Browse through this website for several papers on airgun safety mechanisms.
And also click on this website's Airgun Safety Record section.
See also the note on Airgun Injuries to Youth in the What's New (click here) section of this website.

SAFETIES ON AIRGUNS?
by Robert D. Beeman, Ph.D.
Revised 5 December 2004
 (I have previously published some of this material; see the Literature Review).

A "safety" is a mechanical device which is supposed to keep a cocked, loaded gun from firing. "Safeties" have appeared on various airguns since at least well back into the 19th century. They generally are not discussed in gun books because it is just assumed that like motherhood, the flag, and apple pie, they are good things. I don't believe that this necessarily is the case. The "safety" is a mechanical device and as such, it is subject to failure. It is entirely possible that safeties have prevented some injuries, but in other cases the presence of the safety actually has caused accidents. Top gun instructors have been known to disable or remove safeties from guns used in training to prevent new gun handlers, particularly youth, from learning to become dependent on these mechanical devices. They do this to emphasize the inescapable fact that the only real gun safety is safe gun handling and that the golden rule of gun handling is: "Always see that the muzzle is pointed in a safe direction!".

I believe that the ill-advised reverence for the "safety" mechanism on guns began long ago in the military. There, safe gun handling procedures are not nearly as important as accomplishing the dirty business of war. It is much easier to drill into a recruit a simple dependency on a safety rather than teaching an awareness as to where the barrel is pointing; often an impractical consideration in the urgency and violence of combat. So what if a few lives are lost because the recruits were taught a false sense of security by their dependence on safety mechanisms? Those lives are weighed to be of much less importance than battle success. However, the civilian world weighs each human life as extremely important and civilians generally are not faced with the urgency and overriding priorities of combat. Our perspective of the safety mechanism in civilian life should move from a position of unquestioned value to one of neutral or even negative value.

Those who bemoan the lack of safeties, in the form of firing latches, on some airguns, have not taken a full perspective of the situation. For instance, barrel cocking, single shot airguns often lack a firing latch, but they actually are among the safest guns in existence. They open for loading with the barrel pointing away from the shooter and afford the shooter a quick, safe (from the rear) view of the full length of the bore. He instantly can  see  not only if the gun is loaded but if there is any obstruction in the barrel. The gun cannot discharge its pellet until the action is fully closed. It is the design and intent of these guns to be aimed and fired as soon as they are loaded. A number of other airguns have loading taps, etc. which must be deliberately moved into a firing position just before actual firing is intended. Putting a safety latch on any of these guns, especially the barrel-cocking gun with the enormous safety measure of its full view bore, seems like putting a lock on the gate of a castle which has a moat around it.

Automatic Safeties on Airguns?

Automatic safeties, those that automatically go into a locked position when the gun is cocked, seem to me to be the least appropriate of all, especially on guns intended for youth or for training new shooters. The user of an airgun with an automatic safety may soon come to feel that his gun automatically is  safe until he deliberately releases the safety and pulls the trigger. There is a very great danger that the shooter will transfer this habit to firearms, which almost always do not have an automatic safety. In fact, many firearms, such as most revolvers, do not have any safety latch at all. The term "safety" is perhaps one of the most poorly chosen words in all gun terminology. At times, I have attempted to substitute the term "firing latch" but that usage is definitely against the current and less likely to be understood. Again, safeties may prevent accidents and safeties may cause accidents. On balance, I would prefer to be without them. I have allowed them to be installed on Beeman's airguns for two reasons: one, misplaced, but very strong, public liability pressure, and two, avoiding barrel snap-up ("bear trap action"). On barrel-cocking guns, it is possible for the barrel to snap up from its downward cocking position with enough violence to bend the barrel, crack the stock, and perhaps injure the user or nearby persons. I think that this latter reason is the only good reason for having a "safety" on airguns and that automatic safeties, if ever included in the design features, should be present only on guns intended for adults, preferably only for adults already familiar with the safe handling of guns.

