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"Model Designation" for Dead Air Silencers

RedBreast21

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Nov 24, 2020
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Tennessee
TLDR: Dead Air's Customer Service is Miserable rant, and FATF.

I'm not new to the Form 4 and Form 1 Processes. I have over 30 stamps at this point. I made the mistake of venturing out into the Dead Air brand, though, and I've come to regret it. I purchased 3 cans (a Sandman S and a Wolverine in one batch and then the third - a Sierra 5 much later). The first two were filed before the e-Forms, and I'm sitting at 459 days now. I was recently notified by BATFE that both of my forms would need to be resubmitted because the model names were incorrect. The ATF's position is that the models are NOT "Sandman S" and "Wolverine", but instead are the PART NUMBER that is listed on Dead Air's website.

Box 4.d. isn't even always a mandatory field, and it says so in the form 4 instruction ("(4) Item 4d. show the model designation (if any)"). Note also that the instructions for Box 4.d are "Markings AND description" and not "Description of Markings". There is nothing on either Silencer that says "Model: XXXXX", and there is nothing in the instructions that says that the Model is something written on the silencer.

Nevertheless, Dead Air - in its infinite Wisdom - has apparently listed the Model Name something other than "the model name", and instead made the "Model Name" what they list on their website as the Part Number (in the case of the Sandman) and in the case of the Wolverine - NOT the part number (which is just "Wolverine") but instead the "Wolverine PBS-1". Is that hard to follow? I think so, so I've made some graphics (note the portions circled in green, below).

For the Wolverine, Dead Air says that the Model is "Wolverine PBS-1". You might best saying: Yeah, that's what it says right at the top RedBreast, you dummy". Fair enough. . . . but scroll down to the Sandman. The Model is NOT "Sandman" or "Sandman S" - it is instead "SMS762".

When you call Dead Air, they send you into a "full mailbox" and say that if you would like to someone to call you back, leave a phone number and a time. So, I did that. I got an email saying "Our phone lines are down." What a crock of shite. Y'all don't have backup lines, or company cell phones?

So - FATF and FDead Air. These three silencers will be the last I ever purchase from them. Of the 30-ish cans I have, TBAC is the best as far as customer service that I've needed and received. Dead Air is now firmly in the bottom spot.



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Sample size of 1, but no issues with Form 4 on my Sandman S. In the box "MODEL" (4d) is clearly typed "SANDMAN S." Sounds like the ATF being cunts, but at 459 days now you already knew that...
 
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What was on the Form 3?

It should always match the Form 3 (and the Form 2 before that).
In an ideal world, maybe. But, it really shouldn't matter . . . there isn't any part of the instructions that say "Must match Form 3." There's no statutory or administrative law requirement that says there must be continuity. Beyond that, I'm not sure I've seen all of - or even 1/2 of the Form 3's for my Silencers. Although these were on paper forms, nowadays with the e-file and Silencershop kiosks, I'm guessing almost no one sees "their" form 3's.

For argument's sake . . . what if the Form 3 was approved and there's an error in the Form 3? Should the error be repeated? Let's assume that there is "one correct" model name for the Wolverine and it is "Wolverine PBS-1". I refuse to believe that every Wolverine that has been transferred on a Form 3 and then a Form 4 has had "Wolverine PBS-1" on both forms. It simply beggars belief. So - if I'm making the same assumption about the name, and a Form 3 transferor sends it to me, should I repeat the "error"? Nah . . .

I appreciate what you're saying, but the ATF is just being obstructionist. . .I would say pedantic, but they're not even correct about the details.
 
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In an ideal world, maybe. But, it really shouldn't matter . . . there isn't any part of the instructions that say "Must match Form 3." There's no statutory or administrative law requirement that says there must be continuity. Beyond that, I'm not sure I've seen all of - or even 1/2 of the Form 3's for my Silencers. Although these were on paper forms, nowadays with the e-file and Silencershop kiosks, I'm guessing almost no one sees "their" form 3's.

For argument's sake . . . what if the Form 3 was approved and there's an error in the Form 3? Should the error be repeated? Let's assume that there is "one correct" model name for the Wolverine and it is "Wolverine PBS-1". I refuse to believe that every Wolverine that has been transferred on a Form 3 and then a Form 4 has had "Wolverine PBS-1" on both forms. It simply beggars belief. So - if I'm making the same assumption about the name, and a Form 3 transferor sends it to me, should I repeat the "error"? Nah . . .

I appreciate what you're saying, but the ATF is just being obstructionist. . .I would say pedantic, but they're not even correct about the details.
So the issue in this case is that the form 4 says Wolverine PBS-1 and the ATF says it should just say Wolverine? Mine says Wolverine PBS-1 in box 4D.

Additionally, the dealer that sells the suppressor should have a copy of the Form3 on which it was transferred to them, right? The description on that form should match the description from the Form2 that the Manufacturer filed when making the suppressor. The description on the form 4 should also match the form 2 and form3. If these forms do not match, there is a discrepancy. There is nothing more anathema to a bureaucracy than a discrepancy on a form. The ATF has a form for YOUR suppressor filed when it was made. They have a form filed when it was transferred from the manufacturer to the dealer. They are now attempting to reconcile those forms with the form 4 filed when the dealer attempts to transfer the suppressor to you. But, now the forms do not match.

I had a form get bounced back to the ATF because the agent transposed 2 numbers of the serial number when writing it upon the stamp. I had another bounce back because the dealer put the business name (not an individual's name) in the box for name and title of authorized official.

I am going to hazard a contention that whatever the form 2 says for model is the legal designation- whether it be an 'error' or not. I'll let the guys from TBAC, who have already weighed in on this thread, expound further if they care to. The description of that can, attested to by the serial number, should follow that can on all subsequent forms. And, the dealer should have the form 3 with the approved description for that can, which should be entered verbatim on the form 4.
 
Sample size of 1, but no issues with Form 4 on my Sandman S. In the box "MODEL" (4d) is clearly typed "SANDMAN S." Sounds like the ATF being cunts, but at 459 days now you already knew that...

I had no issues with my Nomad. The stamp says Model Nomad-30.
I am literally waiting for a Sandman FDE that I am hoping to get any day. My form says the Model: SMS762-MIL

They have at least three versions of the Sandman S the two OP mentioned plus the Military version which I ordered. I don't find it surprising they all have different model #'s.
 
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I have 3 DA cans. All are phenomenal. Zero issues with filing them and using them. My favorite cans.
 
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Box 4.d. of my Sandman-S Form 4 that has been approved for a LONG time now…

Model is in-fact “SANDMAN S”…

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That being said, if you bought the Sandman-S MIL contract FDE suppressor, the model number is listed as “SMS762-MIL”. I also have one of these…

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I have 4, and had zero issues with the Form 4’s for any of them. My guess is either the dealer fucked up his Form 4, or he’s a troll.
Doesn't need to be an either/or proposition...
 
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never had issues with any of mine (knock on wood) and all but one are DA cans. just make sure it matches the F3 and you shouldn't have issues
 
Same as others have said - this is an ATF problem (surprise). My models are "Sandman-S", "Sandman-K", "Sandman-L", "Wolverine PBS-1" on my approved forms.
 
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This is most likely a DEALER issue. The dealer- most likely- did not copy the info from the form 3 to the form 4 correctly.
 
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