Locks - what is 'best practice' according to DOJ/BATFE?

[Librarian]

What have you FFLs been getting as feedback/criticism/what have you from DOJ and BATFE regarding the lock issue?

To refresh, CA law is pretty fairly summarized at the state web page

Effective January 1, 2002, no firearm may be sold, transferred, or manufactured within California unless that firearm is accompanied by a DOJ-approved firearms safety device (California Penal Code section 12087, et seq).

The safety device requirement does not apply to the following:

• Persons who can demonstrate the purchase of a DOJ-approved safety device in the 30 days prior to taking possession of the firearm by presenting the device to the firearms dealer and providing the firearms dealer with a receipt showing the purchase date and model name of the device.
• The commerce of any firearm defined as an "antique firearm" pursuant to federal law.
• The commerce of any firearm intended to be used by a salaried, full-time peace officer for law enforcement purposes.
• Transfers of firearms to persons who demonstrate ownership of a qualifying gun safe. Ownership may be demonstrated by displaying to the firearms dealer: 1) A receipt indicating purchase of, or an affidavit, signed under penalty of perjury, stating that the purchaser owns a gun safe, and 2) An affidavit, signed under penalty of perjury, stating that the gun safe meets the standards set forth in DOJ regulations.

Particularly 12081.1 is applicable:

12088.1. (a) All firearms sold or transferred in this state by a licensed firearms dealer, including private transfers through a dealer, and all firearms manufactured in this state, shall include or be accompanied by a firearms safety device that is listed on the Department of Justice's roster of approved firearms safety devices and that is identified as appropriate for that firearm by reference to either the manufacturer and model of the firearm, or to the physical characteristics of the firearm that match those listed on the roster for use with the device.

Federal law is 'squishier', because there are no (so far as I am aware) documentation requirements. It's the "CHILD SAFETY LOCK CHILD SAFETY LOCK ACT OF 2005" enacted in 18 USC 922 (z). (http://www4.law.cornell.edu/uscode/h...2----000-.html)

(z) Secure Gun Storage or Safety Device.—
(1) In general.— Except as provided under paragraph (2), it shall be unlawful for any licensed importer, licensed manufacturer, or licensed dealer to sell, deliver, or transfer any handgun to any person other than any person licensed under this chapter, unless the transferee is provided with a secure gun storage or safety device (as defined in section 921 (a)(34))

(34) The term “secure gun storage or safety device” means—
(A) a device that, when installed on a firearm, is designed to prevent the firearm from being operated without first deactivating the device;
(B) a device incorporated into the design of the firearm that is designed to prevent the operation of the firearm by anyone not having access to the device; or
(C) a safe, gun safe, gun case, lock box, or other device that is designed to be or can be used to store a firearm and that is designed to be unlocked only by means of a key, a combination, or other similar means.

for that handgun.

[jtmkinsd]

Locks are not a high priority on the audit. As long as I can point to something in my paperwork proving the gun left with a lock, or for long guns, a safe affadavit is there, it's a non issue. On PPTs, if a gun comes into the shop with a lock, then I annotate that on the DROS. If they buy a lock from me, or bring one with a receipt, a copy of the receipt goes in the packet

In all honesty, they've never even questioned whether it was a "California approved" lock.