This from the National Shooting Sports Foundation website.
http://www.nssf.org/news/PR_idx.cfm?PRl ... 070207.cfm
New rules by OSHA would include evacuation of ammunition plants everytime a thunderstorm was close.
At the very least, it will be another reason to raise prices.
New Threat to Ammunition from OSHA
Moderator: carlson1
New Threat to Ammunition from OSHA
Mike
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It's a long read, but may be worth the time.
http://www.nssf.org/share/PDF/FedReg041307.pdf
Pay particular attention to paragraph (c)(3)(iii) A, B and C.
I am also a bit uncomfortable with open ended clauses such as transporting detonating devices with explosives. This could be construed by someone with a 3rd grade imagination to include manufactured firearms cartridges. There are too many generalizations in these "laws" that lead to unnecessary burdens on those they purport to protect.
http://www.nssf.org/share/PDF/FedReg041307.pdf
Pay particular attention to paragraph (c)(3)(iii) A, B and C.
I am also a bit uncomfortable with open ended clauses such as transporting detonating devices with explosives. This could be construed by someone with a 3rd grade imagination to include manufactured firearms cartridges. There are too many generalizations in these "laws" that lead to unnecessary burdens on those they purport to protect.
It's not gun control that we need, it's soul control!
I couldn't pull up the word document, so I printed it out and retyped it. I'll go ahead & C&P it here. If you can't open it, you can C&P it to Word and fill in your own name & date. (Please check for errors. I was on the phone while typing. 
)
[date]
OSHA Docket Office
Docket No. OSHA-2007-0032
U.S. Department of Labor
Room N-2625 200
Constitution Avenue, NW
Washington, DC 20210
RE: Docket No. OSHA-2007-0032
Request to Extend Public Comment Period and Request for Hearing on
“Significant Regulatory Action� as Defined in Executive Order 12866
Dear Secretary Chao:
I am writing to request an extension for public comment set to expire on July 12, 2007 for Preliminary & Initial General Observations on OSHA Explosives Proposed Rule (29 CFR Part 1910) -- Published at Federal Register Vo. 72, No. 71, at P. 18792 (April 13, 2007).
After reviewing the proposed regulations it is my belief that the proposed rule is a “significant regulatory action� as defined in Executive Order 12866 (1993) Sec. 1(f)(1) in that it will clearly “adversely affect in a material way� the retail sector of the firearms and ammunition industry, productivity, competition, and jobs and that the annual compliance cost for all retailers of ammunition will far exceed $100 million dollars.
Below is a bulleted list of what I am most concerned about:
Massive Costs: The cost to comply with the proposed rule for the ammunition industry, including manufacturer, wholesale distributors and retailers, will be massive and easily exceed $100 million. For example, ammunition and smokeless propellant manufacturers would have to shut down and evacuate a factory when a thunderstorm approached. The proposal mistakenly states that this is an industry fair practice. A retailer would have to do likewise. Thus, retailers, such as Wal-Mart, selling ammunition would have to close down and evacuate customers. This is simply not realistic.
Exacerbate Ammunition Shortage to DoD and Law Enforcement: The proposed rule as major national security and homeland defense implications. There is already a shortage of ammunition for our troops and law enforcement. The Department of Defense has contracted to purchase ammunition from the commercial market because the Department’s arsenal cannot meet demand. The rule will delay production and massively increase prices, making the ammunition shortage even more severe. In addition, the rule applies to the DoD arsenal, which is run by a commercial manufacturer under DoD contract.
Unrealistic Assumptions: Portions of the proposed rule are not feasible and cannot realistically be complied with. The concept of evacuation to a “safe remote location� in case of thunderstorms or accident is untenable to manufacturers and retailers and is in disagreement with the DoD Safety Manual for Ammunition and Explosives.
One Size Fits All Approach: The provisions in this proposal treat all explosives as if they have the same degree of hazard to employees. Retail outlets for small arms ammunition, primers and smokeless propellants, including massive facilities such as Wal-Mart, must maintain a fifty-foot barrier and specifically authorize all customers to enter only after searching them for matches or lighters (c.3.iii.A) and determining that they are not under the influence of drugs or alcohol (c.1.vii). This is despite the fact that small arms ammunition is extremely safe even when subjected to open flame, heat, and shock. A customer would not be able to purchase ammunition because under this rule they are not allowed to carry it from the counter to the exit (c.3.iii.C). Even more damaging, the many “mom and pop� firearm outlets located in strip malls would be forced to shutdown as they have neighbor stores less than fifty feet away.
