Replies

“This is not an exaggeration.”

Yes. It is.

You claim “For example, ammunition and smokeless propellant manufacturers would have to shut down and evacuate a factory when a thunderstorm approached...”

When I downloaded the pdf of the proposed rule, I searched for the word thunderstorm. It doesn’t appear in the proposed rule.

When I searched for lightning, what came up was a requirement to install lightning protection systems to manage stray currents produced by lightning. Seems reasonable to me.

And further, OSHA is specifically requesting input on its requirement about 50 feet of separation. It recognizes that it may not be feasible. From the preamble to the proposed rule itself:

“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 employers 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 ammunition, small arms primers,
and smokeless propellants from the
requirements of proposed paragraph
(c)(3)(iii)?”

As far as the cost impact, when I read the preliminary economic analysis in 71 FR 18828 to 18833, it seems reasonable when spread over the entire industry.

I’ll get worried when the workers at these companies that have to put up with risks daily complain.

But if you have concerns, please do comment. It’s what this process is all about. Instructions on how to comment and the deadline (July 12, 2007) are presented on 71 FR 18792. But please read the proposed rule carefully and make sure your comment is based in fact (not hyperbole) and is logical and persuasive.