Oil filter adapters?

[danb35]

Apologies if this has been discussed already--I didn't see any threads on this, but please point me to them if this is old news.

I've seen discussion here about "solvent traps", and how they can easily (and illegally) be used to make a silencer by simply shooting through the oil filter. Today, though, I ran across someone selling an oil filter adapter as a registered NFA item. See the "Econo-can" on http://www.americanspecialtyammo.com/Class_III.html.

My question centers on replacing oil filters. As I understand it, ATF has ruled that silencer parts are themselves silencers, and subject to all NFA requirements. As applied here, I'd think that would mean that the end-user has two options to replace the filters: (1) pay a tax, and wait for a stamp, for each replacement filter; or (2) send the device back to the manufacturer to have the filter replaced. Both are completely stupid, of course, and there's essentially no chance that anyone's going to do either of them, but my question isn't about reality, it's about legality. Is there a legal way for the end-user to cheaply replace the filters? Is there specific ATF guidance on this?

[Bendersquint]

You already know your answer.

(1) pay a tax, and wait for a stamp, for each replacement filter; or (2) send the device back to the manufacturer to have the filter replaced.

[GHEN]

You already know your answer.

(1) pay a tax, and wait for a stamp, for each replacement filter; or (2) send the device back to the manufacturer to have the filter replaced.

Just to add to Bender's post, if my memory serves the manufacturer states on their website that they offer the filter replacement as a service for $25.00.

I know a person that has one of these whom I haven't spoken to in a while but he likes the hell out of his. If you just want suppression and aren't worried about using your sights or other such nonsense it seems OK as long as you remember that the shipping back and forth to the manufacturer regularly could be a hassle.

GHEN

[danb35]

Pretty much what I figured, thanks. A friend says that his SOT says there's a recent ATF ruling indicating that the end-user can replace the filter himself, but neither he nor I have seen a copy of that, and it doesn't sound right to me.

[Bendersquint]

Pretty much what I figured, thanks. A friend says that his SOT says there's a recent ATF ruling indicating that the end-user can replace the filter himself, but neither he nor I have seen a copy of that, and it doesn't sound right to me.

Your friend or more likely his SOT is full of it.

If there was such a letter it would be posted EVERYWHERE as this is a hot topic!

[danb35]

Your friend or more likely his SOT is full of it.

Don't think the friend is; he's a pretty straight shooter. Possible, I guess, that he misunderstood what the SOT said, but that doesn't seem too likely in this case. I know nothing about the SOT in question other than that he seems to be giving out bad info, at least on this subject.

It's interesting to me how much bad legal info gets put out from FFLs/SOTs regarding their own licensed activities. I'd think it'd be very much in their interest to get the law right, but it does seem that a lot of them just don't.

[telero]

It doesn't have to be the original manufacturer that replaces the filter does it? Any 07/02 can change out the filter?

[Bendersquint]

It doesn't have to be the original manufacturer that replaces the filter does it? Any 07/02 can change out the filter?

Any 07/02 can change out the filter.

[ranb]

Are there any metal mesh oil filters out there that would work better than the paper ones? Of so, which ones are metal?

Ranb

[Modeler]

It doesn't have to be the original manufacturer that replaces the filter does it? Any 07/02 can change out the filter?

Any 07/02 can change out the filter.

So then, if a person were to use a 'solvent trap adapter' to legally build an oil filter suppressor on a Form 1 would that person be able to change the filter since they are the maker?

[srs]

It doesn't have to be the original manufacturer that replaces the filter does it? Any 07/02 can change out the filter?

Any 07/02 can change out the filter.

So then, if a person were to use a 'solvent trap adapter' to legally build an oil filter suppressor on a Form 1 would that person be able to change the filter since they are the maker?

Absolutely not! ATF rules state that only a "manufacturer" (07/02) can do that. The Form 1 builder is a "maker", not a "manufacturer".

[Bendersquint]

Absolutely not! ATF rules state that only a "manufacturer" (07/02) can do that. The Form 1 builder is a "maker", not a "manufacturer".

