TYPES OF GUN LOCKS
Gun locks currently for sale in the United States are Chinese and Taiwanese-made products. A few are designed in the United States, but manufacturing is done overseas. Below is a three-part video series introducing the subject of gun locks.
Gun locks Part 1: The most common form of gun lock a gun owner will find in the U.S. is a form of padlock. This is why the ASTM Standard Performance Specification for Padlocks is incorporated into California’s testing procedures for firearms safety devices.
Gun locks Part 2: The second most commonly found gun lock is a trigger lock. Trigger locks fall into two distinct categories. The first category includes devices that have actual locks incorporated into their designs. The second comprises trigger fasteners.
Gun locks Part 3: This third video looks at a miscellaneous assortment of gun lock designs.
THE PROJECT CHILDSAFE INVESTIGATION
My investigation into the gun lock industry began with locks distributed by Project ChildSafe, the 501(c)(3) nonprofit of the National Shooting Sports Foundation (NSSF). Project ChildSafe is a joint operation of the NSSF and the United States Department of Justice (DOJ). The nonprofit promotes gun safety and works to build a network of police departments that distribute firearm safety kits to the public. Each kit comes with a pamphlet covering gun safety and a free gun lock.
Project ChildSafe’s gun locks are padlock-styled with a cable to loop through the action of a firearm. (With a cable looped through an open gun, the slide—or the cylinder if it’s a revolver—cannot close and the gun cannot be fired.) I gathered my first sampling of Project ChildSafe gun locks from the Eugene and Springfield Police Departments in Oregon, both of which provided me with cheaply made wafer locks. This style of lock has small plates, or “wafers,” inside that are brought into alignment when a key is inserted, allowing the plug inside to rotate and the lock to open. Though wafer locks can be designed to resist picking, the Project ChildSafe locks I examined offered no resistance to picking.
When I discovered that cheap wafer locks were among the gun locks distributed by Project ChildSafe, I gathered samples from police departments throughout Western Oregon. I visited twelve police stations between August 2015 and April 2016, and collected safety kits from each. Eight of the police stations provided wafer locks, which have either the model numbers RX14SC or RX14SU on their sides.
The chart at the end of this page shows the type and model number of all the Project ChildSafe locks I gathered. The chart also includes copyright dates taken from the pamphlets that came with the locks, giving some idea of the demand for these locks.
Roughly half of the RX14SC and RX14SU gun locks I’ve examined barely work, their manufacture so poor the keys bind when turning. The locks that do function work too well. Their wafers can be jiggled open with paperclips and plastic zip ties. I’ve also pulled the plastic sleeves off of them and found the locks are made of plastic. They can be broken with a hammer and cut with a hacksaw.
In 2001, the Consumer Product Safety Commission (CPSC) reviewed 32 models of gun locks, including locks distributed by the NSSF through their nonprofit, called Project HomeSafe at the time. Nearly every model of lock failed the review. As a result, the NSSF in cooperation with the CPSC voluntarily recalled around 400,000 gun locks. According to a CPSC press release dated February 7, 2001, “Under certain conditions, these locks can open without the use of a key.” But if the CPSC considers a gun lock unacceptable if it can be opened without a key, why are the RX14SC and RX14SU gun locks in circulation?
How gun locks are tested
By the time the NSSF buys gun locks from a supplier, the locks have received California DOJ approval. California’s Firearms Safety Device (FSD) Standards are set down in Section 4094 of California’s Penal Code, Title 11, Division 5, Chapter 6. The section that deals with FSD testing is Section 4095, which describes a number of tests that gun locks are subjected to, including a test of a lock’s resistance to being picked open. Subsection (c)(1) explains that gun locks “shall resist picking with the use of paper clips (jumbo size), paper clips (#1 size), and small screwdrivers that fit in the keyway for two minutes each.” In legalese “shall” means it’s mandatory.
Therefore, a gun lock that has received California DOJ approval has been determined to be capable of resisting an attack with a paperclip for a minimum of two minutes. Subsection (c)(1) goes on to say, “This test shall be performed by a tester with no specialized training or skills in lock picking or manipulation (e.g. locksmith training or the use of reference guides on lock picking or manipulation).” The idea behind this requirement is to simulate a real-world attack by a non-expert lock picker.
Yet, as can be seen in the video posted here, the RX14SC and RX14SU gun locks can be opened with #1-sized paperclips, and they can be opened within the two-minute time constraint. Whether a gun lock passes additional required tests—a forced removal inspection, a shock (impact) test, a shackle or cable-cutting test—is irrelevant if the lock fails the to resist being picked open. Thus, for the RX14SC and RX14SU locks to have received California DOJ approval reveals that California’s program for approving FSDs is failing in ways unforeseen by lawmakers.
Part of the problem has to do with California’s Certified FSD Laboratories. The independent laboratories certified to test FSDs are listed on the DOJ website. These labs perform standards testing for civilian, law enforcement, and defense-related industry, and have multiple accreditations to meet the needs of agencies like the Federal Communications Commission. Personnel certified to test FSDs are recertified every two years by a California DOJ representative.
