna or Budapest. The Serbian king and government went to Paris; survivors of the Serbian Army were recovered by the French in Durazzo (Durrës) on the Adriatic Sea; they moved to Salonique (Salonika) and began reconquest of the country.

A long time before the end of the war, headquarters required all the branches of the army (infantry, cavalry, engineers, sanitary corps, etc.) to keep one or more specimens of all small arms, equipment, uniforms or accessories used to create a reference collection. A visionary and foresighted spirit rarely encountered (look around … ).

A New Museum

After peace was achieved, the hunt for pieces stolen by the enemy began, and a new museum was created inside the Kalemegdan fortress.

The museum opened in 1937; collections were widely developed, and new divisions were opened including a library, an artist section and several tanks; aircraft were located in a shed near the museum.

After the beginning of WWII in 1941, museum managers placed many pieces in wooden boxes stored in underground tunnels of the fortress. It was a very good idea because several bombs fell here, and some pieces were kept by Germans.

Belgrade recovered freedom on October 20, 1944, after a combined fight of the Resistance and the Red Soviet Army. On April 2, 1945, a new collection of historical pieces began. The museum was partially destroyed, but some temporary exhibitions were organized.

In 1956, the museum moved to the former building of the Geographic Institution and was completely rebuilt. It was inaugurated on October 20, 1961. Numbers of visitors increased, many of them were foreign presidents, monarchs, chiefs of government or WWII military commanders.

Guided Visit

My last visit in Belgrade was on October 2018. Walking through the beautiful Kalemegdan park, visitors will discover several decades of old and modern cannons. A visit of the rooms by crossing a particular way allows one to discover Serbian history of 2,000 years. After the Roman artifacts comes Middle Age items with edged weapon armour and scale models of catapults or others, mainly Byzantine. Further in there were primitive and flintlock rifles, mainly Turkish.

When the country was independent many European small arms were used before the country chose various Mauser rifles:

• M1871
• Mauser Milovanovič M1880, 1884 and 1880/07
• M1899, 1899/07, 1899/08, 1908 and 1910

Handguns used were mainly Gasser and Nagant revolvers.

Most of the wars where Serbia fought are exhibited; mainly the Balkans wars and WWI. Weapons, uniforms and flags are exhibited in several rooms with maps, pictures and military equipment. Most of the small arms are German, Austrian, Turkish or French. Some curious models could be seen, such as the Chauchat light machine gun converted for the 7.92mm cartridge by Kragujevac Arsenal in the 1920s.

Histories of the Serbian, Croatian and Slovenian Kingdoms and later Yugoslavia are also presented. The dramatic story of King Alexander I’s assassination in Marseille, France, on October 9, 1934 is described. The king’s jacket with several bullet holes and the assassin’s gun, a Mauser Schnellfeuerpistole (it is a copy; the original is in France), are exhibited.

Rooms about WWII exhibit many German, Italian, American, British or Russian small arms. A scarce Knorr-Bremse light machine gun can be seen. A large room is dedicated to Marshal Tito, the Yugoslavic communist revolutionary and political leader whose memory is still present in the country.

In the newest rooms Serbian small arms produced by Zastava are exhibited and so is the recent history of Serbia:

• UN peace representation in Yemen, Congo, Namibia, Iran, Egypt (etc.)
• Civil war
• NATO bombing

Outside of the fortress, a large collection of tanks is exhibited in a moat. The aircraft museum is now near the international Nikola Tesla airport a few miles from Belgrade.

Military Museum

The Serbian Military Museum is located in the fortress of Kalemegdan in Belgrade. It is a Vauban-style castle built with brick at the top of a hill between the Danube and Sava Rivers. It is open from Tuesday to Saturday between 10:00a.m. and 5:00p.m; entry is 200 Serbian dinars ($2.00). There is a cloakroom and a store where technical and historical books can be found. Several of them are written in Serbian and English; they are cheap and very interesting. It is possible to find several restaurants in the park around the fortress.

How to Visit Serbia

Serbia can be accessed by one or more daily flights from all the main cities in Europe. It is possible to lease a car; driving is on the right, but gasoline is expensive.

Money is the Serbian dinar. Check a currency exchange website, such as xe.com, for rates.

Belgrade has a variety of features: small streets, large avenues, old buildings recently restored or near downfall, Stalin-style concrete buildings, old monuments and churches, futurist construction, an embassy, hotels, many small stores, modern shops and restaurants.

There is sufficient security in the country; many people (in cities, hotels or stores) speak English.

It is easy to find a hotel via Trip Advisor or similar reservation site. Prices are cheap: $35-$40 for a night in comfortable hotel including breakfast.

Restaurants are also inexpensive: $6-$8 for a quick meal and $15-$20 for a good dinner.

Some useful Serbian words to know in a restaurant:

Voda = water

Pivo = beer

Nema = finished! (y’en a plus)

The most difficult problem in Serbia is orientation. Inside large cities all the signals along the roads are written in Cyrillic alphabet, which is different than Russian! The use of a GPS is absolutely necessary.

Have a nice trip!

Bibliography

Serbian and Yugoslavian Mauser Rifles, Branko Bogdanovič, North Cape Publications (2005).

Пешалијско Аутоматско Оружје Другог Светског Рата (World War Two Infantry Automatic Weapons), Dejan Milivojevič & Vuk Obradoivič – Odbrana (2012).

Војни Мчэеј Ъеограѧ (Military Museum Belgrade), Predrag Lazevič & Andeliza Radovič – Odbrana (2013).

Eventually, no matter how much you enjoy shooting and collecting firearms, there comes a day when it’s time to pass your coveted collection onto new stewards. Many collections take a lifetime to build. Finding the appropriate venue to market your collection can be a daunting and emotional process.

Selling

What is the best way to legally dispose of your guns? Today, there are several options available; many that did not exist in the past. If you have had your collection for a number of years, you probably bought most of your guns through the advertisements in one of the monthly periodicals of the day, back when your word was your bond. Unfortunately, things have changed. A few potential buyers and sellers are simply scammers out to swindle unsuspecting individuals. And then there are those that get what is referred to as “cold feet.” These are individuals who want details, photographs and your time, only to back out of the deal using a plethora of excuses, too numerous to list here.

Disposing of your cherished collection through your heirs, who may not know the value, legal or other protocols of selling Class III goods, can be confusing for them. And they could open themselves up to being duped by a “friend” of the late owner; someone offering one low-ball price for everything, including all associated accessories that usually have substantial value themselves. If you haven’t made a list of your collection, accessories and their current values, it is prudent that you do so. Tagging each firearm, or making an inventory list, with a value and status: transferable, pre-May or post-May dealer sample. The Class III market is continuously changing; be sure to update the value of your inventory periodically.

Today, there are many more options available for disposing of machine guns and related goods.

One popular venue for buying and selling that has become very popular is the internet. This option allows for inexpensive advertising and instant posting of an ad. The disadvantage to this method is that many potential buyers and sellers are not comfortable with the internet; making a deal and sending a substantial amount of funds, without ever speaking or meeting the seller. Another option is to request an offer from one of the reputable dealers, many who will purchase entire collections.

Buying—Where Have All the Machine Guns Gone?

During the “good old days” just a few years ago it was relatively easy to find whatever machine gun or accessory you wanted. More recently, the availability of “the good stuff” has diminished, which often raises the question of “Where have they all gone?” The answer is into personal collections, and usually, the collections are not liquidated until the owner retires or passes away.

