BREAKING: ATF Decides Dead Air Wipes Are Silencer Parts
In a decision that could have broad implications throughout the silencer industry as well as with shooters/consumers, the Bureau of Alcohol Tobacco and Firearms (BATFE or ATF) has notified silencer manufacturer Dead Air Armament that the wipes used in their Ghost M silencer is a silencer part. News came to me from fellow blogger Nathan at ModernRifleman.net, who reported on an informational post on Dead Air’s Facebook page stating the company will discontinue sales of the rubber insert immediately.
Historically, the ATF has viewed wipes made of rubber or other disposable materials not to be silencer parts, making them replaceable by the end user. Replacing actual silencer parts, no matter how small, can only be accomplished by an FFL/SOT.*
* Thanks to the HansohnBrothers.com team for the clarification any FFL can replace wipes, which is fairly significant. Instead of sending your Silencer to an SOT, your local FFL can legally do the replacement.
At this point, it is unclear why the ATF has decided to reverse their opinion on a nearly 20 year old issue. Once used in a variety of now dated silencer designs, the wipe has seen a limited resurgence as of late in modular suppressors and small silencers that require the use of an ablative media (“wet”) for increased noise reduction.
From Dead Air Via Facebook:
Please read regarding Ghost 45M
Valued Dead Air customers, dealers and wholesalers,
Last week, we were notified by the BATFE that they consider the accessory aperture wipe on our Ghost 45M suppressor to be a “silencer” part. We presented them with the Bardwell ATF opinion letter (http://www.titleii.com/bardwell/atf_letter66.txt)* that is commonly used as justification for the use of wipes and replacement of wipes in silencers by their owners. This morning, we were informally notified that the BATFE FTB does not share the opinion of the Bardwell letter regarding wipes not being silencer parts, and asked that we take immediate corrective action. As such we are immediately discontinuing the sale of accessory wipes for that product. The aperture wipe for the Ghost has always been an optional use item. We have consciously decided NOT to pursue the issue with FTB, as the resulting opinion letter, based on the informal notification to us, may have a potential negative impact on ALL owners of suppressors that utilize wipes in the design.
Moving forward we are conducting research on a wipe constructed of a more durable material, that will be included with the Ghost 45M. Extra or additional wipes will not be available for sale. Other options and clarifications are being sought as well.
Dead Air has developed and will release a new linear compensator product for handguns and submachineguns that will lead to cross compatibility with some Ghost accessories, including pistons, fixed mounts and caliber specific caps.
We appreciate the support of our customer, dealers and wholesalers, and will continue to bring innovative, quality products to the market. If there are any questions regarding this issue or any questions about our products, please contact us at info@deadairsilencers.com,
Thank You
Gary Hughes
Director of Sales
Dead Air Silencers
In regard to the two parts in your cited example, we consider a
baffle to be a silencer, but a wipe, which is usually nothing more
than a rubber or plastic disc with a hole in it, is generally not
considered to be a silencer. Thus an individual owner could
replace a wipe.
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Here's hoping the BATFEces unemployment rate skyrockets under President Trump.
"* Thanks to the HansohnBrothers.com team for the clarification any FFL can replace wipes, which is fairly significant. Instead of sending your Silencer to an SOT, your local FFL can legally do the replacement."
Since a wipe is a suppressor part, and therefore a suppressor, and if any FFL is allowed to possess and replace wipes, does this mean that any FFL who is NOT LICENCED TO MANUFACTURE NFA FIREARMS can perform any maintenance on any suppressor?
According to the ATF's April 17, 2008 FAQ, only FFLs licensed to manufacture NFA firearms are permitted to repair silencers.