Lithgow Small Arms Factory Museum (LSAFM)

LSAFM’s Submission to NSW Parliamentary Inquiry

Regions have gone through a horror drought and bushfire season and having world-class museums would undoubtedly bring increased tourism. LSAFM could be one of those regional world-class museums, harnessing, supporting and growing a rich history that is specific only to LSAFM.

The Parliamentary Inquiry into the Government’s management of the Powerhouse Museum and other museums and cultural projects in New South Wales invites submissions from interested organisations and individuals.

We firmly believe that regional museums, such as ours, are not truly recognised by Government. Like so many others in regions, we are volunteer run.

We do what it takes to make our Museum the best it can be. But it seems Government bureaucracy favours their own – those Museums with taxpayer funding and with a Sydney centric attitude.  

We sincerely believe those in Government have little idea of what we, and perhaps other regional museums, have and hold. In fact, we’ve not seen anyone from the ‘arts industry’ come through our doors in many years. We are bitterly disappointed that this is now the norm within our diverse industry.

Below is our submission to the Inquiry:


Submission to the Inquiry into the Government’s management of the Powerhouse Museum and other museums and cultural projects in New South Wales

1.0    Who we are and our significance           

Firstly, you and some of your Committee members would be familiar with the Lithgow Small Arms Factory Museum (LSAFM). We are noted nationally and internationally for our historical, educational and cultural significance of the iconic Lithgow Small Arms Factory (Factory) and its nine (9) subsidiary operations in the Central West of NSW.

We are much more than just a firearms museum.

We hold one of the most significant, diverse and detailed records of the industrial, engineering and societal developments which shaped the Australian nation in the 20th century, through the eyes of Lithgow. We have one of the best collections of industrial precision production machines anywhere in Australia.

In February 2019, the Museum was awarded the UNESCO Australia Memory of the World award for its archive significance – a rather prestigious award putting the global spotlight on a piece of Australian history that should never be forgotten. We have access to almost 200 000 archives and almost 2600 objects which date back to 1910. Our visitors are astounded by our exhibits and those from overseas view our collection as better than most similar museums in their own country.

It is an honour to be directly associated with LSAFM and our plans for the future are exciting as we move towards establishing a special museum zone housing precision engineering, firearm objects, exhibits of the Factory’s commanding history, training facilities and hospitality

2.0 Proposed Powerhouse Museum shift

LSAFM’s comments in relation to the proposed shift from Ultimo to Parramatta of the Powerhouse Museum are made as a peer museum, relating to its heritage, relocation and collection significance are commented on below. 

LSAFM has had regular dialogue with the Powerhouse Museum over the years. We know the cultural value of their diverse collection and there is no doubt the Powerhouse Museum carries some of the most significantly important objects anywhere in the world, notably in science, technology and transport. It does also contain a range of objects which are not strictly classed as ‘science, technology and transport’.

Having an allegiance to the Ultimo area of some 140 years, LSAFM is perplexed as to why the Powerhouse Museum needs to relocate and how the fabric of the Ultimo facility is going to be accommodated on a much smaller footprint at Parramatta. It just doesn’t make sense to expend so much money, only to have a smaller sized museum.

As it is now and more so in the future, the Castle Hill facility will be the repository depot – out of sight and out of mind. It would be an absolute shame for precious objects and artefacts to remain hidden, as though lack of exhibit space carries more importance than cultural, historical or educational significance.

