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Old 07-03-2007, 10:23 PM
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Default Proposed OSHA Regulation Threatens

NSSF

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. 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: Regulations.gov and
following the submission instructions.
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Old 07-16-2007, 11:55 AM
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