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IFL R3 Recommendation 2008

IFL R3 Recommendation 2008

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IFL's nomination of the ATF's regulation of fireworks manufacturers like high explosives makers to be reviewed by the Small Business Administration's Office of Advocacy under their R3 (Regulatory Review and Reform) Initiative.
IFL's nomination of the ATF's regulation of fireworks manufacturers like high explosives makers to be reviewed by the Small Business Administration's Office of Advocacy under their R3 (Regulatory Review and Reform) Initiative.

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Published by: The Institute for Liberty on Jan 13, 2009
Copyright:Attribution Non-commercial

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06/14/2009

 
1250 Connecticut Ave, NW, Suite 200Washington, DC 20036
December 31, 2008Ms. Shawne McGibbon, Acting Chief CounselOffice of AdvocacyUS Small Business Administration409 3
rd
St, SWWashington, DC 20416VIA ELECTRONIC MAIL
Re: Recommendation for the Office of Advocacy’s R3 Initiative
Dear Ms. McGibbon:This letter will serve as the recommendation of the Institute for Liberty for a regulation to bereviewed under the Small Business Administration’s Office of Advocacy’s R3 initiative. TheInstitute for Liberty is a 501c(4) advocacy organization based in Washington, DC. We focus onthe impact of the federal regulatory state on small business and entrepreneurship.Several years ago, I had the privilege of meeting with a group of fireworks manufacturers fromaround the United States. The firms that took part in that meeting all fell under multiple SBAdefinitions for “small business”—and they all shared a common problem. Each firm was beingfaced with a serious threat of being regulated out of existence by the Bureau of Alcohol, Tobaccoand Firearms (ATF).Following September 11
th
, the Congress passed the Safe Explosives Act (SEA), designed in partto deal with security issues arising from the manufacture and distribution of high explosives inthe United States. One of the unintended consequences of SEA is that a number of smallmanufacturers of fireworks were caught in the ATF’s regulatory net. As you are well-aware,small businesses are not as able to handle regulatory burdens as their larger counterparts are.Advocacy’s own data shows that regulatory costs are 50% higher for firms with fewer than 20employees, as many of these fireworks manufacturers are.These businesses are not asking for an absence of regulation. What they are hoping is that theR3 initiative can review the situation and recommend that these firms be given their ownregulatory framework, preferably one that lies outside of the ATF, and that takes into account the

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