Whether you’re an advanced Class III enthusiast or ready to make your very first purchase, the procedures of buying a machine gun have changed a lot in the last few years. One of the major influences has been the widespread use of the internet. While the internet allows you to shop at home, there are risks involved. One disadvantage to internet shopping is the often vague descriptions in the text of the ads, which leave out many key details. On what ATF form will it be transferring from the current owner- is there a double tax involved? Any pitting or corrosion present? Can you rely on the (often) poor photographs of the gun taken with a cell phone?

Another increasingly popular option is a firearms auction. Auction houses that specialize in firearms are growing. Machine guns are expensive—if you are planning on spending a substantial sum of money it may be wise to attend the auction and view the guns firsthand. Attending an auction is very much like attending a gun show. All the firearms are available for examination by attendees, and (most) everything will be sold to the highest bidder. If you’re going to bid by phone or online, the auction houses offer professional photographs and accurate, detailed descriptions.

Morphy Auctions

Since its founding in 1997 by Dan Morphy, Morphy Auctions has provided buyers and sellers with a venue for selling antiques and collectibles. Morphy Auctions is headquartered in Denver, Pennsylvania, along with an office in Las Vegas, Nevada, for west coast customers. Morphy’s is a full-service auction house, with over 35 premiere auctions annually. The company’s mission includes ensuring consignor satisfaction with every auction, offering world-class customer service and providing buyer support to create confidence for all clients seeking a pleasant selling or purchasing experience.

Morphy Auctions is one of the largest under-roof auction houses in the country, spanning over 45,000 square feet. The building is designed to meet the growing and changing needs of the industry. The well-lit, fully carpeted and climate-controlled gallery is customized to ensure the ideal atmosphere for the items housed within the facility. The items are secured properly and are professionally displayed to maximize their eye appeal. The auction room’s design features the latest telecommunications, wireless technology and custom acoustics for the best auction experience possible. Adjacent to the auction room is a comfortable dining area equipped with an audio-feed function and windows to enable bidders to monitor the auction activity while taking a break to enjoy lunch or dinner.

Firearms Auctions

Morphy’s has an in-house staff dedicated to assist and advise both buyers and sellers with evaluating firearms, which includes an NFA weapons specialist. If you are new to the Class III world, the terminology and categories of guns can be confusing. The firearms staff at Morphy’s can guide you on the many types of NFA firearms: transferable, dealer samples, original receiver guns, C&R, tube guns, Rewats, Dewats and guns with welded receivers. All Class III items consigned for auction are transferred to the auction house. When the item is sold, Morphy’s submits the ATF paperwork to transfer the item to the successful bidder. The consignor receives payment after 45 days. Upon ATF approval, the shipping department packs the item and ships it to the new owner. There are buyers’ and sellers’ premiums. The seller’s commission fee is negotiable, depending on the size and value of the piece or collection.

Morphy Auctions has experienced tremendous growth over the years. During December 2017, Dan Morphy of Morphy Auctions announced that he had successfully merged with the renowned international auction company of James D. Julia, Inc., which then became a division of Morphy Auctions. Many firearms enthusiasts are familiar with the Julia Auction House for their many successful firearms auctions that offered some very unique and rare firearms. Morphy Auctions realized annual sales of $35 million dollars within the last year. Within this same period, Julia’s generated $43 million dollars in annual sales for a combined gross of $78 million dollars. With this total of potential annual sales, Morphy Auctions is poised to become one of the largest auction houses in the country. No collection is too large or too small for Morphy Auctions to consider.

The combination of the highly experienced and much acclaimed Julia team together with the outstanding auction team that Morphy has already formed will make Morphy Auctions the ultimate place to go for rare firearms and rare collectibles.

Whether you are interested in selling or buying guns, coins, dolls, toys, fine and decorative arts, automobiles, advertising, coin-op, jewelry, cast iron or general antiques, Morphy’s can provide the specialist and departments to accommodate you. By having category-specific sales, they can target the top collectors through their marketing and advertising efforts. Visit their website for the dates and times of upcoming auctions.

For More Information

Morphy Auctions is located at 2000 North Reading Road, Denver, PA, 17517 and can be reached by telephone at 877-986-8880, Facsimile 717-336-7115. Email: info@morphyauctions.com. 

The Denver, PA, Auction Gallery is open 7 days a week, Monday through Friday, 9:00am-4:00pm, Saturday and Sunday from 9.00am-1.00pm. The Las Vegas facility is located at 4520 Arville Street, Las Vegas, NV, 89103 and is open Monday through Friday from 9:00am-4:00pm. For more information regarding Morphy Auctions, visit morphyauctions.com.

The term “AK-47” has become a generic identifier for a popular military rifle. The term is generally used to describe a particular Soviet-designed firearm, of which there are many variations. In most cases, using the designation “AK-47” is not technically correct, yet it has been widely accepted, particularly in the world media, and by most firearm enthusiasts. The original AK-(47) is a Russian-made rifle with a machined-forged steel receiver (except for rare early models) that was designed by Mikhail Timofeyevich Kalashnikov. Like most other Russian military weapons, the designer’s name is used in the nomenclature. It was accepted for Russian service in 1947, with mass production starting in 1949. However, the Soviets never used the designation “AK-47” in their manuals or literature, only the letters “AK” that represent “Avtomat Kalashnikova.” The original milled-receiver AK began to be replaced in Russian service by the stamped sheet metal receiver AKM model in 1959 and the smaller caliber AK-74 in 1976. Copies of all the aforementioned weapons have been produced in at least 20 different countries, none of which have used the name “AK-47” as an official designation.

The favorable characteristics of the AK as a military weapon are its simplicity and legendary reliability. Accuracy was acceptable by Soviet, not Western, standards. The U.S. Ordnance Department’s initial dismissal of the AK rifle, citing its lack of attributes, was due in part to different military doctrines used by the Soviet and U.S. forces. The United States Army viewed itself as a well-trained professional force that used marksmanship, well-trained motivated officers and well-practiced tactics to win battles. The Soviet Army used massed formation tactics that had little regard for the personal safety of its troops. Their small arms requirements placed firepower, simplicity, reliability and minimum maintenance above accuracy, as many members of their diverse conscript army were peasants. Those requirements would also make the AK rifle ideal for its eventual proliferation in many third-world countries.

Ever since the first Egyptian and Chinese semiautomatic-only AK variants were imported to the U.S. in the mid-1980s for the civilian market, the AK rifle has become a favorite of collectors and target shooters alike. Together with both rifles and spare parts sets being imported from former Combloc countries and a wide variety of U.S.-made stamped and milled receivers, an accurate representation semiautomatic AK clone from just about any nation can be purchased or assembled. However, this wasn’t always the case. For many years importation of such goods from communist nations was strictly prohibited, and AK rifles were rare in the U.S.—prior to the early 1980s, there were no semiautomatic AK rifles available in the U.S. The 7.62x39mm ammunition was equally scarce. During that time, AK-74 rifles, 5.45x39mm ammunition and magazines were largely unknown and simply non-existent in the U.S.

In the decades since the first AK rifles were imported into the U.S., many talented gunsmiths have continually strived to improve and upgrade Mr. Kalashnikov’s original design. Improvements and innovations have included making the AK more ergonomic and improving the weapon’s accuracy.

The FCGM SK-17 Rifle

The SK-17, the nomenclature representing “Semiautomatic Kalashnikov 2017,” is a stamped receiver AK variant primarily designed for one purpose, enhanced accuracy using standard 7.62x39mm ammunition. The enhancements implemented into the SK-17 rifle are the result of years of study, observations and range testing. The manufacturer FCGM is an acronym for Fire Control Group Manufacturing LLC, based in Port Charlotte, Florida.