There already are hundreds of millions of airguns in America - the most effective and realistic approach is not to try to force changes of doubtful value onto the small sliver of guns being added to the total each year but rather to spread increased awareness of safe gun handling, proper storage, and supervision of youth when they are using airguns. This apparently mild approach is much stronger because it applies to a thousand-fold more airguns!

 

What is the value of airgun safeties?
By Robert D. Beeman Ph.D., 1991.  Reprinted with permission from American Airgunner, July/Aug./Sept. 1991: pp. 38-39.

Like mother, apple pie and the flag, many American shooters take the value of "safety" latches on guns for granted. British shooters might substitute Yorkshire pudding on that list, but the point is the same - many shooters make passive assumptions about safeties that may not be true, especially in the case of airguns. Other shooters just don't think much about the matter. However, those of us involved in the design of airguns, and those involved with the training of shooters with airguns, have thought about this a great deal. In any case, the subject is more complex than it first appears. Few parts of a gun are as inaptly named as the "safety ". No mechanical device can make any gun safe. Safeties, like any mechanical device, are subject to failure; they may fail at the most inappropriate moment. Furthermore, safeties can even contribute to the unsafe handling of guns by promoting a dependency on the device, rather than on safe handling practices. No experienced shooting instructor would ever suggest that pointing a loaded gun at someone with the safety on and pulling the trigger a good idea. However, this is exactly what some people, particularly those accustomed to automatic safeties, will do. Many airguns, especially spring-piston airguns, have no safety latch at all. Basically, this is because these guns are intended to be fired immediately after cocking. Having a safety on spring-piston airguns could encourage the user to leave the gun cocked, adding to cumulative fatigue of the mainspring, which is com- pressed in the ready-to-fire mode. Several long periods of total compression may cause a deterioration of function. Thus, the presence of the safety on such guns could defeat the very function for which such guns were designed, i.e. firing a projectile. Many airguns, as do some firearms (including double-action handguns), have an extremely long, or two- stage, trigger pull which serves as a safety system and which does not encourage leaving the gun cocked. It does help ensure that the gun is fired only when firing is intended.

Largely as a bow to some who do not understand the above concept and to the American market, with its sometimes misguided concepts of safety, safety .latches began to appear on spring-piston airguns, even single-shot airguns. Many airgun experts still consider this to be an undesirable addition. The safety latches on some spring piston adult airguns have been designed to be automatic. The safety is automatically "on" when the gun is cocked. This automatic feature basically is meant to reduce the possibility of injury to the airgun, the shooter, or to bystanders in close proximity during an accidental snapping shut of the barrel or cocking lever during the cocking cycle. Such a snapping can crack the airgun's stock, bend the barrel, and break or bend the cocking lever of the gun. And, it is possible for a person to be painfully hit by a part of the gun or to be pinched when the action snaps shut. Also, there are certain other mechanisms that are sometimes used to prevent this so-called "beartrap" action. These other mechanisms usually are more complex and expensive than just making the safety automatic. Safety from accidental discharge was not the. primary purpose of any of these safety mechanisms. A wide variety of automatic safety mechanisms have been devised during the centuries-long development of guns. However, although some firearm and airgun manufacturers have tried introducing automatic safeties, the lack of such automatic devices on almost all modern firearms and most airguns attest to their undesirability and unpopularity. Sheridan had an automatic safety on their original "C" series pump pneumatic rifle as manufactured between 1949 and 1963. This safety was a so-called "hold-down" safety that required the shooter to press his thumb on a small metal strip while pulling the trigger, or the gun would not fire.

Sheridan noticed an inordinate amount of modifications to this automatic safety on guns sent in for repair to other parts. These modifications included sheet metal screws, and other devices that forced the safety down, not only doing away with the automatic feature, but with any safety function. These modifications, circumventing the safety, together with consumer complaints, forced Sheridan to abandon the hold-down safety in favor of a manual safety.

