New OSHA Rules Letter by R.G. of NC

OSHA Docket Office Docket No. OSHA-2007-0032

U.S. Department of Labor, Room N-2625

200 Constitution Ave., N.W.

Washington, DC 20210

Re.: Docket No. OSHA-2007-0032 (Explosives-Proposed Rule)

Dear Sir or Madam:

I am writing in strong opposition to OSHA’s proposed rules on "explosives," which go far beyond regulating true explosives. These proposed rules would impose severe restrictions on the transportation and storage of small arms ammunition-both complete cartridges and hand-loading components such as black and smokeless powder, primers, and percussion caps. These restrictions go far beyond existing transportation and fire protection regulations. As a person who uses ammunition and components, I am very concerned that these regulations will have a serious effect on my ability to obtain these products.

OSHA’s proposed rules would impose restrictions that very few gun stores, sporting goods stores, or ammunition dealers could comply with. (Prohibiting firearms in stores that sell ammunition, for example, is absurd-but would be required under the proposed rule.) The proposed transportation regulations would also affect shooters’ ability to buy these components by mail or online, because shipping companies would also have great difficulty complying with the proposed rules. There is absolutely no evidence of any new safety hazard from storage or transportation of small arms ammunition or components that would justify these new rules. I also understand that organizations with expertise in this field, such as the National Rifle Association, National Shooting Sports Foundation, and Sporting Arms and Ammunition Manufacturers’ Association, will be submitting detailed comments on this issue. I hope OSHA will listen to these organizations’ comments as the agency develops a final rule on this issue.

Sincerely,

RG

[NOTE: Name, address and telephone numbers redacted]

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