Shipping is Halted: Proposed restrictions on transportation exceed current DOT Regulations. Mandating wood-covered, non-spark-producing material in trailers for small arms ammunition shipments would bring the transportation of ammunition to a near halt. There are simply not enough trailers in existence today that would be able to substitute for traditional, metal covered surfaces. Small package carriers such as UPS and Fed-Ex would be prohibited from carrying ammunition and components which would shut down mail order houses such as Cabela’s and Bass Pro shops and many business to business transactions. This section alone, with all it would entail (such as two drivers at all times), is capable of paralyzing our industry.
National Fire Prevention Association (NFPA) Rules Exceeded: Proposed restrictions exceed NFPA regulations and would, for example, reduce commercial establishment displays of smokeless propellant from 50 to 20 lbs. with no commensurate increase in safety. This will only add to dramatically increasing the cost to manufacturers and consumers.
It bears noting that scientific testing and safety records clearly illustrate that small arms ammunition is inherently an extremely safe product. I cannot recall a single instance where fire, shock, heat or lightening has resulted in injury from the accidental detonation of small-caliber ammunition. Billions of rounds of ammunition are sold each year in the U.S. and records demonstrate that current production and safety requirements are working.
I urge OSHA to grant an extension to this critical regulatory process.
Sincerely,
)[date]
OSHA Docket Office
Docket No. OSHA-2007-0032
U.S. Department of Labor
Room N-2625 200
Constitution Avenue, NW
Washington, DC 20210
RE: Docket No. OSHA-2007-0032
Request to Extend Public Comment Period and Request for Hearing on
“Significant Regulatory Action� as Defined in Executive Order 12866
Dear Secretary Chao:
I am writing to request an extension for public comment set to expire on July 12, 2007 for Preliminary & Initial General Observations on OSHA Explosives Proposed Rule (29 CFR Part 1910) -- Published at Federal Register Vo. 72, No. 71, at P. 18792 (April 13, 2007).
After reviewing the proposed regulations it is my belief that the proposed rule is a “significant regulatory action� as defined in Executive Order 12866 (1993) Sec. 1(f)(1) in that it will clearly “adversely affect in a material way� the retail sector of the firearms and ammunition industry, productivity, competition, and jobs and that the annual compliance cost for all retailers of ammunition will far exceed $100 million dollars.
Below is a bulleted list of what I am most concerned about:
Massive Costs: The cost to comply with the proposed rule for the ammunition industry, including manufacturer, wholesale distributors and retailers, will be massive and easily exceed $100 million. For example, ammunition and smokeless propellant manufacturers would have to shut down and evacuate a factory when a thunderstorm approached. The proposal mistakenly states that this is an industry fair practice. A retailer would have to do likewise. Thus, retailers, such as Wal-Mart, selling ammunition would have to close down and evacuate customers. This is simply not realistic.
Exacerbate Ammunition Shortage to DoD and Law Enforcement: The proposed rule as major national security and homeland defense implications. There is already a shortage of ammunition for our troops and law enforcement. The Department of Defense has contracted to purchase ammunition from the commercial market because the Department’s arsenal cannot meet demand. The rule will delay production and massively increase prices, making the ammunition shortage even more severe. In addition, the rule applies to the DoD arsenal, which is run by a commercial manufacturer under DoD contract.
Unrealistic Assumptions: Portions of the proposed rule are not feasible and cannot realistically be complied with. The concept of evacuation to a “safe remote location� in case of thunderstorms or accident is untenable to manufacturers and retailers and is in disagreement with the DoD Safety Manual for Ammunition and Explosives.
One Size Fits All Approach: The provisions in this proposal treat all explosives as if they have the same degree of hazard to employees. Retail outlets for small arms ammunition, primers and smokeless propellants, including massive facilities such as Wal-Mart, must maintain a fifty-foot barrier and specifically authorize all customers to enter only after searching them for matches or lighters (c.3.iii.A) and determining that they are not under the influence of drugs or alcohol (c.1.vii). This is despite the fact that small arms ammunition is extremely safe even when subjected to open flame, heat, and shock. A customer would not be able to purchase ammunition because under this rule they are not allowed to carry it from the counter to the exit (c.3.iii.C). Even more damaging, the many “mom and pop� firearm outlets located in strip malls would be forced to shutdown as they have neighbor stores less than fifty feet away.
Shipping is Halted: Proposed restrictions on transportation exceed current DOT Regulations. Mandating wood-covered, non-spark-producing material in trailers for small arms ammunition shipments would bring the transportation of ammunition to a near halt. There are simply not enough trailers in existence today that would be able to substitute for traditional, metal covered surfaces. Small package carriers such as UPS and Fed-Ex would be prohibited from carrying ammunition and components which would shut down mail order houses such as Cabela’s and Bass Pro shops and many business to business transactions. This section alone, with all it would entail (such as two drivers at all times), is capable of paralyzing our industry.
