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Interview from the Firing Range Virtual Summit: FFL Consultants – ATF inspection activities & the new Form 4473

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In this session, JB & JC with FFL Consultants will be covering the critical moves for FFLs to successfully optimize firing range and retail operations through uncertain times.

Although we have partners within the political community, we have insights from the National Shooting Sports Foundation. Right now, we’re all in the same place; we just don’t know. Of course, we’re hoping for many positives.

The first thing everyone’s asking about is assault weapons, will there be a ban?

We know there was a ban in the last Administration. High-capacity magazines are definitely on the Harris agenda. So we know that will be an issue on the table. Firearms surrender and enforcement is talked about all the time. What happens if there’s a ban? Who will enforce the ban, collect firearms… States across the country are adopting Private-party sales. This could sound like a negative, but the real positive is that it brings more business to every gun dealer who can do a private-party transfer.

We have red flag laws being adopted by communities across the country. Laws are being implemented everywhere that penalize lawful gun owners when their firearms are lost or stolen, and they have to report it to the local jurisdiction. That’s not fair. We’ve seen the recent issue with the Honey Badger… they were given a 60-day stay, but there will be some fallout on this for all AR pistols and other NFA-type weaponry. And ATF inspections, are they on the rise? Will they continue to be postponed? We have seen an increase in inspections relatively recently. We can only expect the rise to continue.

Let’s talk about ATF inspection activities and what’s on the table. So, first of all, it’s important to note that inspections are starting to occur again. It comes down to what state you’re in and the conditions in that state. So you have to pay attention to that to see if they’re willing to make their way out again.

And they are playing catch-up. They have many things to catch up on. First of all, they had an entire plate of inspections that were scheduled previously. In addition to that, they have a requirement to get out to all the new licensees. So, anybody who recently applied for a license and was approved during the pandemic can expect a site visit, initial interview, and inspection. So results are pretty much 50-50. We’ve had about 30 or so clients that have received audits so far around the country. Warning conferences are still occurring during the pandemic phase

We have a good relationship with the ATF, so we like to make sure that the FFLs that we support are doing things the right way and ensuring that they’re going to be good to go the next time they get inspected. So let’s talk about what causes an inspection. You have the random inspection that occurs; basically, if you haven’t been inspected in a while. But more importantly, if you’re an FFL or a firing range FFL, and you see a lot of denials, a lot of individuals coming in who have been denied for a transaction to purchase a firearm, that could be an indication that somebody’s targeting you to attempt to buy a gun. One thing we’ve heard a few times now, that we need to be careful when it comes to those individuals that are targeting you to attempt to purchase a firearm; don’t let them walk in and say, “Hey, I just want to see if I can pass a background check.”

That’s a huge red flag. There needs to be a genuine intent to purchase a firearm. The other one is trace requests. If you’re receiving an excessive amount of trace requests, it’s important to pay attention to that and see what’s going on. And then just your overall quantity of NICS or point-of-contact state background checks. If you’re processing a lot of guns, you may show up as a potential target of inquiry; “Hey, we want to take a look at that FFL and see what’s going on there.”

The random inspections are a lot fewer than the rest. Suppose you’re an FFL with a lot of denials – there’s going to throw up a flag.

The things that you need to pay attention to every day; 4473s, your transfers, that’s private party transfers, your FFL-to-FFL transfers, etc. Your A&D logbooks. We have training guides for all of this, and we’re going to make those available to you. So SOPs for critical processes. If you’re a one-person shop or a husband and wife team, it may not necessarily be needed. But if you’re operating a store that has any number of employees, you need to make sure that you have your processes, procedures, and practices documented so they have a point of reference to reference. That’s vitally important. We’re finding that ATF is liking when FFL’s have documented procedures outlining what their employee base is supposed to be doing.

We’re going to talk about double and triple checks. If you’re, again, that one-man-shop or a husband and wife team, maybe a double check’s all you need. But we highly recommend double checks at a minimum. Triple check if you’re processing a lot of firearms. You may want to have that third set of eyes on it at the end of the business day just to make sure everything’s good to go before you file that 4473. Warnings and revocations, we help a lot with warnings and revocations. The warning conference or warning letter is your first indication that you’re on your last step. You’ve got one more chance, and you need to take that seriously. And that’s where those corrective action plans come in. And revocations, that’s serious. You’re going to lose your license.

And that’s where our partner law firms and we come in. We take a look at what’s going on to determine things like willful negligence, and we work with you to figure out if there’s a remedy to the situation that works. The important thing here is at any point throughout your business operations, if you’re sitting back thinking to yourself, “I don’t know if that’s right. I don’t know if I have the right processes in place.” Pick up the phone and call us. Just schedule a call with us. We’re happy to talk to you.

Regarding that warning and revocation piece, what we’ve seen is that once you get that first warning letter, you’re on a list. The ATF is not going to forget about you for quite a while. You talk about reinspections and revisits. That’s one of those triggers that keep you on a list that if you had a bad visit this year, you’re most likely going to have a visit next year. I would tell you between 12 and 24 months is a certainty.

Let’s talk about inspection prep. It’s vital to keep this in the back of your mind that there’s the potential that every 12 months, the ATF can come in and inspect you. That’s by law. They’re authorized to do this. And the frequency of that happening is difficult to estimate. If you have had an inspection and had a pretty lengthy report of violations, received a warning letter or warning conference, make sure that you’re continuously monitoring all of your business activities, paperwork, your A&D records, etc.

So one of the things that I’ll tell you as far as preparation, expect that the ATF will do is that one-year look back. They’re going to go back to the trailing 12 months, review your 4473s, review your denials, review your 3310s, review your NTN reports, and they’re going to bring an NTN report with them. They’re going to verify that for every NTN number you were issued for the sale of a firearm before denial, that there’s an ATF form 4473 present for that transaction. So keep that in mind. They’re going to do an all firearm inventory, and they are going to verify gun-to-book, book-to-gun, and they’re going to do a complete and thorough A&D review. This could include several IOIs in your premises for a week, maybe even two weeks, depending on what your firearm inventory looks like. Finally, they’re going to go through all your ATF form 4473s for at least the last 12 months. So be aware that paperwork is vitally important to your business and is vitally important to pass an ATF inspection successfully.

Next, they’re going to do those employee interviews and observations. We do all of these things on our mock inspections. And I will tell you right now, and we do a lot of corrective action right on the spot with the FFL employees. The ATF will be monitoring how transactions are processed to see how you’re qualifying customers. Lastly, when the inspection is done, they’re going to do that closing conference, and they’re going to walk you through all of their findings. Now, they’re going to allow you to ask questions, give responses, and even dispute things. We want you to be cordial with the ATF. They’re not your enemy. They have a job to do. It goes a lot easier if you’re not adversarial. I sat in on a couple of the closing conferences recently with our clients, and most of them, for the most part, have gone pretty smooth.

One thing to consider is whether or not this is in a random audit, “We haven’t seen you in five years or three years.” Or if this is a visit resulting from a bad visit last year. And I have to say, there are specific indications, whether it goes one way or another. Suppose you get the same inspector there last year on your inspection that didn’t go so well. In that case, you can almost assume it’s going to be somewhat of a little bit of stress going through another review with them again, especially if you haven’t corrected all of the items they documented explicitly in that last report of a violation.

We can’t reiterate enough how important it is to be cordial, inviting, and collaborative during that inspection. It’s vital to have that corrective action plan. Take that report of violations, sit down with each violation, and map out corrective action for each violation. I will tell you the vast majority of FFLs that we support find that to be very, very helpful for them and their staff. So they know. Because that IOI will come back in, and they’re going to bring that report of violations that you had. And they’re going to make sure every one of those things is corrected. So it’s vitally important to take that seriously.

We help gun dealers with FFLs to create that corrective action plan, not only does it get submitted to the ATF, but they review it. And the biggest challenge is you, as a gun dealer implementing it. And that’s where we follow up on our monthly calls with our clients. We must go through that action plan with you and make sure you’re doing what you said you would do.

So let’s go through the top violations from our team visits. This list may not precisely align with what the ATF is publishing, but here’s what we want to reiterate with you right now to get ready for your next inspection. The ATF will verify, inspect and make sure transfers are done correctly. So we want to start by saying that every box counts. It’s not a matter of how many 4473s I had incorrect. The report of violations will list each box online on your form incorrectly completed, missing information, etc. So every box counts, and that’s good training for your employees.

Next is legibility. If the ATF inspector cannot read or decipher a number on a serial number, that will be a problem. So we urge you to make sure your staff is using good penmanship, printing correctly, taking their time, and make it readable.

Remember, these forms will last a lifetime of the firearm for tracing purposes for at least 20 years. And that’s the big concern with Legibility. These forms have to be able to be read 10, 12 years down the road. If that firearm ever shows up in a criminal situation, it has to have a trace done. Next, we find invalid and expired IDs being used all the time. We urge you that if you’re accepting invalid or expired IDs, that they are noted as such in box 31 or box 32 in the new 4473. Note that it was an authorized expired ID due to pandemic. Remember these inspectors might come in a year or two or three from now and look back at your forms and see expired IDs, driver’s licenses being used.

On the next form, so we have a tremendous amount of errors. This is probably one of the most significant issues I see when conducting audits onsite; firearms are being sold to denied folks. That does happen, believe it or not. It may not be happening in your firearms dealership, but it does happen. And that’s a big, big, big red flag—something where the ATF has to go and react to and retrieve those firearms. And we see Brady dates expiring all the time or not documented at all or guns being transferred before the Brady date expiration, another big problem. That whole box 27 information is critical to validating and authorizing the transfer of the firearm. So many eyes are on this section, and very important for you to incorporate or include updated dates.

If you were releasing a firearm on a date before a Brady date because you received the proceed box 27, make sure all of that information is included. It used to be box 19 on the old form. This is probably the most common phone call we get weekly; “I have an out-of-state purchaser looking to purchase a long gun. Am I okay to do so?” And I know it’s hard for everyone to know all of the States’ laws, but we do this all the time. So we either have our list handy, or we see the information. We’ll have to do a little research in places like California and Washington State, or New York. But most out-of-state transfers require that you follow the in-state law for your firearm sale, as well as the out-of-state law for the person if they are from out-of-state.

So again, you must comply with both. Illinois has a lot of restrictions. Florida has restrictions, and more and more States are implementing state requirements for firearms transfers. So the ATF, even though they’re federal, will be validating you’re following both state laws. Missing signatures goes without saying. We can’t be missing a signature by a transferee, and we can’t be missing a signature by an employee. And missing signatures invalidate that firearms transfer and will be a significant citable violation on your report if and when you have an inspection. This is hard to talk about because it happens more and more, and it’s a challenging program to manage. But if you’re not submitting your 3310.4s for handguns and 3310.12s for multiple long gun purchases on the southern border states, these are significant violations, and they’re critical to the functions of the ATF.

That’s why these forms are so important to be sent in on the day that multiple firearms are purchased. These forms are critical for the criminal division of the ATF to be tracking gun trafficking on a daily, possible straw purchasing occurring in a specific region. So these are critical to be submitted, and they can’t be missing from the 4473s during the inspection. It would help if you did not keep them in a separate file. We urge you to keep them attached to 4473s involved in the transfers. One error equals multiple reports of violations. If you miss a signature in a box, a date is incorrect, or a NICS wasn’t updated, not only can you have a violation cited by the inspector for that block or that line that it relates to, but that violation will show up in other sections of the report.

There’s a statute that says the invalid or illegal transfer of a firearm, if you’re missing a signature from a transferee, that shows up in the citation area on the report for missing signatures. But then that same violation will show up elsewhere later when you report for processing an invalid or an illegal firearms transfer. So sometimes, we see the report of violations that are eight or nine pages. And sometimes, we see reports of violations that have 20 or 25 pages long. And we find when we audit and look back at all the violations and try to figure out the action planning that it’s the same violation showing up in many places. Even if you’ve never had a report of violations, it’s an interesting document to review.

If there’s one issue that sets off the fireworks during an inspection, the ATF team finds that you are missing firearms from your book inventory; if firearms are supposed to be in stock, that aren’t. We know this happens for so many different reasons. Still, it all comes back to daily disciplines, training, and responsibilities from your folks who are completing transfers and updating your bound book. Missing a firearm sets off the fireworks, as we say. Not only do you have to get it reported, but this is a critical violation result that’ll show up in your report and certainly lead to the other steps JC talked about, warnings and revocations.

If they’ve left the store and are waiting for that background check to be completed when they come back in, you need to make sure that they’re certifying the date of that box. So the missing 3310.4s, missing but delayed, have to be completed at the end of the business day.

The same day firearms get transferred, you have to submit your 3310.4 and 3310.12, where appropriate. We see it all the time during our mock inspections where they either haven’t submitted or were delayed. Do not take the position of, “Oh, my person does it at the end of the week.” It has to be the same day. On missing firearms, it’s a good thing that you catch the missing firearm. It’s a bad thing if the ATF catches a missing gun. That’s why firearms inventories and firearms counts are so important. Depending on the size of your shop, we make the recommendation for larger shops to do it on at least a quarterly basis. Reach out to us, and we’ll give you some insights into some of the things we recommend to midsize and larger shops.

We have a good methodology for FFLs to follow for firearms inventories and counts. It helps alleviate some of the staffing constraints that come along with that.

Regarding the new form 4473, the significant changes are the format; the five sections. The firearms section they’ve moved to the very top of the form. And I know there’s been a lot of concerns and talk about firearms registration, and that’s why they did it. On the old form 4473, the certification, and question 11. a the buyer, the transferee, was certifying that the guns listed on the form were purchasing for themselves. If you weren’t filling that form out until they finished section A, they were certifying that they weren’t buying any firearms. So all they did was move those firearms to the top of the form.

What does this help you do?

This helps you ensure that the customer has a genuine interest in a firearm; somebody who’s walking into your store and just simply saying, “Hey, listen, I want to see if I can pass a background check.” Absolutely not acceptable! There has to be a firearm on that form before you start the process. So why firearms description first?

Zero, number of firearms transferred on the old form 4473, you’re required to mark out, line out whatever number it was if no guns were transferred, and in a zero. You are no longer required to do that.

Box 8, private party transfers, really simple there. I think it’s pretty much self-explanatory. Box 14, sex, non-binary. It’s important to note what the individual recognizes themselves as; the fact of the matter is unless their identification stipulates non-binary, then it does not apply, and they have to put whatever gender sex they are. So if they’re transgender and transgender to a male and their driver’s license or identification still says male, they have to put that. If it says female, they have to put that. So what you’ll see in some instances, some states they’ve started putting non-binary on the license. It has to state non-binary.

The number one thing is to get it right the first time.

If we train our folks and retrain and review and take time to examine our forms at the end of the day, or maybe you got a second set of eyes throughout the day, go back and have the corrective behavior conversation with every person. And, don’t just correct the form; have the conversation so that we continue to get it right the first time. And think about how much time would be saved, not only on you, on your managers and supervisors and us, if we come in and review, how much time can be saved if everything looks good.

And we’re pretty sure that if the ATF inspector comes to your location for an inspection and reads through maybe 300 or 400 4473s and everything’s good, we can only assume this will be a good outcome. But if they read through 300 or 400 like we do on a visit and find many errors, I think there’s not going to be a great outcome.

So get it right the first time and reduce your errors. Legibility and penmanship; if you’re not using an electronic package to print out the information for make-model, serial numbers or import a distributor, etc., it may be a problem.

We often see enough where FFLs are debating in a warning conference that they can read the form and figure out the numbers, but the ATF inspector marked it incorrect because today, he or she cannot read the document. Well, remember these forms get sent to a tracing center when necessary. They get presented in a court of law to defense attorneys and prosecutors if and when those firearms are involved in criminal cases. That form has to be readable to a jury. Otherwise, that form is not going to be a valid presentation of evidence. So we recommend e-Form 4473; either sign up with the ATF for their electronic package or find the vendor out there. The more electronic you go with your forms and your record-keeping, the better.

On section C; train, train, train. That was formerly section B. Train your staff. Every box, every line meets up with the relative information if necessary. And if you’re a member of the National Shooting Sports Foundation, go ahead and order what they call the 4473 overlay that helps you and your staff look at these forms when they’re completed and before transferring the firearm to make sure the respective boxes that need to be filled in are. It’s a great little tool available from the National Shooting Sports Foundation. Educate the transferee; you’re not allowed to coach- we know that- you’re not allowed to help answer questions. But you can have signs or guides. We have a few available if you need these. Go to our website. You can have signage that says, “Make sure you have a valid, unexpired state photo ID before asking to look for a firearm.” You can have that in writing on your gun counter. You can have a sheet of different things we include; you’ll read the form carefully before proceeding.

Our employees are not capable or able to answer questions in section 12. So you can give especially the first-time gun buyers some information ahead of time so that they can flow through the process more easily for themselves and you. The double-check/triple check can’t be reiterated enough. You’re just losing out if you’re not having a second set of eyes look at the form. In a high-volume, high-transfer location, even a third set of eyes before that form gets filed.

For 3310s and 12s, as we say, same day, end-of-day business. Get those into the ATF. They’re essential to the ATF tracing and trafficking activities ongoing to keep our community safe. And then lastly, just timely transfers in and out, whether it be the A&D process or especially on your 4473 transfers; ensure that you’re getting the proper documentation updated in your bound book or your electronic system.

