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Kelly J

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OSHA is proposing insidious new regulations that will put ammo and reloading supplies on the endangered species list. Here is message I received from SC Grassroots.


6 July 2007,OSHA is proposing the adoption of new regulations, which would reclassify all small arms ammunition and reloading supplies as “explosives.” This creates several new and extremely strict regulations with which all manufacturers, transportation carriers and any retail stores selling these items must then comply. This will have a major effect on all manufacturing, retail sales, mail order sales, and shipping of ammunition and reloading supplies. The increased cost associated with compliance will force most businesses to stop selling ammunition and reloading supplies altogether, and may drive many ammunition manufacturers out of business. A few excerpts from the proposed new OSHA regulations are as follows:


§ 1910.109 Explosives.
Explosive means any device, or liquid or solid chemical compound or mixture, the primary or common purpose of which is to function by explosion. (i) The term ''explosive'' includes all material included as a Class 1 explosive by DOT in accordance with 49 CFR chapter I. The term includes, but is not limited to, dynamite, black powder, pellet powders, detonators, blasting agents, initiating explosives, blasting caps, safety fuse, fuse lighters, fuse igniters, squibs, cordeau detonant fuse, instantaneous fuse, igniter cord, igniters, pyrotechnics, special industrial explosive materials, small arms ammunition, small arms ammunition primers, smokeless propellant, cartridges for propellant-actuated power devices, and cartridges for industrial guns.

Note that ammunition and reloading supplies are all now classified as “Explosives.”


(viii) No person enters a facility containing explosives or a blast site unless authorized to do so by the employer;

This includes retail stores such as WalMart, Cabelas, Bass Pro Shops, and your favorite corner gun stores.


(ii) During the approach and progress of an electrical storm, the employer shall ensure that: (B) Employees located in or near facilities containing explosives or in blast sites are withdrawn immediately to a safe remote location.

This means all retail stores that sell “explosives” (ammo) will be required to evacuate the entire store if a storm approaches (or just quit carrying ammo anymore).


(iii) The employer shall ensure that: (A) No open flames, matches, or spark-producing devices are located within 50 feet (15.2 m) of explosives or facilities containing explosives;

Stores may be required to search customers for matches and lighters, and ban customers from bringing them into the entire store (or just quit carrying ammo anymore).


(B) Smoking is only permitted in authorized smoking areas located a safe distance from explosives;

How far is “a safe distance”? Can a gun store be located in a strip mall near a tobacco store? Is smoking outside the store's main entrance “a safe distance”?


(C) No person carries firearms, ammunition, or similar articles in facilities containing explosives or blast sites except as required for work duties;

Retail stores will be required ban customers from lawful concealed carry on their premises.


(e) Transportation of explosives. (1) General provisions. The employer shall ensure that: (i) No employee smokes, carries matches or any other flame-producing device, or carries any firearms or cartridges (except firearms and cartridges required to be carried by guards) while in, or within 25 feet (7.63m) of, a vehicle containing explosives;

No truck drivers may be armed or carry any ammo, nor can they carry matches or a lighter, nor can anyone who loads or unloads these trucks when ammo is onboard.


(2) Vehicles. (i) The employer shall ensure that any vehicle used to carry explosives: (A) Is able to safely carry the designated load; (B) Has close-fitting floors; and (C) Has wood or other non-sparking materials covering any exposed spark producing metal on the inside of the vehicle body.

All vehicle cargo spaces will have to undergo modifications to make them “spark proof.”


(3) Operation of vehicles. (i) The employer shall ensure that: (C) Except under emergency conditions, no vehicle containing explosives is parked before reaching its destination on any public street adjacent to or in close proximity to any place of employment;

Deliveries of ammo will no longer be able to be made by carriers such as UPS, FedEx, DHL, etc. These carriers often make several stops during their delivery route.


(h) Small arms ammunition, small arms primers, and smokeless propellants. (1) Applicability. This paragraph does not apply to temporary in-process storage during the manufacture of small arms ammunition, small arms primers, or smokeless propellants. (2) Small arms ammunition. The employer shall ensure that small arms ammunition is separated from flammable liquids, flammable solids, and oxidizing materials, by a fire barrier wall with at least a 1-hour rating or by a distance of at least 25 feet (7.6 m).

Small businesses will be required to store all paint & cleaning supplies behind a fire barrier or 25 feet away. Does this also mean during shipment by motor carrier?

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EVERY FIREARMS OWNER SHOULD GO TO THIS WEBSITE AND RESPOND.

ACTION STEPS:

Go to this website and comment on the proposed changes. Visit this website: http://www.regulations.gov then choose option 4, select DOCUMENT ID, then type in OSHA-2007-0032-0001. When the document title comes up, go to the right side of the screen and click on “COMMENTS ADD / DUE BY 7/12/07.”

Let OSHA know that you are concerned about the serious effect these new regulations will have on the ammunition manufacturing, shipping, and retail ammunition sales industries. (Feel free to use the following text, or create your own)


Dear Sir:
The proposed new restrictions outlined in OSHA-2007-0032-0001 will cause a massive increase in costs associated with manufacture, wholesale distribution and retail sales of ammunition, driving many companies out of the market entirely.

These restrictions on manufacture will further exacerbate current ammunition shortages now being experienced by DoD, Law Enforcement, and Homeland Security, causing major national security implications.

Retail stores which simply carry ordinary firearms ammunition for sale to the general public would be required to follow several new and unrealistic restrictions, (for example: being required to shut down operations and evacuate the premises during a thunderstorm). This would cause most businesses to instead choose to halt all sales of ammunition to the public altogether.

Regulations on shipping transportation would prevent carriers like FedEx and UPS from any further ammunition deliveries, effectively ending mail order sales of ammunition, as well as sales by most small retail businesses.
I strongly urge OSHA not to adopt these restrictions on small arms ammunition and reloading supplies, which would have many serious adverse consequences for the small arms ammunition industry.
Sincerely,

YOUR NAME
YOUR CITY





GrassRoots GunRights of SC would like to thank you for taking the time to make your voice heard on this very important matter.
Bill Rentiers
Executive Officer
GrassRoots GunRights of SC
803-233-9295
 
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