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Results
PDF of the presentation at the 2/1 Workshop (pushed back from 1/25 due to snow) can be found here: https://github.com/18F/atf-eregs/files/338033/ATFUserResearchReadout.pdf
- 8 internal ATF discussions
- 8 external users
- 5 in the explosives industry
- 2 in the firearms industry
- 1 consultant who used to work for ATF
- No one knows where the phone number is to call the Firearms Branch, but the public calls all the time.
- Program managers have their own database of past responses they can check when answering an inquiry.
- Past responses are easy to search in email.
- There is a share drive with topic related folders, however, all the content in there is housed in PDFs. If you don’t know where to look, it is hard to find the information you need on the share drive.
- Everyone has been working for ATF long enough that they usually know where to look for answers or who to ask.
- Oftentimes they check the Q&As first because they have an index and are more plain language.
- Difference between regs, rulings, open letters, etc… very well understood, but guidance is guidance. As long as it has been written down by ATF before, they can use it.
Firearms calls (approximate numbers):
- somewhere close to 90% is generated from the general public
- 7% is licensees
- 3% is ATF field investigators
Explosives:
- Get more email traffic than phone traffic.
General:
- People love the paper reference guides. Everyone marks up and customizes their own paper copy.
- People create their own network of support. If they can’t answer an inquiry right away, they call ATF or other people they know who may have the answer.
- Q&As and Newsletters are super important. They are the most plain language and easy to understand guidance that comes from the ATF.
- Difference between regs, rulings, open letters, etc… mostly understood, but not very important. Everyone goes to the reg first and usually the ruling second, but the general distinction isn’t important so long as they find the guidance they are looking for. Anything ATF publishes could be considered guidance.
- Most people using these are not lawyers, and have their own methods for tracking, searching and reading the tea leaves of Regulations. (Only 1 of 8 of the users we spoke to was an attorney.)
- Most “legal or compliance departments” even for the largest of companies, are made up of only 1-4 people for the whole company.
- Biggest question: Have I found everything?
Explosives industry:
- People use the “orange book” religiously.
- People keep databases or binders full of old newsletters from ATF to look up and use during their research.
- Industry works very closely with ATF, and has a very good relationship.
- Dealing with a lot of different government agencies at the same time. Have to comply with ATF, DOT, OSHA, etc…
- The IME is very involved. Many people get a lot of their information on what is changing in the regs from weekly IME newsletters.
- Split between fireworks and high explosives.
- Fireworks licensees could be professionals (create fireworks displays all the time or sell fireworks) or occasional users (someone who creates a display once a year).
- High explosives are usually professionals (quarry owners, construction, etc…), but there are some smaller industry members (farmers, etc…). The monetary and regulatory bars are much higher to buy/use high explosives nowadays, so there are less of the smaller industry members in the high explosives side.
Firearms industry:
- People use the reference guide religiously.
- They used to get newsletters, but no longer do. Aren’t sure if the ATF has stopped sending newsletters or if they just aren’t getting them anymore.
- NSSF is a big trade association. They also send out weekly newsletters, called “bullet points,” that help interpret the ATF’s decisions.
- Really good search
- One-stop research shop
- Cross-referencing to rulings and other docs from the regulation
- Better eForm system (only 1 ask)
- Classes to educate on the regulation’s requirements (only 1 ask)
“Sometimes I feel like I’m wasting time looking for a needle in a haystack and sometimes I feel like I’m risking not looking.”
“In a utopia type of environment, I’d be able to hyperlink to any doc that modifies the reg.”
“We have a hard enough time getting them to read the regulation as it is. … They’re probably more likely to read something a special interest group puts out than something that we put out.”
“I would want a search tool where I type in a certain word, it’d pull up every reg, or ruling that dealt with that specific subject, but all housed in one little database. I could just type it in, and get it back.”
“The ability that if I wanted to look up a theft, it goes back to what we discussed with the rulings, if i’m looking at theft of firearms, it will take me to the reg, and then linked from there is forms, rulings, contact information.”
“I have created a 3 ring binder that has all of the industry newsletters that we put out, all of the rulings we have created - my analysts created a 3 ring binder for firearms and explosives.”
“I used to do field compliance inspections. I used to hold up our reg guide. “Oh yeah, I have one!” “Have you ever read it?” Some do, some don’t. It’s amazing the number of people who get into a heavily regulated industry who do no research.”
Spectrum of “occasional” to “occupational” users.
- Occasional = I sell, manufacture, use, etc… any of these regulated materials once or twice a year
- Occupational = I sell, manufacture, use, etc… any of these regulated materials daily as my main source of business and income
Firearms occasional users:
- I make a couple of guns a year because it is interesting to me.
- I’m an antique store owner. I sell a few antique guns a year to black powder enthusiasts.
Firearms occupational users:
- I’m a gun dealer. I own a small shop with 5 employees in VA.
- I manufacture guns and parts. I’m the second biggest manufacturer of firearms in the US. I have a lot of partners that I sell to on a regular basis.
- As the compliance person in this organization, I understand that even the different parts of the firearms (although they are harmless alone) are classified by ATF and need to be accounted for.
- As a factory worker, I make sure all parts are accounted for, but I don’t understand why all parts (especially ones that are harmless alone) need to be accounted for at all times.
- I’m a big corporate shop who manufactures and sells firearms. I have a big legal department to navigate all the laws and regulations I need to comply with. Even people who are not interested in guns probably recognize my name.
Explosives occasional users:
- Once a year, I plan and run my town’s 4th of July fireworks show.
- I’m a farmer and need to get rid of a stump on my land, or make room for something one-two times a year.
Explosives occupational users:
- I own a quarry and need to use high explosives in my day to day business needs.
- I own a fireworks shop, and sell them all year round.
- I’m a big corporation who manufactures and sells explosives and other destructive devices. I may be one of the largest manufacturers in the US, but I may be considered a small business in the US government’s eyes. I belong to organizations like the IME, and have teams of 5 or so people to make sure I’m in compliance with all the organizations I need to be in compliance with.
ATF eRegulations is part of a larger platform. Find out more at https://github.com/18F/eregs-platform/wiki