The SK-17 was not intended to be a precision or Designated Marksman Rifle (DMR) for long-range engagements, but simply an AK rifle capable of a higher accuracy level than that encountered with standard issue AK weapons. There were a number of changes implemented into the basic AK design by FCGM to enhance the accuracy of the rifle. Starting with the gas system, which was modified by drilling the gas port closer to the breech, the gas port is sized appropriately for its proximity to the chamber. According to the manufacturer, this does three things for the system: it reduces barrel flex during cycling, increases barrel rigidity and reduces the amount of gas required for reliable cycling of the action, requiring a smaller gas port allowing more gas to provide greater energy behind the bullet. Accordingly, the overall length of the gas piston assembly has been reduced to fit the shorter system.

The 7.62x39mm military issue cartridges generally have bullets that weigh 122 to 124 grains and are .92-1.02-inches in length. The short, flat-base 7.62mm bullets offer little bearing surface; not an ideal design for accuracy. The Soviet/Russian 7.62 caliber firearms have a standard bore diameter of .300-inch (land to land), but traditionally have deeper grooves than most U.S. designs. The original Soviet AK barrels are 4-groove with a 1:9.45-inch RH twist.

The heart of any accurate rifle is the barrel. The barrel of the SK-17 rifle is 4150 Chrome Moly Vanadium steel, chromium-lined with 5R rifling to reduce projectile deformation and uses a 1:16 twist rate, which according to the manufacturer, improves gyroscopic stability of the round in flight. The slower twist rate combined with the 5R rifling also leads to an increase in muzzle velocity. The heavy Faxon barrel is precision-machined no more than +/- .001-inch tolerance. These changes increase muzzle velocity, improve accuracy potential, increase effective range and terminal performance. FCGM LLC’s proprietary design is a major step forward in improving the accuracy of the 7.62x39mm cartridge. The SK-17 barrels have a correct groove diameter of .311-inches for the 7.62 Soviet cartridge. The barrel’s muzzle is threaded with the standard 7.62 AK 14x1L left-hand metric thread.

Another key component contributing to accuracy is the trigger assembly. The triggers fitted to the SK-17 are ALG Defense’s AKT single-stage triggers, which are modified in FCGM’s shop for enhanced performance. ALG Defense is a division of Geissele Automatics, a company well-known for its match grade, competition trigger groups.

Like any accurized rifle, the SK-17 is assembled using hand-fitted parts resulting in a very smooth action. The finish on the rifle is Cerakote over manganese phosphate. Standard features of the SK-17 rifle include: a Magpul MOE pistol grip, Magpul ACS stock (other stocks are available), a Midwest Industries Gen2 M-LOK handguard, an ALG Defense AKT trigger, a Sabrewerks 13 Kalashnikov Optics Platform (KOP) scope mount, a JMac Customs GBC-13 front sight/gas block combo, JMac Customs RRD-4C Slim muzzle brake and FCGM muzzle device detent block so that the end user has the ability to use any standard AK muzzle device and to stow a cleaning rod.

The goal of FCGM was to build a system using high-quality parts from the top innovators in the U.S. AK industry combined with FCGM’s barrel specifications and unmatched barrel quality that did not sacrifice any of the reliability the Kalashnikov is famous for.

Other Fire Control Group Manufacturing LLC Services

FCGM builds and services both foreign and domestic weapon systems. The company specializes in Kalashnikov-pattern rifles and its many variants. They offer build services for those customers who would like a rifle built and may already have an AK parts kit, or those who wish to have a ground-up custom AK-47 or AK-74 built by experienced, knowledgeable and skilled craftsmen. Every rifle that is built at FCGM’s Custom Shop is constructed to proper specifications and hand-fitted for smooth and reliable operation for the lifetime of the system. Every rifle is built and assembled with great attention to detail and is test fired and zeroed to ensure the customer does not encounter any issues after delivery.

Firearm Refinishing

FCGM offers a variety of refinishing services—everything from classic restoration to some of the most durable and corrosion-resistant products for the most austere environments. Finishes available include: Manganese phosphate and Zinc Phosphate (parkerizing), Cerakoting, PVD, KG Gunkote, Moly Resin, Bluing and Nitriding Services.

Even with the prevalence of instructional videos on the internet, there is tremendous value in hands-on training with an esteemed instructor like Ernest Langdon. The author attended Langdon’s Tactical Pistol Skills class, and this piece recounts his analysis-driven lessons.

Analytics

Langdon was an instructor for the High Risk Personnel course during his tenure in the US Marine Corps. He attended various shooting schools, analyzed their techniques and fused together highlights for implementation with the USMC. He continued this intellectual approach on the competition and instructional circuit with much success, earning 10 National Championship Shooting titles and two World Speed Shooting titles.¹ At each segment of class, Langdon concisely presented his preferred techniques and their rationale. The author found this effective in facilitating material absorption and preventing a “cargo cult” of blind followers.

Analysis requires data, and Langdon expounded upon the need to track the sights before and after trigger break to gather data. Sight alignment and sight picture at trigger break allow one to “call the shot,” and this early information enables quicker re-engagement if necessary. While this skill should already be familiar to riflemen, the recoil profile of pistols imparts additional information. Front sight movement immediately post trigger break shows whether it (and hence, point of impact) was moved by the finger. This author experienced front sight lateral offset and dip during class. With diligent analysis, he was able to diagnose his trigger pushing and flinching. This information afforded corrections during a course of fire to speed up the learning loop.

Continuous Improvement

Continuous learning and self-improvement through competition and instructor development forms a large part of Langdon’s shooting philosophy. Competition drives innovation and provides inspiration for improvement. Instructor development not only hones analytic skills, but it also improves the community by stocking the pond with good ambassadors. Langdon observed that students already take part in some form by simply trying to “one-up” their friends or taking someone to a shooting range. He encouraged the continual pursuit of such opportunities.

In fact, Langdon encouraged his students to attend classes from different instructors as different renditions of similar information can trigger “lightbulb moments” for different students. His personable nature and freewheeling Q&A on varying topics help students to connect with the material. In a sense, this approach is Kaizen applied to the shooting discipline.

Subconscious Performance

Langdon emphasized that one should train and “build muscle memory” until basic functions like pistol presentation and trigger roll can be performed subconsciously. Under stress (whether life-threatening or competition), the conscious mind is overwhelmed with processes such as discerning targets, relocating to cover and maintaining situational awareness. To draw a real-time computing analogy, these high-priority tasks occupy so many clock cycles of a frame that low-level functions get little or no execution time. When shooting the X-Drill, this author experienced “CPU overload” on the high-priority task of which box to engage next. To the detriment of marksmanship, there was no time to consciously implement the recently learned grip correction.

Stance

To better absorb recoil in static shooting, Langdon advocated a modified isosceles stance, where the elbows are not locked in full extension. For head and shoulder positions, he preferred a slight tuck of the neck—similar to how one would instinctively protect it when startled. However, he noted an over-aggressive “tactical turtle” may lead to discomfort and long-term health detriment.

Langdon also articulated various reasons to slightly cant the pistol. When firing with weak hand only, canting aligns the sights with the dominant eye without undue lateral shift of the arm. When turning the upper body to address a target on the strong side, lifting the strong side’s elbow can allow additional rotational movement. This cants the pistol as a side effect.

Optimal feet placement, on the other hand, was not overly emphasized due to the compressed timeline and propensity for movement during a defense scenario. Were a situation allowing a static stance to come along, students were taught to slightly stagger their feet (closer to fully squared than Weaver) in an aggressive forward lean while maintaining their weight on the balls of the feet. This affords better recoil control and facilitates movement.

