Come See Us at the Shot Week Supplier Showcase – Booth S2004
Now Expanding to Two Days!
January 22-23, 2018 from 9:00 AM-5:00 PM
Palazzo Ballroom, 5th Floor, Venetian Hotel Meeting Rooms in Las Vegas
The SHOT Week Supplier Showcase is a dedicated event for suppliers to present their products to shooting, hunting and outdoor manufacturers. If you use or produce tools, machinery, plastics, metal extrusions, fabrics, OE materials, fabrication, logistics, software, or other products and services for the shooting sports or outdoor sporting industries, then SHOT Week’s Supplier Showcase is your opportunity to connect with each other at the upcoming SHOT Show.
We will be in booth S2004
Did you hear …
The Bureau of Alcohol, Tobacco, Firearms and Explosives (ATF) is responsible for licensing persons, including Department of Defense (DOD) contractors servicing the U.S. Government, engaged in manufacturing, importing, and dealing in firearms and explosives. ATF conducts inspections of Federal firearms licensees and Federal explosives licensees and permittees to ensure compliance with laws and regulations associated with the firearms and explosives industry. The following discussion of ATF’s compliance inspection process is intended to help Federal firearms or explosives licensees who are DOD contractors prepare for and participate in an ATF compliance inspection, and it should help minimize any intrusion and on-site complications during such inspections.
It is important that DOD contractors understand and are able to articulate the recordkeeping and reporting responsibilities for both DOD and commercial production, variances, product identification and marking standards relative to Defense production and explosives storage requirements to the ATF industry operations investigators (IOIs) at the pre-inspection phase of the on-site inspection.
- The lead ATF IOI generally will contact the licensee’s listed “Responsible Person” or point of contact in advance of an inspection. This contact may be by phone or in person, and it occurs several days before the actual on-site start of the inspection. During the preinspection discussion, the IOI will explain the purpose of the inspection.
- During the pre-inspection contact, the IOI will review the licensee’s business operations, including products, and current licenses and permits. The IOI may request copies of U.S. Government contracts, both primary and secondary contractor information, any issued variances, and other documents relating to the licensee’s operations. This information helps determine the course of ATF’s inspection.
- The licensee should provide the name and contact information of its Defense Contract Management Agency point of contact (quality assurance representative or administrative contracting officer), if any. The IOI will ask the licensee or point of contact about topics that may include: 1) exempted items; 2) commercial products commingled with exempted items and the effect of the commingling on recordkeeping; and 3) registration of certain commodities.
- The licensee should explain DOD security protocols and procedures, including requirements for safety training and access to the facility. For security reasons, ATF will provide the IOI’s personally identifiable information to the DOD representative, and IOIs will not provide the information directly to the licensee. The licensee should provide the IOI with the appropriate contact information for the DOD personnel who will facilitate the IOI’s access to the licensee’s premises.
- The inspection will occur during the licensee’s business hours or at an agreed-upon time.
- The IOI will verify the licensee’s corporate structure and request current lists of responsible persons and employee possessors.
- The IOI will review all Federal firearms licenses and explosives licenses/permits, special (occupational) tax stamps, and any other licenses or permits necessary to operate. If the licensee services a DOD contract, the IOI may ask about the terms of the contract as necessary.
- The IOI will review any variances held by the licensee.
- The IOI may request more specifics on the licensee’s business operations – including information on U.S. Government sales, direct commercial sales (including foreign government sales), manufacturing or importing activities, subcontractors, and shipping procedures – in order to streamline the on-site inspection and make a determination between commercial products and goods destined for DOD use.
- The IOI may request a tour of the facility to become familiar with the location of records, storage facilities, etc.
- If the inspected company is a Federal explosives licensee or permittee, the IOI will request a plat plan. If permissible, the IOI will take photographs to validate the plat plan and table of distances.
- The IOI may request other supplemental records, including Department of Defense magazine information, DODIC numbers, safety data cards, State Department Directorate of Defense Trade Controls registration information, purchase orders, shipping documents, bills of lading, invoices, DSP-5, DD1348 – Issue Release Documents, DD1149 – Requisition and Invoice Shipping Documents, DD 250 – Material Inspection and Receiving Reports, documentation that Certified Statements of Use were provided to suppliers, and other records.
- The IOI will review the licensee’s Acquisition and Disposition Record and related records for accuracy and completeness regarding commercial production. The IOI will also examine the records to verify exemptions. (Manufacturing firearms on behalf of the U.S. Government is not an exempt activity.)
- For firearms manufacturers, the IOI will review the Manufacturer Acquisition and Disposition Record. The IOI may ask to see the annual National Firearms Act (NFA) exemption letter if the licensee is manufacturing NFA weapons for the U.S. Government, and the IOI will validate exemptions if and when applicable.