Issues

  1. The saga surrounding the Powerhouse Museum demonstrates that Government has little appreciation for the valuable assets such museums have. It seems the look and beauty of a building carries far more weight than the inherent value within the building. Architects can design all they want with open-ended ‘cheque books’, but little is said about the incalculable value which the Powerhouse Museum houses. For this reason, the Powerhouse Museum appears to be treated like an asset – to be traded to the highest bidder – with little to no consideration of the Australian intellect inherent in each of the objects and artefacts which shaped Australian life over the years;
  2. The proposed move of the Powerhouse Museum to a smaller site and the consequent rationalisation of its objects and artefacts suggests a scaling down of the collection for display. There will be no net benefit to the people of Western Sydney or anyone else if that occurs;
  3. Relocating the Powerhouse Museum to a flood prone site is inconceivable and is vulnerable to regular (1:20 year) flooding events. There is a limit as to how many objects, artefacts and archives can be placed above flood levels. Heavy objects like the locomotives would be impacted. The location is not fit for purpose;
  4. Looking ahead, Sydney will be a city of 8 million people within 30 years. Surely, a city of that size can sustain several Powerhouse Museums or similar and truly become an international centre with a reputation for culture and the arts. Sadly, there is no long-term plan for the city of Sydney and if there was, this whole issue of the Powerhouse Museum may have become much clearer for everyone to see. It is plain to see that the Powerhouse Museum is clustered among other noted museums, thus creating a cultural hub for the public, researchers and the professionals working in those institutions; and,
  5. With the prospect of the Powerhouse Museum objects/artefacts and archives becoming increasingly hidden through storage, why not give ‘life’ to such historical items by having their presence in other museums across the State. There are outreach and loan agreements in place, although these agreements can be onerous with specific and restrictive conditions, such as temperature controls, humidity levels and security. Such conditions can impact smaller museums significantly and to the point where the ‘fine print’ discourages any mutual arrangement. We have previously engaged with the Powerhouse Museum on their hidden firearms collection with limited success. It is time to re-visit this and maximise the opportunity for the general public to experience Australian history and culture irrespective of ownership.

Conclusion

Governments need to embrace museums for what they truly are and not see them as merely some form of tradeable asset. Learnings and traditions of our past is what we all cherish. The substantial investment made by many people over many years in maintaining and improving museums to world class standards cannot be understated. This is precisely the case with the Powerhouse Museum located within an inner-city site with a 140-year rich history.  Moving the Museum to Parramatta would see an era disappear altogether.    

Proposed recommendations

LSAFM recommends:

  1. Leave the Powerhouse Museum where it is and actively promote its science and technology significance and heritage;
  2. Plan and build new museums in other parts of the Greater Sydney region or regional areas in line with the significance and/or educational value of what is to be exhibited (in line with the stated vision);
  3. For Government to develop a long-term vision and plan for the Museums sector in Sydney and regional NSW; and,
  4. For objects/artefacts of the Powerhouse Museum which are in storage or to be placed in storage be displayed in other museums across the State, where practicable.

3.0 Current Government policy, funding and support for museums and galleries across regional New South Wales

Policy

In relation to NSW Government policy as it applies to LSAFM, there is no clarity around this. Whatever policy or statements made by the NSW Government, they are conflicting, counter-productive and have no semblance of active support and promotion. It seems there is little to no consideration of volunteer-based museums, of which there are many in regional NSW.

LSAFM does not operate under any considered, well-thought through Government Museum Policy.

For LSAFM, our ‘policy framework’ is regulatory. We are seen by the NSW Government as a carrier of firearms needing to be suppressed at all times for ‘public safety’. They do not see us as a museum with a rich history and educational value. Nor do they understand what we have, what we do and the experience we provide to so many.

Under the regulatory ‘policy framework’, we are seen as being no different than a firearms collector or a firearms dealer. In fact, we are relatively worse off under the current Firearms Regulation. It is incongruous to us that we find ourselves in this position. We have provided more details on this issue in our response in section 5 below.

As for advancing Culture and Arts in the State, LSAFM is not aware of any policy which actively drives and encourages regional museums, including ours.

Even if there were a NSW policy specific to museums (notably regional museums), then we believe the ‘regulatory policy’ would take precedence under the current environment in our line of business. It seems to us that Museum firearm objects/artefacts are not viewed as historical, educational or cultural significance. Rather they are viewed as something much less and of no benefit to society. In our case, we believe Government agencies in the field of arts and culture, have lost the knowledge in appreciating industrial heritage, they have lost the drive to make regional museums a stronger force and, lost the desire to confront regulatory agencies on matters impacting regional museums.

Funding

In terms of funding, we regularly apply for Government and private sector funding. We operate like any other volunteer-based museum seeking funds, as required. We have applied for funding under various programs, including Heritage grants, NSW Club grants, National Library of Australia grants, Create NSW grants and Community Fund grants. Those grants have largely gone towards projects involving building improvements, collection and archives management and volunteer training.