Grip

For optimum recoil management, Langdon advised that the pistol beavertail be centered as high as possible on the natural web of the hand. He then explained the importance of maximum skin contact with aggressive grip material to gain traction and manage recoil. The stock plastic grips on the author’s pistol were worn too smooth for good purchase. Aftermarket G10 grips were found to offer improvements; however, it was noted that the golf ball dimple texture irritated the hand, while standard chequering proved insufficiently tactile. The Langdon Tactical Technology exclusive VZ G10 grips provided an optimal balance between hand comfort and grip. The texturing extends high to support a thumbs-forward grip, while the vertically elongated diamond chequering provides substantial recoil resistance without the irritation.

As someone who learned through internet discussion boards and videos, the author very much appreciated the discourse on the rationale for a thumbs-forward grip. Langdon explained that the grip is not about thumb placement but about palm contact with the pistol. Starting with a high strong-hand grip, the thumb is moved out of the way to open up a large area for support-hand contact. The support hand is then rotated down so that the wrists come together with no gap in between for maximum contact. For the author, this positions the strong hand’s abductor pollicis brevis muscle against the support hand’s thenar crease. This downturn of the wrist also preloads it for better recoil management.

To further explain the grip, Langdon drew an analogy between resisting recoil and pushing a table. It is more efficient to push against the table ledge in comparison with placing one’s hands on the tabletop to push via friction. Similarly, it is more efficient to catch the backstrap with the support hand instead of resisting recoil through grip panel friction alone. Specific to the Beretta 92 series, Langdon explained that the backstrap hump of the 92FS/M9 cleared the strong hand away for more support-hand contact, while the smaller grip of the Vertec model allowed less contact for most shooters. The 1.8-meter-tall author, after grip adjustments by Langdon, found that the 92FS/M9 was very comfortable and permitted an effective support-hand grip. To confirm good posture during practice, Langdon advocated firing at least two rounds after re-establishing grip (as in a reload drill). This is a corollary to how a low-recoil 5.56x45mm rifle hides bad posture even during the rapid-fire stages of high-power rifle competition, while a 30-caliber rifle breaks down and reveals poorly built positions.

Langdon also highlighted grip strength as the common thread between accomplished pistoleers (whether bullseye or International Practical Shooting Confederation), as it enhances recoil management and encourages consistent groups. Embracing the analytic approach, the southpaw author observed his front sight shifting right under recoil which required a manual reset after every shot. Reasoning pointed to a weak support-hand grip, as recoil naturally follows the path of least resistance. Assiduous application of full grip strength on both hands cured this problem.

During the two-day course, the author discovered his office-worker hands to lack in raw strength and stamina. Langdon suggested hand gripper exercise tools, reverse curls and even wringing out a wet towel. Using the fingers to gather a piece of paper into the palm and then ball it up also promotes finger dexterity, with reverse stretches recommended to maintain muscle health.

Trigger

Langdon is an advocate of the Double-Action/Single-Action (DA/SA) semi-automatic pistol.² To quickly and accurately deploy the DA first shot, Langdon advised performing a smooth trigger “roll” as part of the pistol presentation. When extending the pistol, one should keep the front sight slightly proud of the rear in order to better see and steer out lateral errors. Start rolling the trigger at the end of the presentation while obtaining the sight picture. The trigger should ideally break just as the proper sight alignment and sight picture are obtained, but by no means should one break the shot just because the pistol is fully presented.

Quickly pushing out the pistol can cause a “whipping” sight picture that requires time to dampen, while rapidly “slogging through” the trigger affords precious little time for proper trigger control. In order to better illustrate the benefits of combining trigger roll and presentation, Langdon used a shot timer to demonstrate both methods. While the combined deliberate motions seemed slower, it was actually about one-tenth of a second faster. After some practice, the author recognized how Langdon’s method allowed him to “take his time in a hurry.”

In teaching the optimal trigger break for self-defense, Langdon eschewed the traditional wisdom of “ever-increasing pressure with a surprise break” and opted for “slapping the trigger without disturbing the sights” instead. Given that target and own-ship motions are inherent to a defense scenario, it is nigh on impossible to maintain proper sight alignment and sight picture while applying ever-increasing pressure for a surprise trigger break. Instead, one must “slap the trigger without disturbing the sights.”

To do so, Langdon instructed the author to critically observe his own dry fire in order to discover the proper trigger finger placement to make the pulling movement effective. On command (from an assistant or a timer set on random), he broke the SA trigger promptly without a thought to ever-increasing pressure while observing any front sight movement. For the southpaw author, such movement to the right required the trigger finger to reach deeper onto the trigger face. Discovery of this proper placement, combined with a proper grip, vastly improved marksmanship.

Peculiar to DA/SA pistols are the two different trigger break points, but Langdon remarked that there was no need to shift finger position if they were close enough together. He further opined that Beretta does the best job of closing that gap in his experience. The author can anecdotally report that the difference between DA and SA break point was not discernible on his Beretta 92, and it was not necessary to shift finger placement.

Cover and Movement

Working with and from cover is a necessary skill, and Langdon imparted some wisdom for the responsible citizen who would probably respond to the threat alone. He mentioned that one should not tuck up overly close to cover, as it limits situational awareness, prevents full pistol presentation and increases exposure to ricochets. In order to lean left around corners in the most stable manner, one should lead with the left foot when standing. When kneeling to the left, place the left knee down to avoid contact between the elbow and knee at aggressive angles. Note that this is different than a team environment, where two people peek around the corner together (one standing and one kneeling), so the kneeler must place his left knee up to create space for his teammate behind.

While the class was focused on aspects of shooting, Langdon did provide tactics tidbits when applicable. He cautioned that part of one’s body is always exposed before the threat is sighted, because the eyes are not at the scalp or other extremities. While slow and cautious have their place, aggressiveness and commitment are sometimes warranted to reduce the time between exposure and response.

To demonstrate the importance of movement during a self-defense scenario, Langdon presented a Tueller-inspired drill while holding ground versus moving sideways. Movement created additional space and afforded the defender time to draw and shoot. Additional wisdoms include the fact that people are predominantly right-handed and are therefore more likely to miss leftwards when slapping the trigger, so it might be advantageous for the defender to move right (as viewed by attacker).

As for the mechanics of shooting on the move, Langdon advised students to squat somewhat in order to isolate the upper body from the impact of footsteps. To further reduce the shock, one should “roll” the feet to create smooth and continuous motions. Lastly, Langdon reminded students to incorporate movement into their draw practice to better prepare themselves.

Final Thoughts

The outline presented in this article does not do Langdon’s Tactical Pistol Skills class justice, as it merely reflects parts the author gleaned and not the entirety of the class. Langdon not only taught pistol skills (gave this man a fish), he instilled a philosophy of continuous improvement through critical analysis (taught this man to fish). The championship-winning techniques, concise delivery and masterful pedagogy make Langdon’s class well worth the price.

1. Langdon Tactical: langdontactical.com/about/
2. Ernest Langdon, “Why Choose a Traditional Double Action Gun?” YouTube, April 11, 2018: youtube.com/watch?v=m42IJIreRoc

WALTHER

PPS M2

The PPS M2 is everything you’re looking for in a compact handgun. The slim profile, push button magazine release, smooth trigger pull, superior accuracy and signature ergonomics deliver the powered performance needed for you to succeed on the range and in defense.

