Legislative and Regulatory Branch
GPO Box 4306
CC: The Hon. Gordon Rich-Phillips
1 Macarthur Street
The Australasian Living History Federation (ALHF) represents the interests of over 2,000 historical reenactors across Australia. Many of these reenactors use black powder in the demonstration firing of historical firearms as part of historical displays, public events, historical anniversaries, and official commemorations.
It has been bought to the attention of ALHF that your draft RIS, currently open for comment, appears not to have considered the activities of historical reenactors in Victoria and across Australia.
Your proposal appears to have several elements that will make it difficult, if not impossible, for many historical reenactors to continue their activities.
The ALHF support other black powder shooters who have suggested moving all the Black Propellant Shooting Powders into the Propellant Class 1.3C, or, the creation of a sub-category that has the same requirements and storage quantities as this class.
The ALHF fully supports measures that further the safety of the general public and in the workplace for those who deal with black powder. However we believe that the current proposals are completely unworkable for historical reenactors and that Worksafe may not be aware of the full effects of the proposal upon the conduct of historical reenactment activities and official historical commemorations in Victoria, and across Australia.
The ALHF must strongly state that if these draft proposals were to be implemented as they currently stand, historical reenactment that involved historical firearms that use black powder would be severely impacted, if not completely disbanded in Victoria.
Most importantly, the ALHF believe it would be an embarrassing situation for local governments, community groups, state and federal governments – all of whom call upon historical re-enactors for commemorative events - to be told that they cannot have any military historical reenactment that involves black powder. Recent commemorative events for the bi-centennary of Governor Macquarie’s arrival in New South Wales in 1810 for example, involved the current Governor of NSW, Marie Bashir. In fact, the annual calendar of such historical commemorations where reenactors provide displays of black powder firing, is quite extensive. Hundreds of public events every year in Victoria alone would be affected.
The ALHF look forward to your serious consideration of these issues and the sensible suggestions that may help to continue the long-standing practices of historical reenactment in Victoria, and indeed across the nation.
5th April 2011
Dr Stephen Gapps MPHA
Australasian Living History Federation (ALHF) Inc. 9878072PO Box 61 Pyrmont NSW 2009
Tel: 0402 969 535