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Posts Tagged ‘American Suppressor Association’

ASA Statement Regarding Potential ATF Determination On Modular Suppressors

Friday, August 11th, 2017

ATLANTA, GA – Over the past week, multiple claims have stated that the BATFE’s Firearms and Ammunition Technology Division (FATD) is in the process of issuing an industry wide determination on the legality of modular suppressors. After speaking at length to several of our contacts within ATF, ASA has concluded that these assertions stem from misinterpreted comments made by ATF officials at a recent industry conference. According to our contacts at ATF, these are the facts related to three separate areas of discussion:

Modular Suppressor Design – FATD is in the process of reviewing a request from an independent industry representative regarding a single, specific modular suppressor design. The representative is seeking a determination regarding their specific product, not a blanket determination that would apply to other existing modular designs. The issue in question is whether or not the suppressor being reviewed has the ability to assemble more than one functional suppressor out of the component parts that are supplied as a single suppressor to the end-user.

ATF 29P – On May 4, 2016, ATF published an Advance Notice of Proposed Rulemaking (ANPRM) in response to an eight year old request by the National Firearms Act Trade & Collectors Association (NFATCA) made in 2008. In the ANPRM, ATF sought to specify that manufacturers must mark the outer tube of suppressors, not just any externally visible part. The ASA, along with many members of the industry, submitted comments to the ATF opposing ATF 29P. We have been told by ATF that 29P is no longer being worked on by the Bureau, as many current suppressor designs without an outer tube have made the proposed rules within 29P obsolete.

NFA Handbook – The NFA Division and Firearms & Explosives Industry Division are working on a long overdue update to the NFA Handbook. Within the updated handbook, new language will be included that addresses the repair or replacement of modular suppressor components. This language will be consistent with previously published guidance, which states that the serialized component of a suppressor cannot be replaced without the filing of a new Form 2 by the manufacturer, and a new Form 4 by the consumer, including the payment of applicable transfer taxes. Unmarked components of a modular suppressor may be replaced by a licensed manufacturer on a one-for-one basis, just as previously allowed in the silencer FAQ published by ATF on April 17, 2008.

In summation, there are currently no widespread determinations set to be issued by ATF with regards to modular suppressors.

americansuppressorassociation.com

Hearing Protection Act Language Incorporates Into Comprehensive Sportsmens Package

Tuesday, June 13th, 2017

This is some great news regarding the future of removing suppressors from the National Firearms Act. Most of us have heard of the Hearing Protection Act, a bill championed by the American Suppressor Association which seems to have recently lost steam. But, they’ve been working hard behind the scenes to make the language even more effective and to package it into new legislation with more sponsors and additional enhancements for outdoorsmen amd firearms owners.

WASHINGTON, D.C. – The House Committee on Natural Resources has scheduled a hearing for the morning of June 14, in which the Federal Lands Subcommittee will hear a discussion draft of the Sportsmen’s Heritage and Recreational Enhancement (SHARE) Act. The SHARE Act, which is being championed in a bipartisan manner by Congressional Sportsmen’s Caucus (CSC) Co-Chairs Representative Jeff Duncan (R-SC), and Representative Gene Green (D-TX), is a comprehensive package that covers a wide range of hunting, fishing, and outdoor related issues. Included in the legislation is Title XVII, a strengthened version of the Hearing Protection Act.

Since the re-introduction of the Hearing Protection Act by Rep. Duncan and Senator Mike Crapo (R-ID) in January (H.R. 367, S. 59) the American Suppressor Association (ASA) has met with the Bureau of Alcohol, Tobacco, Firearms and Explosives (ATF) on multiple occasions to discuss technical amendments to the language. As a result, we were able to create several technical amendments that were incorporated into the current draft of the SHARE Act. These include:

Sec. 1702: Removing suppressors from the National Firearms Act, subjecting them to the same instant NICS background check as long guns, and issuing a refundable tax credit to anyone who has purchased a suppressor since the HPA’s original date of introduction
Sec. 1703: Ensuring that suppressors will remain legal in all 42 states where they are currently legal, after suppressors are removed from the National Firearms Act
Sec. 1704: Preempting states from levying taxes or registration requirements on suppressors. However, this will not make suppressors legal in any state where state law currently prohibits them.
Sec. 1705: Granting the ATF 365 days to destroy all suppressor related records from the National Firearms Registration and Transfer Record (NFRTR)
Sec. 1706: Developing a “keystone part” definition, and requiring that such keystone part is serialized on every suppressor. This will ensure that individual suppressor parts, like pistons and endcaps, will not require serialization.
Sec. 1707: Imposing a 10% Pittman-Robertson excise tax on the manufacture of each new suppressor, a tax that is currently imposed on all Title I firearms

