Saturday, July 7, 2007

OSHA Proposed "Safety" Regulations

I have went to the government regulations site and left my comment with them. When you click on the link below, you will have to do a search for the document. Just copy and paste this to search for.

OSHA-2007-0032 (Explosives—Proposed Rule)

I have also contacted both of my Senators and my Representative about this new safety regulation. I would suggest that you do the same very soon.
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The Occupational Safety and Health Administration (OSHA) has proposed new rules that would have a dramatic effect on the storage and transportation of ammunition and handloading components such as primers or black and smokeless powder. The proposed rule indiscriminately treats ammunition, powder and primers as "explosives." Among many other provisions, the proposed rule would:
  • Prohibit possession of firearms in commercial "facilities containing explosives"—an obvious problem for your local gun store.
  • Prohibit delivery drivers from leaving explosives unattended—which would make it impossible for delivery services such as UPS to deliver ammunition or gun powder.
  • Require evacuation of all "facilities containing explosives"—even your local Wal-Mart—during any electrical storm.
  • Prohibit smoking within 50 feet of "facilities containing explosives."
It's important to remember this is only a proposed rule right now, so there's still time for concerned citizens to speak out before OSHA issues its final rule. The National Rifle Association, National Shooting Sports Foundation, and Sporting Arms and Ammunition Manufacturers' Association will all be commenting on these proposed regulations, based on the severe effect these regulations (if finalized) would have on the availability of ammunition and reloading supplies to safe and responsible shooters.
The public comment period ends July 12. To file your own comment, or to learn more about the OSHA proposal, go to http://www.regulations.gov and search for Docket Number OSHA-2007-0032"; you can read OSHA's proposal and learn how to submit comments electronically, or by fax or mail.
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OSHA Docket Office Docket No. OSHA-2007-0032 U.S. Department of Labor, Room N-2625 200 Constitution Ave., N.W. Washington, DC 20210 Re.: Docket No. OSHA-2007-0032 (Explosives—Proposed Rule)

Sample Comment

Dear Sir or Madam:
I am writing in strong opposition to OSHA's proposed rules on "explosives," which go far beyond regulating true explosives. These proposed rules would impose severe restrictions on the transportation and storage of small arms ammunition—both complete cartridges and handloading components such as black and smokeless powder, primers, and percussion caps. These restrictions go far beyond existing transportation and fire protection regulations.

As a person who uses ammunition and components, I am very concerned that these regulations will have a serious effect on my ability to obtain these products. OSHA's proposed rules would impose restrictions that very few gun stores, sporting goods stores, or ammunition dealers could comply with. (Prohibiting firearms in stores that sell ammunition, for example, is absurd—but would be required under the proposed rule.)

The proposed transportation regulations would also affect shooters' ability to buy these components by mail or online, because shipping companies would also have great difficulty complying with the proposed rules. For instance, the rules against leaving any vehicle containing "explosives" unattended would make it impossible for companies such as United Parcel Service to deliver ammunition to businesses or consumers without massive changes in their operations (such as putting a second driver on any truck that might happen to deliver a case of shotgun shells).

There is absolutely no evidence of any new safety hazard from storage or transportation of small arms ammunition or components that would justify these new rules. I also understand that organizations with expertise in this field, such as the National Rifle Association, National Shooting Sports Foundation, and Sporting Arms and Ammunition Manufacturers' Association, will be submitting detailed comments on this issue. I hope OSHA will listen to these organizations' comments as the agency develops a final rule on this issue.



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