When do you mark the tube.

[BWE Firearms]

I have been told that I have to mark the tube as soon as I get it if I intend to use it to build suppressors. I have also been told it doesn't have to be marked until it is ready to go out the door and everything in between. I make a habbit of marking my tubes at the point I can assemble them into a complete working suppressor. At my last inspection I was told I had to mark all the DOM tubing I had in my shop. I asked what I would do once I started buying tubing in 12' lengths and was told it would have to be marked rite away. That would create all kinds of problems since I use only a few sizes of tubing but different lengths and calibers. I realy dont know what length or caliber suppressor a peice of tubing is going to be until I make the suppressor. I am not a production shop, I build suppressors as people order them and build them how people want them. During my inspection I marked a couple of peices of tubing to make the inspector happy then took all the rest of the DOM tubing I had as well as any pipe I had and stuck it in my van so it wasn't in the shop. Out of sight out of mind. I know the bid suppressor manufacturers dont mark there raw material as soon as it comes in the door because I have seen it sitting in the storage racks.

I was also told that I had to mark all the baffles I made after the inspector saw a box of K baffles I had sitting there. As far as I understand the rulings baffles only need to be marked and registered if you are selling them sepperately and not as a finished suppressor. I know that Gemtech does not mark the baffles in their Alpine suppressor because I had one in for transfer during my inspection and showed it to the inspector.

Is there something that can be done so everyone at ATF if quoting the same rules.

[ExecDirector]

The problem is that the IOI's are not always up on what the rules are, especially if they are not dealing with this stuff on a regular basis. For instance, the bit about marking the baffles is pure BS. Even when acquiring baffles from contractors:

7.4.6 Marking silencer parts. Some FFLs/SOTs assemble silencers, for subsequent sale, from parts acquired from their contractors (NOTE: this activity is the “manufacture” of NFA firearms requiring the assembler and the contractor to qualify as manufacturers under the GCA and the NFA). Under these circumstances, ATF takes the position that contractors are not required to place identifying markings on silencer parts. They may, however, place an assembler’s markings on these parts if the assembler so desires. It should also be noted that these contractors are not required to register the parts they produce by filing Forms 2, nor are they required to obtain approved Forms 3 to transfer the parts to assemblers.

From the NFA Handbook, no less.

I do not believe that there is an official policy as to when the tubes should be marked, but will ask.

[ExecDirector]

What is likely happening here is that the IOI is incorrectly attempting to apply Ruling 2012-1, which is a recent publication. 2012-1 does NOT apply to NFA, though. Still digging.

[BWE Firearms]

This is what really irritates me dealing with ATF. It doesn't matter which group I deal with most of the time I have to teach them what is legal and what is not especially with the Uzis before they can answer my question. It just kills me that I have to know every federal firearms law as well as just about every state firearms law since there is only a couple of states I do not have customers in, yet the people who are supposed to be regulating it are not required to know any of the laws. Down here in Florida there is Class 2 manufacturers everywhere especially in this ATF district.