“The inclusion of the Hearing Protection Act in the sportsmen’s package highlights the commitment of the Sportsmen’s Caucus to make the hunting and recreational shooting experiences safer and more enjoyable for all,” said Knox Williams, President and Executive Director of the American Suppressor Association. “We know for a fact that exposure to noise from recreational firearms is one of the leading causes of hearing loss, which is why the CDC, NIOSH, and the National Hearing Conservation Association (NHCA) have all recommended using suppressors as a tool to mitigate the danger. We look forward to working with the Sportsmen’s Caucus to make this legislation a reality.”

Suppressors have been federally regulated since the passage of the National Firearms Act of 1934. Currently, prospective buyers must live in one of the 42 states where they are legal, must send in an application including fingerprints and passport photos to the ATF, pay a $200 transfer tax, and wait for an indeterminate amount of time for the ATF to process the application. As of June, 2017, wait times are in excess of 10 months. In stark contrast, many countries in Europe place no regulations on their purchase, possession, or use. This legislation will remove suppressors from the onerous requirements of the NFA, and instead require purchasers to pass an instant NICS check, the same background check that is used during the sale of long guns. In doing so, law-abiding citizens will remain free to purchase suppressors, while prohibited persons will continue to be barred from purchasing or possessing these accessories.

To voice your support for the Hearing Protection Act, visit www.HearingProtectionAct.com.

CDC Study: Use Suppressors To Reduce Noise Exposure

Tuesday, January 24th, 2017

The American Suppressor Association shared this press release with us. Anti-2A organizers have long wanted to use the Center for Disease Control and Prevention as source material to curtail gun rights. However, this report doesn’t follow their expected narrative.

The question of increased access to firearms Suppressors is indeed a public health question. Their implementation as a standard, over-the-counter device would not only help preserve the hearing of gun owners, but also their dogs used for hunting as well as nearby livestock and wildlife. Additionally, the use of suppressors would lower the profile of firearms ranges and lead to a decrease in spurious nuisance complaints.

Finally, with an increased market size, prices will come down and technological innovation will increase. Military and law enforcement will benefit from this boon, better protecting those serving, as well as the public.

With the reintroduction of the Duncan-Carter Hearing Protection Act, suppressors have been thrust to the forefront of the national political debate. According to many traditional gun control advocates, firearms are not loud enough to cause hearing damage. They make definitive statements, like this one from a recent LA Times article, that, “there’s no evidence of a public health issue associated with hearing loss from gunfire.”

To this end, they could not be more wrong.

In a study from 2011 entitled Noise and Lead Exposures at an Outdoor Firing Range – California, researchers from the Centers for Disease Control and Prevention (CDC) found the following (see page 5):

“THE ONLY POTENTIALLY EFFECTIVE NOISE CONTROL METHOD TO REDUCE STUDENTS’ OR INSTRUCTORS’ NOISE EXPOSURE FROM GUNFIRE IS THROUGH THE USE OF NOISE SUPPRESSORS THAT CAN BE ATTACHED TO THE END OF THE GUN BARREL. HOWEVER, SOME STATES DO NOT PERMIT CIVILIANS TO USE SUPPRESSORS ON FIREARMS.”

If you still don’t believe that hearing loss is a public health issue associated with gunfire, and that suppressors help hunters and recreational shooters reduce their exposure to dangerous noise levels, there is likely nothing that we can say that will change your mind. Just know that the correct term for your opinion is willful ignorance.

Full CDC Study: CDC Study – California Firing Ranges

ASA Announces Reintroduction Of Hearing Protection Act: A Bill To Remove Suppressors From The NFA

Monday, January 9th, 2017

WASHINGTON, D.C. – The American Suppressor Association (ASA) is pleased to announce the reintroduction of the Hearing Protection Act (HPA) by Rep. Jeff Duncan (SC-03) and Rep. John Carter (TX-31). This historic piece of legislation, which was originally introduced by Rep. Matt Salmon (AZ-05) in the 114th Congress, will remove suppressors from the purview of the National Firearms Act (NFA), replacing the antiquated federal transfer process with an instantaneous NICS background check. The HPA also includes a provision to refund the $200 transfer tax to applicants who purchase a suppressor after October 22, 2015, which was the original date of introduction.

