8/14/2019 IFL R3 Recommendation 2008
1/2
1250 Connecticut Ave, NW, Suite 200
Washington, DC 20036
December 31, 2008
Ms. Shawne McGibbon, Acting Chief Counsel
Office of Advocacy
US Small Business Administration
409 3rd
St, SWWashington, DC 20416
VIA ELECTRONIC MAIL
Re: Recommendation for the Office of Advocacys R3 Initiative
Dear Ms. McGibbon:
This letter will serve as the recommendation of the Institute
for Liberty for a regulation to be
reviewed under the Small Business Administrations Office of
Advocacys R3 initiative. TheInstitute for Liberty is a 501c(4)
advocacy organization based in Washington, DC. We focus on
the 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 from
around the United States. The firms that took part in that
meeting all fell under multiple SBA
definitions for small businessand 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, Tobacco
and Firearms (ATF).
Following September 11th, the Congress passed the Safe
Explosives Act (SEA), designed in part
to deal with security issues arising from the manufacture and
distribution of high explosives in
the United States. One of the unintended consequences of SEA is
that a number of small
manufacturers of fireworks were caught in the ATFs regulatory
net. As you are well-aware,small businesses are not as able to
handle regulatory burdens as their larger counterparts are.
Advocacys own data shows that regulatory costs are 50% higher
for firms with fewer than 20
employees, as many of these fireworks manufacturers are.
These businesses are not asking for an absence of regulation.
What they are hoping is that the
R3 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
