Volunteers are person that are handling, using the explosives in helping you but you do not pay them. It is still your responsibility to make sure you are not using someone who is a prohibitive person. so to answer your question, if you do not pay them, they are not to be listed as possessors.
Legal Instruments Examiner
BATF&E – FELC
Via email, August 21, 2017
[What this means is that my unpaid staff at Boomershoot does not need to go through the hassle of filling out ATF paperwork.
I’m not sure who this change in understanding helps the most.
I saw some part of the paperwork, yes, literally paper, on their side each time I added a person to help with the Boomershoot reactive targets and that person and/or I doesn’t keep up their paperwork in a timely manner.
This changes some things beyond the obvious.—Joe]