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:
http://www.regulations.gov and following the submission instructions.