MSRP: $469–$699, waltherarms.com

WALTHER

PPQ Sub-Compact

Signature ergonomics and a smooth Quick Defense trigger are cornerstones of the award-winning PPQ platform. Accuracy and concealability are perfectly meshed together in this premium self-defense handgun. The PPQ Sub-Compact is extremely comfortable and controllable thanks to the superior ergonomics and customizable fit of the included interchangeable back straps.

MSRP: $649, waltherarms.com

SMITH & WESSON

Performance Center Ported M&P Shield M2.0

The Performance Center Ported M&P Shield M2.0 features a ported barrel and slide, PC tuned action, manual thumb safety, manual thumb safety, HI VIZ fiber optic sights or tritium night sights, front cocking serrations and a slim compact profile for concealed carry. The Performance Center Ported M&P Shield M2.0 also has a polymer frame with embedded stainless steel chassis system for steel-on-steel contact between slide and frame. Two magazines are also included: one standard with a flush-fit and one with an extended finger groove.

MSRP: $539, $623 (night sights), smith-wesson.com

SMITH & WESSON

M&P9 M2.0 Compact 4”

Designed for personal, sporting and professional use, the M&P9 M2.0 delivers an entirely new platform, introducing innovative features in nearly every aspect of the pistol, including trigger, grip, frame and finish. Highlights of the M&P M2.0 pistol include an extended stainless-steel chassis and a low barrel bore axis for reduced muzzle rise and faster aim recovery. The M&P M2.0 pistol further improves performance with a fine-tuned, crisper trigger, lighter pull and a tactile and audible reset. The pistol includes an aggressively textured grip and four interchangeable palmswell inserts for optimal hand-fit and trigger reach. Includes two magazines, a limited lifetime warranty and a lifetime service policy.

MSRP: $569, smith-wesson.com

ALIEN GEAR HOLSTERS

ShapeShift Modular Holster System

Adapt to every environment with the revolutionary ShapeShift Modular Holster System. Effortlessly shift from one comfortable carry position to the next and stay prepared for anything that life throws your way. This American-made holster system is backed by our 30-Day Test Drive and Forever Warranty.

MSRP: $99.88, aliengearholsters.com

ALIEN GEAR HOLSTERS

ShapeShift Shoulder Holster

Conceal your sidearm and spare magazines with the most advanced shoulder holster on the planet! Designed with breathable CoolVent Neoprene and adjustable leather straps, this cutting-edge holster delivers all-day comfort. Enjoy customizable Level 3 retention for enhanced safety. American-made and covered by our Forever Warranty.

MSRP: $133.88, aliengearholsters.com

TACTICA DEFENSE FASHION

Tactica IWB Holster

Finally—a gun holster specifically designed for women! This slim, formfitting inside-the-waistband holster is ready to conceal your sidearm underneath a variety of clothing. Breathable Neoprene conforms to your body and provides all-day comfort. Feel confident and prepared to take on the world with Tactica.

MSRP: $59.99, tacticafashion.com

TACTICA DEFENSE FASHION

Tactica Concealed Carry Corset

Stay prepared and protected with the all-new Tactica Concealed Carry Corset. Unlike ordinary holsters, this concealed carry corset is incredibly comfortable and easy to wear. And with its formfitting Neoprene, it’ll keep your handgun hidden underneath your clothing. Covered by our 30-Day Warranty. Dress to protect!

MSRP: $109.99, tacticafashion.com

TACTICA DEFENSE FASHION

Tactica Concealed Carry Knit Sweater

This beautiful merino wool sweater is ready to keep you warm (and protected). With faux pockets, you can access your sidearm from a belly band, corset, or appendix holster. Simply conceal your micro or sub-compact firearm underneath your plush sweater until you’re ready to draw.

MSRP: Not yet available, tacticafashion.com

TACTICA DEFENSE FASHION

Tactica Women’s Western Leather Gun Belt

Ordinary belts sag and twist under the weight of your holstered handgun. Eliminate belt sag with the all-new steel-reinforced Western Leather Gun Belt. This luxurious belt is handcrafted with floral embossed English Bridle leather. Wear it with a variety of outfits to complete your look.

MSRP: $91.99, tacticafashion.com

VISTA OUTDOOR

Blackhawk! Apparel/Verity Shirt

The BLACKHAWK! Verity Shirt was designed with comfort in mind. Comfort starts with the fabric, which is treated with an Enzyme Garment Wash Finish for the ultimate in softness. The cotton/poly construction dries quickly, so sweat and moisture doesn’t stick around. Printing is mitigated by the plaid pattern, and a breakaway snap placket provides quick concealed-carry access.

MSRP: $74.99–$79.99, vistaoutdoor.com

VISTA OUTDOOR

Blackhawk! Apparel/Extreme Pursuit Pant

Flexible, durable and comfortable, the BLACKHAWK! Extreme Pursuit Pant represents the next evolution in tactical gear. Made of 4-way mechanical stretch ripstop fabric, this construction delivers superior fit and movement. With seven exterior multi-purpose pockets positioned for optimal comfort, gusseted crotch and added action waistband, the Extreme Pursuit Pant is ideal for all-day comfort and optimal gear storage. Wear the Extreme Pursuit Pant all day, every day.

MSRP: $74.99, vistaoutdoor.com

SAVAGE

MSR 15 Competition

The speed, accuracy and customization needed to win are built into every aspect of the new MSR 15 Competition. Savage has teamed up with PROOF Research to craft a barrel specific to the firearm. Its unique ported muzzle brake allows the shooter to tune the recoil impulse to stabilize the muzzle for faster, more accurate follow-up shots. The custom-length gas block can be adjusted for optimal cycling of the full range of bullet weights as well as for use with a suppressor. The gas block has also been upgraded with an integral Picatinny rail and a custom handguard. Some features include: Savage by PROOF Research 18-inch carbon fiber wrapped stainless barrel; nickel-boron bolt carrier; custom-forged upper and lower receivers; non-reciprocating side charging handle; Savage tunable muzzle brake; Magpul CTR buttstock; two-stage trigger; rigid free-float handguard with M-LOK; anti-glare grooves; and red QD sling mount.

savagearms.com

FEDERAL PREMIUM

45 Auto 210-Grain Hydra-Shok Deep HP

New for 2019, Federal Premium has expanded its Hydra-Shok Deep line with new loads in 40 S&W and 45 Auto. Like the original 9mm Luger, the new offerings’ design improvements better meet modern performance measurements. The bullets feature a more robust center post and a core design that penetrates to critical depths through common self-defense barriers, without over-penetrating.

Features:

• Penetrates 15 inches in bare ballistics gel—the optimal depth according to FBI standards
• Improved penetration to optimal depths
• Significant improvement in FBI protocol score
• Iconic center post design has been improved for better, more consistent expansion through standard barriers
• Consistent, specially formulated propellant

federalpremium.com

MAXIM DEFENSE

M-RAX Picatinny M-Slot Rail Sections

Maxim Defense offers a new accessory mounting solution called the M-RAX attachment system. Thanks to the spring-loaded screws, the M-RAX system removes mounting frustrations. Simply push the screw in with a standard hex tool and rotate 90 degrees. The locking lugs engage that easily. Unlike the traditional M-Slot mounting systems, M-RAX utilizes the full slot of your rail, maximizing space. This makes the M-RAX system end-to-end stackable, giving you the option to create seamless monolithic rail sections where needed. No more fighting or timing screws. Just push, turn and tighten.

MaximDefense.com

DELTA 14 CHASSIS, INC.

