By John Brown
This year, the NFATCA began the process of looking at issues affecting the manufacturer’s community and elected to form an organization dedicated to exploring all of the rules and regulations that drive the manufacturing process; for NFA manufacturing and the regular firearms industry. As most of us know, there are a ton of regulations that affect how any firearm is manufactured, not only by an individual but also by manufacturers large and small. In early 2009, ATF counsel began issuing new regulations that not only caused some pause in the industry but led many of the manufacturers to begin to ask for better clarification and understanding of the language and the proper interpretation. This process actually began at the first manufacturer’s conference that was held in the spring of 2008. The second conference that was held in April of this year not only yielded a higher attendance but saw an amazing collaboration between the industry and ATF. Many questions concerning a variety of issues kept the entire conference buzzing with high energy discussions and commitments from both sides of the aisle to create a new manner of not only understanding regulations but, in many cases, a hard push for changes in regulations that have been in place for many years.
The manufacturer’s conference has been one of the most successful events that have been jointly hosted by the NFATCA and the National Shooting Sports Foundation (NSSF) for two years running. At these conferences ATF personnel have pulled out all of the stops, rolled up their sleeves and worked nose to nose with industry personnel to get to the heart of issues that have caused a lot of turmoil in the manufacturing community.
For example, this year ATF determined that if someone blued or parkerized a firearm, that in itself would be considered manufacturing, requiring the appropriate 07 licensing process and all the bells and whistles requirements of a manufacturer. This announcement created quite a storm in our community and raised a number of real concerns about the need for additional engraving on the firearm to excise tax. To their credit, ATF was willing to listen to these concerns and sit down with industry representatives and see if there were some amicable solutions to the problem. After all, if four or five processes were performed on a firearm by four or five manufacturers, imagine the engraving mess that would occur if all five manufactures engraved the appropriate information on your weapon. Worse yet, if an ATF Industry Operations Inspector (IOI) performed a compliance inspection on your inventory and found all of this engraving, how confusing would that be in your bound book?
Both ATF and the industry realized there could be some major issues created if we didn’t all sit down at the table together and figure it all out. Probably the best suggestion that I heard at this year’s conference was an invitation from Ohio Ordnance for a number of ATF individuals, including counsel, to actually come to a manufacturer’s facility and make a gun, gaining a full life cycle understanding of how the regulations can affect the manufacturing process. By the time you read this article I am certain that the invitation will have been accepted and the actual exercise completed. What a magnificent idea!
As a result of all of the work put forth by ATF and the industry, the NFATCA decided it was time we put together our own set of experts so that we can initiate the process of offering a level of expertise to ATF that had never been collectively put together. That being said the mission of the Manufactures Working Group will be to meet with ATF once a quarter to discuss all aspects of the manufacturing regulations. This working group will focus heavily on industry issues and begin the process of working with ATF to determine the best course of action in resolving any issues that affect the manufacturing community. Collaboration is a wonderful thing and working with a branch of the government that is responsible for enforcing the law and the ensuing regulations from this vantage point makes common sense to everyone. Sit at the table, define the issues of concern, make appropriate recommendations, make the changes or grasp a better understanding and everyone learns.
The Manufacturers Working Group now consists of a core team that will be responsible for defining the mission and selecting appropriate task leaders to take on the multitude of issues facing the industry. Over time, the core team will bring different experts to bear that can make valuable contributions in the exploration of the various issues that either ATF or the industry brings to the table. Simply speaking, many of you in the manufacturing industry will sooner or later be called upon to work with the team and bring your own expertise to the table on some issue facing our community. Similarly, ATF will call on their own experts so that collectively we have all the right people on board to saturate any issues with enough information to make well informed decisions on how to move forward.
If you missed both the 2008 and the 2009 Manufacturers Conference you missed some good information. Missing good information is always a bad thing and we want to make certain that we share that information with you at every opportunity. In future issues of Small Arms Review and in guest articles we will make every attempt to keep you informed on the Manufacturing Working Groups progress. As always, we will also present as much information as possible at the major shows and events.
These are exciting times with much resolution on the horizon. Don’t miss out on being a part of this. Join the only organization in the country that is watching over every single NFA issue possible; and all of this energy, just for you, the NFA owner.
Come join the NFATCA today by visiting us at www.nfatca.org.
|This article first appeared in Small Arms Review V12N11 (August 2009)|