OSHA proposed regulation on Explosives comment period extended {US regs affect YOU}

John Y Cannuck

John Y Cannuck

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Email from the Canadian Firearms digest:

Date: Fri, 13 Jul 2007 15:19:39 -0600
From: Joe Gingrich <whitefox@sasktel.net>
Subject: "OSHA proposed regulation on Explosives comment period extended"

Subject: "OSHA proposed regulation on Explosives (OSHA-2007-0032-0001)
comment period is extended"

The OSHA proposed regulation on Explosives ( OSHA-2007-0032-0001 ) has had
its comment period extended. The comment period was to end on Thursday (
July 12 ), but now is September 10.

There are few comments thus far. We must tell them what we think. Don't
delay, we need input now.

Remember the site www.regulations.gov is a bit hostile. Try the following
technique to get to the comment section

At www.regulations.gov do this:

Step 1 select: All Documents (Open and Closed for Comment)

Step 2 select: Occupational Safety and Health Administration

Step 3 select: All Document Types

Step 4 select: Document ID and add OSHA-2007-0032-0001 in the blank space
to the right of it

Step 5 select submit

Step 6 you will then get
http://www.regulations.gov/fdmspublic/component/main where under views you
must select pdf or HTML formats to open the comment page for OSHA

- ----------------------------------------------------------------------------------------------
The following letter is a template form letter from http://gunlawnews.org/
You certainly should make up your own letter to OSHA using your ideas. The
comment period has already been extended to September 10, 2007 so this
template letter is already out of date. However, it does provide some
arguments you could incorporate into a letter you write.

Joe Gingrich
White Fox, Sask.
 
Last edited:
Click here for a template letter. 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.

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 standard 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 has 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 still wouldn't be able to purchase
the 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 fewer than 50-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,
 
Well that makes two threads without any response from our members. I sometimes wonder what the US guys think of us when we ask for their help but don't respond in kind.

Take Care

Bob
 
Is it cool to just copy your letter and then sign it with my name? Dang firewood would be illegal if people read the MSDS and OSH got even more cranky....
 
seems like theres a surplus of leftist BS being thrown in the stink pot latley the fumes are making me ill
 
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