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View Full Version : NRA and CRPAF Submit Comments Opposing California Regulations to Implement GCI


CRPA News and Updates
11-22-2010, 9:15 AM
The California Department of Toxic Substances Control (DTSC) has submitted its Proposed Regulations to the Office of Administrative Law that would implement the so-called "Green Chemistry Initiative.” The submission begins the official rulemaking process, including the public comment period. To see the proposed regulations click here (http://www.dtsc.ca.gov/LawsRegsPolicies/upload/SCPA-Regs_APA-format-9-07-10-rev-9-12.pdf).

Under the controversial Green Chemistry Initiative (GCI), thousands, perhaps even hundreds of thousands, of consumer products could fall under DTSC’s jurisdiction to regulate, and even to ban.

On November 1, 2010 the National Rifle Association (NRA) and the California Rifle and Pistol Association Foundation (CRPAF) submitted comments about the proposed regulations, and raised serious questions about the GCI’s potential impact on lead ammunition usage. To see NRA’s comments click here (http://calgunlaws.com/images/stories/Docs/NRA.LeadAmmo/comments%20on%20green%20chemistry.pdf). In light of the potential problems the GCI presents, the NRA and CRPA has again engaged the expertise of the environmental experts, scientists, and civil rights and environmental lawyers to oppose regulations that would detrimentally effect hunters and recreational shooters.

GCI could have an enormous impact on hunters and shooters, because DTSC could have the power to halt the sale and distribution of lead ammunition in California. As currently written, the Proposed Regulations grant DTSC the authority to identify and ultimately list "priority” chemicals (those chemicals/compounds alleged to have hazardous traits and environmental and toxicological endpoints). Once any of those chosen chemicals are identified in a particular consumer product, DTSC could produce a "priority product list” and place onerous demands on the manufacturer or distributor of the product forcing them to justify the use of the priority chemical within the consumer product. Quite likely the DTSC would require the use of a costly alternative chemical/compound in the product, or outright ban the product from being sold or distributed in the state of California.

Allowing DTSC itself to potentially ban lead ammunition in California is bad enough, but the Green Chemistry Proposed Regulations also allow third parties (i.e. environmental organizations) to petition DTSC for the listing of priority chemicals and products, and would then allow these environmental groups to qualify as "experts” and become involved in evaluating a specific priority chemical and/or product. Given the politics of the extremist environmental groups, its not hard to see where this would lead. Considering all of the blatant attempts by environmentalists and regulators to outright ban lead ammunition, the Green Chemistry Proposed Regulations, if adopted as they read now, are bad news for hunters and recreational shooters everywhere.

The proposed regulations are just the most recent battle in the fight to protect traditional ammunition from the attacks of radical environmental groups and the pseudo science they are using to justify their efforts to ban all lead ammunition use for hunting and recreational shooting across the country. Since at least 2003, the NRA and the CRPA have raised legitimate and serious questions about the purported relationship between traditional ammunition and lead poisoning and/or mortality in California condor or other animals.

The Green Chemistry Proposed Regulations are being opposed by the NRA/CRPA Foundation through the Legal Action Project (LAP), a joint venture to advance the rights of firearms owners in California. Through LAP, NRA/CRPA attorneys fight against ill-conceived firearms and firearm ammunition control laws and ordinances, and educate state and local officials about available programs that are effective in reducing accidents and violence without infringing on the rights of law-abiding gun owners.

The NRA, CRPA and like-minded wildlife and natural resource conservation groups continue to monitor and scrutinize various regulatory threats to traditional hunting and recreational shooting activities both in California and nationally. Where science leads to a wise management conclusion, LAP supports wildlife managers in their efforts to conserve our natural and wildlife resources, but where the science is faulty, politically biased, or a group’s distorted and unsupportable agenda, LAP continues to work tirelessly to expose the truth and protect the right of hunters and recreational shooters.