Occasionally, manufacturers found special reasons for putting an automatic safety or an airgun As with the spring- piston guns for adults, special reasons overruled the advantages of leaving off this generally undesirable feature. Thus, Daisy put an automatic safety on their Model 21/104 double-barrel rifle to prevent finger injuries in this break-open gun. They also put a sort of automatic safety, a half -cock safety, on their Model 1894. This reduced the hazard of accidental discharge by impact to the exposed hammer, and also made the rifle a more realistic replica of the Winchester Model 94 firearm.

The very nature of an automatic safety can also defeat its own purpose. That is, most users of guns with automatic safeties soon develop the habit of taking off the safety automatically, without even thinking or realizing that they have done so. The user becomes as "automatic" as the safety.

The acquisition of lower-cost gas and pump pneumatic guns is, more often than not, the prelude to the use of firearms. New shooters, particularly youth, have traditionally been taught shooting skills and shooting safety via airguns before being introduced to firearms with their far greater potential for being lethal. The habits formed during this preliminary training, and during the use of airguns, generally serve as the basis for a lifetime of habits in handling other guns. Thus, most manufacturers of such gas and pump pneumatic airguns have carefully avoided the introduction of automatic safety mechanisms on almost all of their guns. Shooters who have come to rely on their airgun being automatically "safe" could transfer those habits, with tragic results, when they start using firearms.

Firearms, as already noted, rarely have automatic safety latches. Revolvers typically have no safety latch of any kind. Among the very few firearms with automatic safeties are double-barrel shotguns. Puzzled by this anomaly, I asked Bob Brister, shooting editor for Field and Stream magazine and one of the deans of American shotgunning for the reason. He stated that the addition of safeties to double-barrel shotguns was a historical accident brought about because it "seemed" like a good idea, coupled with the fact that designing automatic safety mechanisms into such guns is quite easy. Brister feels that the safety feature is most undesirable, an "abomination" that is removed or defeated by many shooters. And, an automatic safety could cost a firearm shooter his life in situations where he is under stress with dangerous animals or persons.

The National Rifle Association, the world's largest shooting organization, has expressed low confidence in airgun safety latches. In their training manual titled "The Basics of Airgun Shooting," written to train thousands of gun safety training instructors, it was stated that "automatic safeties are more prone to failure than manual safeties, but their biggest draw- back is that they teach a person that a gun automatically becomes safe. This can be a bad experience when a person switches to a gun with a manual safety or no safety ."

Some training instructors feel so strongly about not letting shooters develop a dependency on any sort of safety latch mechanism that they insist that any guns used during the training period either have no safety latches or have disabled safety latch mechanisms. Gun associations and shooting instructors everywhere agree that the only true gun safety is in the mind of the gun handler.

There are various rules of safe gun handling, but one common sense rule stands out as The Go1den Rule: “Always see that the muzzle of a gun is pointed in a safe direction!"

Note that this admonition applies not only to the person handling the gun, but to all those around that person. The matter of safety always overrides the matter of courtesy -one should never hesitate to object when another person is handling any gun in an unsafe manner.

Those involved with airguns should resist proposals for regulations requiring airgun safeties to be automatic. This is another extension of the false idea that safety can be legislated. While automatic safeties can be appropriate with some air- guns, applying the automatic feature to all airgun safeties could actually increase hazards.

There already are hundreds of millions of airguns in America - the most effective and realistic approach is not to try to force changes of doubtful value onto the small sliver of guns being added to the total each year but rather to spread increased awareness of safe gun handling, proper storage, and supervision of youth when they are using airguns. This apparently mild approach is much stronger because it applies to a thousand-fold more airguns!

 

Loaded chamber indicators for airguns - and other such notions
by Robert D. Beeman Ph.D.
Reproduced by permission from American Airgunner, Oct./Nov./Dec. 1991, page 8.