Some other errors that we see in the A&D record-keeping: importing. When we do our mock inspection, I look for my troublemakers; my Berettas, my Glocks, my Taurus, Walther, any number of those firearms that I know have been imported. The first thing I look at is the A&D log. I make sure that the FFL knows how to print it off because the ATF will expect you to print it off. And then I look down the line, and I start filing the guns. And then once I do that, I actually go out to the floor, and I verify. I check everything. So you must be paying attention to what’s on that physical form and understanding that importer is required.

Make sure that you’re training your staff on how to receive firearms, what to document when they need to document it, et cetera. Timely transfers in and out, a gun gets transferred, physical custody of that firearm goes to the transferee, the buyer, the purchaser, guess what? You’re on the hook. Document your A&D record books that that firearm left your building.

You don’t want to wait. Things get lost in the process. People don’t realize, “Oh, I thought Jim over here did it. He thought I did it.” Make sure that those are documented in A&D records. Everything you’re doing as far as your A&D records and your 4473 are focused on potential traces coming down the pipe later on.

Warning and revocations: I want to call out as far as a warning where revocations are concerned is that if you have an inspection and it goes sideways quick, there’s nothing that says that you have to go through any type of step process before revocation. So, in other words, if IOI shows up and does an inspection in your store and they find out that you’re transferring firearms to people that were denied previously, you’re transferring firearms without 4473s. This is the most extreme scenario; you can go right to revocation.

The ATF takes this stuff very seriously. So you need to make sure that you are conducting business properly. So let’s walk through it here. So you get revoked, you get that letter of revocation, you receive a certified mail, and here’s the process: essentially, what’s led to this is you had an inspection, which led to a report of violations. From there, you probably either received a warning letter or a warning conference. You’ve then been reinspected. And at that time, they’ve taken your past reports of violations and said, “You know what? You’re not only not correcting what we’ve already found multiple times potentially, but you’re also making mistakes on other things.” So they take a look at that, and they determine that this individual is not serious. They’re not doing what they signed up and said they were going to do, following the laws and regulations governing a firearms business.

So this is the process: once you get that revocation letter, you’ll have a revocation hearing. You’ll have two. You can request an informal hearing where you have a conversation, and you can plead your case. And then there’s a formal revocation hearing. And you will have to travel to the field division to have that conversation. Depending on wherever you are, that could be a long way off. There’s a process to this. We help with a lot of these. The law firms that we support bring us in to help them with these processes. And we build out the corrective action plan. We have relationships with most of the field divisions that have conversations. But I will tell you, once you get to this step, it’s a fight. And it is what it is. You may have been given multiple chances to do what you’re supposed to do, and you haven’t. So the ATF has taken that pretty seriously.

How do you stay compliant?

As we know, the inspections are going to be forthcoming. The Biden Administration could be imposing stricter guidelines for FFLs. So avoid willful negligence.

Make sure your trace requests are going in on time. We explained earlier how important they are, especially to the ATF criminal division. Make sure they’re going in within 24 hours. And if you’re in a demand-letter program, make sure you’re getting that information to the ATF quarterly. We help a lot of our clients with this. We use the electronic files and send them in timely so that the tracing centers, first of all, can use that information more quickly to determine traces without bothering you. That’s what this is all about. They don’t want to call you all the time if they could just figure out the information from files you’re sending in.

Straw purchases: Prevent straw purchases!

Too many straw purchases, and you will be a target of an inspection or a criminal investigation by the ATF. Make those pamphlets available that the ATF and FBI have available to you. Youth Handgun Safety Act, make sure the sign is posted. It’s imperative to community safety. Handgun locks must be distributed to used and new gun purchasers, new transferees. If you don’t have them, contact your local law enforcement agency, they usually have some available. Or contact us. We’ll provide cheap vendors for you. The National Shooting Sports Foundation has revamped the” Don’t Lie” program. All of those materials are available for free. So go to nssf.org or dontlie.org and find out where those program components are available for display in your place of business. NFA segregation is critical. If an ATF inspector comes in and finds you mixing NFA inventory or your books with your non-NFA, it’s going to be a problem. So make sure it’s all segregated and secured. And lastly, make sure you’re cordial to that ATF inspector if and when they ever show up.

Regarding “willful intent/willful negligence,”- I’ve mentioned the most extreme; knowingly transferring a firearm to somebody that was denied, something of that nature, or transferring a gun to somebody and not getting a 4473 completed. Those are probably the most extreme. But I will tell you that if IOI comes in and does your inspection, and they start seeing the same thing; missing signatures, missing certifications, not checking boxes, etc. Those are also willful. So you want to watch that.

We see more and more cases and revocation issues we’re dealing with that willful negligence is being cited simply as the FFL not adhering to knowledge and requirements as outlined in the FFL guidebook. So because you have the ability, you’re just not using it is being cited as willful negligence. So just be aware of that. We work with the ATF across the country, every field division. And I will tell you right now, for the most part, where they can, they will bend over backward to help you and make sure that you know how to conduct business properly. So don’t take an adversarial role when they show up. Be cordial, welcome them in, let them do their job.

Range issues: So, one of the big ones right now, we’re getting it from FFLs and ranges across the country, is, “How do I survive without ammo?” Or, “How do I even get ammunition?” Well, I wish I had a good answer for you. Essentially ammunition, nobody is increasing their supply chain in this, mainly because we said it earlier, there aren’t any supplies.

Ammo is constrained right now, metals, raw materials, et cetera. So surviving without ammo is tough. You can do some training and coaching classes without ammo. There are cheaper solutions out there. Many FFLs in ranges maintain their supply and hold back one box of ammunition for every firearm they have for sale. In other instances, we see ranges reserving their ammunition supplies for individuals coming in to utilize the range facilities. So that’s a couple of strategies that we see out there that are working pretty well. It’s a rationing process. And that’s the other thing FFLs are doing, the two-box rationing or one-box rationing, depending on how much ammunition they’re getting. So we’re going to talk a lot more about pandemic here in a few, but pandemic restrictions, make sure you have a plan.

Touching on noise suppression real quick; if you’re operating a range, maybe you’re in a residential area or have other neighbors or business neighbors. If you’re starting to see complaints about any noise, or you’re staying open later, or whatever the case may be, reach out to us. We have noise abatement solutions. We have several organizations that work with us and refer to help with noise abatement concerns. So just reach out to us. We can help you with that.

We’ve had people who considered moving into a range and purchasing a range or constructing a range. Know that we do have an entire range development team to help you. So again, reach out to us; we’ll get you in contact with them. There’s a little bit of a process to it. Our folks like to vet and make sure that the individuals are ready to go. And we’ve got a complete checklist that will help you determine whether or not a range is suitable for you. So definitely reach out to us for that as well.

Safety training for new shooters is another hot topic. And it’s something that we talk to many of our ranges, with 12 million new firearms out there right now. And of that, about five-to-seven million of those firearms are in the hands of new shooters. People who have never been involved in shooting sports before. Here’s an excellent opportunity for you to either do coaching or do instructions for concealed carry or whatever the case may be. It’s a huge opportunity. We talk to FFLs and ranges all the time, and I’m just simply having a cleaning class, teaching people how to clean their firearm appropriately, how to break it down, how to put it back together, and what to use to clean it and things like that.

We get many questions about NRA versus non-NRA and all the politics and all the other things going on with that. There are other organizations out there with training curricula, such as the USCCA, for example, which have an excellent curriculum that you can use to train your new customers or even your existing customers. So take a look at those opportunities. The industry as a whole is very focused on the female shooter, and that should continue. Having women’s leagues and family-oriented events, that’s a big one. Groups, businesses, corporate entities, the “Let’s Go Shooting” program, the “USA Shooting” program, the +ONE program from the National Shooting Sports Foundation. All great programs offer extensive advertising and marketing suggestions, recommendations, and solutions that you should be taking advantage of as an FFL and as a firing range.

Looking ahead to range operations, there’s a lot of competition out there, and it’s only growing. We’re getting a lot of calls. Our range development team is doing a lot of work as far as starting up new ranges, doing construction, just feasibility studies on whether or not a range can be placed where an individual interested in owning a range wants to put one. So I will tell you that I think range operations and range facilities will be growing for a while now.

Regarding range compliance, ATF, state, local OSHA regulations, we support all of those different functions. We’ve been seeing quite a bit of local ordinances, and in states, we would never have expected it as far as gun ranges, and gun stores are concerned. So be aware of that, especially if you’re a new FFL.

We’ve developed SOP manuals across the board, whether standard FFL operations, FFL transactions or the 4473 or range operations. Our human resources team has an entire gambit of standard operating procedures as far as your employee handbook and things like that.

Reach out to us if you’re interested. We can certainly help you with all that. Compliance auditing, and training, we’re doing a lot of onsite work right now. We have many FFLs that have us come in unannounced just to test their employees. To make sure operations are running the way they’re supposed to. So reach out to us for any questions relative to your insurance or risk management. We can help you with all those things. We work closely with all the insurance providers out there, especially the underwriters, to ensure that you all know exactly where you need to be covered and how to protect yourself in the long term.

Watch the full video interview on the MT2 Firing Range Services Virtual Summit; click here

FFL Consultants is a specialty consultant group focusing exclusively on supporting firearms retailers, range operators, manufacturers, distributors, and importers. Our experts possess many decades of experience with ATF/OSHA regulatory compliance and the big-box sporting goods retail sector. Over the last 7 years FFL Consultants has grown from presenting at various firearms industry training and educational events sponsored by the National Shooting Sports Foundation, the ATF and FBI/NICS, to providing time-sensitive support to more than 10,000 FFLs nationwide. When it comes to supporting our FFL community, no question is too trivial and no project too difficult. We’ve “been there done that” many times over and stand ready to help you with your everyday needs as well as your next challenge! We stand ready to support you and your FFL business 24/7!

https://www.FFLConsultants.com

John “JB” Bocker – Co-Founder, FFL Consultants JB is the co-founder of FFL Consultants and a leading expert in commercial security, internal operations, and firearms compliance programs for the firearms industry. He is a well-known and respected presenter, author, educator, and supporter of FFL's nationwide. JB also consults for the firearms trade association and is an SBA-SBDC Certified Small Business Advisor. Having managed an inventory of over 85,000 firearms and more than 80 licensees, John believes in supporting clients through trustworthy relationships, simplicity, confidentiality, shared education, and time-sensitive 24/7 support. Contact JB: [email protected] PH: 720-336-0028

John “JC” Clark – Co-Founder, FFL Consultants

JC is co-founder of FFL Consultants and a veteran of the military, law enforcement, and retail arenas. JC has also been directly responsible for managing and overseeing nearly 500 licensees operating across the country. This has afforded him extensive personal knowledge and experience related to the firearms industry, FFL business operations, driving profitability, and protecting organizations against risk. JC thrives in supporting clients in the areas of state and federal compliance initiatives, business assessments, OSHA and range operations, internal control functions, and the implementation of corporate governance practices. JC also serves as a primary business, security, and compliance consultant to the firearms industry, supporting the Members of the National Shooting Sports Foundation.

Contact JC: [email protected] PH: 720-431-8821

About MT2 Firing Range Services

MT2 is the Firing Range Lead Management Authority. We operate from regional offices across the country and always pay the highest value for range lead Guaranteed!!

You Operate the Firing Range. We Get the Lead Out!

https://mt2.com/trust-your-contractor/

The post Interview from the Firing Range Virtual Summit: FFL Consultants – ATF inspection activities & the new Form 4473 appeared first on Firing Range Services | Gun Range Cleaning Services | Shooting Range Cleaning Services| Firing Range Lead Maintenance | Shooting Range Lead Mining | MT2.com.

from Firing Range Services | Gun Range Cleaning Services | Shooting Range Cleaning Services| Firing Range Lead Maintenance | Shooting Range Lead Mining | MT2.com https://mt2.com/blog/18778-interview-from-the-firing-range-virtual-summit-ffl-consultants-atf-inspection-activities-the-new-form-4473/

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davidbwalliam · 4 years ago

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Spotlight on Top Colorado Gun Ranges | Sponsored by MT2 Firing Range Services

RANGE NAME RANGE NAME A little “about the range” info. A little “about the range” info. A little “about the range” info. A little “about the range” info. A little “about the range” info. A little “about the range” info. A little “about the range” info. A little “about the range” info. A little “about the range” info. A little “about the range” info. A little “about the range” info. A little “about the range” info. A little “about the range” info. A little “about the range” info. A little “about the range” info.

STOP BY THEIR LOCATION: 1234 ROAD ST. | NOWHERE, KS 33333

**Delete this** If you type their address into google, and take a screen shot, you can drop it in the img box. I tried to use the map function but it’s broken. Or a picture of their range?

SPECIAL EVENTS TO NOTE: A little “about the range” info. A little “about the range” info. A little “about the range” info. A little “about the range” info. A little “about the range” info. A little “about the range” info. A little “about the range” info. A little “about the range” info. A little “about the range” info. A little “about the range” info. A little “about the range” info. A little “about the range” info. A little “about the range” info. A little “about the range” info. A little “about the range” info.

ABOUT THIER RETAIL AREA: A little “about the range” info. A little “about the range” info. A little “about the range” info. A little “about the range” info. A little “about the range” info. A little “about the range” info. A little “about the range” info. A little “about the range” info. A little “about the range” info. A little “about the range” info. A little “about the range” info. A little “about the range” info. A little “about the range” info. A little “about the range” info. A little “about the range” info.

GUEST AMENITIES:

Coffee mug

restrooms

ear plugs

THINGS THAT MAKE THIS RANGE UNIQUE: A little “about the range” info. A little “about the range” info. A little “about the range” info. A little “about the range” info. A little “about the range” info. A little “about the range” info. A little “about the range” info. A little “about the range” info. A little “about the range” info. A little “about the range” info. A little “about the range” info. A little “about the range” info. A little “about the range” info. A little “about the range” info. A little “about the range” info.

youtube

from Firing Range Services | Gun Range Cleaning Services | Shooting Range Cleaning Services| Firing Range Lead Maintenance | Shooting Range Lead Mining | MT2.com https://mt2.com/blog/firing-ranges/11860-spotlight-on-top-colorado-gun-ranges-sponsored-by-mt2-firing-range-services/

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davidbwalliam · 4 years ago

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New study finds Army special operations troops have lower blood lead levels after firing range fixes were instituted

Stars and Stripes reported that a study published in the March issue of the Medical Surveillance Monthly Report found out that several changes at firing ranges can potentially decrease blood lead levels.

Lead in the blood can be toxic not only to troops who use the facilities but to their family members too. Their family members can be exposed to lead, if the particles that have accumulated on the skin, equipment, and clothing during firearms training are not removed before service members enter their vehicles or homes. Lead exposure can cause brain and nervous system damage, delayed growth and development, and other health problems to children and can cause high blood pressure, joint and muscle pain, headaches, abdominal pain, etc. to adults.

The changes were made after an assessment by the Army’s Industrial Health unit found that soldiers who used the ranges were exposed to airborne lead levels more than eight times higher than the level at which the Occupational Safety and Health Administration says action should be taken, the study said.

The full report including the before and after blood lead levels can be read here: https://www.stripes.com/news/europe/army-special-operations-troops-have-lower-blood-lead-levels-after-firing-range-fixes-study-finds-1.668175

Safety is the most important concern for everyone who visits a firing range. In order to ensure a safe experience regular firing range maintenance is a necessity.

Firing ranges face increasing scrutiny for the effect they have on the environment. A key aspect of maintaining a firing range is the recovery of lead from the soil, and minimizing the impact lead has on the environment.

MT2 is the #1 Nationwide Professional Firing Range Lead Reclamation, Maintenance, Cleaning & Construction Contractor for both Indoor and Outdoor Shooting Ranges. MT2 Firing Range Services Uses Exclusive PATENTED Technologies That NO Other Gun Range Services Contractor Can Perform.

You Operate the Firing Range. We Get the Lead Out!™

As the only firing range services provider with Nationwide operations, MT2 operates from our network of regional offices offering full 50 state coverage with OSHA and EPA-certified work teams.

Contact MT2 in your region to schedule your firing range project as soon as 1-3 weeks. www.MT2FiringRangeServices.com

The post New study finds Army special operations troops have lower blood lead levels after firing range fixes were instituted appeared first on Firing Range Services | Gun Range Cleaning Services | Shooting Range Cleaning Services| Firing Range Lead Maintenance | Shooting Range Lead Mining | MT2.com.

from Firing Range Services | Gun Range Cleaning Services | Shooting Range Cleaning Services| Firing Range Lead Maintenance | Shooting Range Lead Mining | MT2.com https://mt2.com/blog/11856-new-study-finds-army-special-operations-troops-have-lower-blood-lead-levels-after-firing-range-fixes-were-instituted/

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davidbwalliam · 4 years ago

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Interview from the Firing Range Virtual Summit: Jeff Hewitt-SVP, Lockton Affinity Discuss Insurance Questions & Risk Mgmt. FFL’s Need to Know and Have In Place During Challenging Times

Today’s presentation is “Insurance Questions & Risk Management Firing Ranges Should Have In Place During Challenging Times,” tell us about yourself and Lockton Affinity.

Jeff Hewitt:

In my role at Lockton Affinity, I’m a program executive, which is a program manager. I manage all of our outdoor activities, which are almost all centered around shooting sports—everything from individual gun insurance to clubs to businesses. And today, we’re going to talk specifically about the business insurance aspect of what we do.

