News from Reeves & Dola, LLP 
*** R|D ALERT ***


The Bureau of Alcohol, Tobacco, Firearms and Explosives has published newsletters for the federal firearms and federal explosives industries. 

In this first issue for 2017, available on ATF's website at, ATF provides important updates affecting the federal firearms industry, including the following:  
  • 2016 Rulings on Recordkeeping: summaries of ATF Rulings 2016-1, -2, and -3, which addressed the requirements for maintaining electronic records and consolidating manufacturer records with disposition records.  The rulings are available at
  • Firearms Rental: ATF explains the proper procedures licensees should follow when renting firearms both on- and off-premises.
  • E-Check system: ATF reminds licensees that if they use the E-Check system, they must check the system prior to transferring a firearm when the initial background check comes back "delayed" from NICS.

In this issue for the federal explosives industry, available on ATF's website at , the following topics are included:
  • ATF P 5400.15, Safety and Security Information for Federal Explosives Licensees and Permittees: announces an update to this publication to include information on explosives incidents taking place outside the U.S.; binary explosives; disaster preparedness; chemical security; ATF advisories; and guidelines for reporting thefts or losses of explosive materials. 
  • Structures Used for Indoor Storage: ATF addresses the indoor storage of explosive materials under the regulations in 27 C.F.R. Part 555. As the regulations allow indoor storage of explosive materials only in buildings a variance from ATF is required to store explosive materials in other conveyances, such as fishing vessels or mobile vehicles. Conversely, no variance is required to store explosive materials within an indoor magazine inside a portable or permanent building or structure. The article sets forth the criteria ATF uses to evaluate whether a structure is acceptable to house an indoor magazine without an approved variance.    
  • Distribution Dates: ATF addresses the record keeping requirements of 27 C.F.R. Part 555 and the date of disposition being the day on which the explosive materials leave the licensee's custody or possession.
  • Identification of Explosive Materials: The article provides additional guidance concerning markings for detonators (blasting caps), and clarifies that persons manufacturing or importing explosive materials for their own use are not required to mark them. The article provides guidance on how to apply for a marking variance, including manufacturers who wish to mark with unique alphanumeric codes in lieu of serial numbers.  
The newsletter also includes questions and answers on several topics, including s torage of binary explosives, u se of an aluminum Type 3 day box for temporary attended storage, and l ocking requirements for Type 2, 4, and 5 magazines.  Also included is a useful list of current explosive rulings issued by ATF.  The rulings are listed with a link to each that takes you to the text of the ruling on ATF's website.  Several of the rulings listed are law enforcement sensitive and must be requested from the Explosives Industry Programs Branch. 

The above alert is for informational purposes only and is not intended to be construed or used as legal advice. Receipt of this alert does not establish, in and of itself, an attorney-client relationship.    

Questions about this alert can be directed to: 

Johanna Reeves: 202.715.9941 |   j[email protected] 
Teresa Ficaretta: 202.715.9183  [email protected]
About Reeves & Dola

Reeves & Dola is a Washington, DC law firm that specializes in helping clients navigate the highly regulated and complex world of manufacturing, sales and international trade of defense and commercial products. We have a deep understanding of the Federal regulatory process, and use our expertise in working with a variety of Federal agencies to assist our clients with their transactional and regulatory needs.

Reeves & Dola, LLP
1775 Eye Street, NW, Suite 1150
Washington, DC 20006