“The American Suppressor Association believes that citizens should not have to pay a tax to protect their hearing while exercising their Second Amendment rights,” said Knox Williams, President and Executive Director of the ASA. “We are thrilled for the opportunity to work with Representatives Duncan and Carter, who have reintroduced the Hearing Protection Act in this new Congress. Although we recognize that introducing this bill is the first step in what will be a lengthy process to change federal law, we look forward to working on the Duncan-Carter bill, alongside the Congressional Sportsmen’s Foundation and the NRA to advance and ultimately enact this common- sense legislation.”

Also known as silencers, suppressors are the hearing protection of the 21st century sportsman. Despite common Hollywood-based misconceptions, the laws of physics dictate that no suppressor will ever be able to render gunfire silent. Suppressors are simply mufflers for firearms, which function by trapping the expanding gasses at the muzzle, allowing them to slowly cool in a controlled environment. On average, suppressors reduce the noise of a gunshot by 20 – 35 decibels (dB), roughly the same sound reduction as earplugs or earmuffs. In addition to hearing protection, suppressors also mitigate noise complaints from those who live near shooting ranges and hunting lands.

Unfortunately, suppressors have been federally regulated since the passage of the National Firearms Act of 1934. The NFA regulates the transfer and possession of certain types of firearms and devices, including suppressors. Currently, prospective buyers must send in a Form 4 application to the ATF, pay a $200 transfer tax per suppressor, undergo the same background check process that is required to purchase a machine gun, and wait months for the ATF to process and approve the paperwork. In stark contrast, many countries in Europe place no regulations on their purchase, possession, or use.

The Duncan-Carter Hearing Protection Act will fix the flawed federal treatment of suppressors, making it easier for hunters and sportsmen to protect their hearing in the 42 states where private suppressor ownership is currently legal, and the 40 states where hunting with a suppressor is legal. This legislation will remove suppressors from the onerous requirements of the NFA, and instead require purchasers to pass an instant NICS check, the same background check that is used during the sale of long guns. In doing so, law-abiding citizens will remain free to purchase suppressors, while prohibited persons will continue to be barred from purchasing or possessing these accessories.

www.AmericanSuppressorAssociation.com

American Suppressor Association Hires Owen Miller As Director Of Outreach

Thursday, October 13th, 2016

WASHINGTON, D.C. – The American Suppressor Association (ASA) is pleased to announce the hiring of Owen Miller as the ASA’s new Director of Outreach. In this position, he will be responsible for a host of initiatives for the organization as they relate to interaction with the Association’s membership base. This includes responsibility for member engagement, outreach, and retention; new member recruitment; customer service; and compliance inquiries from members. He will begin work immediately.

“We’ve known for quite some time that in order to grow the Association we would need someone focusing on our members fulltime,” said Knox Williams, President and Executive Director of the ASA. “Owen was an ideal candidate for this position and we know that he’s the right guy to get the job done. Not only is he personable and professional, he also brings a decade of knowledge from his time in the suppressor industry to the table. We are incredibly thrilled to have him join our team. Simply put, there is no other person that we would rather have serving as the face of our Association to our membership base than Owen.”

With over 10 years of experience at Gemtech World-Class Silencers, Miller is no stranger to the suppressor industry. In his previous position, his responsibilities ranged from sales to customer service to compliance. Miller has also served on the Board of Directors for other non-profit organizations, assisting with training, leadership and fundraising efforts. His skills in those fields will be an asset to the ASA.

“This is an exciting opportunity for me to take my passion for suppressors, and my experience from a decade at one of the premier suppressor companies, and utilize those skills to support the entire industry,” said Miller. “I am looking forward to working with our members to make sure their voice is heard through the ASA, and to effect positive change for other suppressor enthusiasts like myself. Knox Williams, and the ASA have done an incredible job of advancing suppressor legislation at the state and national levels since its inception, and I look forward to making sure our membership and the industry as a whole are engaged with the Association moving forward.”

For more information on how you can join the ASA, and help protect and expand your right to own and use suppressors, please visit www.AmericanSuppressorAssociation.com.