I’ve been in the insurance business for over 35 years and with Lockton for 27 years. And for the last 20 years, I’ve been managing our Lockton Affinity outdoor brand as it exists in the space. In January of 2000, we became the broker for the National Rifle Association Insurance program. And I’ve been in charge of that relationship. From there, we’ve continued to expand the products that we have available to folks who sell firearms and commercial and membership-driven ranges. We’ve built a team of specialists who focus on questions like: “How do you make your business better? How do you safeguard yourself against claims? How do you continue to make yourself attractive to an insurance provider so that you can continue to buy insurance at an affordable cost.”

Now, some of you would argue whether the cost is affordable or not, but we can get into some of those types of questions as we move on. So I want to talk a bit about who Lockton Affinity is and what’s going on in the insurance marketplace today. I’m sure some of you have seen some upheaval with current carriers and moving off of your particular insurance or price increasing, those kinds of things.

We’ll go over insurance coverages that drive your business costs and how to make yourself safer, and the things you need to ask your current agent to make sure that you’re in the best coverage. We have over 20 years of experience in the firearm retailer and range segment. We started off focusing only on gun stores that didn’t have gunsmiths; we were very conservative in our underwriting. We didn’t do a lot of commercial range operations. We were just getting our feet wet with doing retail stores. As our underwriting team got more comfortable, we expanded to those FFLs with gunsmiths on staff.

We created a gunsmith program that provides the product and general liability. Then we expanded over to those commercial ranges and folks that are doing firearm-related training. They may have their employees doing that training, or they’re allowing outside instructors to come in; we’ll talk a bit about how to protect your business from these external entities coming into your facility. If you’re paying someone on a 1099, you know how to handle those from an insurance standpoint properly.

What are examples of third parties?

Jeff Hewitt: They could be a third-party like an NRA certified instructor or a non-NRA certified instructor. They might just be certified in the state’s concealed carry class. Some of those require an NRA instructor. So it’s kind of all of those outside folks using your facility, whether it’s instructions or you have a group.

One of the clients we work with is The Well Armed Woman. They don’t have a specific range, but they might be using your firing range where they bring in their team with or without an instructor, or they might have a social shooting event. We write all their insurance, and we provide lots of certificates out there to range operators. Again, to make sure that someone else’s insurance is standing in place of yours first, for someone else’s event.

Today, we have over 4,000 ranges and retail stores that are in our program. That provides a large body of premium that the insurance carrier would look at, and it creates some aggregated buying power in the marketplace. So it helps keep our pricing at a more stable level.

Lockton is a Certified Great Place to Work in insurance eight years in a row. If anyone has a local agent, call them and ask, “Hey, I’ve got this federal firearm license and a gun store, and I need some liability and property insurance coverage.” They may say, “Yeah, we’d love to help you out.” Still, they probably don’t understand everything involved because when they try to find a reasonably priced provider, they find out that no one wants to write this; there are only about three or four carriers who want to write this type of policy. They all have different underwriting appetites and different pricing metrics, and it becomes frustrating to talk to a non-specialized agent in this space. And that’s where we come in and help with that.

We have underwriting for the long-term in mind, and this is why we’ve been able to offer this type of coverage 20 years ago, and we’re still offering it today. And we still want to be leading the industry for the next 20 years. And so, how do we do that? It’s because of our underwriting mix and expertise. In fact, 7 out of 10 folks that call and talk to us about getting an insurance quote will end up buying from us.

There are a couple of carriers we don’t quote because they don’t have good business practices, or when we look at their claims information, they continue to have the same types of claims exposures. We give a target to run toward, and some advice on how to get better with their current carrier, and then they can come back to us. But we’re usually able to match up price and coverage requirements that make a lot of sense versus the competition that’s out there. One of the things we do is survey about 25% of our insureds each year; we get about 40% of those who respond. Here are the top three reasons why people end up purchasing with us, and then they stay with us.

Our products are well priced, we’ve got good coverage, and we have a highly specialized team that understands what our clients want. Today we’ve got Stacy, David, and Jake, who all work on a team for me, if you wish to call it our sales team or the enrollment side, but between the three of them, they’re not trying to write a shoe store this morning and maybe write a gun store this afternoon, or a range. All they do is gun stores and ranges, that’s it. And so, we’ve got three people full time, just on the enrollment side of this, so that we’re able to take the time and help each one of those folks out there understand what they need, what drives their pricing, what can make them better.

It’s more than just sending them a proposal and saying, “Hey, do you want to sign up?” It’s an education – every month, we’ll talk to a little more than 100 store owners or range owners from a new business side, and we probably write 70 or 80 new locations a month. So we’re excited about the prospects of continuing that type of growth in this program.

Over the last five to seven years, we have seen the carrier markets shrink from 10 down to three. And some of you have gone through being non-renewed by some of those carriers. And then some of you have not been non-renewed, you’ve been offered a renewal, but the pricing is so extreme that the insurance company is, in essence, telling you to shop and move your coverage. And if you’re willing to pay the price they put out for you, they’re happy to renew you. This is the type of corrective action they’re trying to do because of losses.

Some of the smaller players out there, and when I say it’s a smaller player, it might be a big insurance company, but they’ve got a small book of this business. When they have their first policy limit claim, they realize, writing coverage for commercial gun ranges is risky. Or they reevaluate why they are writing gun stores that have gunsmiths?

Can you shed just a bit of light on what you hear about the insurance industry overall for firearms?

Jeff Hewitt: I would say that the media predominantly drive me, things around the pandemic; you’ll see in the media consistently about the increase in the background checks and record firearms sales. In one instance, I know, a question got asked at a board of directors meeting at a large carrier and said, “You know, I understand all this stuff’s going on with talks about defunding the police, we’ve got this pandemic, and we’ve got these riots going on. We’ve got people in Kenosha using assault weapons to defend themselves. And we want to make sure we’re not writing any of that stuff.” Well, they said, “Well, we’re writing this stuff, and we’ve had this program and this division for X number of years.” There’s a political backlash of being associated with the firearm industry. And that tends to come from the more liberal side. We’ve had another carrier that simply had an underwriting head retire. The following person who came in to replace that person is of a different political bent; they’re very liberal. And they don’t like being in this space. They don’t want to understand it. And they’re just putting a blinder on to a way to have a profitable book of business in the firearms industry segment. And they’re just looking at the industry segment and saying, we don’t want any part of that.

Who knows what they want to do. Hopefully, we’ll have some balance where there’ll be some control with the Senate because the House and the White House will be in a different area. So I think that there’s more to come out of that political environment and what it means to the firearm industry.

So let’s shift gears here for a little bit. And as I mentioned earlier, we’re going to talk about a couple of coverage things that I think are very important for you to understand and good questions to ask your agent. General liability is our liability to a third-party. So whether that is a customer, a trespasser, somebody in our parking lot that might not be a customer, what’s our legal liability to injury or damage to someone or something else where a lawsuit could be brought against us?

We tend to see when something goes bad; there’s a fatality or some other kind of debilitating injury that’s going to be ongoing. And those tend to be more for policy limit type claims. Then somebody else that’s on your same street that’s retailing something other than firearms when they have a slip and fall or something goes wrong with one of the products they’re selling, they don’t tend to have nearly as high claim payment issues as the gun industry does. So carriers have to price for that and understand that there’s going to be these “shock losses.”

There are a couple of critical points that you can ask your current provider to make sure that you’ve got proper coverage. One of them is to ensure that you have the right coverage. General liability is written on two forms; one is called a broad form, and the other is called a limited form. One is offering what I’d call a universal coverage that protects you, employees, other owners, and members if you’re running a range or you sell memberships. Those should all be listed as insured on your policy. Because if an employee does something on the store or the ranger’s behalf, or you’ve got a member of your range that gets involved in something, you want to make sure that they’ve got protection under your policy.

So if a member is using the range and they’re involved in something that causes injury or damage to someone else or something else, they’re held liable. They’re going to be named, and you’re going to be named. You want your policy to respond to both of those. You don’t want to have an individual lawsuit from one of your members or a separate lawsuit from one of your employees because they did something and the policy doesn’t protect them. So ask your agent about those kinds of things. Broad or limited is the way that the insurance agent will understand it.

When you’re going through the quote process, whether it’s with us or someone else, we often offer a second opinion. We don’t care if you white-out your insurance premiums so that you don’t feel like you’re giving us a target to shoot for to be $5 cheaper. Send us the policy form so we can tell you what you have and compare it to what we’re proposing.

We have people say, “Oh, wow. Those guys are so much cheaper than you are.” Well, they may not be so much cheaper. It just may be your exposure limits are different.

You could go to someone unfamiliar with writing this class of business, and they can’t find anyone to write it. So they’ll go to an insurance wholesaler, who will find them a market. They usually have high minimum premiums; you could spend $5,000 to $10,000 for this policy. And they may give you a limited coverage form for the designated premises and business only. So, if you also have a range or if you have a gunsmith on staff and those aren’t listed in the designated premises and operations, any claim you have may not be covered. So you have to look at comprehensive or universal coverage under the broad form where it picks up all those things first and foremost because that’s part of your operation.

It’s an intended or implied part of your operation first. Secondly, it helps you also protect yourself and your employees when you’re away from your premises. Whether you do some transactions at a gun show or you’re going to a convention, you have a booth, or you’re out helping with a community outreach program for other people in the firearm industry.

There may be liability you might have associated with that. So again, that’s the big point I would look for when you’re looking at your policy with your current broker.

The other thing, as I mentioned earlier is, you want to make sure that you’re presenting yourself in the best way you can as a business to make the insurance carriers want to continue to provide you coverage at an affordable cost. Many of us will have outside groups coming to use our facility, whether that be an instructor, a training business, or another shooting group that doesn’t have its own range. Ensure that you’re getting a certificate of insurance from that organization and listing your business as an additional insured.

You want to make sure the club or instructing entity that came in to use your range has insurance standing in front of yours if there’s a claim that happens. Let’s say that someone has an accidental discharge and gets shot in the leg, and there’s $100,000 of medical expenses. As a range owner or the business owner, you don’t want to have anything to do with paying that. You want to make sure that you’re documenting that because they’re going to name you in the suit. You’re going to give the claims adjuster that other entity’s insurance provider and tell them that the claim is theirs.

So you want to make sure you continue to present yourself in the best case that you’re doing safety practices like always getting certificates of insurance from outside groups or that you have successfully been able to use those. Again, it’s like anything else; whether it’s your automobile or your homeowner’s insurance, it’s all about claims. How is your insurance provider going to look at you after claims are made?

Let’s talk a bit about property coverage. This is intuitive in the sense that it works like your homeowner’s insurance. I need to provide protection so that I’ve got replacement cost coverage on that. If you’ve got outside lending sources, those are things that are going to help drive your decision of whether or not you buy the property coverage. And you have to consider property coverage in really three ways that I want to point out.

One is you’ve got the real property, the building, and anything that’s permanently attached to the building was considered a building. So cabinets, display cases that are permanently mounted – those are all part of the building. And then you’ve got your inventory or your contents, that’s the stuff that’s not attached that you can sell, or someone can steal by walking out with it from your store. Several variables are driving the cost of coverage. If you’re not near fire protection, several things intuitively drive that cost if you don’t have sprinklers. What’s the building made of? Is it a concrete structure? Is it frame building, masonry combustible? When you talk to us, we’re going to walk you through and do a cost evaluator on what you would require in today’s dollars to replace that building based on square footage, construction type, those kinds of things. So we don’t want you to go in and have a co-insurance problem where you’ve under-insured when you have a total loss. That gets messy between you and an insurance carrier.

Usually, they come back to the agent saying they were sold faulty insurance because of this penalty from the insurance carrier because we didn’t insure it for enough. We make sure we get rid of all those types of variables.

So talk to your agent about a couple of different things if you fit into this category. Look at what your deductible on the property is on your policy and ask for some additional limit options. So if you have $1,000, look at a $5,000 or a $10,000 deductible and see what kind of cost savings you get on those types of property losses. If you’re in a building and you’re not using all of the building, or it’s an older building, and we walk you through your cost estimate or what it’s going to cost to replace that building. You’re saying, well, wait a second. I’m not using all of the building currently. And if I have to replace this due to a total loss, I don’t want to replace it for $2.2 million. I think I could build a nice $1 million building to serve the purpose I need. Or, if you don’t need much of a showroom anymore because you’re making a lot of sales over the internet. So whatever the reason may be, you can talk to your agent about putting together what’s called an “agreed value policy.” You can pay the premium on a much lower valued building. And that’s a way to help minimize those costs.

Is it prudent for a store owner to do their assessment before calling you to have a better idea of protection they can put in place before you start writing and reviewing their property for a policy?

Jeff Hewitt: I think simultaneously is probably good. And let’s just face it. I know you may think that your insurance doesn’t come up until July 1st, so today, I don’t care about it unless I’ve got a claim, right? It’s just like me on my automobile insurance. I ignore it until I get the renewal in the mail. I would say that the two are kind of independent to me. If it coincides with their insurance coming up for renewal at the end of the year, I think they do those simultaneously. One of the important things I want to make sure that I talk about in this particular area is business interruption insurance. Business interruption insurance will help provide income at a level you select in your policy for a covered loss. So if you have a smash and grab where you have to be closed while they’re fixing the building and making the changes or you’re getting more inventory in, those kinds of things.

Then the insurance company will pay you a determined amount, and you and your agent will determine that amount. It can be everything, which is the most expensive, called actual loss sustained. So it says for 12 months, we’re going to give you whatever it needs to keep your business going even if you have to be shut down because you had a total fire loss.

A more affordable option is to look at your monthly revenues. Then buy a 90 day or 180-day policy that will give you a monthly income replacement. This way, you can continue to keep your employees on the payroll, pay your mortgage or your rent, and any outstanding liabilities that you have.

Continue to pay your insurance and those kinds of things that business interruption. And that’s a consultative thing that you need to spend a little bit of time with your agent on and make sure that when I talk about things you can do is not to buy too little or too much. The top end of the spectrum is this actual loss sustained; that’s the most expensive. And if you think 180 days’ worth of coverage or six months’ worth of coverage at $20,000 a month is good, that’s going to cost you a lot less. Again, run through your books with your agent when getting a quote for these types of options.

It’s not automatically included with most carriers out there, so you’ve got to ask for it. And if someone’s trying to win your business at a skinny price, that’s one of the first things to go.

Worker’s compensation is one of those compulsory things required by your state, and you can talk to us about your state requirements. Some states have minimum payroll requirements. Some have a minimum number of employees requirement before you have to start buying it. It’s non-health insurance, but it takes care of your liability to employees if they’re injured on the job. It takes care of their employee injuries, and it can take care of any lost time from work if they have to do that. And there are some deductibles or waiting periods there for them to get wage replacement. If you go to the doctor or the emergency room, they’re going to ask if it’s a work-related injury because they will file it on health insurance or your employer’s workers’ compensation.

And there’ll be a difference here for this group; if you have a store and no range operations, then you’re paying a retail rate. So your counter workers, managers, you are paying the same rate as the shoe store down the street, in terms of what workers comp rate. When you have a range and have employees that will go out onto the range, you have range officers, then you get into a different classification that’s a little more hazardous, and you’re going to pay more because the risk of injury is there.

And that’s just the way those work. The beauty of how all the states are set up around the country is each one has its state insurance department. And they all have a little bit different rules, which’s very similar to what happens here with worker’s compensation. So if you’re in California, inherently, you’re paying a higher rate because it’s got very rich benefits versus a store in Texas. Texas has low rates because they have low benefits for workers comp-related injuries. So you can shop around and find different carriers that are going to find different things, different pricing. So it’s worth your while to shop around

Something essential to call out, relative to workers compensation, is that you as a range need to ensure that if you have those third-party contractors working on your range, doing lead mitigation, things like that, that they have the proper coverages in place for their employees. Because we’ve seen it in the past where a business is using that third-party and that third-party didn’t have insurance, then suddenly the business is the one getting the attention and the focus as far as claims.

Our partner MT2 Firing Range Services can assist because they are the Firing Range Lead Management Authority specializing in providing environmental firing range services and lead remediation.

Watch the full video interview on the MT2 Firing Range Services Virtual Summit; click here

About Lockton Affinity

Jeff Hewitt is a Senior Vice President and Program Executive with Lockton Affinity. He has over 35 years of experience in the insurance world and more than 27 years with Lockton Affinity. He has spent the last 20 years specifically focused on providing firearm-related businesses with customized insurance solutions for FFL retailers, gunsmiths, and firearms ranges.

Learn More: http://www.LocktonAffinity.com

About MT2 Firing Range Services

MT2 is the Firing Range Lead Management Authority. We operate from regional offices across the country and always pay the highest value for range lead Guaranteed!!

You Operate the Firing Range. We Get the Lead Out!™

https://mt2.com/trust-your-contractor/

The post Interview from the Firing Range Virtual Summit: Jeff Hewitt-SVP, Lockton Affinity Discuss Insurance Questions & Risk Mgmt. FFL’s Need to Know and Have In Place During Challenging Times appeared first on Firing Range Services | Gun Range Cleaning Services | Shooting Range Cleaning Services| Firing Range Lead Maintenance | Shooting Range Lead Mining | MT2.com.

from Firing Range Services | Gun Range Cleaning Services | Shooting Range Cleaning Services| Firing Range Lead Maintenance | Shooting Range Lead Mining | MT2.com https://mt2.com/blog/11848-interview-from-the-firing-range-virtual-summit-jeff-hewitt-svp-lockton-affinity-discuss-insurance-questions-risk-mgmt-ffls-need-to-know-and-have-in-place-during-challenging-times/

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davidbwalliam · 4 years ago

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If Your Gun Range Offers Services as a Firearms Dealer-You Must Understand How to Prepare for an ATF Inspection.

