Featured Barcodes Aren’t Just for Your Groceries Anymore Adam Kraut August 27, 2017 Join the Conversation Barcoded: ATF Accepts Industry Help in Modernizing NFA Paperwork Processing Adam Kraut, Esq. Unless you’ve been living under a rock, you’re likely aware of the announcement that ATF implemented a new barcode system for NFA Forms that are being processed with the help of input from industry members Silencer Shop, Dead Air Silencers and Gemtech Silencers. This is great news for a variety of reasons, including that it appears ATF, under the new administration, is willing to work hand in hand with industry to find solutions to problems while operating under the current laws and regulations. Barcode affixed to the front of the form Barcodes You Say? For those that aren’t aware, we’ll give a quick run through of what the barcode system actually entails. The IT wizards over at Silencer Shop developed a bar code which encapsulates information contained on the Form 4 and cross checks this with a few databases, such as FFL eZ-Check. The purpose of this is two-fold. First, it enables a person who is entering data to scan the form, rather than manually input all of the information. Dave Matheny, the owner of Silencer Shop said that “if a form takes 2 minutes to enter manually, with the barcode, it can automate that down to a second or a second and a half.” Coupled over a period of time, this faster entry of forms results in a few tangible benefits, including the forms being queued up for faster processing. It also reduces the number of man hours (which eventually translates into man days) required to process forms on the front end and eliminates the need for the NFA Branch to pull individuals from other tasks, such as staging the forms for the examiners, to process the incoming forms. Second, because the barcode cross checks information in databases like FFL eZ-Check, the error rate of submissions will be reduced drastically. Silencer Shop learned that there was a 50% error rate in forms submitted to ATF from dealers. That’s not ATF making errors, that’s the dealer filling out the form making the error. Handwritten forms (yes people are still doing this even though it is 2017) also add to the confusion, delay and chaos. Author's Handwriting Sample (It's lawyerly, is it not?) Beep, Beep, Beep When a form with the new barcode arrives at ATF, it is scanned and put into queue. After that, it is ready for the background check part of the process. Essentially, ATF kicks your information over to FBI to run a NICS check. For those doing this as a legal entity (like a trust) all of the information for the Responsible Persons is sent to FBI for the NICS check. Assuming there are no issues with the check, they take about 3 weeks to process. That, however, does not mean that your application will be processed in 3 weeks. Issues can arise in the form of delays and denials which can be detrimental to the speed of an application. After the NICS check comes back approved and the examiner has looked over the application, it is ready to get that shiny stamp you’ve been waiting for. Quick note, if you’re using a legal entity, ATF does have the validity of the entity confirmed by legal, which can add to the time. All Systems Go Form 4 and RPQ Barcodes The system has already been implemented on ATF’s end and they are currently processing forms that have barcodes. The faster the industry adopts submitting forms in this fashion, the quicker processing times will drop for everyone. Obviously with people still sending in handwritten forms (and I’m still not why anyone would invite the hand cramp in 2017) there will not be a 100% participation rate. However, you should encourage your dealer to utilize the Form 4 Generator located on Silencer Shop’s website. Q&A with the Architects Dave Matheny Can you give me a bit of the backstory behind the barcodes and how they came to be? DM – The idea of the barcodes came up about a year and a half ago. Every time I mentioned the idea to ATF, it was kind of pushed to the side with the insinuation that they would get around to implementing such a thing on their own. I discussed the concept with Eric at Dead Air, that’s when the idea began to move forward. He really drove the process and was responsible for setting up the meeting with ATF to demonstrate the concept. I created a demo and we presented it to ATF. After they saw it in action, they were very open to getting it implemented in a timely manner. As timely as government can get things done. There has been a lot of discussion on what information the barcode has. Some people have indicated that the barcode does not contain all of the information on the Form 4. Can you tell us what information the barcode actually contains? DM – The barcode has everything found on the Form 4 in it except the firearm information. The reason for this is there was issues with consistent formatting of firearm information. ATF now only manually enters the serial number of the firearm or silencer and the NFRTR auto-populates the rest of the information. Unfortunately, there was no way to automate that part of the process, as it would require access to each individual SOT’s eForms account. The barcodes themselves are relatively simple. It's actually the programming of the scanners themselves that is the important part to this system. There are at least two barcodes for every transfer. On a Form 4 submitted by an individual, there are two barcodes. On a Form 4 submitted by a legal entity, such as a trust, there is one barcode on the Form 4 and one on each Responsible Person Questionnaire. What databases are referenced? DM – The Form 4 Generator, that is available for all dealers to use free of charge, references FFL eZ-Check. On our internal forms we pull from a variety of publicly available databases to ensure accuracy. I have seen posts that some people want to create their own barcode to use. I presume they are going to attempt to do this based on “decoding” the ones on the forms and then recreating their own. Are there issues with people recreating their own version of the barcode? DM – Yes, there are issues with people recreating their own version of the barcode. Since the complexity is in the programming of the scanner, people recreating the barcode won’t have the proper format to be sure that the information is entered into the system accurately. We’ve