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Proposed rule changes for shipping blackpowder

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Proposed rule changes for shipping blackpowder

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Old 07-04-2007, 01:01 PM
  #11  
Boone & Crockett
 
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Join Date: Mar 2007
Location: Comance county, OK
Posts: 11,408
Default RE: Proposed rule changes for shipping blackpowder

Finally printed out the document and studied it in detail. It gets much worse: SAAMIpetitioned OSHA for the change. Looks like SAAMI got exactly what they asked for. See page 18793 of the document fordetails of the petition quoted here.

Just checked, still no comments from any pro-gun organization.

"On July 29, 2002, OSHA received a
petition (the Petition) from the Institute
of Makers of Explosives (IME) and the
Sporting Arms and Ammunition
Manufacturers’ Institute (SAAMI) to
revise the standard. A copy of the
Petition can be found at Docket No.
OSHA–S031–2006–0665 (Ex. 2–1). IME
is an association of manufacturers of
high explosives and other companies
that distribute explosives or provide
other related services and the SAAMI is
an association of manufacturers of
sporting firearms, ammunition, and
related components. The Petition
claimed that § 1910.109 does not reflect
significant technological and safety
advances made by the explosives
industry since the standard was
promulgated. It further contended that
the standard contains outdated
references, classifications, and
jurisdiction-related provisions that do
not accurately represent the current
regulatory environment.
The Petition requested OSHA to make
a number of changes to the standard,
including the following, and provided
draft regulatory language:
• Exclude the manufacture of
explosives from the PSM requirements
of § 1910.119 and incorporate revised
PSM requirements for the manufacture
of explosives into § 1910.109;
• Replace references to outdated DOT
explosives classifications with the
current DOT classification system;
• Eliminate the provisions in
§ 1910.109 covering the storage of
explosives and the construction of
magazines because they are regulated by
the Bureau of Alcohol, Tobacco,
Firearms, and Explosives (ATF);
• Eliminate provisions in § 1910.109
applicable to the transportation of
explosives on public highways because
such transportation is regulated by DOT;
• Update provisions for guarding
against accidental initiation by sources
of extraneous electricity;
• Include provisions governing the
intra-plant transportation of explosives;
• Include provisions for the use of
nonelectric detonation systems;
• Revise provisions regarding the
crimping of detonators to safety fuse;
• Update provisions for clearing the
blasting area of unauthorized personnel;
and
• Update the provisions for the
design of bulk delivery and mixing
vehicles and of mixing equipment.
In response to the Petition, OSHA
carefully reviewed the requirements of
the current standard and other related
OSHA standards. It analyzed the
recommendations as well as the draft
regulatory language provided in the
Petition. OSHA also examined the
regulations of other federal agencies
relating to explosives and consulted
with interested parties about the need to
revise the standard. Apart from IME and
SAAMI, these interested parties
included the International Society of
Explosives Engineers (ISEE), the
American Pyrotechnics Association
(APA), the United Steel Workers of
America (USWA), and the Paper, Allied-
Industrial, Chemical and Energy
Workers International (PACE). In
addition, OSHA consulted with other
Federal agencies about their explosives
regulations and procedures. These
Federal agencies included the DOT,
ATF, the Interagency Committee on
Explosives (ICE), the Department of
Defense Explosives Safety Board
(DDESB), the Consumer Product Safety
Commission (CPSC), and the Mine
Safety and Health Administration.
Based upon its review of the Petition
and the standard, OSHA has concluded
that the following actions are
appropriate. These actions are discussed
in greater detail in the summary and
explanation section of the proposed rule
(see section III).
A. Update the Standard
Workplace hazards associated with
explosives activities pose significant
risks to employees. OSHA has
determined that the existing standard
needs to be updated to adequately
protect employees from these risks."

"........"
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