ATF Inspections will inevitably occur if you are a gun range offering services related to retail gun sales, a firearms dealer, manufacturer, pawnbroker with firearms, or a manufacturer.

The secret behind the ATF Inspection is knowing what to expect and how to prepare accordingly. MT2 Firing Range Services’ trusted strategic alliance partners, JB and JC from FFL Consultants, share their experience and expertise and help educate you for this unnerving experience.

This in-depth series of video interviews will be critical in helping your firing range prepare for this type of inspection.

FFL Consultants provides support services to retail firearms and range operators across the U.S. Their specialties include ATF compliance, risk & security programs, range EPA & OSHA reviews, serving and supporting the success of more than 10,000 NSSF members.

You may also be interested in the interview from our Firing Range Virtual Summit with Tom Chittum, Assistant Director of Field Operations with ATF, click here to read it now

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MT2 is the Firing Range Lead Management Authority who specializes in providing environmental firing range services, and lead remediation. We are the nation’s #1 largest professional contractor for all your indoor and outdoor firing range service needs including: o Lead cleaning services o Lead reclamation & Brass recycle o Range Maintenance, HVAC systems support o We are consulting and Assessment by our OSHA/EPA experts! o Range Construction and Renovation o Lead Remediation & Abatement

Before you hire a lead maintenance contractor, consider: how are they protecting you, the Managers and Owners, from claims or potential illegal actions? At a MINIMUM the contractor you select must have an insurance policy that covers you to the level needed in event of claim or event including: Workers Comp General liability Lead/pollution The MT2 standard contract is the industry leader in methods and legal compliance! Our $10 million package protects the owner/manager and range because potential damages and regulatory fines for mismanagement can be hundreds of thousands up to millions of dollars.

Clients who work with us have the peace of mind that their project will be effortlessly scheduled, successfully completed with minimal down-time for their range, and quickly receive a check for the absolute highest value for their reclaimed lead or use their lead proceeds in our new store! MT2 guarantees to pay the highest percent of LME lead value – no one pays more than MT2!

Learn More about Lead Liability Mitigation: https://mt2.com/firing-range-liability-mitigation/

The post If Your Gun Range Offers Services as a Firearms Dealer-You Must Understand How to Prepare for an ATF Inspection. appeared first on Firing Range Services | Gun Range Cleaning Services | Shooting Range Cleaning Services| Firing Range Lead Maintenance | Shooting Range Lead Mining | MT2.com.

from Firing Range Services | Gun Range Cleaning Services | Shooting Range Cleaning Services| Firing Range Lead Maintenance | Shooting Range Lead Mining | MT2.com https://mt2.com/blog/11798-if-your-gun-range-offers-services-as-a-firearms-dealer-you-must-understand-how-to-prepare-for-an-atf-inspection/

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davidbwalliam · 4 years ago

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How Competitive Shooting Sports Became Popular

Whether you’ve been to a gun range and seen a true marksman at work or watched shooting programs on television, the sport of shooting is a sight to behold. However, many don’t realize the place that competitive shooting holds in history; or the advancements that have been made.

How Far We’ve Come

3,000 years before guns were invented, the Egyptians were shooting at targets with slings. Hieroglyphics depict bows and arrows used in competitions. Competitive shooting has a strong foundation in history!

During the Medieval ages, the crossbow became a means of sport. From hunting competitions to William Tell’s infamous apple shot, Europe developed the shooting concept as a sport further. Shooting clubs were founded as early as 1100. The first shooting clubs were formed by German-speaking peoples in the 13th and 14th centuries.

Of course, while the origins of shooting date back that far, it wasn’t until the gun was invented that the sport truly rose to the place we now know.

Earliest Firearm Competitions

When the first firearms came around in the 1600s, it wasn’t long until they took over the sport. During the Frontier era of American history, turkey shoots were organized as a sport. This was when the Kentucky rifle became popular. Men would have one shot to hit a wooden target or a marked tree, and the winner would get anything from food to money.

We’ve come a long way today! We wrote a helpful article on our blog titled: “3 Tips to Improve Your Shooting Skills At The Gun Range” – you can read it here: https://mt2.com/blog/11026-3-tips-to-improve-your-shooting-skills-at-the-gun-range/

The 1800s were the prime years of shooting sports, with Annie Oakley and Buffalo Bill becoming two of the most known figures. Trick and trap shooting became popular in this period, but it wouldn’t be until later in the century after the Civil War that things elevated.

The first pistol shooting competition took place in 1860, where two men shot at plates from 100 feet away. Five years later, Buffalo Bill began holding shooting events and spreading the idea of shooting as a sport through the U.S.

The NRA was founded in 1874, one of the first national shooting federations in the world. These federations organized numerous shooting competitions and continue to do so to this day. Skeet shooting, firing at clay pigeons, came about in the early years of the 20th century, but just a few years before, the first “Olympics” took place.

Welcome to the Olympics

In 1896, a French pistol champion named Coubertin hosted the first Olympics consisting of nine sports. The shooting portion of the event involved four pistol competitions and two with rifles.

Since those days, shooting events in the Olympics have advanced to include shotguns. But even more than that, the games became more inclusive. Margaret Murdock achieved a silver medal in 1976 to become the first woman to win a medal in Olympic shooting.

This brought about women having their own events beginning in 1984 with the air rifle, three-position rifle, and sport pistol events.

U.S. shooters mostly dominate the modern Olympics and shooting competitions in general. Shooting sports have come a long way from the slings and arrows and continue to progress and grow. Television shows like “Top Shot” created a reality competition with shooting various ranged weapons even beyond the televised events.

It’s not just about accuracy anymore, but the speed and the ability to transition between multiple firearms or hit targets at varying ranges. Shooting competitions continue to garner support and interest, primarily due to media and celebrities becoming more involved with firearms. As advances are made in weaponry and marksmen continue to attempt the “perfect shot,” the history of shooting sports will deepen and become even more competitive.

Guest Author Bio:

Richard Douglas is a long-time shooter, outdoor enthusiast, and technologist. He is the founder and editor of Scopes Field and a columnist at The National Interest, Cheaper Than Dirt, Daily Caller, and other publications.

About MT2:

We operate from regional offices across the country and always pay the highest value for range lead Guaranteed!!!!

You Operate the Firing Range. We Get the Lead Out!™

www.MT2.com

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davidbwalliam · 4 years ago

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Interview from the Firing Range Virtual Summit: Kutak Rock Discuss the Biden/Harris Administration on the Firearms Industry

As part of their Firing Range Operations, Safety, and Lead Management Thought Leadership Series for FFLs and firing ranges, MT2 Firing Range Services and FFL Consultants sponsored a Virtual Summit focused on helping gun range owners and retail services dealers successfully optimize firing range and retail operations.

Topics covered:

Proper lead management of recyclable lead

Range construction expansion & design-build considerations

Legalities with ATF – inspections and liabilities – how bad is bad when it comes to inspections?

Preventing straw purchases & range suicides

HR: Hiring/firing during “uncertain times”

Legal: What lies ahead for FFLs if there’s a Biden / Harris administration, liability pitfalls for range and retail operators, and what legal protections should be in place to protect FFL’s from the ATF inspection process and civil lawsuits?

The new Form 4473 – Highlights and Updates Explained

Firearm Business Insurance: Can you survive a crisis? Vast differences in firearms-related business operations require policies tailored to meet your needs

The hot topic issue of the day is this Biden-Harris administration and what it means to the industry as a whole; what is an overview of what we can expect?

Joe Kavan: I would caution anyone as we talk about some of these legislative proposals that might be coming through by way of this new administration. Traditionally, if you go back for the last 20 years, there is a degree of alignment based on a specific Party concerning firearms control initiatives. However, you can’t guarantee it. Many Democratic Senators and Democratic Congressmen represent districts don’t like additional legislation pertaining to firearms.

So you can’t guarantee that just because the Senate may have one member who happens to be Democrat or have one member control of the Senate, the Senate will always vote in lockstep, same way with Congress.

We’ve seen people go back and forth on the aisle; that’s important from the perspective of most of the initiatives that the new administration has been talking about. There will require Acts of Congress changes, and most of them will have to pass both Houses of Congress. That’s an essential element. There’s a lot of stuff that can be done by Executive Action, but the majority of these initiatives are going to have to be approved by Congress. Even if they are passed, bear in mind what the composition of the Supreme court is. Over the last four years, there have been many appointees to the Federal District Courts and obviously to the Supreme Court. Many of these acts and laws that get passed will have to work their way up through the courts before they’re declared constitutional or unconstitutional.

We can make some predictions about some of the things they’ve said and how this will work out, but we aren’t going to know a lot until we get the full administration and then find out exactly what they’re planning.

What do you see there as far as potential executive orders?

Joe Kavan: We’ve heard that President Biden has indicated that he wants to reverse an Executive Order from about a year ago. This would be changing the export governance of firearms and certain ammunition from the Department of State to the Department of Commerce. In other words, from ITAR to the EAR. And that was a long thought initiative on this that started with the Obama administration, and then the only hangup was in this class of particular firearms. And it took the Trump Administration to get that through with the Executive Order.

People are finally getting used to doing this under commerce, and it’s been working pretty well. It’s much more streamlined to do it under commerce, unfortunately, now because there is a lot of rhetoric out there that the state department and ITAR should be controlling this, it may well be easily pushed back to the state department. And then it’s going to have to be administered under that. Now, there will have to be corresponding regulations associated with that. They’ll probably just go back to the same regulations they had before. And so now we’ll be back under that same regime. It begs the question, “will there still be congressional notification requirements?”

We’ll have to see how that all plays out. If it goes back by far, presumably, the congressional notification stuff will go back in place because of that statute.

What direction do you see Ars/MSRs going?

Joe Kavan: Well, let’s remember, in 1994, then-Senator Biden, in conjunction with Senator Feinstein, were some of the major proponents of the assault weapons ban. There was so much resistance that the only way they could get that passed was to put a tenure cap on; that limitation went away in 2004. And then the manufacturing sale of the so-called assault weapons and large-capacity magazines went back in place. Universally, almost all of the Democratic candidates had been pushing for an assault weapons ban. It has been stated time and time again by President-elect Biden, while he was campaigning, and he had it on his website, that he will push for an assault weapons ban on the manufacturer and sale of so-called assault weapons.

And I think we all know what those definitions are, but they’re modern sporting rifles, as well as large-capacity magazines. He’s even gone so far as to say he will ban these items’ manufacture and sale and then require the current ownership of those types of firearms to be governed under The National Firearms Act. So presumably, everyone that has them now would be required to register them. Now you go, “Wow, how’s that going to happen?” They’re talking about a buyback program for these types of items, and bear in mind, and I think this is extremely important.

We can’t forget. Senator Harris was the Attorney General for California when many of the California laws went into effect. So a lot of these, she was the architect. Many of these California laws that most people in the firearms industry just loved so much were started by then, Senator Harris, and by then-Attorney General.

And so, if you want to look at what could happen, look to California. To make matters a little bit more interesting, President Obama appointed then-Vice President Biden to look at what type of gun legislation could get put in place as a Vice President. So if President Biden does the same thing with his Vice-President, well, she has the playbook. She has the playbook for what was done in California. Add one more thing. The current Attorney General for California, Xavier Becerra, has been mentioned numerous times as a potential Attorney General under the new administration. So if you put all of those together, you would presumably think that the playbook would be bad.

Mike Brown: Also, when she was Senator, Harris supported two assault weapons bans that Senator Feinstein authored in 2017 and 2019. And she was adamant and very outspoken against Heller on second amendment issues.

Can you speak about the AR pistols and everything that happened with QLLC?

Joe Kavan: What we’ve heard is just absolutely anecdotal comments. And we’ve seen a few letters. We’ve seen a few of the pieces going back and forth concerning the short barrel rifle issue. We’d be guessing about how and why all of this went down. The fact of the matter is that most gun manufacturers were submitting the braces for approval from the ATF, from the firearms branch, and the technology firearms branch. And they were waiting for them. I think in this case, that is something went awry, and the relationship went sideways. This was the first time we’ve seen that; bear in mind that it was a proprietary brace. It wasn’t a brace that had been approved previously.

Many of these manufacturers that are making this type of firearm right now are using braces that had already been approved. So this was a proprietary brace. I mean, there are several factors in that matter that would lend one to say, yeah, but there were some unique circumstances in this case. And I think that’s what is the case here. We don’t know the full background of what happened there. We don’t know the relationship that was going on. We don’t know how all of that worked out. And maybe they didn’t want to wait, and they just decided to move unilaterally on this thing without waiting for approval. And this is the kind of thing that happens when you don’t go through the usual channels.

However, it will be interesting under the new administration because it sounds like The National Firearms Act will become much more prevalent. And there’s always the concept of a short barrel rifle. If this administration will be putting modern sporting rifles, like assault weapons and large-capacity magazines, under the auspices of The National Firearms Act, it would be a quick and easy piece to clarify a short barrel’s definition rifle. So that many of these existing pistols that are out there with a brace, the collapse, the world brace, whatever the case may be, they could quickly throw those into the mix.

We saw it before with bump stocks; an executive action can clear that up by regulation. It wouldn’t surprise me in the least if that gets cleared up very quickly and throws one more of these types of firearms that are out there under the auspices of the National Firearms Act.

It is recommended to seek partnership, get answers, and go through the processes.

Joe Kavan: Bear in mind that there’s no question as a log jam at the firearms technology. Many people have been submitting these samples and the rules changed a bit not too long ago; you didn’t have to submit as many samples. It put some new requirements on this, and that’s fine. That’s entirely within their purview to do. So everybody complied and submitted their samples, and people were very frustrated. We got a lot of phone calls about the log jam at the technology branch. And you can jump up and down and complain and do anything you can. At the end of the day, it works your way through the queue.

We have received phone calls from people asking for our best guess about if they didn’t wait to get approval before going to market. And I said, “Boy, that’s a big risk.” Based on past examples, when you don’t wait, and it goes South, it goes really, really South.

I would not like to be on the other end of what you have to send out that letter and face the backlash of all of their customers saying I have to spend $200 now to register this. I have to tear it apart immediately. I have to give part of my gun away to be compliant. So you get this registered, that’s kind of a nasty ramification or a nasty letter you have to send out to your customers. I don’t think that will affect their business. The issue is, do you really want that happening?

Mike Brown: A part of Harris’ platform was revoking manufacturing licenses for manufacturers who violate the law. So if she is put in charge by the President of these things, that may very well percolate subject to the Senate.

I don’t think that any gun legislation or firearms legislation will probably be the number one priority coming out of the gate. Still, we’ll have a little more color as to what the administration is going to look like and maybe get a little better guess as to what type of initial 100-day agenda they have. Bear in mind that many of these bills have been sitting in Congress for two or three years.

Joe Kavan: The Protection of Lawful Commerce in Arms Act is one of the pivotal protections that manufacturers and dealers have had since 2005. There has been no secret about the credit incoming administration’s desire to eliminate the Protection of Lawful Commerce in Arms Act. During the last congressional session, a bill was introduced to repeal the Protection of Lawful Commerce in Arms Act.

And I’m sure that bill will be re-introduced. And if Congress is controlled by a Democratic Senator or Congressman, that probably will get passed, then we’ll have to see what happens in the Senate. Don’t forget why the Protection of Lawful Commerce in Arms Act was passed. There were several states, cities, and Attorney Generals who were suing firearms manufacturers. Some of them were because they had a product out there that increased the cost of medical assistance and law enforcement because they had firearms on the streets. I mean, some of these were some pretty absurd arguments, and some of them were getting way off the track.

It was directed at trying to shut down the firearms industry. And so the Protection of Lawful Commerce in Arms Act was put in place to protect that. If that goes away, we’re going to be right back in that same regime and these nuisances. And most of them were, in fact, a nuisance. And you’ll see more, and more of them will come up, which will make insurance much more expensive, and that’s going to be a significant problem, and Protection of Lawful Commerce in Arms Act would go away. We have heard time and time again that the firearms industry is immune to lawsuits due to the Protection of Law Commerce in Arms Act. And the fact of the matter is that this was a carefully drafted bill, and there are some exceptions to the Protection of Lawful Commerce in Arms Act. Our firm has defended some manufacturers in these cases and won due to the Protection of Lawful Commerce in Arms Act.

Some lawsuits have been initiated, alleging one of the exceptions to the Lawful Commerce in Arms Act that has been successful. Not the least of which is the Soto case. The case up in Connecticut, and this most people know it as Sandy Hook. And that is using one of the exceptions to the Protection of Lawful Commerce in Arms Act. And as of right now, that lawsuit is continuing, except for the Remington bankruptcy, but the judge has allowed that lawsuit to go forward. So the concept that this was some blanket immunity for the firearms industry is just absolutely false. But to have that go away, the ramifications could be very, very dramatic.

Mike Brown: The mayor of Kansas City, Quinton Lucas, has already filed another one of those lawsuits against firearms manufacturers for increasing the cost of public safety, police and fire response, and that sort of thing. And that case is being a slow walk through the courts because of the pandemic, and everything is just proceeding very, very slowly right now in our court system. But if something should happen in the early term of the new administration, that case could accelerate.

Can you give an overview of the PLCAA?