We make three comments in relation to funding:

  1. Funding of regional museums seems a ‘hit and miss’ affair. Unlike their State-owned counterparts which are underpinned by a continuous flow of tax-payer funding, many regional volunteer-based museums do not have access to on-going funds. They also lack the wherewithal to complete the mass of paperwork required for funding. We appreciate that funding must be evidence and merit based. But ‘missing out’ on funding can be detrimental to regional museums.
  2. Regionally based volunteer run museums operate with little, if any, support. Their displays reflect their region and its history. Each of these museums has a story to tell. In some cases, local Council might lend a hand but many have no external support. Their collections are valuable and unless there is community support (financially or otherwise), then this will be lost. It is important they receive advisory services through for example, the regional network which the Government established some years ago.
  3. Funding for museums is spread across many agencies (Local, State and Federal). There is no one ‘peak’ Government agency that coordinates or promotes all of this either at State or Federal levels – it seems this is left to State or National Associations to carry this out. What is required as a starting point is an easy to understand Government funding pack which lists the various bodies, basic details of the program, contact details and timings (if possible).

Support

We are one of very few across the State (and Australia) which has secured a listing on the UNESCO Australian Memory of the World Register.  We have not been contacted by anyone from the NSW Arts and Cultural bureaucracy about this, even though we’ve made it known to all. There is no promotion and certainly no attempt to support us when we needed it – a case in point being the fiasco over the Firearms Regulation of late 2017. From our perspective, there is no real destination marketing by the State of volunteer-based museums or similar – they seem to focus very much on food and wine. There is no real coordination by the State of significant regional museums.

The LSAFM has a critical mass that can be further developed into a significant, world acclaimed, regionally based museum.

We appreciate there are many museums across the State – over 200. But if the NSW Government truly wants to have a sustainable and thriving museums sector, then it needs to get to understand, at the very least, those which are renowned nationally and internationally. It needs to start getting behind those museums with a track record of achievement and working with them to further develop.

Some may say this approach is like ‘picking winners’ and that is not what the Government should do. If that is the case, then all government funded museums are ‘winners’, with the Powerhouse Museum being one such example where $500M to $1.5bn in funding is projected to be spent in any relocation.

In our view, the essence of Government support should be driven by the ‘historical, educational and cultural’ significance held by museums as shown through nation building heritage, national and international reputation and propensity to grow into world-class institutions.

As mentioned above (in the funding section), regional museums need a better program of support to secure their future, where this is possible. What LSAFM is seeking is an equitable process whereby Government support is forthcoming proactively with promotion both here and overseas. An ongoing funding platform for regional museums with ‘community value’ and the potential for national / international significance, should be introduced. The current practice of continually applying for grant funding is too uncertain and does not provide any certainty in planning and budgeting for growth.

Conclusion

Regional communities receive a disproportionate allocation of funds for museums. The Arts & Cultural bureaucracy appear to be Sydney centric, with considerable funding going into a few Sydney based museums. Regional museums need support, especially those which are volunteer based. And Government needs to have a Regional Museums Plan and associated funding where the working relationship with key museums are identified and defined.

Proposed recommendations

LSAFM recommends:

  1. The NSW Government develop an overarching Regional Museum Plan and Regional Museum Fund that fosters the development and marketing of museums with ‘historical, educational and cultural significance’ into world-class facilities;
  2. The NSW Government reform its policy towards ‘firearms classed museums’ by a more rigorous definition of such museums and for those to be exempted from the provisions of the Firearms Act; and,
  3. The NSW Government through its regional development program ensure that regional museums are supported through site visits, advisory services and specialist services, as required.

4.0    Whether there is equitable access to collections across New South Wales, including at the Powerhouse Museum and the Australian Museum

Accessing collections held by other museums is almost near impossible, especially between Government funded museums and volunteer-based museums. LSAFM cannot understand why there is a roadblock in all of this, other than perhaps it is personality based or museum policy based. Whatever it is, the lack of sharing of valuable collections significantly deprives the community of viewing objects and artefacts of value. This needs to be un-locked.