Delta 14 Chassis Gen 2

American Built Arms Company, a veteran-owned, Type 07/NFA FFL manufacturer of firearms parts and accessories has designed, developed and manufactured the butt stock system for the Delta 14 Chassis. The Delta 14 Chassis is constructed of glass-filled nylon. Mounting of the stock is simple with the 5/16X18 fastener that will mate in any Mossberg 500 stock onto the chassis system. Installation of the chassis with the rifle does not require any tools. Simply pull the trigger guard from old rifle and remove the barrel and action. Drop into the Delta 14 Chassis and reinstall the trigger group. The chassis is lightweight, paintable, has an M-LOK mounting system and is guaranteed for life.

Delta14chassis.com

GUNWERKS

Magnus 28 Nosler with Revic PMR 428 Riflescope

The Magnus stock was designed to mitigate recoil on some of the larger hunting calibers that we produce. From the negative comb angle, to the larger, more vertical grip and the wide forend and flush Picatinny rail, the stock is designed to make the gun recoil straight. These features help the shooter to keep big and small cartridges alike on target while custom fitting to each shooter for ease and comfort.

The Revic PMR 428 smart optic scope with integrated ballistic solutions makes dialing in-field situations faster and less error prone. The clarity of the optic also allows for better visuals at extended ranges. While this scope is battery powered, it does not need the battery to function as a normal mechanical turret system. The combination of these two products make a perfect rig for shooting out to whatever range you are comfortable with.

gunwerks.com

GALCO GUNLEATHER

Ankle Glove (Ankle Holster)

For those who need concealment 80 hours a week, year in and year out, the Ankle Glove holster is so comfortable to wear that they forget it’s there–until they need it. The Ankle Glove’s wide neoprene ankle band and Velcro closure offer extended wearing comfort and unmatched security. Additional comfort is provided by sheepskin padding between the holster and ankle. It also features a reinforced thumb break for speed of draw and detailed molding for firearm retention. The Ankle Glove holster is constructed from full-grain Premium Steerhide.

galcogunleather.com

CHRISTENSEN ARMS

Traverse

New for 2019, the Traverse elevates Christensen Arms’ backcountry rifle offerings with time-honored styling and performance for every kind of hunter. The Monte-Carlo carbon fiber composite gunstock gives the rifle a classic feel, while the light target contour Christensen Arms carbon fiber wrapped barrel, stainless steel side-baffle brake, 0-MOA optic rail and bottom Picatinny rail ensure state-of-the-art operation. The Traverse weighs in starting at 7.3 pounds and is backed by the Christensen Arms Sub-MOA Guarantee. Current chamberings include: 22-250 Remington, 243 Winchester, 26 Nosler, 6.5 Creedmoor, 6.5 -284 Norma, 6.5 PRC, 7MM-08 Remington, 7MM Remington Magnum, 28 Nosler, 280 Ackley, 270 WSM, 270 Winchester, 308 Winchester, 30-06 Springfield, 300 WSM, 300 Winchester Magnum, 300 PRC, 30 Nosler and 300 RUM.

christensenarms.com

FLIR

Scion Professional Thermal Monocular (PTM)

The new FLIR Scion Professional Thermal Monocular (PTM) is built for public safety professionals and is powered by FLIR’s high-performance Boson thermal core for greater image quality. The Scion features connectivity with FLIR TruWITNESS to allow real-time encrypted thermal video streaming to provide professionals with greater situational awareness. The rugged Scion PTM features FLIR’s most advanced thermal imaging core, which allows users to quickly detect objects with greater detail and offer clear vision in low visibility conditions. Available in a 60 hertz refresh rate, the Scion PTM features 2 gigabytes of internal storage and a microSD card slot to record both geotagged video or still images for later playback. Additional features include picture-in-picture zoom, global positioning system (GPS) functionality and both Bluetooth and Wi-Fi capabilities to allow simple file transfer between devices.

flir.com/scion

SAMSON MFG

SOPROD Accessory

Designed to fit all battery-compartment style, adjustable stocks on the market, the SOPROD enables users to clear stuck cases and other bore obstructions. The SOPROD ships with enough extensions to clean a 20-inch barrel. Included are two self-adhesive rubber bumpers to line the ends of the storage compartment and two rubber O-rings which keep the sections together and rattle-free. An available accessory kit includes a rotating-head which accepts standard GI bore and chamber brushes and a thread adapter for commercial cleaning accessories. Constructed of solid brass or stainless steel, the SOPROD is designed to withstand the abuses GI cleaning rods are regularly subjected to.

While a stand-alone product, the SOPROD can be used in conjunction with the patented SOPROD Field Survivor tool which fits into the cavity of a standard A2 pistol grip or Magpul MIAD. The Field Survivor has a male-threaded adapter to act as a handle for the SOPROD in its cleaning capacity and includes a broken shell extractor, bore brush, sight adjustment tool and a compartment with two spare M4 firing pin retainers. The SOPROD rides silently in its compartment until needed and can get your rifle back in action in seconds.

samson-mfg.com

TUFFY SECURITY PRODUCTS

Tactical Security Lock-Box

Tuffy Security Products offers an array of products for many vehicles including Jeep, GM, Ford, Dodge, Toyota, Land Rover and more. The tactical security lock-box features steel construction, durable powder coating finish and a heavy-duty locking system to prevent picking.

tuffyproducts.com

GLOCK, INC. 

G4X & G48 

GLOCK, Inc. announced two additions to the GLOCK pistol family. The G43X and the G48 feature the design of the Slimline series with a silver nPVD finish slide. Chambered in 9×19, both pistols feature a 10-round magazine capacity making them ideal for concealed carry.

us.glock.com

AIMPOINT

Acro P-1

The Aimpoint Acro P-1 is developed for use on pistols and other weapon platforms requiring a small enclosed red dot system. It is the only sight in its size category fully tested for shock, vibration, temperature span and other environmental stress.
The Acro P-1 is the smallest enclosed system on the market. Tested with 20,000 rounds on a .40 cal pistol slide, this small optic has proven to lead in ruggedness and reliability in its category. The Acro P-1 can be used as a backup sight for magnifying scopes, personal defense weapons, and any area where a small red dot system is applicable.
us.aimpoint.com

(This is the second of a two-part series.)

In Part One of this series (see “Legally Armed,” Small Arms Review, Vol. 23, No. 4 (April 2019)), we walked through the U.S. anti-discrimination laws that prohibit employment discrimination on the basis of national origin or disability and identified where these laws intersect with controls on technology transfer and firearm possession restrictions that apply to the manufacture of firearms and other munitions. In this article we discuss how to reconcile the seemingly conflicting requirements of anti-discrimination laws and the technology controls of the Arms Export Control Act, Title 22, U.S. Code, Chapter 39 (AECA), its implementing regulations of the International Traffic in Arms Regulations, Title 22 Code of Federal Regulations, Parts 120-130 (ITAR) and the restrictions on transfers to and possession by certain persons under the Gun Control Act of 1968, Title 18 U.S. Code, Chapter 44 (GCA).

As we touched on previously, the laws and regulations governing the manufacture, possession and transfer of firearms and other defense articles protect our national security and public safety and are no less important than those that protect us from discrimination in certain areas of our life. Navigating the overlap among these laws can be challenging but is a must for any company seeking to maintain a robust compliance program. As with violations of anti-discrimination laws, violations of technology control and firearm possession requirements are serious. Penalties for violations can come with hefty fines, potential prison sentences and debarment from federal contracting.

I.       Protecting Controlled Technology

For firearm and ammunition manufacturers, questions often arise as to how to protect against unauthorized export of controlled technology, including manufacturing know how. In navigating the intersecting U.S. export laws and anti-discrimination laws, the questions could include:

• As a manufacturer of firearms, can I require all my employees to be U.S. citizens because we work with controlled technology or technical data?
• Can I have a blanket corporate policy not to assign non-U.S. citizens to certain job functions?
• If an employee was born in an embargoed country and I am not able to obtain authorization to share technical data with that employee, do I have to offer accommodations to that employee because he or she is not able to perform his or her job?