Mike Brown: It protects the entire industry: manufacturers, retailers from liability arising out of the lawful sale of a firearm. The exceptions typically involve unlawful sales, negligent entrustment, knowingly participating in a straw purchase, things that you might expect not to have protection for. If they do their due diligence at the point of sale and they run the background check, and they get a next proceed. They don’t have any other extrinsic evidence of a straw purchase where people are acting funny or somebody comes in and gets denied, and their buddy comes out of the car and comes in and buys the same gun, and you see that because it’s in front of your glass storefront. Somebody comes in with a marijuana card, and you see it in their wallet, these sorts of things that you knew or should have known reasonably that this sale, there’s something wrong with this sale. That falls under the exceptions.

Is it correct that the PLCAA will only protect the straw purchase if they do everything correctly?

Joe Kavan: The most significant distinction is that when you’re looking at the letter of the law violations from the standpoint of a revocation hearing. We’ve all seen the notice of violations where numerous boxes have not been checked on the 4473; you get written up by the ATF. The ATF pool will come back and perhaps certainly give you a warning conference, maybe even revoke your license if you continue to do that. Nothing else happened by and large; none of those firearms were used in any crime or any injury. It ends there. I mean, the ATF has limited ability to find you; in some cases, they can pursue criminal sanctions against you, but by and large, going through the whole exam process and finding these types of violations are one thing.

However, when you get into the civil realm and an injury of any type, there is an absolute playbook for plaintiffs’ lawyers. It’s a well-written playbook by many of these anti firearms advocacy groups backed by many giant anti firearms law firms and money behind this.

So it’s a very, very important act for the firearms industry. And bear in mind one more thing I want to add about that is that if the PLCAA would go away, so let’s go back to having it in place right now. With it in place, we seldom see an action that goes through the dealer back to the manufacturer. It’s challenging to get back to the manufacturer; if you look at all of the exceptions of the PLCAA, how would the manufacturer know that this was a straw purchase? There was no negligent entrustment. There was no negligence per se. And so the manufacturers have a great deal of protection of the PLCAA. Even if there is a liability at the dealer level, it doesn’t get back to the manufacturer.

We could probably see if this goes away, cases where they’re alleging that this dealer sold the firearm knowing, or should have known this, and the manufacturer sold it knowing it as well. This is precisely what happened in all of these nuisance cases by cities and Attorney Generals before this law was passed. The automobile industry has laws like this. The pharmaceutical industry has laws like this. There are industries out there that it’s in the interest of commerce in the United States to protect from these types of losses. So this isn’t a unique act just for the firearms industry. It exists in all kinds of industries throughout the United States.

Mike Brown: We’ve seen those exact allegations filed in courts. Again, they’re local court cases that I’ve represented the dealer on. But here in Kansas City, we had a lawsuit. It was the genesis for the City of Kansas city lawsuit against the manufacturer that I mentioned earlier. But they’re alleging that the manufacturers sold several very inexpensive firearms directly to the purchaser on the FFL license number, but they essentially drop-shipped these firearms as one part of the problem. It turns out he was a straw purchaser; he pled guilty to that.

But that was the genesis for the mayor of Kansas City, going after the manufacturer for putting these firearms into the local stream of commerce and causing the city enhanced expenses in police response, medical, and the like.

I like to say that people, policies, procedures, and training can go a long way to going around willful if you make sure. Whether it’s with the help of FFL consultants or you’ve got the software and good strong, robust policies and procedures in place to double-check your 4473 at the end of the day and make sure your A&D book is accurate. You must keep good records and make sure your frontline sales personnel follow the same procedure with every customer. Sometimes straw purchasers are impossible to identify if they do it right; it’s going to be virtually impossible to figure it out. Other times, it’s right there, standing on the other side of the counter in front of you. And those are the ones that you need to be catching.

You can say what you want about willfulness, and yes, absolutely, if you’re going to protect yourself from these types of losses, which will cost you an absolute fortune, win or lose, they’re very, very expensive to defend. If you want to protect yourself against that, do everything according to the letter of the law. Have your procedures down to make sure that every box on the 4473 has been checked. Make sure that your A&D books are up to date immediately. All of your forms are in place; anticipate an inspection. Those are the things you can do but bear in mind; there is the stuff that falls out of the sky as well- it’s that straw purchaser where you would not have been able to identify the straw purchase. Still, if there is a crime committed, if there’s a civil liability associated with the use of that firearm, they will be brought into this thing.

Another aspect of this that we have seen in recent years was that the plaintiffs start using this concept of violation of laws concerning the marketing or sales of a particular item. And that’s precisely what happened in the Soto case and the Sandy Hook case. It’s important to understand that you need to comprehend all the aspects of the exception of the PLCAA.

And there are a lot of brilliant lawyers who are plaintiff’s lawyers, just trying to figure out a way ways around this. And that whole concept of the violation of the Connecticut unfair Trade Practices Act is exactly why Soto has survived for such a long time. And those are the kinds of things that just come out of the blue. I mean, who would have known that the way those people were marketing those firearms, that someone would have come up with that argument and said that, “Oh, well, because they were showing these type of ads, it suggested this.” I mean, it was a very noble way to approach this, and you have to recognize the fact that they got through the judge, and she let this continue.

Again, pick up the phone, see what’s going on. Right after that was alleged in the Soto case, we received many phone calls asking if we would look at marketing materials to assess how they are displaying their products, to see if it would violate laws. These Fair Trade Practices Acts are all over the board, every state has one, and they’re all different. So it’s difficult to say what would work or not.

Watch the full video interview on the MT2 Firing Range Services Virtual Summit; click here

About Kutak Rock

The only AmLaw 200 firm with a national firearms industry group. While other law firms might claim they serve the industry, Kutak Rock has more than 20 lawyers focused specifically on the business and legal needs of firearm, ammunition and accessory manufacturers, and dealers and ranges. Kutak Rock offers turnkey services, able to serve every legal need our clients require. We are a true industry group.

KutakRock.com

About MT2 Firing Range Services

MT2 is the Firing Range Lead Management Authority. We operate from regional offices across the country and always pay the highest value for range lead Guaranteed!!

You Operate the Firing Range. We Get the Lead Out!™ – Contact us today to learn how we can help you keep your range safe!

https://mt2.com/trust-your-contractor/

The post Interview from the Firing Range Virtual Summit: Kutak Rock Discuss the Biden/Harris Administration on the Firearms Industry appeared first on Firing Range Services | Gun Range Cleaning Services | Shooting Range Cleaning Services| Firing Range Lead Maintenance | Shooting Range Lead Mining | MT2.com.

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davidbwalliam · 4 years ago

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Risk Of Hiring Small Scale Lead Salvagers For Your Gun Range Maintenance Services. Expectations vs. Reality During a Site Visit.

Recently MT2 Firing Range Services completed a site visit for a gun range needing lead reclamation. A Gun range site visit service is a standard practice we routinely complete for more extensive projects, which consist of:

Tailgate meeting at range location to discuss the purpose of the visit, identifying customer need, concerns, goals for the outcome of firing range lead reclamation, and or maintenance services for their range project.

Discuss sampling if required for lead reclamation, treatability, and or remediation purposes.

Walk the site to identify site conditions to determine access, off-site challenges, potential pathways of concern (wetlands, waterways, streams, ponding), stormwater discharge.

Determine what equipment may be the best use for lead reclamation (time and cost savings)

Typically sampling consists of:

Identify sampling locations and depths on a map or Google Earth locations.

Add range dimensions; add information to Chain of Custody.

Take digital photos of sampling locations, target systems, firing lines.

Something very interesting happened on this site visit!

Because of how the RFP read, it sounded like it was an existing project that just needed updating. When we inquired about the status before the site visit, they told us that the lead removal project had recently been awarded, but they ran into pretty dramatic issues after choosing the contractor with the lowest bid.

Below is the timeline of events of what they communicated to us happened:

The contractor was hired who submitted the lowest bid.

The contractor showed up with equipment and began working on positions.

Their equipment broke down a day or two into lead reclamation.

The contractor began hand sifting.

The contractor was let go on the spot.

The old saying “what you seek is not always what you get” rings accurate with small-scale lead contamination salvagers! Chances of this happening increase when the undertaking is of such complex nature it requires best management practices.

The Potential Risk You Face When You Compromise

If you are a gun range owner, you must be mindful of complying with all of the EPA and OSHA regulations. As easy as it may be to assume any lead salvager is aware of these laws, any deviation in the quality of work is a risk that falls squarely on your lap. This is called “Cradle-to-Grave,” and we wrote a thorough article with an infographic here.

Bear in mind most small-scale salvagers are often under-insured. To add insult to injury, limited resources associated with small-scale salvagers sometimes can hardly cover for any liability, and this leads to the perfect recipe for disaster.

Cost Implications

In some instances, fines and penalties levied for noncompliance or claims against harmful practices are sufficient to bring down a gun range business. In one case, South Carolina caught everyone’s attention when an environmental organization faced action for knowingly neglecting to protect its workers against lead poisoning. The resultant fines totaled a whopping $480,000! We compile a list of news stories related to this on our website here https://mt2.com/industry-research/

While There is Potential Risk, the Good News is That There is Help! Below are a few items to consider when hiring a lead maintenance contractor to perform services on your gun range.

Prequalification of Gun Range Contractors:

For gun range owners, it is essential to ask the gun range reclamation or lead maintenance contractor to present the following:

Documented audited financials (Complete with firm’s equity) The financials should be adequate to cover any claim or contractual breach.

Contractors must carry comprehensive insurance coverage, including Pollution Liability. ~At MT2, our $10 million insurance package protects the owner/manager and range because potential damages and regulatory fines for mismanagement can be hundreds of thousands up to millions of dollars.

The contractor must provide project contract documents.

The contractor must provide, upon request, their operating history and list of completed projects.

While they struggle to learn the ropes, small-scale lead salvagers can also miss stringent OSHA regulations and deadlines. Unfortunately, your gun range can’t accommodate this. The results can be unacceptable work delays, revenue loss, and depending on state legislation, fines and penalties. For any degree of success, you should turn to professionals for this particular job.

MT2 has never received OSHA or EPA violations. In fact, not only does MT2 comply with regulations, but we have also helped establish industry standards for environmental and safety methods.

Get a FREE quote for your range at the most cost-effective & BEST VALUE with the LOWEST RISK and get the Highest value for reclaimed lead based on our #1 Nationwide position in the industry. No one reclaims more lead or finishes a project faster than MT2!

Click on the Contact tab above to reach out to the MT2 Range Engineer in your region!

www.MT2FiringRangeServices.com

The post Risk Of Hiring Small Scale Lead Salvagers For Your Gun Range Maintenance Services. Expectations vs. Reality During a Site Visit. appeared first on Firing Range Services | Gun Range Cleaning Services | Shooting Range Cleaning Services| Firing Range Lead Maintenance | Shooting Range Lead Mining | MT2.com.

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davidbwalliam · 4 years ago

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Workers’ Compensation Service for Shooting Ranges | Facts and Considerations to Protect Your Firing Range Employees

The following is a brief overview of workers’ compensation and what it provides. We’ve included some essential bullet points specific to Workers’ Comp services for gun ranges to help you control your costs and improve your employees’ safety.

What Is Workers’ Compensation?

Workers’ compensation insurance helps protect businesses and their employees from financial loss when an employee is hurt on the job or gets sick from a work-related cause. Workers’ compensation is also known as workman’s comp, workman’s compensation, and workers’ comp. These terms all mean the same thing and help protect workers from potentially devastating costs of work-related injuries. It also helps protect employers from potential damages that could cripple a business based on workers’ comp claims. Most states require companies to carry workers’ compensation insurance except for Texas and New Jersey. In those states, coverage is elective.

What Does Workers’ Compensation Cover?

Another frequently asked question includes the coverage of workers’ compensation insurance. Workers’ compensation insurance helps cover medical expenses, lost wages, ongoing care costs, as well as funeral expenses if an employee is hurt, becomes sick, or dies as a result of a work-related accident or illness.

What Is Not Covered by Workers’ Comp?

Workers’ compensation insurance can help protect your business and employees in the event of a covered loss. Still, some situations take place on the job that workman’s comp insurance cannot cover. These vary from state to state and are typically determined by different state laws.

Here are a few examples of what most workers’ compensation plans do not cover:

Injuries received by a fight that an employee started

Injuries an employee sustains due to being intoxicated in the workplace

Injuries an employee gets intentionally

Emotional injuries that are not accompanied by a physical workplace trauma

Work comp for shooting ranges has historically been a headache. Today over 85% of shooting ranges still buy their workers’ comp from the state pools because they don’t think they have options. SAGE has been providing real workers’ comp solutions for several hundred ranges since 2007. We proudly support the shooting sports industry and are here to serve. Here are a few key things to consider for your firing range:

Growth – There’s been tremendous growth, over 8.4 million first time gun owners, in 2020! All of these people are looking for places to shoot and need proper safety training. Most ranges have added staff to accommodate this new demand, which results in higher payroll. Work comp premium is calculated off of an estimated payroll at the start of your policy. If you’ve had growth, you need to talk to your insurance carrier or agent and let them know so they can adjust your policy. If not, you’ll owe more money at the final audit.

Safety – With growth comes a faster pace that can lead to safety procedures being overlooked. You must take time to review your safety programs and employee training procedures. Keeping your employees safe should be a #1 priority; slow down and stay focused.

Experience modification factor – this factor is used to compare your work comp experience against the industry. A “credit ex mod” means your experience is better than your peers, while a “debit mod” means you’ve had some claims. It’s important to note that any claim you have will impact your ex mod for three years.

Claims – Statistics prove claims reported in the first 24 hours of the injury are settled 59% faster and with dramatically lower costs. Here’s a hint: Most insurance companies are in no hurry to close work comp claims. The longer they stay open, the longer your ex mod factor will remain high. It would be best to work with an insurance partner who understands this and can get claims closed.

Lead exposure – Believe it or not, proper lead handling/cleaning training and removal procedures are the first questions SAGE considers when underwriting a firing range. Ranges with proven comprehensive safety training procedures, utilize proper PPE’s, and work with certified lead management companies, like MT2 Firing Range Services, receive additional pricing discounts. Lead is no joke and can have a significant impact on your employee’s and public’s safety, which can hurt your business today and for years to come.

Final audits – At the end of your work comp policy, you’ll be asked to verify your actual payrolls for the year. The biggest issue many gun ranges face at the audit is the payroll allocation for employees who work in retail vs. range employees, and it gets messy. Although the rules can vary by state, in most cases, an auditor will put the payroll of a retail employee in the range classification if that employee ever steps foot in the range. Like most ranges, an employee will spend time behind the counter and on the range as an RSO or cleaning. You must keep exact payroll breakdowns so that you can make a case for split payroll. Again, you are most likely dealing with an insurance company/state that doesn’t know how ranges operate or don’t care.

Premium payments – Once the premium is established, the insurance company will set the payment terms for the premium. These terms typically range from 100 percent down, 50 percent down with one installment, 35 percent down with three payments, or 25 percent down with five payments. Many shooting sports businesses, more than 80 percent, are insured with state funds/NCCI (National Council on Compensation Insurance) or assigned-risk pools. The payment plans for these policies often require larger down payments and fewer payments for the balance. This has a real effect on the cash flow of a business. If your policy is on installments, your premium payments will remain the same regardless of payroll fluctuations unless you contact your insurance agent or the company. For businesses that have seasonal operations or shifts in payroll over the year—outdoor ranges, for instance—having the ability to pay based on actual payroll is a very attractive option. This type of payment plan, offered by only a few insurance companies, is known as “payroll reporting.” SAGE offers payroll reporting and other payment options, including a zero deposit plan.

Knowledge of the industry – You must work with an insurance agent or company that understands the shooting sports industry. Many things can go wrong that can leave you holding the bag. A low price might look good but take the time to investigate the company and coverage behind the policy.

About SAGE Program Underwriters

SAGE Program Underwriters is a leading national insurance organization that creates insurance programs for industries often neglected by the insurance community. SAGE has been proudly providing workers’ compensation to ranges, retailers, and manufacturers since 2007 and is a member of NSSF®, a Gold Sponsor of SHOT University, and a Partner Organization of Project ChildSafe®. To learn more about SAGE, visit our website at https://www.sageuw.com/ or email us [email protected]

Best Practices for Preventing Bullet Ricochet at Firing Ranges and Protecting Shooters and Range Employees Special Considerations When Changing HEPA Filters to Protect your Firing Range from Lead and Lead Dust MT2 Firing Range Services Earned Designation as a Great Place to Work Certified™ Company in 2019

from Firing Range Services | Gun Range Cleaning Services | Shooting Range Cleaning Services| Firing Range Lead Maintenance | Shooting Range Lead Mining | MT2.com https://mt2.com/blog/11701-workers-compensation-service-for-shooting-ranges-facts-and-considerations-to-protect-your-firing-range-employees/

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davidbwalliam · 4 years ago

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Firing Range Virtual Summit: Conversation with Tom Chittum, Assistant Director of Field Operations with ATF, and Alphonso Hughes, Assistant Director of Enforcement Programs and Services.

Topics covered:

Proper lead management of recyclable lead

Range construction expansion & design-build considerations

Legalities with ATF – inspections and liabilities – how bad is bad when it comes to inspections?