Equitable access

Over recent years, the LSAFM has approached some museums seeking to display objects and artefacts, which would otherwise be ‘locked away’. Four examples are provided:

  1. From the date of its opening in 1997, the LSAFM had on display a Captain Cook Bicentenary exhibit showing an iron ballast from the ship ‘Endeavour’, along with a Queen Anne musket made at the Factory. The ballast we had on display was a gift from the Factory which in the late 1960s restored it and other iron ballast blocks for the Captain Cook Bicentenary in 1970. The Maritime Museum demanded our ballast be given to them for conservation purposes, which we did, and on the understanding the ballast would be returned to the LSAFM in 3 months. There was no such return. The Maritime Museum placed onerous conditions and requirements on LSAFM which we could not fulfil. Our protestations fell on deaf ears and so our iron ballast has been sitting in a basement within the Australian Museum for many years. As far as we know the iron ballast was never conserved by the Maritime Museum. This type of behaviour is outrageous. How can something of significance be sitting in a basement warehouse collecting dust. And, equally why does a taxpayer funded museum have the right to dismiss any request from the rightful owner of the iron ballast, one that was gifted by the Factory which carried out the restoration all those years ago.
  2. The Powerhouse Museum has a magnificent firearms collection. Those firearms were on display at the Powerhouse in the early years but now they are no longer – they are housed in a basement. One such firearm artefact is the Australian made McCrudden light machine gun, which if on loan, would be able to be displayed at our Museum rather than being hidden away. This and other firearm artefacts would be able to be accommodated at LSAFM, thereby allowing the wider public to appreciate objects and artefacts;
  3. A collection of colonial firearms was bequeathed to the Australian Museum, which chose to act in self-interest by selling off the collection. A rather selfish act – the ethics around all of this is questionable. That collection or part of it could have come to LSAFM for display and recognition; and,
  4. NSW Police Ballistics Section has a very comprehensive firearms collection with many duplicate and redundant items. Coming into being in 1936, the collection was meant to be a reference library for police forensic and was deemed not a collection of historic firearms. While the LSAFM acknowledge this, the fact is that part of the collection is surplus to need and given that, the collection could be made available to bona-fide researchers or donated to a museum, like ours.

LSAFM has been disappointed by the response to date, as illustrated. We have a Vickers machine gun on loan to the Cowra Council and this transaction was approached with mutual respect and need. The sale of donor gifted objects is particularly galling and no museum should be allowed to take a unilateral action such as this without proper consultation and consideration.

These above examples can all be successfully dealt with for the benefit of the wider community.  Museums have inter-loan processes and with proper security and governance procedures in place, any sharing should be straight-forward.

Proposed recommendation

  1. Where a decision to part with a donated object, the museum in question should firstly approach other museums to ascertain their interest and capacity to display that object. Any museum which sells donated objects for financial gain, without prior consultation, should be discouraged as such actions would send a message to potential donors that their objects are not valued; and,
  2. All museums need to have the proper security measures, transfer records and governance in place to transact any loan transfers or gifting of objects for public viewing. If an object of significance can be appropriately displayed by a museum with all of the necessary protections and marketing, rather than being hidden from public view, that very outcome is in itself justifiable and should be encouraged.

5.0    Whether comprehensive consultation with communities and experts has informed cultural policy and projects across New South Wales, such as that applying to heritage arms and armour collections

The short answer here is absolutely not.

As mentioned above in Section 3.0, the LSAFM operates under a regulatory policy regime. Unbeknown to museums with firearm permits and the NSW Government’s own Firearms Registry, a new Museums Firearms Regulation took effect in late 2017. It wasn’t till 12 months later that the new Regulation became known. The new Regulation required museums to permanently deactivate all prohibited firearms and handguns – a rather draconian decision where consultation with the museums sector was non-existent. That action of late 2017 was taken with absolute disregard for any affected museum party.

Pre-late 2017

There were two Stakeholder Committees formed which provided advice to the Government on Firearms legislation. LSAFM was not a party to either Committee since we were considered as not being a representative body (representing members).

We are told the first Committee was dissolved by the Government after its report and recommendations were not aligned with Government thinking. The second Committee we are told was slightly more successful in that it wasn’t dissolved but the Government hastily chose to bring down its 2017 Amendment taking the Committee by surprise.

We understand the deliberations over museum firearms was considered by the first Committee, it was not so at the second Committee since it was never tabled by the Government.

Post-2017

There was no communication to any museum in the State of the decision.

It was December 2018 that LSAFM became aware of the new Regulation. This was by chance only after an approach for assistance from the Gunnedah Rural Museum. 

The LSAFM collection of firearms numbers just over 2500 and of those, 70% would require permanent deactivation. It made no sense to us as to why we should destroy our firearm artefacts. We pushed back and led the charge to overturn this rather ridiculous and unjust piece of legislation.