- The IOI will conduct a physical inventory and reconcile it against the Acquisition and Disposition Record and the Daily Summary of Magazine Transactions, if applicable. This will help the IOI distinguish between Department of Defense exempt products/storage and commercial products.
- The IOI may request documentation to confirm that items are exempt under Title 27, Code of Federal Regulations, Parts 478.141 and 555.141.
- The IOI will request to see any applicable variances for residual completed munitions (e.g., remnants and rejects) that are not part of a U.S. Government contract and are not marked, registered, or stored properly.
- The IOI will review Importer Forms 6 and 6A.
- The IOI will examine NFA Forms 2, 3, 5, and 9 and will compare those documents with the licensee’s Acquisition and Disposition Record and the National Firearms Registration and Transfer Record.
For non-exempt explosives:
- The IOI will review the licensee’s Acquisition and Disposition Record and related records for accuracy and completeness.
- The IOI will conduct a physical inventory and reconcile it against the Acquisition and Disposition Record and the Daily Summary of Magazine Transactions.
- The IOI will inspect explosives storage magazines and process buildings.
- The IOI will verify that products originally manufactured as explosives and then manufactured into a destructive device appear in both the explosives and firearms Acquisition and Disposition records or records of manufacture. The IOI will also verify commercial markings and markings pertaining to a DOD contract.
- The IOI will request to see applicable variances for residual completed munitions (remnants and rejects) that are not part of a U.S. Government contract and are not marked, registered, or stored properly.
The IOI will hold a closing conference with a Responsible Person to discuss inspection findings. If violations are found, the IOI will issue a Report of Violations and discuss it with the licensee.
3rd Quarter 2017
In This Issue:
+ Come See Us at the Shot Week Supplier Showcase – Booth S2004
+ The Next Generation of Easy Bound Book Lite is here .. and it’s web-based!
+ Did you hear … DOD Contractor Inspections: ATF Inspection Process
+ Atlantic Firearms ATF Audit
+ Fire, floods, hurricanes … oh my! How to protect your Bound Book records
The Next Generation of Easy Bound Book Lite is here .. and it’s web-based!
The latest version of Easy Bound Book Lite still provides the same great features such as audit trails, integrated best practices, bulk serial number processing, same great reporting features and more. The only change is that it is now web-based, instead of installed on your computer or server. This makes updates to the software instant and your Easy Bound Book solution is now available from any device. But don’t worry, all the data is secure.
We have clients that have already made the move, and they love the accessibility, data security, and instant access to software updates. If we haven’t contacted you to make the move yet, don’t worry – we will. And if you aren’t an Easy Bound Book user yet, now is a great time to take a look at Easy Bound Book Lite!
Atlantic Firearms ATF Audit
A few months ago we shared our latest Easy Bound Book success story with you on Atlantic Firearms. A few weeks after that, they were audited by the ATF. According to a company Responsible Party, “The audit was spotless with zero violations. The ATF came in on Monday with three agents and scanned all 6,000 firearms in inventory in two days (with a little help from our staff). They were validating data on Wednesday morning. The whole audit was wrapped up with the final closing conference on Friday. The last audit, before barcodes and Easy Bound Book, took five agents three weeks to enter all the physical inventory serial numbers, then another week with three agents to complete the audit to the final closing conference on the fourth Friday. The ATF IOIs were very happy.” All in all, it only took 15 man days with Easy Bound Book inventory reconciliation and scanning compared to 90 man days and four weeks of IOIs in the warehouse when done manually. This is a significant reduction in business impact and the hazard of having visitors in the warehouse. That is an 83% reduction in man hours and a 75% reduction in business impact.
Fire, floods, hurricanes … oh my! How to protect your Bound Book records
In September, the ATF issued a News Release in advance of Hurricane Maria providing guidance on disaster preparedness for FFLs. Specifically, they stated that “a disaster preparedness plan should be established by all FFLs to safeguard their businesses by protecting required records. If necessary, licensees should take precautionary steps by contacting their local ATF field offices regarding the removal of records including ATF Forms 4473 and 3310.4; and acquisition and disposition records from business premises to a safe location.”
Of course, hurricanes are just one of the many natural disasters to affect the U.S. in 2017. With fires and floods ravaging the South and West, we’ve seen that time isn’t always available to make disaster preparations.
One way to protect your FFL bound book records is with a hosted version of Easy Bound Book. With Easy Bound Book “in the cloud” – all the EBB data is stored off site and can be accessed from anywhere internet is available.
Don’t be caught off guard and don’t risk losing your records. Talk to us about moving to EBB hosted before the next disaster strikes.
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Minneapolis, MN 55433-5644
Phone: (763) 571-8580
Toll Free: (877) 571-8580
Fax: (763) 571-5504