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Author Topic: Proposed OSHA Regulation Threatens Firearm and Ammunition Industry  (Read 12585 times)

Offline Ray

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http://www.nssf.org/news/PR_idx.cfm?PRloc=common/PR/&PR=BP070207.cfm


Proposed OSHA Regulation Threatens Firearm and Ammunition Industry

The Occupational Safety and Health Administration (OSHA), the government agency charged with assuring the safety and health of America's workers, is proposing a regulatory rule affecting the manufacturing, transportation and storage of small arms ammunition, primers and smokeless propellants.

As written, the proposed rule would force the closure of nearly all ammunition manufacturers and force the cost of small arms ammunition to skyrocket beyond what the market could bear—essentially collapsing our industry. This is not an exaggeration. 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 and customers would not be allowed within 50 feet of any ammunition (displayed or otherwise stored) without first being searched for matches or lighters.

NSSF and SAAMI have already had a preliminary meeting with OSHA officials to begin the process of explaining to them the major problems this proposed rule presents for all levels of the firearms and ammunition industry. Furthermore, NSSF and SAAMI are each seeking a 60 day extension of the public comment period (currently scheduled to expire July 12).

NSSF is urging all retailers to contact OSHA directly and request a 60-day extension of the public comment period. Retailers should inform OSHA that the proposed rule constitutes a "significant regulatory action" as defined in Executive Order 12866 (1993) Section 3(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.

Click here for a template letter in rich text format (Word). If you choose to draft your own letter, the reference line must read as follows:

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

Please fax the letter to: 202-693-1648 (include the docket number and Department of Labor/OSHA on the cover sheet and in the reference section of your letter).

Please e-mail the letter by visiting: http://www.regulations.gov and following the submission instructions.



Even consider contacting our Senators

Cantwell, Maria- (D - WA) Class I
511 DIRKSEN SENATE OFFICE BUILDING WASHINGTON DC 20510
(202) 224-3441
Web Form: http://cantwell.senate.gov/contact/index.html
 
Murray, Patty- (D - WA) Class III
173 RUSSELL SENATE OFFICE BUILDING WASHINGTON DC 20510
(202) 224-2621
Web Form: http://murray.senate.gov/email/index.cfm

House

http://www.house.gov/

Upper left side of this page fill out the zip code form.....
« Last Edit: July 05, 2007, 06:55:45 PM by huntwa »

Offline jackelope

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new potential "explosives" law
« Reply #1 on: July 06, 2007, 08:34:23 AM »
:fire.:

" In today's instant gratification society, more and more pressure revolves around success and the measurement of one's prowess as a hunter by inches on a score chart or field photos produced on social media. Don't fall into the trap. Hunting is-and always will be- about the hunt, the adventure, the views, and time spent with close friends and family. " Ryan Hatfield

My posts, opinions and statements do not represent those of this forum

Offline Ray

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Re: new potential "explosives" law
« Reply #2 on: July 06, 2007, 08:56:54 AM »

Offline jackelope

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Re: new potential "explosives" law
« Reply #3 on: July 06, 2007, 10:25:56 AM »
OOPS....wide awake here.
nevermind
:fire.:

" In today's instant gratification society, more and more pressure revolves around success and the measurement of one's prowess as a hunter by inches on a score chart or field photos produced on social media. Don't fall into the trap. Hunting is-and always will be- about the hunt, the adventure, the views, and time spent with close friends and family. " Ryan Hatfield

My posts, opinions and statements do not represent those of this forum

Offline Ray

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Re: new potential "explosives" law
« Reply #4 on: July 06, 2007, 11:03:20 AM »
It's good to know there are other people on the prowl :D

Offline Curly

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Re: new potential "explosives" law
« Reply #5 on: July 06, 2007, 11:23:34 AM »
Looks like I better get stocked-up on reloading supplies.  BTW - does anyone know the shelf life of say H1000.  I'm trying to decide how many pounds of powder I should have on hand; if it will stay consistent over the next 20 years, I might just buy enough to last me that long.
May I always be the kind of person my dog thinks I am.

><((((º>` ><((((º>. ><((((º>.¸><((((º>

Offline jackelope

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Re: new potential "explosives" law
« Reply #6 on: July 06, 2007, 11:32:46 AM »
thats all well and good curly, but if there's a thunderstorm, you had better get the hell out of dodge 8)  8)  8) !!

:fire.:

" In today's instant gratification society, more and more pressure revolves around success and the measurement of one's prowess as a hunter by inches on a score chart or field photos produced on social media. Don't fall into the trap. Hunting is-and always will be- about the hunt, the adventure, the views, and time spent with close friends and family. " Ryan Hatfield

My posts, opinions and statements do not represent those of this forum

Offline Choclab

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Re: new potential "explosives" law
« Reply #7 on: July 06, 2007, 02:41:14 PM »
whole thing is a scam....

The Institue of Makers of Explosives and Ammunition Manufacturers' Institute were the ones that called for the reform in the first palce.

I've read most of the document...(if you want the gists of it you can start on page 47 for a summary) Almost ALL of the proposals are not new regulations... they are only rewording of current regulations to make them more understandable.