LSAFM immediately sought and was granted a meeting with the then Police Minister. It was clear from our dialogue with NSW Firearms Registry that they had little idea of the decision made or impact of that decision. Our discussions with the then Police Minister was short-lived, overtaken by the State election of March 2019.

LSAFM met with the incoming Police Minister, The Hon. David Elliott. Our concerns were heard and we spent numerous days, weeks and months trying to get across to the bureaucracy the role and significance of museums with firearm permits and the rationale for museums to be totally exempted under the Firearms Act.

Slight changes to the 2017 Regulation were made but these did not change the ‘tipping point’ fundamentals. The Regulation now in place maintains permanent deactivation. It gives the museums the provision to apply for an exemption to permanent deactivation, but there is no guarantee. The Police Commissioner has the power to refuse or cancel any exemption without reason.

The end point in all of this is that museums in NSW are worse off compared to a shooter, collector or firearms dealer. If that is sensible policy, then we all should believe that ‘pigs do fly’.

Issues

There are several issues which need airing:

  1. The NSW Government’s management of the museum firearm Regulation was appalling. There was no attempt to consult. There was no appreciation of the impact. They treated museums as dispensable. There was no understanding of nor any attempt to understand the role that museums play. There was always a hidden agenda;
  2. Museums are defined within the regulatory framework. In NSW there are 63 museums with firearm permits. But those museums are not ‘like for like’. They vary from a backyard collection to something that is world class like LSAFM. We operate as a fully-fledged museum consistent with its definition – we service society by acquiring, conserving, developing, researching, educating, communicating and exhibiting. There are many other ‘so called’ museums under the regulatory framework which do not meet the baseline requirement.  Attachment 1 outlines LSAFM’s definition of Museums.
  3. The NSW Government has made no attempt to treat fully fledged museums as exempt under the Firearms Act. Prior to late 2017, publicly funded museums were exempt under the Act, even though they had no firearms on display (their firearms were kept in basement facilities). But privately run museums were not afforded that exemption even though they abide by strict security measures. Today, no museum is exempt under the Act. It is absurd that fully fledged museums are not exempted from the Act altogether;
  4. There is a lack of support for museums from associations or even the NSW Government’s lead Arts & Culture organisation. Their attitude towards our plight with the firearms Regulation was of utter distancing. It seemed to us that no-one wanted to know about museum firearms. They chose to ignore us. In one case, they lost our formal request for support, only to find it again and then silence took over. They lack any sense of knowledge;
  5. There is no cultural policy in relation to industrial heritage in NSW. The LSAFM has one of the best industrial artefacts collection anywhere in Australia. Our UNESCO recognition should be sufficient for lawmakers to take note but sadly they chose to ignore it and their only solution for supporting museums is to lump on us more regulation. It is diabolical;
  6. Museums need a voice at the ‘Government table’. We have requested that we are represented, not through some association but rather by the people on the ground who understand what is happening. The LSAFM has underway an initiative to establish a Museums Alliance (of like-minded museums) where ‘our voice’ can be heard directly, whether in a regulatory or non-regulatory environment;
  7. Museums in NSW seem to operate in silos. The LSAFM is based in Lithgow but we are part of a much bigger region of the State. There isn’t any program or the like in bringing such museums together through networking or information flow. While there is some attempt by Local Councils to do this, they have other priorities and don’t have the wherewithal or funding capacity to make it happen; and,
  8. LSAFM is the only volunteer-based museum in the State (and Australia) able to provide formal training to State authorities on technical aspects of firearms. From our viewpoint, there is an educational void among some Registry officers / Licensing Police relating to firearm knowledge. LSAFM has offered to provide such training.

Conclusion

Museums, especially those in regional areas, are not well understood by the policy makers or lawmakers. There is no overarching cultural policy governing the support and promotion of museums. Regional museums will disappear unless there is a meeting of the minds within the NSW Government bureaucracy about the issues raised above.

Proposed recommendation

LSAFM recommends that:

  1. Museums be properly defined with clear mandates of what they must have in order to operate as fully fledged museums;
  2. Fully fledged museums be given exempt status under the NSW Firearms Act;
  3. The NSW Government work with regional museums providing proactive networking programs and the like;
  4. The NSW Government invite the museum sector representatives to be part of the consultative process – whether regulatory or otherwise – so that its position can be voiced; and,
  5. The NSW Government make clear their cultural policy and program in relation to museums and overcome the current division within the bureaucracy.

