Friday, October 11, 2024

FFL Disaster Preparedness Plan

Natural disasters can strike anywhere at any time. Having seen what has taken place in western North Carolina and eastern Tennessee as Hurricane Helene caused flooding that was not only unexpected, but equally as devastating should get everyone’s attention. As we prepare this blog, Hurricane Milton is being described as severe as Earth’s atmosphere can mathematically produce.

Steps for FFLs to Prepare Before, During, and After Natural Disasters

As FFLs, there are several steps that can be taken to help prepare your business before, during and after these events. Industry has for years provided guidance on how to prepare for these disasters whether a hurricane, flood, fire or tornado, to help FFLs secure their firearms and firearm records.

Prioritizing Personal and Family Safety

First and foremost, your personal safety and safety of your family and employees’ families is of the utmost importance. Nothing is more important than this, and while we will focus on how to make sure your business, property and records are protected and secure as humanly possible, we are in no way presuming any of these to be more important than personal and family safety. As we have seen in the aftermath of Helene, you must take your personal and family preparedness seriously and ensure their safety before anything else.

Industry Guidance from ATF and NSSF

ATF and NSSF have each provided industry with suggestions and sample checklists and preparedness plans. They focus on your inventory, records, employees and security at your business. There is no universal size that fits all businesses. We recommend considering both NSSF and ATF’s suggestions and customize a plan that makes the most sense for your business.

Sharing and Updating Your Disaster Preparedness Plan

Once you have a plan, be sure to share the plan with your team. Make updating this plan part of your regular store operations. As your business evolves, your plan should evolve with your business’s growth.

ATF's Disaster Preparedness Resources

ATF has provided industry guidance on their website. Please click the link below to review the entirety of their suggestions.

https://www.atf.gov/resource-center/prepare-natural-disasters

ATF's Sample Disaster Plan Checklist

At a high level, ATF suggests the following starting point for an FFL’s preparation plan:

FFLs: Sample Disaster Plan Checklist

The following sample five-part checklist is recommended for disaster preparedness:

Records: Create and maintain a current set of records that includes insurance policies, suppliers and contact lists, and computer records backup. Store these in fireproof and waterproof locations. Keep current copies of important records off-site. If a disaster is imminent, contact the ATF Firearms Industry Programs Branch at 202-648-7090 to seek approval to remove all business records to a safe location.

Employees: Maintain a list of all employees’ phone numbers, and if warranted, create a phone tree for notifications. Establish a plan under which, in the event of disaster, employees know whom to call to report that they are safe.

Inventory: Conduct an inventory and ensure that records are up to date. These will be vital to assisting law enforcement and establishing losses for insurance purposes. Secure your inventory by utilizing safes, cable locks and other measures that can deter burglaries and looting. If a disaster is imminent, consider relocating inventory. FFLs are encouraged to inform ATF of the new firearms inventory location.

Insurance: Review your policy annually. Most policies do not cover floods and other natural disasters. Consider enhancements to your policy for more complete coverage and reimbursement for business disruption in addition to physical losses.

Security: Review your alarm system and consider updating antiquated systems like older camera systems. Consider having more than one security service evaluate your current system.

Additional Guidance from NSSF

Additionally, NSSF has also provided guidance to FFLs. Please click the link below for their most recent article on preparing for a storm.

https://www2.nssf.org/l/127421/2023-08-21/4ty6h4

Partnering with Local Law Enforcement

Whether you take ATF or NSSF’s guidance as a whole or use suggestions from both to develop your FFL’s plan, just know that the sooner you put this together and share it with your team the better. We suggest partnering with local law enforcement to share your business’s plan. Once you are in recovery mode, having additional support from your local LE office can be extremely valuable.

Embracing Digital Record-Keeping Solutions

Additionally, when it comes to your business records and maintaining those regulatory records it begs the question of why continue to use paper? We all know that paper is antiquated and leaves your records at considerable risk during a natural disaster. Since 2008, FFLs have been able to operate using digital A&D records and have been allowed to digitally complete ATF Form 4473s without ATF variance approval. ATF issued two separate rulings in 2008, which were updated (with industry input) in 2013 and with the most recent iterations coming in 2016.

Understanding ATF Rulings on Digital Records

ATF ruling 2016-1 and 2016-2 provide specific requirements that the software you choose must meet. If it does, you do not need to ask ATF for permission to use it. However, and this is a BIG however, you as the FFL are fully responsible for vetting the software you choose. What the software company tells you isn’t relevant. It is your responsibility as the FFL to know the rulings’ requirements and to ensure you choose a software that meets them.

These same requirements apply to ATF Ruling 2022-1 as well. This ruling allows you to never print 4473s again and retain them digitally. The cost benefit aside (yes, it is software that SAVES you money), when speaking about disaster preparedness and recovery plans, storing your 4473s digitally is the biggest no brainer on earth. Why risk your records when you don’t have to? Simply store them securely in digital format. Making your records the LEAST of your worries when dealing with natural disasters or a fire will allow you to focus your efforts and prep elsewhere.

Contact Us to Transition into the Digital Storage Age

When you have your disaster preparedness plan in place and are ready to take the next step and go fully digital with your records, contact us here. 4473 Cloud was designed to protect your FFL’s most valuable records – your 4473s – and we welcome the opportunity to assist you with transitioning into the digital storage age!