Was there a problem in the past at ammo factories when thunderstorms rolled through? Or were people with lighters causing explosions at ammo retailers?
OSHA is asking for comments via the following (see their proposal, page 14, column 3):
"Issue #4: OSHA seeks specific comments on the impact proposed paragraph (c)(3)(iii) would have on the storage and retail sale of small arms ammunition, small arms primers, and smokeless propellants. Do open flames, matches, or spark producing devices create a hazard when located within 50 feet of small arms ammunition, small arms primers, or smokeless propellants, or facilities containing these products? Can employeres involved in the storage or retail sale of small arms ammunition, small arms primers, or smokeless propellants prevent all open flames, matches, or spark producing devices from coming within 50 feet of these products or facilities containing these products? If not, why not? Should proposed paragraph (c)(3)(iii) use a protective distance other than 50 feet and, if so, what distance should it be and why? Should OSHA exclude small arms ammunitiion, small arms primers, and smokeless propellants from the the requirements of proposed paragraph (3)(3)(iii)?"
Well, what is the real risk of explosion due to an open flame, matches, or spark producing device being within 50 feet of small arms ammunition, small arms primers, or smokeless propellants in a retail setting? There is no need whatever to speculate about it, as we know from a real-world experiment, which has been conducted over the last 100 years, what the risk is.
Consider: How many times in the last 100 years has someone gone into a retail store, stood in front of a shelves loaded with small arms ammunition, primers, and powder, and lit up a cigarette? Until very recently, such behavior was the norm for smokers who own guns and purchased ammunition, wasn't it? A quick estimate is: (the average population of the country over the last 100 years) x (the fraction of the population who owns guns) x (the fraction of the population who smokes) x (once per year per person) x (100 years) x (1/2, just to be a bit conservative). In round numbers, that's about one billion times. I'm not aware of even a single time that such behavior, boorish as it is, has resulted in an explosion of any of these "explosive devices".
How about "spark producing devices"? A light switch is a "spark producing device". Have you ever heard of a gun shop blowing up because someone turned on the lights? Should all light switches be moved at least 50 feet away from the ammo display?
Ah, but consider further. A gunsmith shop will likely have many such spark producing devices as grinders, files, saws, drills, and so on. My brother worked as a gunsmith for many years in such a shop, and none of the ammunition, primers, or powder in the store ever exploded as a result. How many such shops have been in business over the past 100 years?
And finally, consider a business such as H & H Shooting Range in Oklahoma City, where I've been known to spend some money. It is a very nice gun shop, selling small arms, small arms ammunition, and so on. It has four indoor shooting ranges that are located only about 30 feet from the display of ammo for sale. It's been in business for a long, long time. Is it the only one that hasn't blown up?
You can't beat a real-world experiments for evaluating risk, especially an experiment that has been run across the whole country for 100 years. We can conclude with extreme confidence from this 100-year-long experiment that the risk that OSHA asks about that I've highlighted above approaches zero. It isn't a problem and it doesn't need fixing.
I've never even heard of anyone setting off a cartridge with a lighter or match except by pulling the bullet and spilling the powder. Normal sealed cartridges caught in a house fire do go off eventually, but I'm under the impression that it only happens at temperatures far higher than you'd get by holding the primer end over a lighter flame.
So the 50 foot regulation is definitely designed to cripple ammunition sales rather than to improve safety. The two main places to buy guns and ammo in my small town are Walmart and one gun shop. Walmart obviously couldn't cordon off 50 x 100 feet around sporting goods, so they'd have to stop selling ammo and might as well stop selling guns. Even if the gun shop collected lighters and matches at the front door, it's not 50 feet from the door to anywhere in the store, so they'd be out of business.
As for the ammunition plant regulations, how often have these blown up?
Let's imagine that this comes to pass, and as a result factory ammunition becomes prohibitively expensive and almost unavailable.
Do you think that experimentation with home-made propellants will increase or decrease? And how will that affect ammunition-related accident rates?
Following that, of course, we would see a crackdown on all those new felons and their secret ammo labs.
Damned if it didn't have an effect! Go see http://www.nraila.org/Legislation/Read.aspx?ID=3162 and then see http://a257.g.akamaitech.net/7/257/2422/01jan20071800/edocket.access.gpo.gov/2007/E7-13925.htm
At this point, OSHA says comments are closed and "The Department intends to re-propose the Explosives NPRM at a later date in order to clarify the intent of the rulemaking."
Hmmm ...
The problem is the proposed rule, and the intent is clearly stated in plain English. It ain't over yet.
Note:
All avatars and any images or other media embedded in comments were hosted on the JS-Kit website and have been lost;
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JS-Kit/Echo comments for article at http://smallestminority.blogspot.com/2007/07/spread-this-alert-far-and-wide.html (9 comments)
Tentative mapping of comments to original article, corrections solicited.
Was there a problem in the past at ammo factories when thunderstorms rolled through? Or were people with lighters causing explosions at ammo retailers?
When I send my objections in, I will word them even more simply: Precisely what problem are the proposed regulations a solution to?