Because of the breadth of U.S. export controls over technology, especially ITAR restrictions on disclosing “technical data” to “foreign persons,” it is not uncommon for businesses to conclude that a prudent policy is to restrict employment to U.S. citizens. However, such blanket policy may violate the federal laws on discrimination.

At the time of this writing, firearms and associated parts, components, attachments and accessories are controlled for export as “defense articles” under the AECA. Consequently, this article focuses on its implementation regulations, the ITAR. Readers may recall that last May 2018, the Departments of State and Commerce published proposed rules to transition certain firearms, ammunition, parts, components, accessories and attachments away from the ITAR controls and over to the Commerce export controls known as the Export Administration Regulations, 15 C.F.R. §730 et seq. (EAR). See also the two-part “Legally Armed” columns reviewing the proposed transition rules in Small Arms Review, Vol. 22, Nos. 8 and 9 (October and November 2018). However, as we entered 2019, the agencies had not yet published these rules as final. Rest assured, when the agencies do publish the final transition rules, we will explore the impact on technology transfers.

The ITAR places restrictions on the transfer of controlled technical data to non-U.S. persons. A license or other authorization (e.g., ITAR exemption or agreement) is required prior to transferring ITAR-controlled technical data to a non-U.S. person. Under the ITAR, a person’s nationality takes into account where the individual was born and all countries in which he/she has or had citizenship or permanent resident status. In order for an employer to know this information and be able to make a licensing determination, it must inquire as to that individual’s country of birth and country(ies) of citizenship. Requesting this information from an applicant or current employee, or shaping a job posting around this requirement, if done improperly, can violate U.S. anti-discrimination laws. Before we delve further into this intersection, it is important that we cover some basic ITAR definitions that will help guide our discussion.

It is important to note that the EAR also places restrictions on the transfer of technology to non-U.S. persons. Even though this article focuses on the ITAR requirements, please be aware that the anti-discrimination considerations discussed are equally applicable to the technology transfer controls under the EAR.

A.     Defense Article

The ITAR defines the term “defense article” (22 C.F.R. §120.6) as any item or technical data designated on the U.S. Munitions List (USML). This term includes technical data recorded or stored in any physical form, models, mockups or other items that reveal technical data directly relating to items designated in the USML. Defense articles also include forgings, castings and other unfinished products, such as extrusions and machined bodies, that have reached a stage in manufacturing where they are clearly identifiable by mechanical properties, material composition, geometry or function as defense articles. The term does not, however, include basic marketing information on function or purpose or general system descriptions of USML items.

USML Category I controls firearms, close assault weapons, combat shotguns, silencers, as well as components, parts, accessories and attachments for these items. Guns over .50 caliber are controlled in USML Category II, as well as components, parts, accessories and attachments for these items. Ammunition for those firearms controlled in USML Categories I and II is classified under USML Category III. Components, parts, accessories and attachments for ammunition are also controlled in USML Category III.

B.     Technical Data

The ITAR defines “technical data” in §120.10 as “information, other than software as defined in §120.10(a)(4), which is required for the design, development, production, manufacture, assembly, operation, repair, testing, maintenance or modification of defense articles. This includes information in the form of blueprints, drawings, photographs, plans, instructions or documentation.” The definition also includes classified information relating to defense articles and defense services on the USML and 600-series items controlled by the Commerce Control List; information covered by an invention secrecy order; and software directly related to defense articles. There is a technical data control paragraph in all USML categories.

As important as it is to know what constitutes technical data, it is equally important to understand what is not considered technical data. The definition does not include “information concerning general scientific, mathematical or engineering principles commonly taught in schools, colleges and universities, or information in the public domain as defined in §120.11 or telemetry data as defined in note 3 to Category XV(f). It also does not include basic marketing information on function or purpose or general system descriptions of defense articles.”

C.     Export

The term “export” is defined in 22 C.F.R. §120.17, in relevant part, as an actual shipment or transmission out of the United States, including the sending or taking of a defense article out of the United States in any manner or releasing or otherwise transferring technical data to a foreign person in the United States (a “deemed export”). Any release in the United States of technical data to a foreign person is deemed to be an export to all countries in which the foreign person has held or holds citizenship or holds permanent residency. The ITAR defines “foreign person” to mean any natural person who is not a lawful permanent resident of the United States or who is not a protected individual (as defined in the Immigration Reform and Control Act, discussed in Part One of this series), as well as a foreign corporation, business association, partnership, trust, society or any other entity or group that is not incorporated or organized to do business in the United States and any international organization, foreign government and any agency or subdivision of a foreign government. It is important to note that the EAR makes it clear that the term “foreign person” is synonymous with the term “foreign national” as used in the EAR.

As you likely have already surmised, the “deemed export” concept is where companies find the direct intersection of anti-discrimination laws and U.S. export controls. How can a company walk the line between requesting relevant information on an employee’s (or potential employee’s) nationality without violating anti-discrimination laws that prohibit discrimination based on nationality?

D.    Navigating the Intersection with Anti-Discrimination Laws

The U.S. Government has provided some guidance for industry with respect to the intersection between the various laws controlling technology transfer, firearm possession and anti-discrimination laws. First, with respect to technology transfer, the licensing requirements of the ITAR are not prohibitions against hiring non-U.S. persons. In fact, nowhere in the regulation is there a prohibition against the hiring of non-U.S. persons to perform license-required tasks. The only requirement is that the employer seek the proper authorization before the person is allowed access to the controlled technical data.

An employer may consider citizenship status if it is required in order to comply with a law, regulation or executive order, or the terms of a Federal, State or local government contract (8 U.S.C. §1324b(a)(2)(C)). However, this must be done in a non-discriminatory way. The U.S. Department of Justice (DOJ) has published letters it has issued to companies seeking guidance on how to comply with anti-discrimination laws when verifying an employee’s citizenship status under U.S. export control laws. In DOJ’s February 25, 2013 letter, it advises that “if the information is sought for compliance with export licensing requirements, and not for employment eligibility verification or any discriminatory purposes, inquiring about an applicant’s citizenship or country of origin for this purpose would not appear to violate the [Immigration and Nationality Act] anti-discrimination provision as long as such inquiries are made uniformly and without the intent to discriminate on the basis of national origin or citizenship status.” The full text of this letter is available at: justice.gov/sites/default/files/crt/legacy/2013/02/28/163.pdf. Additional DOJ letters addressing anti-discrimination laws and U.S. export controls are available at: justice.gov/crt/file/837281/download (March 31, 2016 letter), and justice.gov/sites/default/files/crt/legacy/2011/06/07/134.pdf (October 6, 2010 letter).

However, DOJ advises that “to the extent an employer screens out all applicants from particular countries or rescinds job offers for certain applicants based on the assumption that the employer would need to obtain an export license for those individuals at some point during the employment relationship, the applicants may allege national origin discrimination in a charge filed with [the appropriate agency].” This guidance applies equally to current employees. Having to obtain an export license to employ an individual cannot be used as the sole reason for refusing to hire or promote non-U.S. persons.

II.     Gun Control Act Restrictions on Transfer and Possession

Another potentially tricky area of compliance is the GCA prohibition on certain categories of persons to ship, transport, receive or possess firearms or ammunition. One type of prohibited person is an individual who is an unlawful user of or addicted to any controlled substance (as defined in section 102 of the Controlled Substances Act, codified at 21 U.S.C. §802). To add a layer of complexity to this, many states have passed laws legalizing marijuana use in some form. So it is not uncommon for a business licensed under the GCA to ask:

• Can I screen potential employees against the prohibited persons provisions of the GCA without violating the Americans with Disabilities Act?

