Osha 2007-0032

[Eightball]

Just as a thought to add to some of the comments:

If they institute this, the cost of ammunition for the military will skyrocket; since most of the commercial businesses that would otherwise eat the cost of making the required changes will just stop selling product, the companies (being part of the wonderful free market of capitalism) will "pass the buck" on to the military and law enforcement, seeing howas they'll be the only people properly equipped to handle ammunition; in other words, this will raise taxes as well, because when prices for the military go up, they aren't just going to let it slide and have it eat into their budget, they'll pass a BIGGER budget (which due to the new "pay as you go" style legislation) forcing instantly higher taxes.

I already submitted my comments, but maybe someone would like to feed them quantifiable analysis of the above comments; I would do so, but since I WORK at an FFL, I'm already worried about my job....

 

[hso]

Oh, if they don't retain the old language exempting business with less than 750,000 rounds or primers or 750 lb of powder from the requirements they'll have a huge problem on their hands beyond our concerns. All construction companies and supply businesses that have powder actuated (cartridge) nail drivers will have to apply all these rules. I bet they'd just love to "evacuate the site) every time thunder is heard. Armed security companies would have to do the same and they couldn't keep ammunition on site if firearms were present. Even police departments would have to follow the rules.

This has all the earmarks of ivory tower professionals (yes, I'm a safety pro too) who got caught up in the process safety thinking for explosives manufacturers and the blasting/demolition industry and had no familiarity with the shooting and firearms using industries. Their stovepipe thinking led them down the merry path of treating all explosives the exact same way and now they're going to horribly embarrassed by their sloppy thinking.

We can probably toss SAAMI into the brier patch with OSHA on this also for the same reason. I'd just love to see what they're draft proposed changes in their petition looked like. Odds are the language in the OSHA comment copy is strikingly close to SAAMI's suggestions. Just no one remembered about retailers and distributors of small arms ammo. No wonder he wouldn't talk with you alsaqr.

Hammer your elected officials and the OSHA administrator. Make fun of them for having forgotten about the largest part of the explosives industry, the shooting sports. Point out the existing OSHA standard has an exemption intended for retailers and wholesalers and that it should be retained in the new revision under consideration.

 

[Alexfubar]

I thought gunpowder was classified as an "accelerant" , not "explosive."

 

[hso]

Yes, but then again, no. OSHA added smokeless powder, primers and ammunition to the regulatory definition (that term "regulatory definition" is an important distinction) of explosives in 29 CFR 1910.109 back in 1972. It was done much like we'd add laser guns or particle beam rifles to our definition of "gun" instead of calling it something else all together. They've been regulating them for the past 30+ years, but up until SAAMI and EMI petitioned OSHA to update the standard they were pretty much treated as being almost no hazard when in small enough quantities. OSHA or SAAMI forgot that distinction in the proposed revision (we may never know until we see SAAMI's petition to OSHA to revise the standard).

The simplest action we could take would be to insist that OSHA retain the language from the existing standard exempting establishments with less than 750,000 rounds of ammunition, 750,000 small arms primers, or 750 lbs of smokeless powder from the proposed requirements under this revision. That would keep things as they are for ammo dealers.

 

[Eightball]

Well, we need to get more members here to do just that--petition them/point out that that language is lacking, and would have severe backlash, or something to that effect written politely in legalese.

 

[xsquidgator]

OSHA-2007- 0032 comment period extended to Sept 10th

http://www.nraila.org/Legislation/Read.aspx?ID=3151

OHSA Grants 60 day extension on Proposed "Safety" Rule That Would Address Ammunition Sales

 

[hso]

http://www.regulations.gov/fdmspublic/component/main

We need to continue to email/call/write our elected officials and push them to ensure language exempting retailers, security companies, construction companies, commercial ranges, etc from those requirements beneficial to workers at explosives manufacturers is put back into the revision of 1910.109.

We also need to contact everyone we know that owns a business that would be affected by this revision (security, construction, ammo dealers, ranges, etc.) and help them understand that this is their opportunity to comment and have OSHA treat them differently than the explosives manufacturers and blasting/demolition companies. The should request that the language exempting any business with less than 750,000 rounds of small arms ammunition or primers or 750lbs of powder be restored to the proposed revision.

 

[cgraham]

Hso: how do we get the attention of THR members who do not read this sub-forum?

We need an announcement that briefly states the issue and the recommended action, included the links to the Proposed Rule and the comments page, and a draft letter. (Reference to this discussion would be appropriate, but would be confusing on its own.

This would be good to print out and distribute too (preferably formatted in Word or PDF for display).

Edit: 750,000 rounds of ammo AND 750,000 primers AND 750,000lb of smokeless powder.

C

 

[hso]

If they're not reading Activism then they're not interested.

I consider it inevitable that changes to the revision will be made to not treat small arms ammunition businesses the same as manufacturers. That will include powder-actuated tools cartridges as well as ammunition. OSHA has gotten comments resulting in an extension of the comment period and now will receive detailed comments from SAAMI, NSSF, NRA, etc. pointing out the nonsensical nature of applying the same rules to their member businesses as manufacturers (gotta love the irony of SAAMI's involvement). The end result will be a revised 1910.190 that will apply regulatory controls where they need to be applied and not using a one-size-fits-all approach for manufacturers and small gun shops alike.

If you want to do anything constructive continue to inform your chamber of commerces about this and it's implications. Tell every small gun shop/gas station selling ammo/construction company about it so they can point out the nonsense of imposing the same requirements on small businesses as on large manufacturers. Poke your congress critters in the ribs over OSHA having made such a bone-headed error. Be sure to include the docket number so they know what we're upset about.