To: OSHA Docket Office
From: Larry Pratt, Executive Director of Gun Owners of America
Re: Docket No. OSHA-2007-0032
Date: July 3, 2007
As a Second Amendment organization representing 300,000 members, we are writing to express our concern over Docket No. OSHA-2007-0032.
Those in the industry who are familiar with the process of manufacturing ammunition are contending that "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 the industry." They contend that the cost of the regulation will exceed $100 million, and that, for example:
* A factory would have to be shut down and evacuated every time a lightning storm approached; and
* Customers would have to be searched for matches and lighters before approaching an ammunition display.
Suffice it to say, such a result would be not only a "significant regulatory action," but also a crippling blow to American firearms ownership -- and would be directly contrary to the spirit and letter of the McClure-Volkmer Firearms Owners Protection Act of 1986, which was intended to deregulate ammunition.
At a time when anti-gun zealots in Congress have temporarily backed away from the vigorous pursuit of at least some of the gun control agenda, what an irony it would be if an agency of the Bush administration were to devastate the Second Amendment through an unconstitutional backdoor effort.
We would encourage you to back away from such an exercise.