NPRM Responses?

Not to beat a dead horse, but I was wondering if anyone received an official BATFE response to their NPRM comments.

I both snail and e-mailed my comments. So far; nada, zip, zero.

I was under the impression that concerned "entities" would receive a response to the points in their comment letters.

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That's correct, however it usually takes several months just to process all the comments, and more months to concoct and publish the responses.

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A couple of points to make regarding NPRM mechanics.

An agency asking for public comment is under no legal obligation to individually acknowledge or respond directly to individuals or entities who made them.

The agency is also under no obligation to issue a final, or interim rule based on the input it received.

The agency is under no time restrictions relative to when it must reply.

However, the agency cannot change the regulatory environment under which it operates without responding to comments issued under the NPRM prior to issuing a final rule.

= = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = = Mark B. Bundick mbundick - at - earthlink - dot - net NAR President www - dot - nar - dot - org

"The great enemy of truth is very often not the lie - deliberate, contrived and dishonest - by the myth - persistent, persuasive and unrealistic . . . We enjoy the comfort of opinion without the discomfort of thought." - JFK

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Mark B. Bundick

If you review some past NPRMs (specifically any dealing with fireworks), you'll see comments from the manufactures and organizations about outrageous costs and unpractical implementation, then an ATF 'reply' which boils down to "tough, we think it's safer".

There is no doubt in my mind that the 1/2" shackle rule on paddlelocks will be enforced, along with the rest of the crap.

Joel. phx

Reply to
Joel Corwith

7/16" seems to be a standard "extra heavy duty" size... I wonder if that's why the BATF picked 1/2" :) It almost seems like they want to be sure that nobody _can_ (officially) lock up their supplies of Explosives "properly": that way they have a nice little "technicality" to write up anyone, anytime...

-dave w

Reply to
David Weinshenker

I've checked every store I've been in since the NPRM response for 1/2" padlocks. I've yet to find one at any price.

Bob Kaplow NAR # 18L TRA # "Impeach the TRA BoD" >>> To reply, remove the TRABoD!

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Bob Kaplow



caps off

Reply to
Jerry Irvine

McMaster Carr P/N 1537A12 has a 1/2" shackel but also a $137.45 price tag. Not sure if it meets the other criteria for BATF use?

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(cut and paste the part number into the box under the Find Products Tab)


Reply to
Norm Dziedzic

Great! That's more expensive than the entire contents of my magazine! Someone needs to tell all those JBGTs that they can go themselves.

Bob Kaplow NAR # 18L TRA # "Impeach the TRA BoD" >>> To reply, remove the TRABoD!

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Bob Kaplow

They also have model 1831A24 which comes in at $39.47. I don't know if this one doesn't answer the criteria in some way, but it looks reasonable.

Scott McCrate NAR 71680

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Scott McCrate

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