6.0    The continuing impact of the efficiency dividend on the budgets of museums and galleries over the last 10 years

LSAFM supports every effort for tax-funded museums to operate as efficiently as they can and not think of funding as an infinite, ongoing resource where budgets keep rising. But it is important whatever budget is set, that this delivers best-practice services with excellence in visitor experience.

We do not necessarily agree with the use of the ‘efficiency dividend’ marker as a universal measure of efficiency. In some cases, museums are required to have higher budgets and higher staffing to meet increasing demands through exhibits, events, promotions and educational displays. Funded museums are generally 7 day / week businesses where the public expects such service.

As such, the Museum’s operational recurrent budget is crucial. One can deploy technology or build new facilities, but the essence of a museum is what it holds. One cannot replace the knowledge and craft involved in curatorship, public education, conservation and care for collections. It is their core business and restricting funding for some ‘efficiency dividend’ makes no sense.

Obviously, every organisation must be accountable for their actions. As professional museums, they must have the rigour and governance practices in place to effect best-practice. We have seen some tax-payer funded museums reduce their services and staff numbers; equally, we seen the reverse. But we’ve also seen other tax-payer funded museums allocated hundreds of millions of dollars for works that could have been better spent elsewhere.

In the case of the LSAFM, we run our museum on a low-cost budget. We have volunteers carrying out various works. Our annual business plan budgeting is dedicated to improving both the visitor experience and artefact quality.  We have operated without the need for ongoing tax-payer funding and have been successful in securing grant funding for much needed building and archiving works.

We have seen grant programs expand in NSW in recent years, but at the same time we have seen a scaling back of programs for regional museums in relation to advisory services, networking and promotion. The use of consultants to advise museums of what they should do, while admirable, is in some cases counter-productive as their advice is not practical for a number of small, regionally based museums.

7.0    Funding levels for museums and galleries in New South Wales compared with other states

As a State, we have many museums per head of population and funding is very much heavily biased in favour of larger metropolitan institutions. With museums accessing Federal, State and/or Local Government funding, each museum has its own funding model.  

The LSAFM is not in a position to offer a well-informed view between State budgets and ensuring there is an ‘apples with apples’ comparison.   We do not have an equivalent similar organisation operating in other States and hence, it is difficult for us to make any comment on State by State funding as it relates to what we do.

From what we have seen, the Arts and Cultural industry in Victoria appears to be more advanced than most other States. The peak Government body ‘Creative Victoria’ is very open and shows strong leadership. The Victorian branch of the Australian Museums & Galleries Association (AMaGA) is also highly active in promoting and informing its members, with a greater recognition of regional museums.

In NSW, there are over 220 museums outside Sydney. There are some 14 Regional Arts Development Organisations (RADOs) in NSW, each providing strategic direction for sustainable arts and cultural development in their region. Some $2 million is allocated annually to support the RADO network. As a leading regional museum in the State, LSAFM does not see nor interact with any RADO.  Our association with the State Branch of AMaGA is non-existent and there was no reason for us to maintain any form of membership – we did not renew our annual membership with the AMaGA national body.

As mentioned above, LSAFM applies for grant funding, which is a ‘hit and miss’ exercise. This form of funding is common for not-for-profit organisations. While this might be a convenient way to allocate funds across the wider community, it is perhaps not optimal for regional museums.  In the case of LSAFM, over 80% of our grants comes from State funding, with Federal funding making up the remainder. We do not have Local Government funding. Our recurrent funding is largely provided through entrance fees and shop sales. But perhaps a different funding model is required and one possibly is the creation of a Regional Museums Fund.

8.0    Whether there are other more cost-effective strategies than the sale of the Powerhouse Museum site at Ultimo to support museum development across New South Wales, including consideration of the new Parramatta site and the proposed standalone Western Sydney Museum at the Cumberland Hospital site

It is about time consideration be given to expanding regional museums. Regional NSW accounts for over 30% of the State’s population and so why can’t attention be turned towards developing more than one showcase museum in regional NSW. Regions have gone through a horror drought and bushfire season and having world-class museums would undoubtedly bring increased tourism. It would shift the current Sydney centric approach to more of a State approach.