In an article appearing in the previous issue of American Airgunner ("What is the value of airgun safeties?" Vol. 6, No.3), I discussed the concept of automatic safeties for airguns. While such devices may be appropriate for some airguns, they are not advisable on most airguns, especially those oriented toward use by new or younger shooters. There are other so-called safety ideas that, at first blush, may sound good. But when these ideas are examined, it is clear they should not be adopted. While many of these ideas stem from anti-gunners, some are mistakenly supported by firearms-oriented persons. The problem is that there are some basic differences between firearms and airguns. While some of the differences are only those of degree, such as discharge sound and power, other differences are absolute. The absolute differences often make it difficult for many persons, especially many firearm experts, to see airgun matters from a non-firearm perspective. One of the key absolute differences is that airguns almost always have their propulsive power within the mechanism of the gun rather than being packaged with the projectile. Another key absolute difference is that airgun projectiles generally do not have handling rims, grooves or cases, such as those found on firearm cartridges. Thus, airgun projectiles cannot be restrained so easily within the gun, especially in the chamber area. A loaded chamber indicator might easily tell a shooter if a given firearm held a cartridge in the firing chamber . However, even if a suitable device could be developed to visibly demonstrate that the firing chamber of an airgun did, or did not, contain a projectile, it could not tell the user if a projectile was present further up the barrel. Because of that separate propulsive force, an airgun projectile (perhaps a deformed, reused, or improper one) that is stuck in the barrel could be even more dangerous than a projectile in a chamber. That is, a loaded chamber indicator in an airgun could lead a shooter to think that there was no projectile in a position from which it could be fired. This is downright dangerous.

It has even been suggested that an answer to this special problem is to make airgun barrels transparent so that a projectile anywhere in the barrel would be visible. Perhaps a clear plastic could be developed that could be rifled and that would be strong enough to use as barrel material. Such a transparent barrel might be a great arrangement for a few shots. But abrasion of the bore and fouling from the projectiles, as well as clouding by lubricants and dirt, would soon make it hard to clearly see the projectiles within -leading to a dangerously false sense of security for someone who did not see a projectile present in the gun.

"Visible" airgun magazines have also been introduced for repeating airguns. However, it is almost impossible to make a projectile magazine with a viewing slot that truly allows quick and easy projectile viewing right up to the point before the firing chamber. Transparent magazines have been suggested. (Daisy even produced one years ago), but such magazines would suffer the same development of impaired visibility as the transparent barrels discussed above.

In addition, various magazine slots, visible loading ports and the like have been developed on a wide variety of repeating airguns. Such features may offer real convenience, as compared to airguns that allow little, or no, visibility of projectiles being fed into the barrel. However, these features should indeed be considered only as convenience, not safety, features.

While such devices may give the user a greater sense as to whether or not a projectile is present in a projectile storage area of the gun, or is being fed into the firing chamber, they have a down side. They may divert a shooter from considering that a projectile may be within the barrel, ready to be propelled out in a potentially dangerous manner. Also consider that the only place from which a projectile may be fired is from the bore (including the chamber). Thus, it is almost irrelevant, from a strictly safety standpoint, if there is a projectile, or projectiles, in other parts of an airgun. It has also been suggested that the U.S. Standards for Non-Powder Guns require that a visible pressure indicator be placed on airguns. If developed, such devices would work only on CO2 and pneumatic guns and not on the spring-piston mechanisms so popular in both high- and low-market airguns. It is possible that shooters could become dependent on such indicators on CO2 and pneumatic guns and then come to handle spring-piston airguns, which would not have this "security blanket," in an unsafe manner. Even in CO2 and pneumatic guns such devices would be likely to teach new and young shooters to depend on mechanical devices, always subject to failure, for gun safety. It does not take much imagination to consider the tragic possibilities that could result from a less -than-thoroughly-diligent young shooter seeing a pressure indicator stuck in the down position of a fully-charged, loaded airgun, with which he is playing. Better not to have any indicator rather than to have the possibility of a faulty one telling the shooter that the gun "cannot" go off. Clever designs and mechanisms can add much to the convenience, fun, and performance of airguns. But let's keep simple and consistent in the area of safety. We must not let firearm-oriented thinking mislead us, nor think that gadgets or legislation will make airguns safe. The only true safety is in the mind of the shooter.

