July 16, 2007
OSHA Retracts Proposed Regulations Pending Review
The Sporting Arms and Ammunition Manufacturers' Institute (SAAMI) is
pleased to report that, following discussions with OSHA, the
proposed regulations for explosives (29 CFR 1910.109) is being retracted pending
a full review and clarification of the purposes of the regulation.
Many people do not understand the properties of modern ammunition and
gunpowder. Classifying these products as explosives is simply wrong-it's
not consistent with their physical properties. SAAMI has been able to
demonstrate the safety of ammunition and ammunition components by conducting
and videotaping burn tests of these and other common household products.
The tests show conclusively why the proposed changes to 29 CFR 1910.109
were completely inappropriate. As a result of this information, SAAMI
petitioned OSHA in 2002 to exclude ammunition from 29 CFR 1910.109 and
adopt NFPA (National Fire Protection Act) 495 to properly regulate the
safe storage of ammunition and components.
We believe the professionals at OSHA were sincere in their efforts
to improve regulations of explosives using the most up-to-date information
and technology. Ammunition and components were summarily included in
the proposed changes based on perceptions of authors unfamiliar with
these products. While unfortunate, the end results have proven that
OSHA is genuinely interested in making decisions based on science and
not politics when promoting workplace safety and protecting employee
health.
SAAMI looks forward to a continued dialogue and working relationship
with the professionals at OSHA-and other regulatory agencies-to promote
safety and reliability in the design, manufacture, use, transportation,
and storage of firearms, ammunition, and components.
Richard Patterson
Managing Director
Sporting Arms and Ammunition Manufacturers' Institute
July 6, 2007:
Proposed Changes to OSHA
Regulation 29 CFR 1910.109
The Sporting Arms and Ammunition Manufacturers' Institute (SAAMI) has
a decades-long history of working with government agencies
to ensure the safe and responsible design, manufacture, use, transportation
and storage of SAAMI member-companies' products. These efforts have
included a positive working relationship with OSHA. In the past, SAAMI
has recommended changes to OSHA regulations that have ultimately been
accepted and adopted. We have also been able to show--through sound
science--when proposed regulations are unwarranted and needlessly restrict
the smooth flow of firearms, ammunition and components.
Recently, OSHA has proposed new changes to 29 CFR 1910.109. These proposed
new regulations may include requirements that are unduly restrictive
and not supported by science. SAAMI has requested a
60 day extension to fully review, evaluate and comment on these
proposed changes. Once we complete this review and evaluation, we will
post our comments on this web site. At that time, we will also ask the
National Shooting Sports Foundation to include a notice of this posting
in their "Bullet
Points" e-newsletter.
Richard Patterson
Managing Director
Sporting Arms and Ammunition Manufacturers' Institute