You have too much freedom, DJ. These nice occupational safety professionals are going to solve that problem for you. Duh.
OSHA is asking for comments via the following (see their proposal, page 14, column 3):
"Issue #4: OSHA seeks specific comments on the impact proposed paragraph (c)(3)(iii) would have on the storage and retail sale of small arms ammunition, small arms primers, and smokeless propellants. Do open flames, matches, or spark producing devices create a hazard when located within 50 feet of small arms ammunition, small arms primers, or smokeless propellants, or facilities containing these products? Can employeres involved in the storage or retail sale of small arms ammunition, small arms primers, or smokeless propellants prevent all open flames, matches, or spark producing devices from coming within 50 feet of these products or facilities containing these products? If not, why not? Should proposed paragraph (c)(3)(iii) use a protective distance other than 50 feet and, if so, what distance should it be and why? Should OSHA exclude small arms ammunitiion, small arms primers, and smokeless propellants from the the requirements of proposed paragraph (3)(3)(iii)?"
Well, what is the real risk of explosion due to an open flame, matches, or spark producing device being within 50 feet of small arms ammunition, small arms primers, or smokeless propellants in a retail setting? There is no need whatever to speculate about it, as we know from a real-world experiment, which has been conducted over the last 100 years, what the risk is.
Consider: How many times in the last 100 years has someone gone into a retail store, stood in front of a shelves loaded with small arms ammunition, primers, and powder, and lit up a cigarette? Until very recently, such behavior was the norm for smokers who own guns and purchased ammunition, wasn't it? A quick estimate is: (the average population of the country over the last 100 years) x (the fraction of the population who owns guns) x (the fraction of the population who smokes) x (once per year per person) x (100 years) x (1/2, just to be a bit conservative). In round numbers, that's about one billion times. I'm not aware of even a single time that such behavior, boorish as it is, has resulted in an explosion of any of these "explosive devices".
How about "spark producing devices"? A light switch is a "spark producing device". Have you ever heard of a gun shop blowing up because someone turned on the lights? Should all light switches be moved at least 50 feet away from the ammo display?
Ah, but consider further. A gunsmith shop will likely have many such spark producing devices as grinders, files, saws, drills, and so on. My brother worked as a gunsmith for many years in such a shop, and none of the ammunition, primers, or powder in the store ever exploded as a result. How many such shops have been in business over the past 100 years?
And finally, consider a business such as H & H Shooting Range in Oklahoma City, where I've been known to spend some money. It is a very nice gun shop, selling small arms, small arms ammunition, and so on. It has four indoor shooting ranges that are located only about 30 feet from the display of ammo for sale. It's been in business for a long, long time. Is it the only one that hasn't blown up?
You can't beat a real-world experiments for evaluating risk, especially an experiment that has been run across the whole country for 100 years. We can conclude with extreme confidence from this 100-year-long experiment that the risk that OSHA asks about that I've highlighted above approaches zero. It isn't a problem and it doesn't need fixing.
I've never even heard of anyone setting off a cartridge with a lighter or match except by pulling the bullet and spilling the powder. Normal sealed cartridges caught in a house fire do go off eventually, but I'm under the impression that it only happens at temperatures far higher than you'd get by holding the primer end over a lighter flame.
So the 50 foot regulation is definitely designed to cripple ammunition sales rather than to improve safety. The two main places to buy guns and ammo in my small town are Walmart and one gun shop. Walmart obviously couldn't cordon off 50 x 100 feet around sporting goods, so they'd have to stop selling ammo and might as well stop selling guns. Even if the gun shop collected lighters and matches at the front door, it's not 50 feet from the door to anywhere in the store, so they'd be out of business.
As for the ammunition plant regulations, how often have these blown up?
Rush Limbaugh talked briefly about this today.
He called it a sneaky, backdoor gun-control measure.
Let's imagine that this comes to pass, and as a result factory ammunition becomes prohibitively expensive and almost unavailable.
Do you think that experimentation with home-made propellants will increase or decrease? And how will that affect ammunition-related accident rates?
Following that, of course, we would see a crackdown on all those new felons and their secret ammo labs.
On 07/09/07, OSHA has extended the comment period through 09/10/07. See document OSHA-2007-0032-0018.pdf
Damned if it didn't have an effect! Go see http://www.nraila.org/Legislation/Read.aspx?ID=3162 and then see http://a257.g.akamaitech.net/7/257/2422/01jan20071800/edocket.access.gpo.gov/2007/E7-13925.htm
At this point, OSHA says comments are closed and "The Department intends to re-propose the Explosives NPRM at a later date in order to clarify the intent of the rulemaking."
Hmmm ...
The problem is the proposed rule, and the intent is clearly stated in plain English. It ain't over yet.
Note: All avatars and any images or other media embedded in comments were hosted on the JS-Kit website and have been lost; references to haloscan comments have been partially automatically remapped, but accuracy is not guaranteed and corrections are solicited.
If you notice any problems with this page or wish to have your home page link updated, please contact John Hardin <jhardin@impsec.org>