There already are hundreds of millions of airguns in America - the most effective and realistic approach is not to try to force changes of doubtful value onto the small sliver of guns being added to the total each year but rather to spread increased awareness of safe gun handling, proper storage, and supervision of youth when they are using airguns. This apparently mild approach is much stronger because it applies to a thousand-fold more airguns!

 

AIRGUN COCKING INDICATORS
by Robert D. Beeman Ph.D.
Revised 5 December 2004
(Submitted in 2001 for publication in The Airgun Letter)

In previous articles, I have discussed the shortcoming of many notions on how to make airguns safer, and why automatic safeties ought to be restricted to only certain adult airguns. Cocking indicators are another notion that has been proposed to make airguns "safer". Again, the idea may sound good at first, but careful consideration dictates that the idea is not sound, at least for youth oriented airguns.

Of course, a cocking indicator adds complexity, and thus possible improper performance. A cocking indicator could become stuck in the "uncocked" position. It is impossible to say that a cocking indicator will always indicate that the gun cannot discharge. Would you feel comfortable and safe if a gun, with the cocking indicator in the uncocked position, was pointed at you?

Many firearms, lethal weapons, including all those known as double action, which probably includes most handguns today, can be fired from the uncocked condition. Many guns with exposed hammers, especially including many older single action revolvers, can be fired by an impact to the hammer, such as may occur if the gun were dropped. A cocking indicator suggests, very strongly, that a gun cannot fire when that indicator is in the uncocked position. Is it good to develop a habit, an attitude, in young shooters who are establishing their lifetime perspectives and behavior concerning guns, that an uncocked gun cannot be fired?

A cocking indicator would mean nothing to the inexperienced, careless, or malicious shooter, the kind who is often involved in causing shooting injuries. At best, it might be a convenience to the careful, knowledgeable shooter, but is it right to let even a generally careful shooter, especially a young one, think that a gun cannot discharge if it is uncocked, or a device indicates that it is uncocked? It is my opinion that airguns, especially those intended for young shooters, should not have a so-called cocking indicator. A manual safety mechanism may be appropriate, because most firearms have a manual safety. Gun safety mechanisms should be simple, intuitively understandable, and as universal as possible. In any case, the best safety is safe gun handling behavior.

There already are hundreds of millions of airguns in America - the most effective and realistic approach is not to try to force changes of doubtful value onto the small sliver of guns being added to the total each year but rather to spread increased awareness of safe gun handling, proper storage, and supervision of youth when they are using airguns. This apparently mild approach is much stronger because it applies to a thousand-fold more airguns!

 

 

Airgun Safety Statement Prepared for Presentation to the U.S. Consumer Product Safety Commission in August 2001:
by Robert D. Beeman Ph.D. as an Airgun Expert Witness

AFFIDAVIT

1. My name is Robert Beeman.

2. I previously owned Beeman Airguns, an importer and manufacturer of airguns.

3. I have been a consultant on numerous occasions in matters involving airgun litigation as well as airgun information issues.

4. I was the author of Airgun Digest, First Edition. I have also published numerous articles discussing airguns, automatic safeties, feeding mechanisms, loaded chamber indicators, visible magazines and other design concepts. I have written hundreds of technical bulletins regarding airguns.

5. I have tested, examined and reviewed hundreds, if not thousands, of different airguns and BB guns. I am quite familiar with the multi-pump pneumatic air rifle of the Model 856 and Model 880 variety as sold by Daisy Manufacturing Company for the last twenty to thirty years. In fact, I have owned a number of these rifles and have used them for various purposes.

