The atf now considers replacement of wipes to be manufacturer servicing. But before 2015 it wasn't. Early commercial silencers were dependent upon user replaced wipes.
They can legally only be served by an occupational tax payer. Or cut a form 1 when you change the wipe. It used to be only the original manufacturer could only work on their own shit. Now any special occupational tax payer silencer manufacturer can work on any silencer.
Oh and just don't think you will be able to make a silencer and screw it on your gun and everything will be perfect. Today I leaned that if you screw a 22LR sized monocore on a 22WMR rifle you won't even hit a pizza box at 100 yards. I cut the distance in half and the bullets that did hit were keyholed. I'm going to retest with the cone baffel "trash can" solvent trap. The trash can has a bigger blast chamber, over all is a little bigger and has looser baffel tolerances than the gemtech GM22. I screwed the 5.56 appropriate rebel SOS on there and it was fine. But the rebel SOS is gigantic compared to the GM22 and the trash can.
22lr is 223 dia bullets 22mag is 224 diameter bullets. No surprises when using a gun and can with the wrong size. My single six is, for some reason, happy with mags, less so with lr. No can involved.
All the 5.56 I load uses .224 bullets. The baffel holes in a typical 22 silencer are going to be around .28 inches. So a thousandth isn't going to matter. The first 2 baffels on the trash can are more like .32 inches, as I was getting really horrible instability even at like 5 yards. It's mostly because you are firing a gun into a tightly confined space that is so confined the blast is disrupting a bullet stability.
Holey shit a pair of form one cans I submitted back around some time in August finally went from "submitted" to "in progress". Edit: I originally submitted them august 30 and 31.
It took them start to finish (Mer getting my stamp) less than thirty days at the beginning of the summer. My second 4 months just like yours. I expect any future submissions will not get a stamp.
Now I wonder since they went to in process and I sent in finger prints if they will go from in process to approved in about 3 weeks. I should resubmit my form 1 antifa peace lantern.
You'll probably be ok. I think the critical date is going to be the inauguration. ...'course we are talking the vagaries of the atf.
One of them is another trash can. The other one is the big black can or bbc an 8 chamber cone baffel 30 cal.
When I originally got my quiet bore form 1 solvent trap I tried it out on the 92fs with no booster on factory 115gr ammo and it wouldn't cycle, as I expected. Well I went to the range to test out some of my 147gr +P reloads, loaded with hornady xtp over 6gr of winchester 540 and a cci 500 small pistol primer. Fired some with out the silencer, yep you knew you were shooting heavy plus pee ammo, put the silencer on, still with no booster and the gun fully cycles, it cuts down on recoil and locks the slide back on an empty mag. An unexpected surprise, but a welcome one. Need to chronograph because these 147gr 9mm sound like they are super sonic. The fired shells didn't show any signs of anything scarry.
You aint kidding. General word out right now is dont bother with filing a form 1. They did mass denials. Some gobblety goop about not really manufacturing your own if you buy kits that you only have to drill holes. You can easily see this government overstep spilling over to lowers.