From a federal law perspective, the use or possession of marijuana remains unlawful regardless of whether it has been legalized or decriminalized for medicinal or recreational purposes in the state where you reside. This means that any person who currently uses or is addicted to marijuana, regardless of whether it is legal in your state, is “an unlawful user of or addicted to a controlled substance and is prohibited by federal law from possessing firearms or ammunition.” ATF issued an open letter in 2011 directly addressing the use of marijuana for medical purposes and federal firearms laws (available at: atf.gov/file/60211/download).

As with the question of an individual’s nationality, the question becomes how may a company inquire about an individual’s current drug use without violating the anti-discrimination laws surrounding addiction disabilities?

With respect to GCA prohibitions on the transfer of firearms to a person who is an unlawful user of or addicted to any controlled substance, the EEOC provides guidance on its website (eeoc.gov) to assist employers on making a determination as to current drug use. Remember, past drug addiction and recovery may be considered a disability—the ADA does not allow questions about disabilities before making a conditional job offer. However, because current drug users are not protected under the ADA, an employer may ask about current illegal use of drugs. Indeed, the EEOC advises, “questions may involve illegal drugs (cocaine, crack, heroin) and the illegal use of prescription drugs. An employer also may require an applicant to take a drug test. (If the drug test is positive, the employer may validate the test results by asking about lawful drug use or other possible explanations for the positive result, other than the illegal use of drugs.)”

III. Summary

It can be challenging to navigate the thorny intersection of anti-discrimination prohibitions with technology transfer controls and GCA transfer and possession restrictions. As we have seen, employers must be aware of the potential for anti-discrimination claims when verifying citizenship status for purpose of export controls. Contrary to what some believe, the ITAR does not contain outright prohibitions related to employment of non-U.S. persons. Inquiries related to citizenship status must be made uniformly (i.e., of all employees or potential hires) and be solely for the purpose of determining whether an export license is required. These inquiries should be separate and distinct from those made to determine employment eligibility generally. On the GCA side, questions surrounding current illegal drug use are permissible, but those related to past use or recovery are not.

To avoid running afoul of federal non-discrimination laws, it is important that businesses recognize the intersection of these laws with export controls over technology and GCA restrictions. Companies should put in place comprehensive processes and procedures, including training, to guide the various functions within a company when making hiring, firing and advancement decisions.

The author extends her appreciation to the generous contributions of Katherine Heubert, Esq., at Reeves & Dola, LLP.

***The information contained in this article is for general informational and educational purposes only and is not intended to be construed or used as legal advice or as legal opinion. You should not rely or act on any information contained in this article without first seeking the advice of an attorney. Receipt of this article does not establish an attorney-client relationship.

About the Author

Johanna Reeves is the founding partner of the law firm Reeves & Dola, LLP in Washington, DC (reevesdola.com). For more than 15 years she has dedicated her practice to advising and representing U.S. companies on compliance matters arising under the federal firearms laws and U.S. export controls. Since 2011, Johanna has served as Executive Director for the Firearms and Ammunition Import/Export Roundtable (F.A.I.R.) Trade Group (fairtradegroup.org). She has also served as a member of the Defense Trade Advisory Group (DTAG) since 2016. Johanna can be reached at jreeves@reevesdola.com or 202-715-9941.

One of the most vexing aspects of manufacturing firearms covered by the National Firearms Act (NFA) is marking requirements. The NFA and GCA are very specific about these requirements, though the requirements often provided even more confusion. Of particular concern was the issue of weapons ultimately having two or more sets of separately identifying maker names, locations, model names and serial numbers. Certainly, having all of these multiples created logistics problems (marking space on a firearm sometimes being at a premium) and increased confusion for law enforcement when trying to figure out which mark meant what. NFATCA worked with ATF for several years to address this issue and the publication of ATF Ruling 2013-3 was the result. Five-plus years after publication, 2013-3 is still poorly understood, even by some ATF Industry Operations Investigators.

ATF Ruling 2013-3 allows manufacturers to adopt already engraved information on existing firearms. ATF had received numerous inquiries from manufacturers and importers of firearms, plus makers of NFA firearms (makers), asking if they can adopt the existing markings that were placed on a firearm by the original manufacturer. They asked specifically if they may use the existing serial number, caliber/gauge and model already placed on a firearm instead of marking this information on the firearm when they further manufacture or import the firearm. Further, some firearm manufacturers and importers acquire receivers and assemble them into completed firearms for the purpose of sale or distribution. Others, including makers, acquire complete firearms and further manufacture them (such as re-barreling or machining the frame or receiver to accept new parts). In either case, the firearm is already marked with a serial number, original manufacturer’s name, model (if designated), caliber or gauge (if known) and place of origin. Many manufacturers, importers and makers asserted that marking firearms with their own serial numbers, calibers/gauges and models, in addition to the existing markings, is costly and burdensome. They also contended that multiple markings are confusing for recordkeeping and tracing purposes.

ATF agreed with all these premises and published 2013-3 to specifically allow the adoption of existing markings. In doing so, ATF Ruling 75-28 was superseded and ATF Industry Circular 77-20 was clarified. The devil is in the details. Part of 2013-3, at the end, states “…Held further,licensed manufacturers seeking to adopt all of the required markings, including the original manufacturer’s name and place of origin, must receive an approved variance from ATF.” This is the part that has caused and still causes confusion. A marking variance must be obtained if the manufacturer wishes to adopt all of the existing markings and not use/engrave their own name and location. This scenario is exceedingly rare and ATF could not cite a single instance of it during a recent inquiry.

ATF authorizes licensed manufacturers, importers and makers of firearms to adopt the serial number, caliber/gauge and/or model already identified on a firearm without seeking a marking variance, providedall of the following conditions are met:

1. The manufacturer, importer or maker must legibly and conspicuously place on the frame, receiver, barrel or pistol slide (if applicable) his/her own name (or recognized abbreviation) and location (city and state, or recognized abbreviation of the state) as specified under his/her federal firearms license (if a licensee);
2. The serial number adopted must have been marked in accordance with 27 CFR 478.92 and 479.102, including that it must not duplicate any serial number adopted or placed by the manufacturer, importer or maker on any other firearm;
3. The manufacturer, importer or maker must not remove, obliterate or alter the importer’s or manufacturer’s serial number to be adopted, except that, within 15 days of the date of release from Customs custody, a licensed importer must add letters, numbers, or a hyphen (as described in paragraph 4) to a foreign manufacturer’s serial number if the importer receives two or more firearms with the same serial number;
4. The serial number adopted must be comprised of only a combination of Roman letters and Arabic numerals, or solely Arabic numerals, and can include a hyphen, that were conspicuously placed on the firearm; and
5. If the caliber or gauge was not identified or designated (for example, marked “multi”) on the firearm, the manufacturer, importer or maker must legibly and conspicuously mark the frame, receiver, barrel or pistol slide (if applicable) with the actual caliber/gauge once the caliber or gauge is known.

Change can be difficult. Even rulings from more than five years ago still cause issues in the NFA community. We are acutely aware that much of the confusion relating to regulatory oversight of 2013-3 can be resolved with training and education. And that is part of the mission of NFATCA: encouraging and assisting with training and education. If you have questions or comments, send us an email at info@nfatca.org. Or visit us online at nfatca.org or facebook.com/NFATCA.