Preventing straw purchases & range suicides

HR: Hiring/firing during “uncertain times”

The new Form 4473 – Highlights and Updates Explained

Firearm Business Insurance: Can you survive a crisis? Vast differences in firearms-related business operations require policies tailored to meet your needs

SPECIAL KEYNOTE PRESENTATION: Thomas L. Chittum III | Assistant Director of Field Operations Bureau of Alcohol, Tobacco, Firearms, and Explosives (ATF) “The Important Role FFLs Play in Protecting Themselves and Their Communities”

Watch the full video interview on the Firing Range Services Virtual Summit; click here

Tom Chittum: I want to start a little bit by talking about just the year in review, 2020. It has a particular significance. Of course, the pandemic has affected all of us, but it had a tremendous impact on gun sales. The business has been brisk for the firearms industry, then the civil unrest came and added a new dimension to the challenges we were all facing. Whenever I speak to groups, I always like to start with a little discussion about the law. Of course, I’m the lawyer. I work as a professional law enforcement officer, and I think that’s where we start. Often, whenever we start talking about firearms law, we turn right to the statutes or the regulations.

But I’d like to bring your attention to the opening section of the Gun Control Act. If you have a copy of the federal regs, you can open it up and read it yourself. If you don’t have a copy of it, it’s available on ATF’s website. I want to read a section from the Gun Control Act’s purpose because I think it’s essential to keep everything we talk about in perspective. “Congress hereby declares that the purpose of this title is to provide support to federal state and local law enforcement officials in their fight against crime and violence. It is not the purpose of this title to place any undue or unnecessary federal restrictions or burdens on law-abiding citizens with respect to the acquisition, possession, use of firearms appropriate to the purpose of hunting, trapshooting, and target shooting, personal protection, or any other lawful activity.” I want to start by pointing out that Congress’s motivation in passing the Gun Control Act was to help law enforcement fight against crime and violence.

That’s ATF’s core function. We do that a few ways. One of them is by reaching out to the FFL community. How do FFLs make themselves and their communities safer? Well, first, you, of course, provide legal access and essential training to law-abiding, responsible adults who want to possess, purchase or train with firearms. But it is not an exaggeration to say that FFLs are also the front line of defense against armed criminals in our communities. The reality is, we know that most of the firearms that are either stolen from gun stores or trafficked are recovered in crimes locally. Gun stores are interested in protecting themselves, of course, from being victims, their businesses because it’s costly, and their communities. When we talk about the importance of federal law, it isn’t very sexy to talk about record keeping. But the foundation of the Gun Control Act is record-keeping and licensing. I encourage all industry members to take particular diligence in keeping track of their records.

When a firearm is recovered in a crime, and it always will be, law enforcement has to investigate that firearm’s life through firearms tracing. It’s something that my partner Alphonso will talk about in a moment. Keeping diligent and accurate records about purchasers’ identity is important to us to be able to identify firearms tracking schemes when they occur. One particular area I’d like to talk about is gun store burglaries, FFL burglaries. For many years, I have worked on this topic to educate the industry on things they can do to protect themselves. I want to mention some statistics that are available on ATF’s website. You can go and search for infographics. But from 2015 to 2017, we saw a significant spike in gun store burglaries with the high-water mark in 2017; 577 FFL burglaries were across the country. More than 7,800 firearms were stolen. That was alarming to us because it isn’t firearms enthusiasts driving stolen cars through the front of gun stores or committing smash and grab robberies.

These guns are destined to end up on the black market. We wanted to take an aggressive approach to try and drive those numbers down. In 2018, we saw those numbers reduced through our strategy by about 20%. The number of burglaries dropped to 427. We kept our foot on the gas, and again, in 2019, the numbers dropped by about 20% again, down to 343. However, in 2020, we began to see a spike, and we saw a significant spike around the riots and looting that occurred in late May and early June. What was our strategy? Back in 2017, when we saw all these burglaries and robberies spiking, it was multi-pronged. As Benjamin Franklin said, we believe that an ounce of prevention is worth a pound of cure. We started conducting outreach doing training sessions. Of course, we partnered with National Shooting Sports Foundation for Operation Secure Store to educate businesses about best practices.

I know in the firearms industry, the retail industry, not all of the stores are large retail outlets. Many of them are small proprietorships, and the cost of an extensive security system may seem daunting. But what we know is that people can take some necessary steps to prevent burglaries from occurring. Let me talk a little bit about some of those. First is the structural security of your business. That means locked doors, windows. Some places with bars, making sure roofs are secured, walls and using barriers outside of the business. We encourage the use of a security system, install one and use it. Too often, what we find is the security system was either not functional, not turned on, or had gotten out of date. Video cameras are vital to us because they serve a deterrent value to your customer, and they also provided crucial visual evidence when crimes do occur. Of course, inventory safety is essential. Read our article here on: Gun Range Service Recommendations Go Beyond Addressing Lead Maintenance-Firing Ranges Must Consider If Their FFL Is Next on a Criminal’s Hit List?

In many of these burglaries, we have seen a very methodical approach to shattering glass, grabbing handguns, and then running. Of course, they’re the lightest, and they are the most frequent type of firearm used in crimes in America. Then make sure you use best security practices like lighting, visibility to your store. Making sure that bushes are cut back, so police that drive by can see. You can also undertake general business practices, conducting physical inventories, reconcile to your books, and make sure that your records are accurate. That way, if you are the victim of a burglary or a robbery, you’ve got accurate records to report to the police and insurance. Conduct employee screening, make sure that you guard against internal theft. Have a security training and security policy and training programs, so the new employees know exactly how to handle transactions. Make sure that you notice, record, and importantly report suspicious behavior. We find in a lot of these burglaries that there’s some level of casing the joint.

They’ll come, look, and test whether or not there’s security. By being alert to these attempts, we can often connect them to actual burglaries at later dates. I know that sometimes the concern is, these are costly measures to put in place. But one of the primary things you can do at the end of your day is wipe down your countertops. Glass surfaces are good for preserving fingerprints, giving us biological evidence to pursue in investigations. You have the added benefit of walking in the next morning to a spick and span storefront. The last thing I would say about these business practices is to plan for disasters, natural disasters. In the past, we have seen major natural disasters like hurricanes cause a spike as gun stores are left unattended as police are otherwise occupied. We have seen burglaries occur in those situations. Of course, we hadn’t seen anything like the civil unrest at the time that it happened. Thankfully, through the proactive approach, both ATF and industry members, many gun stores relocated their inventories or secured them before the unrest occurring in their area.

Even if you take all the best precautions, you may still end up being the victim of a burglary. I’d like to talk a little bit about what to do if that occurs. First, you’ve got to ensure employee and customer safety. Do not enter a crime scene or a potential crime scene. Do not disturb possible evidence. Immediately report the crime to the police, but importantly, report it to the ATF as well. The law requires FFLs to report thefts to ATF within 48 hours. If you’re a fan of crime TV, you know those first 48 hours are essential. We want to know immediately when a crime has occurred to start our investigation then, not days later. Use your reconciled inventory to provide a list of stolen firearms to the police. Then, of course, you submit the ATF theft loss report. Also, notify ATF of any recoveries. From time to time, what we will see is the records were inaccurate, and a firearm that was reported stolen actually ends up being in the inventory and was just misplaced.

I mentioned the prevention aspect to combat and reduce FFL burglaries. We do presentations like these at a local level. We do seminars or webinars. When COVID hit, ATF tried to use our resources as effectively as possible. While we were at a maximum telework posture, we began a telephone outreach initiative. We were using our IOIs to make telephonic contact with licensees. We found that we could reach many gun stores that may never be inspected or haven’t been inspected recently and may not have a strong, established relationship with the local ATF. We want to reinforce to everyone that ATF is still open for business. We are here to help you answer the questions you have and make sure you conduct your business lawfully and responsibly. The telephonic outreach had an added benefit. As the civil unrest occurred, ATF continued to use telephonic outreach, having IOIs for gun stores, encouraging them to protect their inventories and protect the records as well.

I mentioned those are vital for law enforcement investigations. Also, as the unrest occurred and we pushed out an FFL alert, an automated caller, to notify people that we’re in areas where they may suffer civil unrest to take those steps, it paid off interestingly. We had been tracking burglary statistics, and the numbers were up. During a four or five day span around the spike in riots in May and June, we documented 91 FFL burglaries or burglary attempts. I’m happy to say that more than a third of those attempts were unsuccessful, and the would-be burglars walked away with no firearms at all. I think in my view, that’s a huge success. I’ve tried to reach out through the media to highlight that success. Of course, they’re often more concerned about the number of stolen firearms, and we’re concerned about that too. But I think it’s important to highlight an untold number of firearms that weren’t stolen because of the firearms industry’s responsible and quick action.

Part of our outreach is also to educate the public and to seek their help. When these burglaries do occur, we often offer rewards for information. NSSF has been an essential partner to us and matches the rewards ATF offers. Increasing the likelihood that someone will call us with information. That’s been successful, and when we make arrests, we try and publicize those to let people know this is not a minor crime; they’re quite serious. In fact, in the recent past, ATF agents have gotten into shootings trying to investigate FFL burglary. These are guns that are destined for the black market. After prevention and collaboration of our strategy to reduce FFL burglaries and robberies, the third prong is through aggressive investigation. In 2017, ATF instituted a 100% FFL burglary response protocol. We respond to all burglaries and investigate them. Of course, we look for solvability factors.

It’s always helpful when we have video evidence. Working with our state and local partners, issuing rewards, what we found is that we have been successful in making a lot of arrests and recovering some of the firearms. I say some because we don’t often recover all of the guns. The fact of the matter is, when guns are stolen from gun stores, they usually hit the streets very quickly. We see them turning up in crimes, often violent crimes. But those are just a few of the things that I wanted to emphasize about FFL burglaries. The bottom line is, the risk of these burglaries is increasing again after significant decreases. There are steps that the firearm retail industry can take themselves, installing structural protections, following safe business practices, and having a disaster plan. Then, finally, reporting these burglaries and these attempts when they occur immediately to the police and ATF. Now, stolen firearms are only one source of crime guns. Of course, criminals seek to arm themselves in other ways too.

The daring among them may drive a car through the front window of your store, but others may recruit conspirators such as straw purchasers. I want to talk a little bit about store purchasing. Of course, when I speak about firearms trafficking, there is no such legal term as firearms trafficking. Firearms trafficking is a law enforcement term, and it’s a layman’s term. When we cross acute firearms trafficking schemes, what we’re prosecuting are the underlying crimes—for instance, making a false statement to an FFL or in records required to be kept by an FFL, of course, conspiring to transfer firearms to a prohibited person. Burglaries can be considered a firearms trafficking offense too.

Legitimate bonafide gifts are not straw purchases. Some encourage if someone is buying a firearm on behalf of someone else, that you work with the gun store so that the actual buyer completes the forms. They are perhaps using a gift card or a gift certificate instead of purchasing the firearm themself.

As with FFL burglaries, there are things that gun stores can do to be alert and to detect attempted straw purchases. The first thing is, it’s just a good business practice to know your customer and ask questions. When somebody comes in and is looking for a firearm, it makes sense to ask them questions about what they want to find. What you’ll often detect is an attempt to evade your questions, being vague about the purpose. Of course, somebody doesn’t have to tell you why they want the firearm, but legitimate buyers will often want to make sure that they’re buying the gun that they need. They may ask you questions about appropriate as for a particular event. In 2020, of course, we saw a lot of first-time buyers buying firearms. There was a spike. If a person comes in and tells you they’re buying a 22 to go deer hunting, that should cause you to ask some additional questions. It just doesn’t make sense.

Again, if someone comes in and appears to have limited financial means, and yet they’re plunking down $12,000 cash to buy a 50 caliber rifle, you should ask some additional questions. It’s not intrusive; it’s good business to know your customers and ask the questions. When an FFL does detect a potential straw purchase, we ask that it be alerted to ATF. I have spoken at venues where FFLs have said, “Hey, I call, and I never hear back.” That doesn’t mean that ATF doesn’t listen. That doesn’t mean that we don’t investigate. Sometimes we investigate and find that there was nothing improper about the purchase even though it seems suspicious on its face. The fact of the matter is, sometimes it results in prosecutions, although they may not be publicized. In the last year, it emphasized the importance of the firearms trafficking offenses to our multi-pronged strategy of reducing violent crime, which is keeping guns out of the hands of violent criminals or prosecuting violent criminals when they obtain firearms. The Department of Justice has significantly increased the prosecution of false statement cases. We’ve seen a lot more straw purchases and the like being prosecuted.

A couple of the other common indicators when you see bulk purchases or repetitive purchases of the same or similar firearms may ask yourself why. I once received a referral, somebody had bought a lot of the same gun, and I recognized that it was just before Christmas in an area I was familiar with. Upon additional investigation, what I found is they were Christmas gifts for a bunch of sons. Entirely appropriate legitimate activity, not criminal activity, but it’s helpful to look into these things. If you see something, say something: other indicators, no haggling over the price. Often there’s a particular angle to firearms trafficking where we see firearms being trafficked across the Southwest border to Mexico. Of course, cartels have lots of cash to provide for these things. So often, you’ll see straw purchasers want to minimize their contact with the gun store employees. They won’t negotiate over price. I don’t know that anyone pays retail. That’s at least one indicator you should look for.

Paying with large amounts of cash, someone that appears to be an obvious and severe drug user or someone who hasn’t previously purchased and now is purchasing almost daily or repetitively, all indicators that you should look out for. The most important thing to emphasize is that you should know your customers, ask questions, trust your instincts, and maintain complete records. If you think that you have a straw purchase that has occurred or attempted, please report it to ATF. At the outset, I mentioned some of the things that we’ve been trying to do to deal with COVID. ATF remains open for business. Even at the height of the pandemic, our agents were out responding to crimes. I’ve said before; I think it’s worth saying again, I have never been more proud to be an ATF agent than I was in 2020. In response to nationwide riots, ATF has conducted many investigations. A lot of gun store burglaries, a lot of commercial arsons. It’s not an exaggeration when I say we’ve made almost 200 felony arrests for crimes associated with the riots.

That’s possession or use of straw, Molotov cocktails, shootings, illegal possession of firearms, commercial arsons, and the like. ATF agents are working hard every day to keep the communities that we also live in safe. Of course, our collaboration and partnership with the industries have been part of that. We have made some changes in our staffing. Andy Graham was the Deputy Assistant Director over Industry Operations in the office of field operations. He has transferred over to our Enforcement and Programs Services division. In his place, now, Megan Bennett is my Deputy Assistant Director. She helps me execute ATF’s inspection mission in the field. Of course, that’s changed a little bit as we’ve had to maintain social distance. In some of these places where the impact of COVID has been geographically distinct, we haven’t been able to do in-person inspections as much as we would like to. We have been trying to leverage video technology.

Of course, we are doing the telephonic outreach that I mentioned, and we’re making greater use of webinars. We hope that whatever may be lost from the personal touch of in-person communication, we have gained some benefit from being able to reach a lot more people. It’s never quite the same, meeting over Zoom as it is meeting over coffee. But we’re trying our best to stay engaged, to reinsure the industry that we’re here, that we’re available, that we want to help you carry out your business.

Alphonso Hughes: I appreciate the opportunity to provide this audience some updates from the Office of Enforcement Programs and Services. We went through a bunch of changes, both internally and related to COVID. But I’ll start real quick with the personnel changes. I took this position here recently in the middle of the pandemic. Mid May 2020 was the timeframe Andy Graham and I transitioned out of Field Operations to Enforcement Programs and Services. I was formerly the Deputy Assistant Director for the Office of Professional Responsibility and Security Operations, ATF’s deputy Chief Security Officer.

Before that, where most of you have known me from was probably from my days in EPS as the NFA Division Chief and the Firearms and Explosives Services Division Chief. I spent about seven years in that role. Before that, I was a Director of Industry Operations out of our Philadelphia field division. I appreciate the opportunity here to continue that collaboration here. Andy Graham brings a lot of experience from Field Operations. When we think of a policy shop and think of enforcement programs, we provide that policy support to Field Operations; I think it brings a lot of level-headedness. Because what he brings to this side is the inspection protocol. That can be interwoven with the enforcement strategies and applying the law and regulation to how we do business. In NFA, probably some new faces and some new names. Steve Rosenthal took over the position as the division chief out there. Prior, Director of Industry Operations out of our Miami field office.

Both out in the field and also to our service centers, we’ve remained diligent. I could tell you we’ve had a high operational tempo. I can tell you the numbers this year, our second highest to when 41F came up. There was over $50 million in tax revenue collected based on NFA firearms transfers. Gun sales across the nation have increased tremendously, and record-breaking tracing of firearms out there, close to a half-million firearms traces.

I can tell you; my commitment is to make sure that we move forward in communicating with you guys effectively. My hats off to the FFL community out there. I mean, you made it happen, orderly and compliant. I can tell you the trials and tribulations of 2020, a round of applause for yourself in this particular instance here to make sure that you comply with the laws and regulations. I want to talk about a few things here in ATF. I wanted to talk a little bit about monetization. I think I’ve been singing the song for about three years now, four years. ATF has been trying to migrate to cloud services. What that means for ATF is that we take our legacy systems pretty much supplant them and put them in a cloud environment—hoping that they work a little bit more effectively, efficiently, and without data type errors out there. What I’ll say in that respect is, it was a surprise to our IT environment. What happened was all of those legacy systems had to be recodified. They had to be changed. The language had to be rewritten so that they would operate in that particular environment. It wasn’t just a lift and shift. I think that plays along with the delays that we see in moving ATF to that specific environment. One of the challenges is e-forms, and I think everybody was waiting for e-forms for years. We got the form one up, and that was for the tax paid making of a firearm.

