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 work force, 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 met with OSHA officials to explain the major problems the proposed rule presents for all levels of the firearms and ammunition industry. Furthermore, industry members requested a 60-day extension of the public comment period to conduct a more thorough review and analysis of OSHA's proposal. OSHA recently honored industry's request by extending the comment submission deadline to Sept. 10.

NSSF continues to urge all manufacturers and retailers of small arms ammunition, primers and smokeless propellants to submit comments on the proposed rule to OSHA. Industry members should inform OSHA that the proposed rule constitutes a "significant regulatory action" as defined in Executive Order 12866 Section 3(f)(1) in that it will clearly "adversely affect in a material way" both the manufacturing and retail sectors of the ammunition industry, productivity, competition and jobs and that the annual compliance cost for makers and retailers of ammunition alone will far exceed $100 million dollars.

All written comments submitted to OSHA must include the following information in the reference line:

RE: Docket No. OSHA–2007–0032
Comment on Department of Labor/OSHA Proposed Rule
"Significant Regulatory Action" as Defined in Executive Order 12866

Please fax the letter to the OSHA Docket Office: (202) 693-1648 (include the docket number and Department of Labor/OSHA on the cover sheet and in the reference section of your letter).