Mar 2, 2008

Proposed Restrictions of Storage and Display of Small Arms Ammunition

Docket No. OSHA-2007-0032

The proposed restrictions of storage and display of small arms ammunition are unrealistic and unnecessary. The propellants and primers used in small arms ammunition are highly stable and are already well regulated, packaged and perfectly safe for transportation, retail, and use.

Individual primers encase their minuscule pellets inside a tiny metallic cup (“large” primers are 0.21 inches across), which are stored individually in a sturdy plastic deck, placed inside a sleeve, then placed inside another box, which is then placed inside yet another box. Completed ammunition separates the primer and propellant encased in a metallic container (the cartridge case and bullet.) Typically, each cartridge is packed separately inside a plastic or foam form, placed inside a box, which is then packed inside a shipping container. Ammunition used by the military takes this further by encasing these boxes in air-tight metal cans wrapped in wooden crates.

One gallon of gasoline weighs approximately six pounds, is liquid, has flammable fumes and the typical consumer dispenses 60 to 180 pounds (10 to 30 gallons) during a typical transaction. By comparison, the amount of fuel in small arms ammunition is negligible. A case of centerfire pistol ammunition (1,000 rounds) has less then 3/4 pound of propellant and primer and even this fractional amount is divided into a thousand individual containers.

Small arms ammunition uses tiny amounts of highly stable material and is already packaged in an extremely safe manner. How much more safety can we possibly need?

Thank You,
John Buol
Free Citizen

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