But now, we’ve been trying to press forward and get this taxpayer transfer form. The eForm 4 up here for a little bit of a time now. The challenge is that we had this legacy portal that we want to try to integrate. One thing I talked about with our CIO is that we don’t just want to lift and shift and put the eForm 4 up there. We want to develop this Form 4 in an environment where we can give back to the FFL industries. We’ve had recently here October timeframe, some industry sessions as we move closer to the cut-over to where we’re supposed to be in the cloud environment. Is having folks come in and tell us those high volume users of the eForm 4 tell us a little bit about what they want to see in this new type of system. We heard you loud and clear. I think some of the areas are APIs. I think some of that is batch processing of those non-tax paid forms.

We’ve even had input where folks want somehow to integrate third-party processing into the tax paid environment. All of those things are on our kanban board. We’re looking at those types of initiatives, and hopefully, we can make some of that work. Hopefully, we can deliver to you some of the things that you want. I think you’ve been compliant. If we can give you some of these enhancements so that you can operate a little bit more effectively, I think we’re going to try and take those and strive. I could tell you when e-forms comes out; it may be a vanilla version at first. But what we plan to use that agile approach and prioritize those enhancements that we would like to get done down the road.

I think when you look at e-forms and how we’ve leveraged them today, our e-forms timeframes are below ten days. That’s across all forms when it comes to the non-tax paid side. On the tax paid side, I think we’re below 60 days. I think you’ve seen that. Unless an application runs into an FBI delay of some sort, then, of course, we have to wait until those things are cleared up before we can proceed on the application. I want to put out there, and this is big for the importers and manufacturers communities, those of you who have FFLs of those types, and this is what we call pending research. When you develop a new NFA firearm and don’t have to record the particular model you’re making, I would like to offer you the opportunity to write into the NFA division ahead of time, giving us those models ahead of time caliber and barrel lanes. What we’ll try to do is update our database tables before you go into full production.

That way, when you do enter those types of firearms into e-forms to notice them, it will be a little bit easier. It won’t get hung up in this process, what we call pending research. Because if you enter a weapon now that doesn’t exist in our particular database, then what happens is it gets hung up. Then another section comes in and has to do manual data entry and get those firearms in there. If you can let us know ahead of time, I think it’ll lend to a lot more ease and processing for the supply chain for NFA firearms. Lastly, I wanted to touch on is the interim final rule. This is regarding the prohibition on the issuance of improper guidance documents out there. In 2017, the attorney general issued a memorandum to DOJ components on improper guidance documents. I think it gave ATF pause.

Right then, we were questioning, “wow, does this even apply to Q&A? Does this even apply to information that we use in the conducting of our business every day, like variants requests determinations classifications?”

Of course, they do apply to those types of those operations. I think the FFL community has expressed their concern to both congressional leaders and the folks here within the department on ATF’s need to provide guidance, especially in this highly regulated industry. With that said, my advice to folks out there in the FFL community is to continue doing what you do. Submit those variant requests, submit those requests for information, submit your Q&A’s. Behind the scenes, we may have to take a little bit longer and vet that information and go through the process, working with the Department of Justice to get some of the information cleared. It may be a notice and comment situation where we’d have to publish some guidance information.

Or it may be one of those situations where it’s a restatement of the regulations. We can just put that out there with a disclaimer regarding it being regular information that’s available via the regulation. I envision in the future the environment where we can put up one-stop informational pages. FFLs can go through, look at the information they need to refer to, and then we can pretty much help provide by putting out there that transparent guidance that I think folks need to operate daily.

What direction is the ATF going in with the new administration?

Tom Chittum: I can tell you that the only information I have on the Biden administration is what’s publicly available. I have worked for ATF now for five administrations. Inevitably there are always changes in perspective and focus. But as long as I am here, my commitment is that you can continue to count on fair, professional, and effective enforcement of the laws that Congress provides us.

ATFs violent crime reduction strategy is essentially two-pronged. Prosecuting the people that illegally possess or misuse firearms and trying to keep guns out of their hands through firearms trafficking, FFL burglaries, and related crimes. I don’t see that changing. ATF is an agency of limited resources, and we try and focus on them in the most effective way that we can. Central to our strategy is the reliance on concepts and tools that we refer to collectively as crime gun intelligence. Firearms tracing provides incredibly valuable leads. We are using cutting edge technology like ballistic imaging to connect shooting scenes that never would have been connected before. With the limited number of special agents and industry operations investigators that we have, we’re going to continue to try and apply those in the way that gets us the greatest bang for our buck. I say it every time I speak to the agents; they focus on matters of consequence.

The people that are misusing firearms can wreak tremendous havoc on our communities. ATF’s relationship with the industry is significant to us. In my inaugural call with all the directors of industry operations, I reinforced that the gun industry is not ATF’s enemy. We both benefit from a collaborative relationship. We rely on you to be alert and prevent gun crime and report it to us when you can. If you don’t already have an existing relationship with ATF, I encourage you to build one. For all of the downsides to not having in-person contact because of COVID, my hope is that because we have been able to connect on how ATF enforces the laws that Congress gives us.

We have limited resources to do that with, and we’re going to bring them in the way that makes the most sense to try in combating violent crime in our communities. I think that’s something that both the ATF and gun store owners can get behind.

Project Guardian embodied three longstanding pillars of ATF’s strategy: a partnership, working with our local, state, and federal law enforcement partners and prosecutors. Aggressive enforcement of federal firearms laws and use of intelligence to guide those. You can read the public reporting about the record number of prosecutions that have occurred. Again with ATF, I’m proud to say, in a country where roughly 400 million guns are in the hands of 100 million people, we know the vast majority of them will never be used in a crime. With the tools and concepts of crime gun intelligence, we can increasingly target those misusing them or trafficking with precision. That allows us to aim our resources at those that are posing the most significant harm.

Of course, ATF enforces the law. It’s not our place to write the law or push legal boundaries. We are here to enforce the laws that Congress gives us. The National Firearms Act or NFA of 1934 was written on the heels of the increase in prohibition’s violent crime. That law passed when Babe Ruth was still swatting home runs, and Elvis Presley hadn’t even been born yet!

As you can imagine, challenges are applying that law to modern manufacturing and firearms innovations. Now, just because it may be hard to enforce, it doesn’t mean that ATF can shrink from enforcing it. We try and work with the industry whenever. The law, of course, does not compel manufacturers to seek ATF input before they manufacture.

When these issues come to our attention through criminal investigations related to something other than a classification, we can’t simply turn a blind eye. I know in the absence of information, speculation often runs wild. But the thought that ATF is trying to take some subversive approach to make felons out of millions of law-abiding gun owners simply isn’t the case. I have been proud to carry out this job. I think ATF’s role in keeping guns out of criminals’ hands and those that misuse the go a long way towards protecting the constitutional rights of responsible, law-abiding adults.

Alphonso Hughes: I would like to add to the Firearms and Ammunition Technology Division’s topic and their role in providing input evaluations as far as determinations and then classifications.

If there is any question on the status of a firearm, go ahead and submit those firearms for determination. Right now, are they backlogged? Absolutely. It’s a small group of men and women who have to testify in court and have to perform these evaluations both on the import side and the civil side. Then also get these determinations out to the FFL community. My recommendation is, continue doing that, and then we’ll try our best to make sure that we can make sure we meet the bill there.

I can tell you in 2021, we will be getting more FEOs, Firearms Enforcement Officers in that particular division. We’ll even be looking at a whole divisional organizational structure to bolster the ranks.

We want to put out there that guidance for what criteria is and make sure that everybody knows to have a framework to comply with.

To what degree would an IOI be looking at the state regulations?

Tom Chittum: My entire career has been as a special agent conducting criminal investigations. Whenever I do talk to anybody, I’ll say, “Look, I’m not an expert in state law. I enforce federal law.” Federal regulations require compliance with state laws, but ATF is a federal law enforcement agency. ATF is not in the business of enforcing state law.

Alphonso Hughes: The bottom line is FFLs must follow the state laws imposed. Now, the enforcing entity would probably be those state agencies. This is especially true for NFA. For example, NFA outlined in the regulations that we will not put the transferee in violation of state law. If there are state licensing requirements, you have to comply with those. If there are owner requirements based on state law, you have to comply with those as well. ATF has jurisdiction to enforce those federal laws on top of that.

What does the near future look like for ATF in regards to the FFL community?

Tom Chittum: I can talk a little bit about field operations; ATF did not close for business. Of course, the pandemic changed how we worked, but ATF continued to respond to FFL burglaries, commercial arsons, riots, and other crimes that fall squarely in ATFs jurisdiction. We will continue to do that. Of course, the pandemic and the requirements of social distancing, and the pandemic’s varied geographic impact did affect our ability to conduct in-person inspections. Which, of course, we tried to fill with telephonic outreach. I don’t think that much about that will change.

Our strategy continues to be tailored to decision-making at the local level. There are various factors, including the mission criticality of particular activities, the local restrictions placed by state or local governments, and what happens in the winter.

I know that across the country, there are concerns about spikes. We’re, of course, monitoring. We must keep our workforce safe to continue to carry out their critical mission. In many ways, we’re along for this ride the same way all of America is. One thing that you can count on for sure is the continued professional, effective, and fair enforcement of the law.

Watch the full video interview on the MT2 Firing Range Services Virtual Summit; click here

The post Firing Range Virtual Summit: Conversation with Tom Chittum, Assistant Director of Field Operations with ATF, and Alphonso Hughes, Assistant Director of Enforcement Programs and Services. appeared first on Firing Range Services | Gun Range Cleaning Services | Shooting Range Cleaning Services| Firing Range Lead Maintenance | Shooting Range Lead Mining | MT2.com.

Firearms Firing Range Security Public works director in North Carolina Indicted for Illegally Transporting Hazardous Waste From the City’s Shooting Range NRA TV Interviews Jim Barthel President of MT2 Firing Range Services the #1 Gun Range Lead Maintenance Contractor

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davidbwalliam · 5 years ago

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Ready, Aim, Fire: 4 Tips For Learning How to Shoot

Firing Range Services | Gun Range Cleaning | Firing Range Lead Maintenance | Shooting Range Lead Mining | MT2.com - #1 and Nationwide Professional Environmental Firing Range Lead Reclamation Maintenance Contractor for both Indoor & Outdoor Firing Ranges

It can be a little discouraging to see that shooter putting round after accurate round into their target when you’re just starting out. Don’t be fooled, though, because everyone has to start somewhere.

The truth is that shooting like a pro means learning how to shoot and perfecting the muscle memory, so don’t worry about modified shotguns and .50 pistols just yet. Here are a few things to focus on for the beginner shooter

Handle with Care

It’s good to be confident with your firearm, but humility can save lives. Especially in the beginning, you might not know all of the rules for properly handling your weapon, and that’s okay.

In this case, though, it pays to learn them before you accidentally make a mistake, you can’t take back. You must not aim your gun at anything you don’t want to destroy, or locking up your firearm when not in use can be the difference between life and death.

That’s why one of the most significant recommendations for first-time shooters is to take a class or learn from a trusted friend that knows what they’re doing. It will also help with the next tip.

Get Comfortable

Becoming familiar with your weapon, or weapons, of choice is an essential early step in your shooting journey. You don’t have to know the difference in weight when there’s one bullet less in your magazine, but a basic understanding of your weapon will help with your experience overall.

Get your palm used to the feel of the grip, the resistance of the slide when you pull it back, or the recoil of your weapon. If your handgun has a hammer, practice cocking it to build the muscle in your thumb.

Of course, do all of these things with an unloaded weapon. That’s why safety was the first point on this list because misfires are one of the leading causes of firearm-related deaths.

One quick note is to find the caliber and weapon that suits you. Just because your friend likes a .45 that he can barely hold doesn’t mean you should go the highest caliber possible.

What matters is to be able to hit what you aim at and be able to replicate it. You want a gun that your wrist can control when it recoils, too.

An excellent way to find out the gun that fits you is to go to a range.

Hit the Range

Many ranges tend to have various weapons on-site that you can rent, sometimes for a deal. You might want to ask to hold a few and rent the promising ones that feel most comfortable.

Pick ones that you can hold out with stability, meaning they don’t sway all over or drag your arm down with their weight. Remember that a fully-loaded magazine will add another pound or two to that weight.

Once you’ve got your options, head to the targets, and follow the safety tips when you load your weapons. Set your target somewhere around 20 or 25 feet if you’re trying to figure out the best choice for you.

If you get a tight grouping (3-5 rounds in a close area) and the weapon feels good in your hand, that’s probably the best one for you. After you’ve decided, then you can start working on your technique and building familiarity.

It can be tempting to show off, but remember that it’s all about accuracy. Most civilians should practice with home defense in mind, which means the situation will be within 20 feet in most cases.

Practice For Consistency

Speaking of accuracy, the final piece of advice is to be consistent. Being able to fire 100 rounds per minute doesn’t mean anything if you can’t hit your target.

Settle on a comfortable stance and relax your posture. If you’re tense, you might jerk your weapon when you shoot.

Squeeze the trigger with the pad of your finger and control your breathing. Use your off-hand to steady the wrist or grip.

Keep both eyes open when you fire and retain the sight picture after you shoot. Again, follow those rules of safety at all times.

The best way to get better is through perfect repetition. You don’t want to build bad muscle memory or get used to bad habits.

Create a routine and practice like it’s the real thing every time. Focus on hitting your target with every shot and adjust when you don’t, but remember to shoot with confidence.

Have fun and be safe when you’re learning how to shoot, and you’ll be able to shoot with accuracy in no time!

Need to find a firing range to shoot at? The NSSF has a wonderful resource at WheretoShoot.org

Guest-Author Bio:

Richard Douglas is a long-time shooter, outdoor enthusiast, and technologist. He is the founder and editor of Scopes Field, and a columnist at The National Interest, Cheaper Than Dirt, Daily Caller, and other publications.

MT2 is the Firing Range Lead Management Authority who specializes in providing environmental firing range services, and lead remediation. We are the nation’s #1 largest professional contractor for all your indoor and outdoor firing range service needs including: o Lead cleaning services o Lead reclamation & Brass recycle o Range Maintenance, HVAC systems support o Consulting and Assessment by our OSHA/EPA experts! o Range Construction and Renovation o Lead Remediation & Abatement

MT2 is the Firing Range Lead Management Authority

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Observations from MT2 Firing Range Services After Spending a Day in a Concealed Carry Class from Tactical Self Defense and Firearms Company in Colorado Tips to Avoid Lead Exposure – Firearm Use Best Practices for Preventing Bullet Ricochet at Firing Ranges and Protecting Shooters and Range Employees

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davidbwalliam · 5 years ago

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Interview With MT2 Firing Range Services CEO, James Barthel About Firing Range Construction and Design-Build Services

What considerations should gun range owners understand about planning upgrade services for renovating an existing outdoor range to improve customer appeal, safety and account for expansion?

James Barthel: MT2 has been involved in providing lead cleaning and maintenance services to outdoor gun ranges for over 20 years. We assist them in expanding and increasing their safety related to lead cleanup, lead removal, maintenance, increasing their customer appeal. We’ve done a wide range of construction and design projects. Some of the projects we get involved with would be extending a range and moving a range further downrange. We’ve been involved with increasing the height of a berm to keep bullets on site. We’ve been involved with a major retrofit of a trap and skeet club to help prevent lead and shot from going into the water, which is an essential point of focus these days with EPA and others.

The considerations that we get involved with from a design-build would be, looking at the Surface Danger Zone (SDZ) as far as ballistics of what’s being shot? How do we keep shooters safe between ranges?

Our design focuses on separation walls and barriers and the different materials needed to meet that need effectively. The ability to improve an outdoor range’s capabilities for managing and reclaiming lead shot and lead bullets from their backstop or the floor is another area we focus on. We’ve been involved in planning considerations for the shooting range floor and how to improve that material on the surface to help maintain its operability and manage the lead. Of course, there are targeting systems and replacement of knee walls that ranges want to look at, and we provide them a perspective that a typical contractor cannot. As the #1 firing range services contractor, we provide gun range cleaning and lead maintenance and a comprehensive firing range for indoor and outdoor range needs. This includes Shooting Range Lead Mining, Lead cleaning services, Lead reclamation & Brass recycling, Range Maintenance, HVAC systems support, Consulting and Assessment by our OSHA/EPA experts, Range Construction, Renovation, and Lead Remediation & Abatement. MT2 Firing Range Services Uses Exclusive PATENTED Technologies That NO Other Gun Range Services Contractor Can Perform.

Another unique approach MT2 provides our clients includes environmental considerations for range improvements. Cleaning up and renovating a gun range and improving environmental health and safety for the employees, shooters, and the community! With stormwater, especially on the outdoor trap and skeet ranges, there’s a need to manage the retention basins, redirect stormwater pathways, and ensure that the lead stays on the range.

Are there different considerations that go into the design and build renovations of existing indoor ranges?

James Barthel: You bet, we’ve been working in the firing range services industry for over 20 years and have successfully completed over 3000 gun ranges including services including Lead Mining, Lead cleaning services, Lead reclamation & Brass recycling, Range Maintenance, HVAC systems support, Consulting and Assessment by our OSHA/EPA experts, Range Construction and Renovation, and Lead Remediation & Abatement. About half of those projects have been indoor ranges where we help the operability, maintainability, and renovation of the range.