On the surface, these labs appear to have the right people for testing gun locks. But personnel have no background in security, and don’t have experience in assessing the vulnerabilities of security systems. Because California’s testing guidelines require tests to be performed by people with no skills in lock picking, the guidelines ensure the wrong people are testing gun locks.
Worse, should a lab technician have an aptitude for security and give a gun lock a failing grade, his work can be undone by another lab. Nothing in the approval process prohibits an importer from submitting a failed product to another lab for testing. California’s DOJ doesn’t collect information on products that fail testing.
To read about the laboratories that perform these tests, please see California’s Certified FSD Laboratories.
GENERIC GUN LOCKS
Firearm Safety Devices Corporation (FSDC), a subsidiary of Regal Industrial Sales, has supplied Project ChildSafe with gun locks for over ten years. FSDC and Regal Industrial Sales are owned by Thomas J. Farchione, who secures California DOJ approval for gun locks prior to marketing them to customers. Through FSDC and Regal Industrial Sales, Farchione is the leading provider in the U.S. of California DOJ approved gun locks. He’s also trademarked the statutory acronym for “firearms safety device,” FSD, and he owns the rights to the Gunlok (formerly Pro-Lok) brand of trigger lock. His companies supply gun locks for Baretta, Glock, Mossberg, Project ChildSafe, Remington, Ruger, Smith & Wesson, and anyone else needing California DOJ approved gun locks.
The cable-styled gun locks Farchione markets are mostly generic products imported from China and Taiwan. One of the larger manufacturers Farchione has purchased from is Haining Anjie Locks Co. Ltd., in China. Other companies marketing this type of lock on Alibaba include Cixi Anli Lock Factory, Lockey Safety Products Co., Ltd., and Hangzhou Joyhoom Technologies Inc., all of which are selling generic lock designs owned by no one. Thus, they can offer to customize their products with any logo a customer chooses, including “Project ChildSafe.”
Once a gun lock has DOJ approval, FSDC and Regal Industrial Sales can sell the lock for as long as the manufacturer produces it. If the manufacturer replaces a lock with a new model, California statute has a provision that simplifies the approval process. Returning to the statute sited above, Section 4093, subsection (c) allows the DOJ discretion to approve an FSD without testing. An importer only has to submit a statement, under oath, declaring that a new device differs in minor ways from a previously approved one marketed by the same importer.
A DOJ office worker may require the importer to provide a sample of the new device for a comparison. But unless that office worker is inclined to go to the warehouse and dig through the multitude of products that have been through this process, no one will ever get around to comparing the old and new gun locks. Almost anything can slip through the process.
california's outdated roster
California’s current Roster of DOJ-Approved Firearms Safety Devices is long, though many products on the list are no longer available. Some manufacturers have gone out of business, or their products have been discontinued, or their products have been replaced with new models. Properly speaking, the roster of approved FSDs is an historical record of products that have managed to get past California’s Certified FSD Laboratories.
This distinction is essential to understand, because certified labs that give passing grades to sub-standard products are able to hide behind the process. Laboratories are not required to make test results public. Neither are manufacturers. Thus, the roster includes no links to test results, and the public has no way of knowing which lab did the testing, or whether a manufacturer simply invoked the statutory provision mentioned above that allows a product to gain approval without testing.
The roster also doesn’t identify which company is ultimately supplying which products. Beretta’s listed gun locks, for example, are supplied by FSDC, while FSDC has its own products listed separately on the roster. All of Pro-Lok’s listings and nearly all of Project ChildSafe’s listings are FSDC products. FSDC is ultimately marketing Regal Industrial Sales products, which are listed separately under the name Regal Industrial Sales, and the products Regal Industrial Sales provides for Ruger are listed separately under the name of Ruger. Regal Industrial Sales accounts for the largest number of gun locks on the roster.
From the copyright notices on the pamphlets included with the RX14SC and RX14SU gun locks I gathered, I know they’ve been in circulation since at least 2005. But the CPSC hasn’t thought it necessary to revisit the gun lock industry since the 2001 recall. In the years since, California’s approval process for gun locks has continued its decline, leaving the NSSF free to distribute whatever gun locks manage to squeak past California’s DOJ—like plastic gun locks that can be opened with a paperclip.
The chart below may be updated on occasion as additional samples of Project ChildSafe gun locks are added to the list.
A couple of points to take note of: First, one of the listed locks is not a Project ChildSafe gun lock. Benton County Sheriff's Dept. in Corvallis and Corvallis Police, which share office space, were giving away plastic trigger fasteners. I included only Benton County Sheriff's Dept. in the set, because Benton County Sheriff's is listed on the Project ChildSafe website as participating in Project ChildSafe and Corvallis Police is not.
Second, though certain police departments listed below provided Project ChildSafe gun locks, they are no longer participating and are not listed on the Project ChildSafe website as having any involvement with the program. These include the Florence and Oakridge Police Departments.