taken steps to address this by locking down the scanners so that unapproved barcodes won’t be accepted. The purpose of the system is to quickly and accurately enter information. A barcode that is not formatted correctly would result in a garbage dump of bad information, slowing the entire process down. That is not what anyone wants. Additionally, the person who submitted the form using a bad barcode wouldn’t know that it wasn’t formatted correctly since it will look like any other barcode. I think this is probably a question with an answer anyone could guess, but, are these barcodes included on all forms that Silencer Shop processes? DM – Yes, they are used on all the forms we process. Pretty much every form that we’ve created since early to mid-May has had this barcode on it. Ron Martinez Can you give me a bit of the backstory as to how you became involved with this collaboration? RM – I was one of the only board members of the ASA that has publically said that the HPA and other legislation would not pass right away due to the make up of Congress. The problem the industry was facing was a rise in wait times for the processing of forms. This became a collaboration between Eric and Dave on how to improve current processes to get silencers to customers in a quicker time frame without waiting for a legislative change that could take two or more years to implement, if at all During our meeting with ATF, they explained that in 1972 they had 5,000 people working for them. At the time we met at the beginning of the year, they had 5,128 people working for them. That means in 43 years they added 128 people. Can you explain what the concept behind the barcodes was? RM – Quality, speed, cost and efficiencies. We replaced a manual keyboard with a scanner. That is efficiency and effectiveness. The opportunity for errors is reduce to almost none. Data entry was a big part of the back log contributing to the wait times for approvals. Forms were being entered manually. It was estimated that an efficient data processor could enter 300-400 forms a day. With the introduction of the barcode, there is need to have the number of individuals entering data that were previously needed. A single individual can process a larger number of forms because of this efficiency. Staff can be reallocated to other tasks that will improve the flow within the NFA branch itself, all because the forms can now be scanned. We were fortunate to deal with officials who were open to suggestions and help from the private sector. This is certainly reflective on the current administration but also officials within ATF. We also plan on taking the barcodes to wholesalers as well in order to improve the efficiency and effectiveness even more. Eric Rogers Can you give me a bit of the backstory behind your involvement with the barcodes? ER – The only way the market was going to loosen up would be if wait times came down. The only way to do that sooner rather than later was to identify “low hanging fruit” that was within ATF’s policy decisions, not a regulation or a law which could take months or even years to implement. I contacted ATF to see about setting up a meeting with high level officials who had the authority to make decisions. At the time I didn’t want this to come off as one company pushing for a meeting but rather an industry effort. So I contacted Dave from Silencer Shop and Ron from Gemtech. It was while talking to Dave that he explained to me the barcode idea he had been trying to pitch to ATF. After hearing Dave’s idea, we decided that we needed to push forward with ATF to get it implemented. We were able to set up that meeting with a number of high ranking ATF officials. I think it is possible that the language found in Ron Turk’s whitepaper that helped facilitate the meeting, inasmuch as ATF had an interest in resolving some of these issues. Dave had the barcode demo ready to go for the meeting itself. After presenting the barcode process, ATF officials seemed to really take to the idea. After that initial meeting, there were a number of trips back and forth to ATF in order to test the prototype system, ensure everything worked properly and hash out the implementation. What can you tell me regarding decisions about the availability of the Form 4 Generator and the information entered into it? ER – The system is free to the industry because we want everyone to adopt it. It’s in everyone’s best interest to submit forms using a method that minimizes errors and allows faster processing on ATF’s end. Based on conversations with ATF, we expect them to make the very same barcode system available to the public on their eForms site. As far as the information entered into the system, none of the information plugged into the generator is available to us. It just standardizes the process. Can you tell me anything about the drop in Form 3 wait times? ER – It’s no coincidence that the barcodes correlated to the Form 3 wait time diminishing. We also pushed ATF to find methods to approve Form 3s in a faster manner, as instantaneously as possible. The idea is that if an examiner has less paperwork on their desk, like a Form 3, they are able to concentrate their efforts on Form 4s and other transfers. The Form 3 and Form 4 approach is part of an overall larger strategy to help the industry. That is to establish predictability on wait times so a consumer can walk in and have a good idea when they’ll receive their approval for the Form. To create predictable wait times today, we had to find a solution that worked within the existing statutory and regulatory framework. We don’t believe that this is a silver bullet for the NFA process, but the faster the industry adopts this method, it allows the wait times to diminish and a predictable wait time pattern to emerge. We expect after the 41F surge is diminished and the front end is stabilized that we will see 60-90 day wait times. About the Author Adam Kraut is a firearms law attorney practicing in southeastern PA and across the country federally. He is currently petitioning to be placed back on the ballot for the NRA Board of Directors in 2018. Adam hosts The Legal Brief, a show dedicated to crushing the various myths and misinformation around various areas of the gun world. He is also the general manager of a gun store in the suburbs of Philadelphia. 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