More discussion on the ATF and Fire Marshal rulings

Hatcher's Armory
#1

Hi Kris,

I have no fear of dealing with the ATF. In fact I’m finishing up and firing a municipal pyrotechnics display this evening. This means pulling inventory for the ATF certified magazine, filling out all logs, placarding and moving explosives, pulling permits and insurance, following all safety regulation, then if product doesn’t fire, repacking it up, logging it back into the magazine. It isn’t that bad dealing with the ATF.

As for Hatcher’s I have a friend that is willing to be a ATF license holder for DMS, given I can actually get what was discussed at the meeting rather than a shotgun blast of ATF ruling without context. But, this request has gone without response.

But, Life is life, I’ve moved on and learned from the experience. I know the gate keeper have seen my messages and chosen to ignore them.

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I'm stepping down as chair of Hatcher's Armory
I'm stepping down as chair of Hatcher's Armory
We're ALL adults
#2

My point was less regarding your willingness to deal with the ATF, and more the relative difficulty getting clear information on how to minimize the risk of organizational and personal liability by setting and enforcing compliant policies within DMS. Apologies if I’ve misspoke or incorrectly perceived the situation.

Legendary as ever, thanks Stan.

#3

@Nick

You are dealing with the ATF for a tightly controlled operation. You have direct supervision of the aspects and the training to handle it. How would this apply if scaled to 1800 people of DMS wanting to do this? We don’t have any staff.

I really like the idea of being licensed. But I think many are just tired of dealing with the subject ATM. They just want something that will not get us in trouble. We still have a ways to go in finding a good place within the laws and rules and what will work for us in the long term without having to watch everyone tightly AND give us the most freedom.

Are you sure they know what they will be getting into?
Can they supervise potentially 1800 or more people as we grow? Would they need to?
I’m just not certain how all that could work. Please, help me understand. I would like this, if it could work.

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#4

Indoor range FTW!!! We go to Eagle in Lewisville about 3 times a month. Nick, thanks again brother. 2nd amendment rights are very near and dear to my heart. And this MESS with Hatchers is once again one of the MANY reasons I decided to suspend my membership. Look forward once again to meeting everyone on the 10th. Guess we will find out who the REAL trolls are then.

#5

First off, we need to stop over stating the problems here. We will not be dealing with 1800 user right out. more than likely the group doing anything gun related will be less than 200 for years. We can do thing to control access as there will be a needed level of trust. The issue isn’t needing someone on sight, we have cameras for documenting use. We would just need to setup systems and practices to make sure we are doing the proper logging. People that violate our rules and the law would be handled accordingly to protect the group as we should always do.

Secondly, I’m not pushing for the manufacturing of firearms, I never have pushed for this. I want to reload and teach hands on classes, I want want to teach non-nfa firearms modification and have the tools needed, This is installing a lighter trigger, fitting new furniture, adding sight, ect. Lastly, teaching the function and use of all the parts of the firearm. So you know how these things work and have competence at using them.This is what I wanted Hatcher’s to be.

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#6

Alright, I can see that.

No one wants to watch hours upon hours of footage, just ask @heyheymama and in low resolution it would be very hard to pick out someone doing things.

I think people fear the penalties for the space if we don’t do what is proper all the time. I think there is still alot of fear/caution around this topic because of the visit from the ATF and not wanting to become an ATF “customer”. What I am wanting is everything to cool down a bit and find things we can work on now and become active as a committee. We then we can explore all of the options a little at a time. Rules can be changed and exceptions can be made as ideas come to light. You are helping in this. It is going to take some learning and thinking through for people.

What I have been told by the board members is that any modification of a firearm is considered manufacturing by the ATF if done at a place of business such as DMS and requires a license . Even removing a scratch from a gun with sandpaper is considered manufacturing. This is what I have been told.

We can teach some of this stuff but not hands on. There will be an exception proposal for gun cleaning going through soon, I think. This will allow the disassembly and reassembly of a gun. We may be able to show what needs to be done with a real gun. Just not do it or allow other to do it on site.

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#7

These points contradict themselves. in the perspective of both the DMS and the ATF as you have shared them. If the ATF and DMS considers assembling a gun at a business (the DMS) as manufacture of that gun, then you can not disassemble and reassemble the gun at a business (the DMS), because the point by which you are reassembling the gun, you are now manufacturing it by the example you gave.