6. The Daisy Model 856 and Model 880 (including various versions of those models) are not unreasonably dangerous and are quite safe for their intended uses. These rifles are reasonably designed air rifles employing the long popular multi-pump pneumatic power plant. These models are intended for marksmanship training, as well as general ( especially outdoor) recreational shooting by persons 16 years of age and older, adult supervision required. The Model 880 and the Model 856 feature the dual and practical capability of allowing their use as a BB repeater as well as a .177 caliber lead pellet single shot rifle.

7. The Model 856 and the Model 880 require the natural motions of handling, cocking and pumping this gun to put it in a vertical position with the feed track directly in front of the shooter's face. Even with a scope mounted, the loading track is easily visible on the right side. The shooter can very readily observe the motion of the projectile in its most important motion, moving into the firing position in the chamber of the barrel.

8. The cross-bolt manual trigger safety of the Mode1856 and Mode1880 is positive and uncomplicated in its design as well as operation. There are a number of manual and automatic safety mechanisms which have been known to firearm and airgun manufacturers for a number of years. These types of safeties are well known throughout the industry. The experience of the industry has led to how and when these well known mechanisms are applied or omitted. Several airgun makers have applied automatic safeties to their guns. Generally, the presence of automatic safeties has been poorly received by the users of these guns. In fact, automatic safeties have been so unpopular with shooters that guns which were supplied with automatic safeties by the factory are received to repair facilities, usually for other reasons, with their safeties intentionally disabled. Such a modification leads to an unsafe condition in that the shooter, familiar with such a model, might pick up such a specimen and expect it to automatically be safe when indeed it is ready to fire. The most modern airguns, intended for the youth or young adult market, are currently made by the U .S. makers of such guns: Daisy, Sheridan, Benjamin and Crosman, employ manually operated safeties, generally of the cross-bolt trigger blocking type. Centuries of experience of the international airgun market have indicated that the very simplicity of this design makes it particularly dependable, almost intuitively understood and effective.

The safeties on the Model 856 and the Model 880 function as almost all other such safeties operate. When the safety is disengaged, a red band is clearly visible around the safety button as an alert to the user regarding the rifle's condition of readiness. It is also possible to ascertain easily that the safety is not engaged by the tactile feel of the safety button protruding from the left side of the trigger guard. In addition, the legends PUSH FIRE and PUSH SAFE can be seen in relief on the right and left sides of the trigger guard respectively, further to help the shooter ascertain the position of the trigger safety.

9. The action of the Model 856 and Model 880 can be readily kept open by retracting the bolt. This allows instant visual access to the breech area and the bolt tip in this gun, as well as in several other models which employ similar design. In a bolt-action firearm, the top cartridge in the magazine would be seen when the bolt is retracted. Obviously, the Model 856 and Model 880 do not use firearm cartridges, but small, round projectiles requiring a very different feed system. There is total visual access to any BB picked up by the bolt in the BB reservoir. Since the Model 856 and Model 880 are ideal as firearms trainers for new shooters of various ages, this design feature is of great value because it duplicates closely the general handling and cartridge loading characteristics of a cartridge bolt-action rifle.

Over the years, I have examined and used air rifles and BB guns with and without automatic safeties. First it should be noted that there are no semi -automatic bolt -action or pump firearms made, of which I am aware, that incorporate an automatic safety. Automatic safeties are relegated to a very small number of side by side shotguns, usually of foreign manufacturer and a few models of over and under shotguns. Because the Mode1 880 and the Mode1 856 are designed to be used as training models for later firearm use, it is important that they function similarly. The addition of an automatic safety on these air rifles would defeat this purpose. American firearms generally do not have automatic safeties for many, many good reasons.