ASA Range Day – Daniel Defense 32 Round Magazine

Thursday, May 19th, 2016

Although it is seeing its industry debut at the NRA Show this week, the new Daniel Defense 32 Round 5.56 Magazine will be available in stores the second week of June.

www.danieldefense.com

Support the Hearing Protection Act

Thursday, February 4th, 2016

As SIG SAUER’s John Hollister says, “Do it for the children.”  The Hearing Protection Act of 2015 (H.R. 3799) would remove suppressors from the National Firearms Act.

Let your voice be heard, but not your firearms.

americansuppressorassociation.com/hearing-protection-act

Chief Law Enforcement Officer Certification To Be Removed From National Firearms Act Transfers

Tuesday, January 5th, 2016

Yesterday, the BATFE issued their ruling on the so-called 41P Notice of Proposed Rule Making regarding NFA transfers. Timing of the release was critical to ensure it was ready for President Obama’s announcement today of anti-2A Executive Action. 

I was up into the wee hours reading this 248 page ruling. I was also on the phone with the ASA so kudos to them for getting this together. While the dreaded CLEO signature is indeed gone, it’s bittersweet. Corporations which own NFA items in particular are going to have a rough time dealing with the new regulatory requirements. And, use of a trust will become equally painful. Additionally, I’m not comvinced the change in the CLEO’s role in this process is enough to prevent reluctant CLEO’s from holding up transfers. At any rate, I expect this to cuase a panic buy of NFA items as we have 180 days from the time this change is published in the Federal Register until it takes effect.


I urge you to read the entire ruling because it references the thousands of comments the government received when it opened the proposed rule change up. www.atf.gov/file/100896/download

Written by ASA on January 5, 2016
WASHINGTON, D.C. – On Monday, January 4th, the Obama administration issued the final rule for Docket No. ATF 41P, the Notice of Proposed Rulemaking (NPRM) published on September 9th, 2013. The final rule has multiple provisions, most notably the elimination of the CLEO certification requirement for all NFA applications. The NPRM initially sought to amend the making and transfer process for National Firearms Act (NFA) firearms by extending the Chief Law Enforcement Officer (CLEO) certification requirement for all NFA transfers to private persons, including those conducted by a trust or legal entity. Had this measure been enacted as drafted, it would have resulted in widespread de facto bans of NFA items in jurisdictions where CLEOs refuse to sign applications. To prevent this scenario, the American Suppressor Association (ASA) rallied the suppressor community by leading the charge to submit comments in opposition to the proposed rule. In all, over 9,500 comments were submitted to the Federal Register, virtually all of which opposed the proposal to expand CLEO certifications.

“Since the announcement of ATF 41P, the American Suppressor Association has spearheaded efforts alongside partner organizations on the State and Federal levels to block the expansion of CLEO certification requirements,” said Knox Williams, President and Executive Director of the ASA. “For the first time in 82 years, local law enforcement will no longer have de facto veto power over any NFA applications. While their inclusion in the process made sense in 1934, before background checks, or even computers existed, the removal of this antiquated measure from the NFA process is a major victory for the suppressor and NFA communities.”

In addition to removing the CLEO certification requirement, the rule creates a mandatory CLEO notification process, and establishes a definition for the term “responsible person” in relation to NFA trusts and legal entities. It also requires that the trust or legal entity provide complete proof of existence, and that all responsible persons associated with the trust or entity submit photos and fingerprint cards with each NFA application, unless the applicant entity has had an application approved within the past two years, and has had no change in structure or personnel. The final rule will not apply to pending or previously approved applications, and is set to take effect 180 days after it is published in the Federal Register. This will occur on or near July 2nd, 2016.

Although the elimination of the CLEO certification requirement is a victory for the suppressor community, the ASA still believes that suppressors should be removed entirely from the NFA. To accomplish this goal, we are working closely with Rep. Matt Salmon (AZ-05) to pass the Hearing Protection Act (H.R. 3799, S. 2236). The HPA will remove suppressors from the onerous requirements of the NFA, and instead require purchasers to pass an instant NICS check, the same background check that is used during the sale of long guns. In doing so, law-abiding citizens will remain free to purchase suppressors, while prohibited persons will continue to be barred from purchasing or possessing these accessories. To contact your legislators in support of the HPA, please visit our Hearing Protection Act legislative contact form.

www.americansuppressorassociation.com