i just finished building the parts kit with a romana receiver.
i put a plate to block the thumbhole..... but no bullet button and it has the original muzzel brake with spring loaded pin holding it on, (dont see any welds)
and it has the bayonet lug.
not sure if its legal. can anyone share there input..
i searched high and low and everyone has a bullet button and or a welded brake?
07-08-2011, 2:23 PM
Don't need to weld your break on a PSL, the muzzle device that comes stock on a PSL is a "Muzzle Break" not a flash hider so it is not a "Evil Feature". The barrel is long enough to clear any length length issue so welding the muzzle device is not needed. To drop the mag lock all you have to do is fill in the thumb hole stock. Only reason to have muzzle break welded is to meet length guidelines and the bayo lug thing is complete BS. It has been discussed in length in another thread on this forum... So don't be a monster and destroy your bayo lug.
07-08-2011, 2:26 PM
As long that stock with the thumbhole can't be used like a thumbhole or a pistol grip, and the muzzle brake is actually a muzzle brake, you should be fine. To the best of my knowledge a PSL should be well over 30 inches so I can't see why one would need to weld the muzzle device on...but I am probably missing something. I'm sure someone more acquainted with PSLs will chime in.
For future reference however, if you are not sure about the legality of a certain configuration, pose the question in the form of a hypothetical...ie "if I were to do this and this to my gun, would it still be legal?". ;)
07-08-2011, 3:35 PM
You are well over 16" in bbl, and 30" OAL, so there is no reason for welding.
07-08-2011, 5:09 PM
For CA AW purposes, it seems like you're compliant as a featureless build - releasable magazine but no thumbhole grip and the muzzle device is considered a break. The trickier issue is 922(r). This post (http://www.calguns.net/calgunforum/showpost.php?p=6682226&postcount=12) (with a few of my additional edits below) is the way I currently understand it:
I've also heard differing opinions on the necessity for a home-built PSL to comply with 922(r).
One school of thought is that a Romanian-built PSL rifle can be, and currently is licensed for importation by the ATF under 18 U.S.C. § 925(d)(3). Since compliance with 922(r) is required only if 925(d)(3) otherwise prohibits importation of that particular firearm, in the case of a PSL (which is importable), there is no need to have less than 10 foreign parts. I like to call this the "if the Attorney General has authorized importation of my rifle, then I can build it here" theory. This gives a lot of deference to the Attorney General, and what he thinks "generally recognized as particularly suitable for or readily adaptable to sporting purposes" means at any given time.
The other theory focuses more on the "sporting purposes" concept under 925(d)(3), and if a rifle would be prohibited from importation as not meeting the "sporting purposes" test, regardless of whether the Attorney General has authorized importation or not. The 1998 Department of the Treasury study listed out several features that were deemed "not sporting," including the ability to accept large capacity magazines, folding/telescoping stocks, separate pistol grips, ability to accept a bayonet, flash suppressors, bipods, grenade launchers and night sights, and I understand that these are still the features considered by the ATF to determine whether a foreign firearm is importable or not. So, if a PSL build has any of these features, then it would be subject to 922(r). This can be referred to as the "features" theory - if it has the features of a non-importable firearm, then you can't build it here. (without the requisite number of US parts).
Mine has a bayonet mount, but the muzzle device is pinned on, and I use the thumbhole stock. There are no magazines that have been manufactured for the PSL with a greater than 10 round capacity as far as I know. So even under this more restrictive theory, if I removed the bayonet mount I would be in the clear as far as 922(r) is concerned.
Your situation may also require the pinning of the muzzle brake so that it's not deemed to be receptive to a flash hider. If you keep the bayonet mount and don't attach the brake permanently, in addition to the fire control group, there would still need to be three less foreign parts.
In my situation, I picked the stock and the forearm furniture to replace with US parts. Because a thumbhole stock technically doesn't include a pistol grip, it wouldn't count towards a U.S. part, nor count against a foreign part, putting me at exactly 10 foreign parts. (1) Receiver, (2) Barrel, (3) Front trunnion, (4) Bolt, (5) Bolt Carrier/Op Rod, (6) Gas Piston, (7) Buttstock, (8)(9)(10) Magazine body, follower, floorplate.
Personally, I'm inclined to believe that if the Attorney General says it's ok to import the PSL, then I can home-build a PSL. The "sporting purposes" test is acknowledged to be a community standard that changes over time, left to the discretion of the Attorney General to establish what exactly that is. This gives me reason to believe he has some leeway, and it leaves the option of licensing the importation of other than sporting purpose firearms if he so desires. Indeed, in the future the interpretation may change to be more liberal and inclusive of all types of firearms that could be imported.
There is, of course, the question of how "identical" the US-built version must be to the importable version. I'm confident that I've seen a completed foreign version sold at a gun store with a pinned muzzle brake, and the bayonet mount intact, in the same arrangement of features as I would like to have on my build if I used foreign furniture. On the other hand, this doesn't seem particularly worth the risk, so I added on the Rhineland Arms furniture and the fire control group parts.
The law is confusing and I'm probably not interpreting it correctly in some places. It all comes down to comfort level, so in my case I decided to go the safer route. I think there are strong arguments either way you go, so I hope what I'm saying doesn't come across as spreading FUD, because that is not my intention. Speaking with numerous people on this topic, I've come to understand that a regular citizen who did a home build has never been prosecuted, and only the big importers (Century, etc.) really worry about it. Then again, we call ourselves "law abiding citizens," so to the extent we are capable of obeying laws, even those we know are unenforceable, unconstitutional, or otherwise illegal, we should strive towards compliance.
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