How can their be an exception made if that is the understand that you have?

There is no room in that opinion for disassembly, cleaning, or maintenance of any firearm at DMS in there. Especially, if buffing out a scratch is considered manufacture. This is just an absurd standard that is unable to be followed and still allow any thing around firearms beyond watching youtube videos and talking. I’m not arguing if it is legal, because it doesn’t have to be legal the DMS can make the rules it wants.

#8

I know it is strange and it might not make much sense. But it is my understanding that the agent did say gun cleaning wasn’t manufacturing. You have to disassemble the gun at least part way to clean it. It is the adding new parts, changing the parts or removing parts that is the issue. As long as you put it back together with all the same parts minus the dirt, it is cleaning not manufacturing.

You can’t come in with parts and assemble a gun. You have to take it apart and then put it back together with all the same parts.

#9

Is there a recording of what the agent said or any record of that conversation? I’d like to see/hear first hand instead.

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#10

No, there isn’t. There might be security video footage, IDK. She was here because she wanted to be here and not because she was told to come here. She wanted to inform us. It was not an ATF come down on you session but rather here is some friendly advice. “Don’t become an ATF ‘customer’.” was one of the things she said.

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#11

@Nick,

I’m surprised that the BOD is considering allowing people to teach gun cleaning classes at DMS.

Before the latest ATF shutdown we were shut down by the fire marshal and I thought that he prohibited ANY gun-related activities at DMS (including gun cleaning classes, teaching, etc.). You were working on getting a consultant to help us overcome that hurdle.

As you remember, I met Kris at Hatcher’s and packed all the dies and loading equipment for offsite storage to prevent anyone from loading at DMS and Hatcher’s still remained closed.

So, once we overcome the ATF issues, I think the first marshal issue still remains.

This is something we should probably discuss on Tuesday as well.

If we get Hatcher’s reopened, I would like to be able to “recycle” brass, even if we still couldn’t load ammo at DMS. And maybe we could get the annealing machine they allocated funds for?

#12

This is one of the exceptions that I hope the committee asks for in its meeting with the BoD.

As long as we aren’t using gunpowder and primers. Kris said she will take care of opening up Hatcher’s Armory with the fire marshal.

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#13

I’ll contact the fire Marshall this week so we can move forward.

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#14

Wow! That’s great news. I hadn’t heard about that development.

So, Hatcher’s should be ready to be reopened, since we have off-sited all the dies and loading equipment.

If you need someone to help move the non-Hatcher’s stuff they have stored there since the shutdown and to get the space organized (again), I’ll be glad to help.

We almost had it usable when we were shut down.

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#15

I supplied materials towards the bench with air lift casters, with the understanding that once construction was complete, I would take back the unused materials. There should be steel C channel that was not used at all, several cut and uncut sections of aluminum extrusion, and channel nuts and bolts. Let me know when to come pick up the unused portion of my donation.

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#16

Who was your understanding with? Was it Nick? I don’t see a problem giving back your unused materials but I am not in charge of it, ATM. I would talk with @Kriskat30

#17

Yes, I believe it was with Nick. Just want people to be aware as access is restored.

#18

Here’s a good channel to get general knowledge about firearms laws.

I recall they had an episode that talks about how the law defines manufacture. It was discussed in the arm brace video iirc.

#19

It might be OK to get a very general idea but take it with a large grain of salt. I would suggest reading the actual documents on the BATFE website to get a more complete understanding.

https://www.atf.gov/rules-and-regulations/rulings

That being said the biggest issue with the BATFE is interpretation of those rulings. Not only can your interpretation be different than someone else’s but the BATFE has different interpretations within its agency.

To air on the side of caution; can I suggest that before any class regarding a firearm takes place have a letter of intent drafted and sent to the BATFE. Detailing the subject, work to be done, and by how many people in each class, having a written response stating it is legal would go a long way if another agent decides to stop by and give their interpretation of the laws.

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#20

Nick did this previously and got clearance from ATF to do the classes in the past which was rescinded according to a previous BOD(?) by the ATF agent’s supervisor; and eventually led to the last ATF visit which no one but the BOD(& person present when it happened) and ATF person that came has details on.
There’s some information but without clear context shared from the visit(therefore really leaving everyone in the dark other than to follow DMS BOD issued guidelines on firearm related classes).

P.S. The guy from that channel is a lawyer and has been campaigning to get elected to the board of the NRA.

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