National Fire Prevention Association (NFPA) Rules Exceeded: Proposed restrictions exceed NFPA regulations and would, for example, reduce commercial establishment displays of smokeless propellant from 50 to 20 lbs. with no commensurate increase in safety. This will only add to dramatically increasing the cost to manufacturers and consumers.
It bears noting that scientific testing and safety records clearly illustrate that small arms ammunition is inherently an extremely safe product. I cannot recall a single instance where fire, shock, heat or lightening has resulted in injury from the accidental detonation of small-caliber ammunition. Billions of rounds of ammunition are sold each year in the U.S. and records demonstrate that current production and safety requirements are working.
I urge OSHA to grant an extension to this critical regulatory process.
Sincerely,
Last edited by Venus Pax on Tue Jul 03, 2007 11:21 am, edited 2 times in total.
"If a man breaks in your house, he ain't there for iced tea." Mom & Dad.
The NRA & TSRA are a bargain; they're much cheaper than the cold, dead hands experience.
The NRA & TSRA are a bargain; they're much cheaper than the cold, dead hands experience.
For some reason this reminds me of a conversation/debate I had with an anti-gunner in my old office.
At one point in the conversation he stated that all ammo should be banned because it contained lead and would cause lead poisoning for anyone I shot by said ammo.
I couldn't stop laughing for probably a good 10 minutes. The irony was lost on him.
At one point in the conversation he stated that all ammo should be banned because it contained lead and would cause lead poisoning for anyone I shot by said ammo.
I couldn't stop laughing for probably a good 10 minutes. The irony was lost on him.
That's a good one. You should have said...nah, they're coated in teflon just for that reason! I'm sure he wouldn't get that either.LedJedi wrote:For some reason this reminds me of a conversation/debate I had with an anti-gunner in my old office.
At one point in the conversation he stated that all ammo should be banned because it contained lead and would cause lead poisoning for anyone I shot by said ammo.
I couldn't stop laughing for probably a good 10 minutes. The irony was lost on him.
I did read somewhere recently that shooting in inside ranges can cause some effects of lead poisoning. I bet you'd have to do it a lot though...
"People sleep peaceably in their beds at night only because hard men stand ready to do violence on their behalf."- George Orwell
NRA member!
NRA member!
>>MY<< only concern in that scenario is why they didn't die.seamusTX wrote:Since the majority of people who are shot don't die, it is a potential concern.LedJedi wrote:At one point in the conversation he stated that all ammo should be banned because it contained lead and would cause lead poisoning for anyone I shot by said ammo.
- Jim
True, but if I shoot 'em, I'm planning on them dying anyway! I've heard that silver coated bullets cause potentially deadly poisoning...seamusTX wrote:Since the majority of people who are shot don't die, it is a potential concern.LedJedi wrote:At one point in the conversation he stated that all ammo should be banned because it contained lead and would cause lead poisoning for anyone I shot by said ammo.
- Jim
"People sleep peaceably in their beds at night only because hard men stand ready to do violence on their behalf."- George Orwell
NRA member!
NRA member!
Nazrat wrote:That reminds me of when I was in the Corps in the Gulf War. I used to keep my personal Kbar with a light layer of rust on it with the hopes that if I couldn't kill them with the blade, I could at least try to give them tetanus.
It made sense at the time.
Ha! I love it!"People sleep peaceably in their beds at night only because hard men stand ready to do violence on their behalf."- George Orwell
NRA member!
NRA member!
Looks like OSHA actually listened to comments, and is extending the comment period to Sept 10th.
http://www.nraila.org/Legislation/Feder ... px?id=3145
http://www.nraila.org/Legislation/Feder ... px?id=3145
This was taken from Brian Enos's forums:The public comment period was originally scheduled to end July 12 but has been extended sixty (60) days until September 10, 2007. To read the OSHA proposal click here (PDF file).
RyanFederal Register
July 9, 2007
SUMMARY: OSHA is extending the comment period for its proposed standard
on Explosives for an additional sixty (60) days until September 10,
2007.
WE GOT OSHA's ATTENTION!
Thanks All who made Comments and contacts to your legislators, News
media, Talk Shows and Associations. This now allows more detailed replys
to be prepared and ... FURTHER GET THE WORD OUT to all involved parties.
No Slacking off though ... PLEASE!!!!! This is a very important topic to
us all
Also, this probably gives OSHA more time to post the thousands of posts
that have been made.
If you have not commented please do so!!!