+1

Maker = Approved Form1 holder, one shot deal
Manufacturer = Licensee that is in the business.

[Modeler]

Any 07/02 can change out the filter.

So then, if a person were to use a 'solvent trap adapter' to legally build an oil filter suppressor on a Form 1 would that person be able to change the filter since they are the maker?

Absolutely not! ATF rules state that only a "manufacturer" (07/02) can do that. The Form 1 builder is a "maker", not a "manufacturer".

Right. Which is why I used the term "maker". I'm aware of the difference.

[LawBob]

So, let's say Mr. Small Autorepair Garageman owns a shop (think service station), personally. Has a wall (say, 134) of oil filters.

He form1s one of these oil filter adapters in his name and using the shop address (so his wife didn't find out!) and puts an arbitrary, but convenient oil filter on it when the stamp came back. IT shoots GREAT (for about 24 shots)...

ATF pays him a visit, randomly of course.

Does he have 133 unregistered silencer parts on the wall?

[ranb]

ATF pays him a visit, randomly of course.

Probably not going to happen.

Does he have 134 unregistered silencer parts on the wall?

Nope. A silencer is "any device for silencing, muffling, or diminishing the report of a portable firearm,..." A silencer part is "any combination of parts, designed or redesigned, and intended for use in assembling or fabricating a firearm silencer or firearm muffler, and any part intended only for use in such assembly or fabrication."

Since his oil filters are also oil filters and not intended solely for use in assembly of a silencer, he should be ok. Unless the BATFE shows up and finds those oil filters full of gun powder residue and with a hole in the top he's not going to have anything to worry about.

Ranb

[LawBob]

A silencer part is "any combination of parts, designed or redesigned, and intended for use in assembling or fabricating a firearm silencer or firearm muffler, AND any part intended only for use in such assembly or fabrication."

I don't see the word "solely"

[ick]

Reminds me of a story.

A man approaches an intersection. He rushes ahead since the pedestrian light is flashing. He makes it in time and steps onto the roadway where he is promptly struck by a bus.

"Why didn't you look both ways before crossing?" says a woman that rushes over to the bloody man.

"The law said that I have the right-of-way.... unnnnnngh."

The ambulance arrives but it is too late. The the woman is sobbing but manages to explain the sequence of events and the last words of the dying man.

The paramedic pauses for a moment and considers what has just happened. "He was right," the paramedic says, "but he was still a fool."

I have personally witnessed, in many cities, pedestrians that think the blinking crosswalk somehow makes them invincible.

[ranb]

I don't see the word "solely"

Only is a synonym for solely. I honestly do not think anyone is going to have a problem with their oil filter cans as long as they are registered and don't give anyone reason to believe they're doing any parts replacement without ATF authorization.

Ranb

[LawBob]

I don't see the word "solely"

Only is a synonym for solely. I honestly do not think anyone is going to have a problem with their oil filter cans as long as they are registered and don't give anyone reason to believe they're doing any parts replacement without ATF authorization.

Ranb

"only" only covers second 1/2 of the sentence.


A silencer part is "any combination of parts, designed or redesigned, and intended for use in assembling or fabricating a firearm silencer or firearm muffler[/u], AND any part intended only for use in such assembly or fabrication."

Is an oil filter one of the "parts...intended for use in assembling or fabricating a firearm silencer"?

[Bendersquint]

I don't see the word "solely"

Only is a synonym for solely. I honestly do not think anyone is going to have a problem with their oil filter cans as long as they are registered and don't give anyone reason to believe they're doing any parts replacement without ATF authorization.

Ranb

"only" only covers second 1/2 of the sentence.


A silencer part is "any combination of parts, designed or redesigned, and intended for use in assembling or fabricating a firearm silencer or firearm muffler[/u], AND any part intended only for use in such assembly or fabrication."

Is an oil filter one of the "parts...intended for use in assembling or fabricating a firearm silencer"?

You are right LawBob!

[LawBob]

You are right LawBob!

It depends on what the definition of "is" is, and whether an "Exchange established by the State" actually means an "Exchange established by the State OR the Federal government" even though there is specific delineation within the law as written...