From a design standpoint, this could include a ventilation system upgrade or modifications to the ductwork, and ventilation testing in the range itself, which you wouldn’t usually see in an outdoor range. We work with some of the industry leaders in the ventilation area and have good relationships to bring our firing range clients.

The maintainability of the ventilation systems and the filtration systems is essential, as well as upgrading the lighting. Some of the old ranges we all used to go to were pretty dark, and with new targeting systems, active systems, then new lighting’s required.

Many new materials are out there for sound mitigation on the walls and the ceilings regarding the sound. Certainly upgrades to improve the OSHA aspects for the workers and the shooters ensure that the lead dust is not in contact with them. Installation of the new and renovations of their current bullet traps. There’s a whole new generation of bullet trap systems out there from numerous manufacturers. We provide the service to our gun range clients of replacing components of bullet traps whenever this is needed on a project.

All of that goes into the consideration of modifying the indoor firing range. Then there’s, of course, the baffling systems and how to put the bullets where we want them to go. Ultimately then, it comes down to operability, maintainability of doorways, electrical systems, and access. Those are all kinds of renovation projects that MT2 gets involved with from a design-build standpoint for indoor gun ranges and outdoor gun ranges to provide services that are the most professional in the industry.

What should firing range managers and owners think of when considering building a new firing range?

James Barthel: Well, we like getting involved upfront in new firing ranges because we can avoid problems we’ve run into from the range projects in the past. We feel like if there is ever a speed bump in a project, we can eliminate it in the future. By building a new gun range, you’re starting with a fresh slate and fresh design.

I think it would be essential to talk about the types of contracts typically used with design-build and the insurances required to do this kind of work. Typically design-build is done under a firm fixed price, cost plus, or guaranteed maximum price basis, and MT2’s experienced with all of those. You want to make sure you’re dealing with a licensed contractor and somebody who’s got direct experience, prior experience with ranges. Being licensed and having that direct experience is essential.

We like to recommend that you look at a firing range construction project in equipment neutral design-build operations; MT2 is not trying to sell you a specific piece of equipment that we manufacture….because we are not in that business. We focus 100% on gun range cleaning and lead maintenance services with comprehensive firing range services. As the nation’s #1 range support firm, MT2 specializes in safety and environmental assessment, consulting services, lead reclamation, range and bullet trap installations, maintenance cleaning, renovations and improvements, lead-waste management, construction, and construction management of new ranges. We work with all the industry partners to provide the best system for that specific range, so I think that’s an important piece.

Regarding bonding, you want a design-build firing range contractor to deliver your range project that will turn out well, especially in new construction services of a gun range. There should be some skin in the game with the firm; payment performance bonding is essential.

Lastly, insurance coverages are often something range owners don’t consider, whether they’re doing a renovation or a new build. General insurance or general liability insurance only covers the general aspects of the work. By policy, it expressly excludes any of the environmental hazards like lead, so if there’s any lead involved whatsoever, you’re not covered if you have general liability insurance. MT2 Firing Range Services offers 10 million dollars of pollution liability insurance, general liability insurance, and builders insurance to ensure that the outcome of the range project is top-notch.

In addition to looking at the types of equipment, targeting systems, ventilation systems, traps, and the specialty range equipment, we also work on the electrical, mechanical, civil aspects of what needs to be done at the site. As far as the business management side, we work with the other firms to make sure that when that range is built, whether it’s a new indoor range or a new outdoor range, it’s ready to go.

Watch the rest of this informative interview on the MT2 Firing Range Services Virtual Summit; click here

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Gun Range Cleaning Tips: GunStuff TV Interviews James Barthel, CEO of MT2 Firing Range Services about and Lead Reclamation for Indoor and Outdoor Shooting Ranges Important Considerations When Evaluating Qualifications to Select a Firing Range Lead Reclamation, Maintenance, Cleaning & Construction Contractor MT2 Firing Range Services Announces Opening of New Expanded East Coast Office and Hiring of Eastern Region Environmental and Construction Operations Manager.

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davidbwalliam · 5 years ago

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Gun Range Service Recommendations Go Beyond Addressing Lead Maintenance-Firing Ranges Must Consider If Their FFL Is Next on a Criminal’s Hit List?

Guest Blog Post By John Bocker, FFL Consultants, who is a presenter of our firing range virtual summit.

Being an FFL comes with some angst, especially when you lock up each evening and head home leaving your firearms protected by gates, alarms, cameras, and …

Wait a minute. Did I just say, “protected by cameras and alarms?”

Today’s brazen firearms thieves are not deterred by cameras and alarms. If they were, the frequency of FFL burglaries we’re seeing now wouldn’t be happening. As I explained for a group during a recent Operation Secure Store workshop hosted jointly by the National Shooting Sports Foundation and the ATF, alarms, and cameras only tell you how and when a burglary occurred – they don’t prevent it!

And the criminal is getting a little 9not a lot) smarter by wearing hoodies and ski masks to avoid recognition by the camera surveillance system and are in and out of your premises in under two minutes—and that’s very often long before your alarm company notifies you or the police of a break-in and actually have law enforcement arrive in time to make an apprehension. This continues to be the most discouraging aspect of being a gun store or firing range owner. You go to sleep each night just hoping that you won’t be the next victim!

So, there it is. Cameras and alarms don’t actually protect and prevent criminal thefts. But what does? Short of removing all your firearms from cases and racks each evening—which is time-consuming and can damage inventory—what cost-effective strategies can you consider for ramping up your security program?

To answer that question, first, conduct your own security assessment and inspect to identify your vulnerabilities. Start out at the street or curb and work your way in, just like a burglar would:

From the street or curb, does your place of business look like it’s going to be a challenge to break into?

Are bushes, trees, and foliage trimmed back to eliminate hiding areas for criminals while they attempt to penetrate your store?

Are your exterior lights on timers and motion sensors? Do exterior flood lights identify after-hours activity bring attention to people lurking? More lights are better than no lights in the middle of the night when vehicles, neighbors, and law enforcement passing by can be alerted to unusual after-hours activity.

Can you use chains or gates to close off your parking area after hours and restrict vehicles from entering?

Do you have bollards, boulders, oversized planters, or other substantial obstacles installed to prevent smash-and-grabs through your doors, windows, and other vulnerable areas? If not, can you park a company delivery vehicle in front of doors? Crime surveillance shows that physical barriers deter criminals, slow down the very determined, and are perceived as making your store a hard target by thieves assessing your location for attack.

How is your glass protected? 3M Lexan security film, laminated glass, roll-down or scissor gates, and burglar bars all provide security layering to deter easy glass-smashing entries. Remember, too, to remove landscape rocks and pavers from your exterior to prevent them from being used to smash your windows and doors.

Are your firearm displays visible from outside after hours? I recommend turning lights off in the firearms area if it’s visible from the street so that criminals can’t immediately see what’s available. If guns are visible when peering into your store after hours, even with the lights off, inexpensive black fabric draped over the cases can hide what people can see when the shop is closed.

Are you using security hinges that have pins to hold doors in place if cut or tampered with?

Do you have guard plates or astragals covering latch strikes and deadbolts to prevent crowbar prying of doors?

Are you using one or more deadbolts on all exterior door entries?

Are fire exits protected with high-security egress panic devices that hold doors in place using the door frame itself versus a deadbolt? How about barricade locks? There are many two-, three- and four-point locking systems available for emergency exits, and though they can be expensive, they are a wise investment.

Are all roof hatches, HVAC vents, and ductwork protected with alarm devices or anti-theft bars, or grating? Are ladders and pallets stored away from the building or secured to prevent easy access to the roof? Check with your co-tenants regarding their roof access if you are in a strip center.

Do you have glass-break sensors installed? How about wall-vibration sensors that detect entry through walls by sledgehammer or vehicle? Such break-ins are becoming more common.

Are all your alarm system components tested monthly for positioning, sensitivity, and communication?

Can you move one or more firearms floor safes in front of your main doors at night to show criminals looking in that gaining entry will be a challenge?

Can you install roll-down gates that separate and barricade your firearms display area away from the rest of the store?

Can you install plywood barriers, slat-wall, or shelving in areas where someone may attempt to smash or cut through an external wall or a wall shared by a neighbor?

Can you add high-decibel sirens, a fogger system, or strobe lights to your alarm system inside your store that disorients burglars and drive them away before accessing your firearms? Can you add external sirens and strobes to your building exterior to draw attention (and potentially drive away someone attempting a break-in) when your alarm is activated?

Do you have a public-view monitor that customers and anyone casing your store can plainly see during open hours, thus alerting them to the fact you have a live-recording surveillance system?

Do you lock your showcases after hours? If capital is available, can you replace current handgun display showcases with tamper-resistant laminated glass or vandal-proof cases that use security shutters after hours? For long gun displays, can you install security cables?

Can you install warning signage in your front window? Try something like, “All firearms removed and secured after hours” or “Guard dog on duty after hours.” Keep the bad guys guessing!

To help with this process we created the Security & Risk Self-Assessment tool. This is available for you to download right here: Click Here for free download

As an FFL, you have a responsibility to do everything you can to strengthen your security and present yourself as a hard target for criminals. Hopefully, this list will help you assess your current security program and offer suggestions for improvements you can make.

FFL Consultants support experts are standing by to assist you with any physical or operational security or safety issue you may have including design, planning, training, and crisis management.

John Bocker is Co-Founder of FFL Consultants and an NSSF Security & Compliance Consultant Team Member. Have a question regarding this article or any FFL related security or ATF compliance issue? Contact John at (720) 336-0028 or [email protected]. To see a complete list of FFL Consultants services, CLICK HERE or VISIT our site.

About MT2 Firing Range Services:

MT2 is the Firing Range Lead Management Authority who specializes in providing environmental firing range services, and lead remediation. We are the nation’s #1 largest professional contractor for all your indoor and outdoor firing range service needs including: o Lead cleaning services o Lead reclamation & Brass recycle o Range Maintenance, HVAC systems support o Consulting and Assessment by our OSHA/EPA experts! o Range Construction and Renovation o Lead Remediation & Abatement

MT2 is the Firing Range Lead Management Authority

The post Gun Range Service Recommendations Go Beyond Addressing Lead Maintenance-Firing Ranges Must Consider If Their FFL Is Next on a Criminal’s Hit List? appeared first on Firing Range Services | Gun Range Cleaning | Firing Range Lead Maintenance | Shooting Range Lead Mining | MT2.com.

Firearms Firing Range Security Rodman’s Neck, NYPD Pistol Range in the News – MT2 Firing Range Services Responds to Article on the Importance of a Lead Maintenance Plan for Firing Ranges Video Reviews about MT2 – Professional Firing Range Lead Reclamation Maintenance Contractor for Both Indoor & Outdoor Ranges.

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davidbwalliam · 5 years ago

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Firearms Firing Range Security

Guest Blog Post By John Bocker, FFL Consultants

If there’s one thing that can surely ruin your day as a gun dealer – it’s the mid-morning call from your alarm company advising you that “several points of detection are activating at your store or range”. UGH! This is something I have dealt with more than 300 times across my 30 years as a career Risk Management professional. And if there is one thing I know for sure, it’s the fact that as long as there are bad guys being born – there will be burglaries!

According to ATF’s FFL Theft/Loss Reports, in 2019 there were 343 reported burglaries at FFLs and 4,490 firearms were reported stolen. That’s really significant progress, down from 577 FFL burglaries in 2017 when 7,841 firearms were reported stolen.

There will always be criminals planning their next big heist, and that means security will always be a top concern for retail firearms dealers and firearms range operators. Theft is never going away, but often a few smart investments can greatly reduce your exposure to losses. It all comes down to finding the right security solution for your budget and situation. Let’s look at the minimum requirements and recommendations you should consider for your gun range. In doing so, we’ll assume that your range is also selling or storing firearms on the premises and subject to ATF requirements for maintaining accurate inventory records and reporting stolen firearms.

Also, for this article I’ll focus on affordable security solutions you should consider right now.

Experience tells us that most criminals targeting a firearms dealer will first “case” your location, looking for obvious vulnerabilities, security systems in and not in place and opportunities to successfully complete their crimes. Most FFL burglaries today are also committed by more than one individual, and stolen vehicles are frequently used to crash through a vulnerable access point to affect a smash-and-grab crime. Therefore, your “impression of control”—what criminals will perceive to be obstacles to their success—will go a long way towards preventing a burglary.

Common vulnerabilities that criminals look for when targeting a firearms dealer or range include:

Lack of adequate perimeter and site security measures, including fences, bollards, landscape design and exterior lighting. Exterior lighting that doesn’t illuminate all night or include motion sensing activation will be noted by criminal elements.

Building designs that lack security considerations, including smash-resistant doors, gates, glass, security grills and gates, exposed perimeter walls and easy roof access.

Lower-quality, non-commercial locks and door hardware or missing lock guard plates. Commercial grade and key way-controlled (keys can’t be copied) access points, dead bolts, guard plates, emergency egress locks and secondary locking mechanisms will be noted as deterrents to criminals.

Alarm systems, including those that encompass glass protection, interior motion sensors, door and access panel contacts and panic buttons.

Lack of security and adequate lighting in loading docks, shipping and receiving areas

Opportunities to access unprotected HVAC systems, roof access doors, panels, and duct work.

Older, outdated security cameras and monitoring systems. Also, systems that are not readily visible (the public can see the cameras) can also be seen as a lack of security. Remember, this is about your impression on criminals. If they don’t see cameras and assume you don’t have such a system in place, you become a more promising target in their eyes. That doesn’t mean hidden cameras won’t catch them in the act, but wouldn’t you rather deter a crime rather than deal with the aftermath of one?

Cameras that aren’t in every place they should be. In addition to exterior and interior points of vulnerability, cameras should monitor all gun range activity (which also serves as a safety and liability safeguard), firearms handling areas and firearms storage locations. With these, public-view monitors demonstrate to visitors—including those with criminal intent–that you have serious security investment and monitoring.

Inferior firearms storage inside your facility. This can include utilizing or not utilizing high-security showcases, firearms safes, cable locks and secure stockrooms.

The minimum protective measures firearms retailers and range operators should consider include:

Planning and preparedness through a site-specific threat analysis and vulnerability assessment.

Discuss a “consequence analysis” with your management team, in other words, what would be the downsides to the business if a burglary were to occur? This kind of perspective—interrupted customer traffic, sales commission loss, pay cuts, job loss, etc.—can help increase awareness of suspicious customers and overall store security.

Develop a crisis response action plan in the event a burglary should occur. This should include a discussion and outline of everything you would have to do in the 48 hours following a break-in.

This last item, your crisis response action plan serves another purpose. Once you’ve created this plan, you can use it to review, upgrade or redesign the basic security requirements of your range. In addition to the areas of vulnerability I talked about earlier, you should also regularly examine:

The flow of range customers from entry-to-exit. Consider how you customers can enter and exit safely with their firearms? Can customers enter casually carrying rifle cases (if permitted) without interfering with retail customers shopping? Is there quick and easy emergency egress available out of the range if necessary?

Considerations for carry of personal firearms, ammo bags, etc. through your store, past all retail product areas and controls in and out of the range. We trust our customers but shoplifting is an inherent challenge when operating a retail store. Having a direct route to and from your range is typical when combined with a retail operation. This may simply mean having a wider unobstructed aisle designed through the retail area. And then consider what retail items would be appropriate to stock and display at or near the range entry for last minute impulse sales. You’d certainly want to stock ammo nearby but in a controlled area to comply with state laws.

Any webcam-enabled system that alerts you to activity and lets you check in on the store from any internet-enabled device. With such setups, make sure you can adjust the sensitivity of detection to avoid false alarms, which can happen if electronics (e.g., a cooling system or wireless router) switches on or off during the night.

Safety and emergency communication systems that enable employees to manage range activity and make announcements.

Your cyber security, such as those systems that protect your computer information systems, intrusion prevention, membership and POS data, retention of electronic range liability waivers, etc.

Physical security is where your store’s anti-criminal efforts begin, but you and your employees are also critical to your security program’s success. Never be afraid to encourage your staff—and even your customers—to follow the now common public rule of “see something -say something.” Communicate any concerns to all staff and certainly to local law enforcement and even the ATF when appropriate.

To support your efforts to improve your physical security, we have created the FFL Retail & Range Self-Assessment. This tool is available to you right now: CLICK HERE

Download this and other FFL Resources right now: CLICK HERE

Do you have questions about your firearms range or store security? FFL Consultant’s team of support experts can help you assess the need for improved or upgrade physical security requirements and pre-build design support. For more information, visit www.fflconsultants.com or contact John directly at [email protected] or call (720) 336-0028. John Bocker Co-Founder at FFL Consultants and an NSSF Security Consultant and Compliance Team Member, serving FFLs nation-wide.

MT2 is the Firing Range Lead Management Authority who specializes in providing environmental firing range services, and lead remediation. We are the nation’s #1 largest professional contractor for all your indoor and outdoor firing range service needs including: o Lead cleaning services o Lead reclamation & Brass recycle o Range Maintenance, HVAC systems support o Consulting and Assessment by our OSHA/EPA experts! o Range Construction and Renovation o Lead Remediation & Abatement

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Observations from MT2 Firing Range Services After Spending a Day in a Concealed Carry Class from Tactical Self Defense and Firearms Company in Colorado MT2 Firing Range Services Celebrates 20 Years of Providing Environmental Gun Range Services, Lead Reclamation and Remediation. Before-After Photos of the Services for the Lead Reclamation Process at an Outdoor Gun Range

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