The reference to evacuating the building in a lightening storm is also hogwash...It has been OSHA requirements since 1972 to require employers to remove employees from the blasting area duing the approach and progress of an electrical store.... They are only revising the definition to add "to require the suspension of explosive manufacturing operations" ... "requires the immediate withdrawl of employees located near explosives" The only thing this proposal is doing is redefining the rules that are already in place.

I'm guess that the author of this was in kahutz with an explosives manufacturer that was somehow affected by one of the VERY FEW new rules... maybe they were storing all of their ammonium sulfate in a wooden barn with a straw roof??? And not they will have to build a new warehouse...

Either way there is ABSOLUTLY nothing that I could find in the proposal that would lead me to beleive that there will be even a minimal effect on the consumer of firearms. If someone could find something that says otherwise... I'd be glad to listen.
 
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Eastsider stuck on the wetside......

Offline Choclab

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Re: new potential "explosives" law
« Reply #8 on: July 06, 2007, 02:44:15 PM »
Mike (Boomn4x4) from WFC did all the research. I copied and posted what he responded...Thanks for the leg work Mike
Eastsider stuck on the wetside......

Offline Ray

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Re: new potential "explosives" law
« Reply #9 on: July 06, 2007, 02:50:25 PM »
I'm not inclined to discard this as a scam without understanding some more specifics. Let's start with - page 47. Feel free to point something if anything out about this page or elsewhere which should gather my attention and discard what people from the firearms and hunting industry are calling out.

Offline Boomn4x4

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Re: new potential "explosives" law
« Reply #10 on: July 07, 2007, 07:23:35 AM »
"Scam"???  Ok, I'll admint.. that is a bit harsh.  But I have read a majority of the proposal (which can be found in huntwa's post or here http://www.nssf.org/share/PDF/FedReg041307.pdf

Page 47 is an overhead view of the proposal.  To get an understand you really need to read the doc.

Quickly, if you read the Summary on page 2 you will see what the intent of the proposed rule is.

"The proposal updates and clarifies the regulatory language, addresses regulatory inconsistencies between OSHA and other Federal agencies, incorporates updated consensus standards, and provides the regulated community with greater compliance flexibility"

This proposal simply updates current regulation, furter defines regulation, and gives the authority more fleixbility in regards to compliance.

The proposal that is being evlauated has been in effect since 1971.  It was the firearms industry themselves, that requested the review of regulation.

"On July 29, 2002, OSHA received a
petition (the Petition) from the Institute
of Makers of Explosives (IME) and the
Sporting Arms and Ammunition
Manufacturers’ Institute (SAAMI) to
revise the standard." - page 3


The request made by the IME and the SAAMI is as follows:
"Exclude the manufacture of
explosives from the PSM requirements
of § 1910.119 and incorporate revised
PSM requirements for the manufacture
of explosives into § 1910.109;
• Replace references to outdated DOT
explosives classifications with the
current DOT classification system;
• Eliminate the provisions in
§ 1910.109 covering the storage of
explosives and the construction of
magazines because they are regulated by
the Bureau of Alcohol, Tobacco,
Firearms, and Explosives (ATF);
• Eliminate provisions in § 1910.109
applicable to the transportation of
explosives on public highways because
such transportation is regulated by DOT;
• Update provisions for guarding
against accidental initiation by sources
of extraneous electricity;
• Include provisions governing the
intra-plant transportation of explosives;
• Include provisions for the use of
nonelectric detonation systems;
• Revise provisions regarding the
crimping of detonators to safety fuse;
• Update provisions for clearing the
blasting area of unauthorized personnel;
and
• Update the provisions for the
design of bulk delivery and mixing
vehicles and of mixing equipment."

The whole point is that this is nothing new... Its just being redefined.... I'm sure after reading the document you will feel the same.






Offline Boomn4x4

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Re: new potential "explosives" law
« Reply #11 on: July 07, 2007, 08:04:03 AM »
I forgot... As far as Evacuating Wal-Mart... this simply isn't true.... The regulation merely says that people must be evacuated to a safe area (it does not say the entire facility must be evacutated) so should there be an explosion, they would not be injured (ie...stay out of that isle).  On top of that, this regulation was put into effect back in 1971... It is not new to this proposal.  This proposal only adds " .. and to cease the operations and manufacturing of" explosives during an electrical storm.  The proposal also acknowledges that this practice is already an industrial standard.

The author also says that these regulations would cause $100 million... How many millions boxes of ammo are sold each year?  Even if it did cost $100 million to update facilites and make regulatory changes... that cost spread across the millions (if not billions) of boxes of ammo that are sold, would be no more than a few pennies.

I shouldn't have said this is a "Scam" those were harsh words... And I'm also not saying that you would be wrong to sign it.  I'm simply saying that this whole this has been blown out of proportion.

My whole point is:
1.  It was the ammunition industry that requested the review to update standards to make for a safer workplace.

2.  These regualations are already in effect... they are just updating them to include new standars and technology.

Offline Michelle_Nelson

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OSHA proposes ne ammunition law.
« Reply #12 on: July 10, 2007, 06:55:08 PM »
http://www.nraila.org/Legislation/Federal/Read.aspx?id=3145

This was E-mailed to me and I thought I would share!

Offline Choclab

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Eastsider stuck on the wetside......

Offline Ray

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Re: Proposed OSHA Regulation Threatens Firearm and Ammunition Industry
« Reply #14 on: July 10, 2007, 10:15:36 PM »
I merged all three topics into one....

 


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