(As indicated above, many users remove automatic safeties on firearms that come equipped with them. It is well known that automatic safeties create frustration in making follow-up shots. In fact, on many trap and skeet shotguns, there are no safeties whatsoever. American shooting enthusiasts have not wanted an automatic safety. On the other hand, a manual safety is something that allows the user to always be in control of the position of the safety on the firearm.) An automatic safety on this type of air rifle would necessarily create a situation where the novice shooter would learn to rely on a device which he would be unlikely ever to encounter with firearms.

10. It is my opinion that while both gravity feed and spring driven mechanisms can be excellent ways of feeding a BB gun from a contained magazine, gravity feed is generally a somewhat better mechanism. Gravity feed is such a simple mechanism, depending on an infallible and intuitively understood force; it does not lend itself to mechanical failure, spring fatigue, or part breakage. Also, gravity feed systems, because of their simplicity, greater dependability and far greater capacity, generally are preferred by shooters. Gravity feed magazines have been favorably evaluated by safety experts and are such a basically good, simple design that they have been a standard feature of scores of models of repeating BB guns as made by virtually every maker of repeating BB guns for over a hundred years.

11. There have been ridiculous inferences that the lack of gravity feed magazines in firearms renders the feeding of firearms more dependable. Firearms are different from airguns in that the power for a modern firearm must be packed with a projectile as a cartridge. A cartridge does not lend itself to a gravity feed system.

The vertical feeding arrangement of the Daisy 856 and Daisy 880 is particularly desirable, not only because of the natural positioning of the all important loading track directly in, or close to, the vision line of the shooter, but because of its natural position for pumping.

The design of the Model 856 and Model 880 makes it easy to see the BB as it is loaded into the chamber. A forced-feed system can obscure the BB entering the chamber. One of the great advantages of the gravity feed system, at least as it is incorporated in the Model 856 and Mode1 880, is the capability of allowing the user to see the BB entering the chamber. In fact, the user is able to pull back the bolt and see the BB. This advantage can be lost with the incorporation of a forced-feed system.

The Model 856 and Model 880 (as well as various versions of these models) incorporate a bolt safety interlock which is activated whenever the bolt is retracted in order to cock and load the rifle. The combination of the manual safety and the bolt safety interlock make the Model 880 and Model 856 remarkably safe air rifles to handle and shoot. However, the users, like users of all airguns, must follow the pertinent rules of safe gun handling.

12. To my knowledge, both the Model 856 and Mode1880 comply with voluntary airgun industry standards promulgated by the ASTM. In fact, I actively participated in the development and drafting of the industry standards. We specifically considered automatic safeties and gravity feed systems and rejected their inclusion after full study of the issue. The only persons to raise these design concepts were persons who testified against airgun companies on a regular basis.

13. Over the years, I have seen the packaging and instruction manuals which accompany the Daisy Model 880 and Model 856. I believe the warnings are written in a clear and concise manner. Further, they are understandable and alert the user to the inherent capacity of airguns to inflict serious bodily injury and even death.

14. The pointing of any firearm or air rifle at another individual and intentionally discharging it, whether one thinks it is empty or loaded, is reckless in the extreme. To sanction such actions as "expected human behavior" makes a mockery of the safety rules that we as firearms instructors, parents and adults try to pass on to our students, youth and readers. No matter what safety system is utilized, what feed system is implemented, or how the particular firearm or airgun is designed, no guarantee can ever be made that an injury will not occur if an individual points an air rifle or firearm at another individual and pulls the trigger .

Further the Affiant sayeth not.

Robert Beeman, Ph.D. VERIFICATION STATE OF )

) ss. COUNTY OF )

I, Robert Beeman, Ph.D., do hereby certify that the facts and matters contained in the foregoing Affidavit are true and correct to the best of my knowledge, information and belief.

Robert Beeman, Ph.D.

SUBSCRIBED AND SWORN TO before me on this day of, 2001.

Notary Public My Commission Expires: