Are We Boycotting Wildcat Moderators?
- Thread starter Klenchblaize
- Start date
Slight legal issues in not selling parts for an item that when sold was described as having spare parts available and the item serviceable ( there are actually laws about having parts available on serviceable items once the model is discontinued ). IE if ford discontinued the fiesta today they would need to sell parts for 5 years after. These where sold as serviceable items yes? Nothing to do with the insurer saying the parts need proof , the company cannot effectively stop selling the parts just like Ford couldn't stop selling the current fiesta and telling folks " tough"
I fear another FAC column for “Moderator Pressure Components” with a maximum number to be “purchased at any one time” and “held”.
Problem solved!
K
Problem solved!
K
A barrel is a part of a firearm - I agree.
That is definitely not what the rules say. They say than an attachment 'forming part of any barrel' must be proofed. Detachable mods arguably do not in any sense form 'part of a barrel', as I've pointed out previously. They're not part of the barrel, they're not part of the firearms. They are a removable accessory, which doesn't form part of the barrel.
Exactly. If it isn't part of the barrel when attached, it doesn't need to be proofed.
Why do you keep saying it forms 'part of a barrel'? It really doesn't. Hitching a trailer to a car doesn't make the trailer a car-part.
It is not the 'discharging of the load' through something that makes is 'part of the barrel': that phrase about discharging or containing the load is used in the definition of a barrel in the context of the barrel being a part of a firearm.
These detachable items including mods are not in law 'part of' anything, let alone the barrel - they are rather accessories.
ChesterP
Well-Known Member
This has been posted before when this topic came up some years ago, and it helps clarify the law:
http://jacksonrifles.com/zz-silencers/files/proof-counsels-opinion.pdf
In particular, attention is drawn to this paragraph:
"It is necessary to engage in the above analysis in order to decide whether what the law requires to be proof tested are ‘parts of a barrel’, or ‘parts of a small arm’. Applying the normal rules of statutory interpretation, and looking at the applicable legislation and statutory instruments as a whole, it seems clear to me that the law relates to ‘parts of a small arm’. The Nick Doherty 3 Proof Authority pronouncement of October 2001 suggests that detachable sound moderators “form part of the barrel” and therefore have to be proof tested. In my opinion this is misleading for two reasons, firstly it is not part of a barrel (unless attached to it at the time of test), and secondly the law requires parts of a small arm to be tested, not parts of a barrel. The question that needs to be asked is:-“Is a sound moderator part of a small arm?” The answer is clearly “No”, as a small arm is whole and complete without it. Although, as I have indicated, the issue is whether it is part of a small arm, this argument applies equally well if one was considering whether it is part of a barrel. I would therefore suggest that if a small arm is submitted for proof testing with a sound moderator attached, the Proof Master can choose to include the sound moderator in the test and mark it accordingly if he wishes. The law does not require him to do so."
Moderators are required to be entered separately on your FAC so are treated separately rather than considered in law to be "part" of a barrel. There is no requirement to list the serial number on the FAC, and what is applied for is a slot for a moderator suitable for a specific calibre. If this were not the case, none of us would have approval for our moderators. The confusion lies in how the barrel is proofed. If a mod is fitted at time of proving then clearly it forms part of the proof for that barrel but the law does not compel a moderator to be fitted, but does require that screw cutting (AFAIK) the barrel requires proving. So we are free to buy a rifle with a slot for a mod' and then fit that mod with no requirement for proof of the mod. We can all interpret the law in different ways (as clearly this thread shows) but the law, whilst arguably a bit of a mess in understanding, currently requires no proof for any moderator and it is left to those having the proving done whether they include it or not. QED, for the purposes of current legislation, a moderator is not considered part of the small arm, but is considered separately on the FAC. If that were not the case then most, if not all of us have got it wrong as have our l;icensing departments.
http://jacksonrifles.com/zz-silencers/files/proof-counsels-opinion.pdf
In particular, attention is drawn to this paragraph:
"It is necessary to engage in the above analysis in order to decide whether what the law requires to be proof tested are ‘parts of a barrel’, or ‘parts of a small arm’. Applying the normal rules of statutory interpretation, and looking at the applicable legislation and statutory instruments as a whole, it seems clear to me that the law relates to ‘parts of a small arm’. The Nick Doherty 3 Proof Authority pronouncement of October 2001 suggests that detachable sound moderators “form part of the barrel” and therefore have to be proof tested. In my opinion this is misleading for two reasons, firstly it is not part of a barrel (unless attached to it at the time of test), and secondly the law requires parts of a small arm to be tested, not parts of a barrel. The question that needs to be asked is:-“Is a sound moderator part of a small arm?” The answer is clearly “No”, as a small arm is whole and complete without it. Although, as I have indicated, the issue is whether it is part of a small arm, this argument applies equally well if one was considering whether it is part of a barrel. I would therefore suggest that if a small arm is submitted for proof testing with a sound moderator attached, the Proof Master can choose to include the sound moderator in the test and mark it accordingly if he wishes. The law does not require him to do so."
Moderators are required to be entered separately on your FAC so are treated separately rather than considered in law to be "part" of a barrel. There is no requirement to list the serial number on the FAC, and what is applied for is a slot for a moderator suitable for a specific calibre. If this were not the case, none of us would have approval for our moderators. The confusion lies in how the barrel is proofed. If a mod is fitted at time of proving then clearly it forms part of the proof for that barrel but the law does not compel a moderator to be fitted, but does require that screw cutting (AFAIK) the barrel requires proving. So we are free to buy a rifle with a slot for a mod' and then fit that mod with no requirement for proof of the mod. We can all interpret the law in different ways (as clearly this thread shows) but the law, whilst arguably a bit of a mess in understanding, currently requires no proof for any moderator and it is left to those having the proving done whether they include it or not. QED, for the purposes of current legislation, a moderator is not considered part of the small arm, but is considered separately on the FAC. If that were not the case then most, if not all of us have got it wrong as have our l;icensing departments.
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I have never understood this in the USA - from an HSE point of view it’s just silly. Especially when you consider how easily a person could make a mod if they did have bad intentions!
On the subject of mods - I tend to go with the Norwegian option -had 4 ATec’s now and they are excellent. You can contact the guys that make them directly if get very good customer service from Jackson rifles.
I do have a couple of DPT’s which are good but don’t seem as good as the A-Tecs.
Regards,
Gixer
Well you could always contact them and ask the question. Is that so difficult ?
BTW on the Wildcat Evos it isn't quite a simple bushing such as you might be imagining. They call it a "bridge piece" and it was designed so that the owner could interchange them readily. Just by hand, if you keep the arrangement cleaned and greased. Maybe a soft strap wrench at the most.
Almost all other moderators do indeed use a "bushing" to match up to your rifle threading. Not generally something that is sold separately for DIYers to swap around.
Of course, nothing to stop you having an adaptor made up to your spec. E.g 1/2" x20 UNF to 7/8 x 24 works well.
Or just standardise all your barrel threads, e.g. to M15x1, or M14x1. BTW if you already have say 7/8x24 , a good smith can turn that down to M15x1 or smaller.
In your dreams (or maybe those of the two Proof houses).
Next thing you'll be telling us is that a thread protector needs proofing.
And that say a muzzle brake also needs proofing.
Witter on all you like, but in no way is a moderator, brake, thread protector, or any other such thing part of the barrel. Nor a barrel in itself. Despite what you might have read, that has not (yet) been tested in law. Hell, even strapping on a Magnetospeed might even fall into that definition.
As for the nonsense that threading a barrel for some such thing materially weakens it so needs re-proofing. A pointless exercise. What, are the proof houses going to actually screw on something like a mod before re-proofing. Of course not. A waste of time, and money that proves absolutely nothing.
Mind you, if you do something ridiculously stupid such as say threading a 308 or 30-06 at 1/2 x 20 UNF (yes some idiots will do that) on your own head be it. But I'm damn sure it would still pass a proof test with nothing actually attached to it.
An imagined conversation, humour me please:
To Birmingham Proof House , You'll have to imagine the Brummie accent).
Hello, I am the Chief designer at CattyWild. We have been making moderators for many years without any problems. But now our insurers and even some customers, are insisting that they must be proof tested before sale. Can you do that for us ?
I'm sure we could do something, if you really think it necessary. It's not a requirement though.
OK initial order would be for one model, in eight different calibres, and five different threadings. Rated for any chambering less than magnum.
Ahh. I'm not really sure we are set up to do that yet. Those calibres?
.17, .20, .22, .270 .30, .375 and .45.
Interesting. Yes we have proof rounds and barrels for those. But they aren't threaded. We are thinking about that. When we do, we'll make adaptors for them for any common thread. What do you use ?
1/2x20UNF, 1/2x28UNEF, 5/8x18UNF, 5/8x24UNEF, 14×1 ,15×1, 18×1
So let's get this straight, you want to send us a bunch of mods in various calibres and threadings. You do realise that for each calibre we have to swap over the test barrel, and then, if the threadings are different for that calibre would have to swap out the adaptor pieces ? Then shoot two proof rounds through each, and visually inspect ?
Yep, that's pretty much what it amounts to. Could we agree on how you would mark them up afterwards, and what chambering of proof rounds would be used for each calibre ?
We can discuss the proof round chambering to be used, and suggest that be the marking. No problem, we'll laser engrave them. There will be a setup fee, but I must warn you, it has been known to happen that a batch of mixed things have sometimes been marked incorrectly, these things happen. But be assured, they will all have been proofed.
Yes these things can happen. But we will know that you have actually proofed each one, because we might even decide to strip them and clean them before sending on to our customers who expect them to look like new. What's it going to cost ?
