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You need an FFL because you will be keeping a customer's gun over some period of time; the rule is that unless the gunsmith does the work while the customer watches (and thus retains custody of the gun), the gunsmith needs an FFL.
The main thing that has driven bluing shops out of business has been the EPA and OSHA regulations. Seemingly endless and often arbitrary, those regulations affect any business that works with hazardous materials or in which there is any elevated risk of injury, which certainly includes bluing shops. This, of course, is in addition to local laws and regulations regarding HAZMAT and pollution, such as dumping caustic salts residue into the sewer system.
I strongly suggest that anyone wanting to start that business consult an attorney, pay for his/her advice and keep him/her on retainer. That is better than investing a lot of money and then being blindsided by some GS-3 twerp from an alphabet soup agency who likes to make up the rules as he goes along.
Also, a bluing shop is not that easy to set up. You need good tanks, preferably gas fired, good controls, proper HAZMAT clothing (apron, boots, mask, etc.), a high volume emergency shower (just in case), etc. Those are dangerous chemicals, not some lemon juice cold blue you swab on with your finger.
And of course, you need to be enough of a gunsmith to be able to disassemble and polish guns then reassemble them without damage. Your reputation will go down pretty fast if you send back guns with all the markings buffed off, the corners rounded, the screw slots buggered up, or parts missing.
Jim
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