My boss will work something out, given this information. But, privately, you must realise that we are stretched anyway doing real proofing on proper guns. Proofing mods that you and I don't seriously expect to fail, is rather a waste of our time and resources. We are not even set up to do this properly yet. There are no standards to work to. It will cost you rather less than for say proofing a batch of imported rifles, which need gauging and detailed inspection.
OK thanks, please send us the quote and availability.
Bo Diddley
Well-Known Member
I don't know if I should be a pessimist about this or an optimist... I'm sure we will lose out somewhere in the process!
Heym SR20
Well-Known Member
Actually you have hit the nail on the head. It is exactly what the proof regulations actually say and a muzzle brake does fall into the definition of a device through which a load is discharged. You could argue that a thread protector might not.
It also states in the proof regulations that if a barrel is converted, and it gives the specific example of become a sound moderated barrel that it falls out of proof and needs to be reproofed. They also go onto say that the barrel for reproof needs to delivered with any attachments unless those attachments have independently proofed and so marked.
Quite why the proof houses are not insisting on following their own regulations, particularly after the fact that they redrafted the regulations in 2006 to include the need to proof moderators - well thats a failing on their part.
The fact that it hasn’t been tested in court is irrelevant.
There are plenty of instances of moderators failing. I would suggest that in the event that the failure of an unprooved moderator causes a fatality or serious injury, especially if it was to an employed person would soon result in court proceedings.
As someone else has stated all military weapons with sound moderators and muzzle brakes go to the proof house and are stamped accordingly.
If the regulations were being followed correctly the rifles would be sent to the proof house with an attached moderator that would be proofed and numbered to the particular rifle. Whether that means that a moderator should be an integral part of a rifle is another whole debate.
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Either of those 'devices' forms 'part of a barrel'
I'd think a 'converted barrel' is one like that of a DeLisle carbine, or Hsuhpower gun - where the barrel is ported, and/or bits are permanently attached to the barrel. That clearly does need proofing. Note also that such 'attachments' (the detachable over-barrel sleeve of a ported Hushpower, for example) are very much not 'accessories' - meaning that the gun cannot reasonably be used without them in place.
Here, I think you have hit the nail on the head:
I suspect that they are are following their own regulations - it's just that they don't agree with you about what their rules mean.
So if what I meant is not a bushing, what is the bit that makes contact with the barrel to support the over-barrel end of the moderator and how do Wildcat get around the challenge of a fluted barrel?
K
K
"That is definitely not what the rules say. They say than an attachment 'forming part of any barrel' must be proofed. Detachable mods arguably do not in any sense form 'part of a barrel', as I've pointed out previously. They're not part of the barrel, they're not part of the firearms. They are a removable accessory, which doesn't form part of the barrel." @Dalua @Heym SR20
I think this is part of the answer. Because the projectile does not/should not touch the moderator it is not part of the barrel.
Best wishes,
David.
I think this is part of the answer. Because the projectile does not/should not touch the moderator it is not part of the barrel.
Best wishes,
David.
ChesterP
Well-Known Member
Pedantic I know but the the law states that "...the parts of the small arm" are tested, of which the barrel is one part. No-where can I find any mention of muzzle brakes nor suppressors unless they are integral to the design and the rifle is designed and manufactured to be used with them fitted (ie cannot be used without them).
This is an archaic law stretching back almost 100 years when $200 would have been a couple of months pay. There is a lot of push to get easier access but it gets bumpy traction. Montana passed a law some time back that said if a (suppressor) was made in Montana, and stayed in Montana, it was not subject to Federal law as it will not involve Interstate Transport where Federal law would take hold. I hope this Bill gets brought to the forefront again -as a matter of principle, if nothing else. ~Muir
Absolutely, for peoples hearing if nothing else! It was the one aspect of guns and shooting I wasn’t keen on while I was there as a moderator just makes a rifle so much nicer to shoot!
On the original point, it would seem wrong to boycott a successful British shooting business simply because of something that is wholly or partly out of their control.
I’d certainly not like to see them go under as “punishment” for not selling spare parts.
It does factor into the buying decision though. I used the consider the extra weight of a wildcat a reasonable penalty for the ease of swapping thread, calibre or replacing worn parts. Not they’re just another moderator that you throw away once burned out.
I’d certainly not like to see them go under as “punishment” for not selling spare parts.
It does factor into the buying decision though. I used the consider the extra weight of a wildcat a reasonable penalty for the ease of swapping thread, calibre or replacing worn parts. Not they’re just another moderator that you throw away once burned out.
Heym SR20
Well-Known Member
Look at the Definition of a barrel and the definition of a barrel attachment requiring proof. It is any part of a small arm that contains pressure or through which a load is discharged.
So if what I meant is not a bushing, what is the bit that makes contact with the barrel to support the over-barrel end of the moderator and how do Wildcat get around the challenge of a fluted barrel?
Always been known as a bushing to me
Perhaps they might consider offering a repair/reconditioning service?
K
K
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