As an example, the LSAFM is a museum that represents design, engineering, manufacturing, workplace advancement and society learning & development. It is a showcase of ingenuity in an area of utter importance to Australia’s development in the 20th century. And the LSAFM has the archives, the objects and the technical knowledge that can be used to heighten educational, research and training interest. As such, LSAFM could be one of those regional world-class museums, harnessing, supporting and growing a rich history that is specific only to LSAFM. That is the crux of the opportunity where the significance of the museum dictates future development and funding, rather than relying only on geographic area discussions about museums.

If the Powerhouse Museum remains in Ultimo, then Sydney/ Western Sydney can easily accommodate a new museum(s) in whatever form that is. For example, the Powerhouse Museum is noted for its science, engineering and technology but it also has a diverse range of other artefacts, including theatrical items. Those theatrical items (and other items) can become the basis of a new museum rather than having such items in storage for no-one to see. But we do not need multi-million dollar buildings to create a museum – museums can be sustained by world class objects & artefacts – it is a question of significance and bringing that to life.

9.0    Any other related matter

Volunteering is perhaps the one universal need across volunteer-based museums. It is a major risk to museums, especially those in regions. We do not have the luxury of paid staff like the taxpayer funded museums. The LSAFM is always seeking volunteers. We offer training and development across an array of roles, thus adding to the capability and competencies of the individual. We also pay base travel costs in some cases where volunteers are required to travel some distance from home to the museum.

But we are one of many museums doing this. We are all ‘fishing in the same pond’.  There does need a new approach to this, especially in bringing through younger people who are willing to learn. Relying on the ‘older brigade’ for volunteering is not sustainable.  But there is no avenue for volunteers in the museum sector (in regions) to gain educational value. The cost of external training is prohibitive.

LSAFM does not have all the answers, but the following suggestions may have some merit.

  1. Create the passion for museums through annual Museum Awards recognising the contributions by both the organisation and individual. The current practice of Awards involves submitting a submission which is then judged by Museums & Galleries NSW – this is a rather invisible process. Awards should be based on what museums are doing in the field, the experience they provide, the individuals making a difference, achievements made and seeing how museums operate;
  2. Develop learning pathways for volunteers leading to a Statement of Attainment training and new skills. Museums are not Registered Training Organisations but having pathways, through tertiary training institutions which help develop skills would be desirable, especially if there were training materials which could be made available to museums for their review and implementation; and,
  3. Provide concessionary status to volunteers undertaking third-party accredited training so as to reduce the end cost paid for by the museum.

Attachment 1

Defining Museums

Introduction

There are various Museums definitions in the open market, many of these are open-ended, high level statements. While this may seem appropriate, it does though create confusion in the minds of many. Not all museums are the same but legislation treats them as having equal standing despite their vast differences in what they do.

What should a Museum be about

To LSAFM, any museum should be about its collection, its significance and how that significance is accessed, promoted and used for educational purposes. We see museums as places of discovery, of history, of technical knowledge and of learning.

LSAFM operating environment

In the line of work of the Lithgow Small Arms Factory Museum (LSAFM), there are taxpayer funded museums, volunteer-based museums, Council run museums and privately funded museums.  But not all of these museums meet the specific criteria but they are still regarded as museums under the law.

We are required to abide by the NSW Firearms Regulation 2017 (Clause 59 – Museum Firearms Permit).  The definition of a museum, per the Regulation is:

Public museum means a non-profit making institution that:

  1. Has a written constitution that states the museum’s charter, goals and policies;
  2. Has a stated acquisition policy;
  3. Acquires, conserves and exhibits objects of scientific or historical interest for the purposes of study, education and public enjoyment;
  4. Is sufficiently financed to enable the conduct and development of the museum;
  5. Has adequate premises to fulfil its basic functions of collection, research, storage, conservation, education and display;
  6. Is regularly open to the public.

The most significant aspect of the definition is point c).

In the context of that Regulation, there are taxpayer museums (and others) which are treated as Museums (through Permits) even though they do not carry out that specific function.

In other words, if Museums are truly about ‘study, education and public enjoyment’ then why is it that some Museums have their firearm artefacts sitting in a basement for no-one to see. They don’t acquire or exhibit, although some monitoring / conservation possibly occurs.  They don’t educate. And they certainly don’t provide public enjoyment.  Then, there is the issue of 63 Museum Firearm Permits issued in NSW which to our way of thinking are ‘lots of museums’ which may or may not satisfy the above definition.

The reason for raising this very issue is because it debases the very essence of why a museum exists. It also highlights how organisations like ours are ‘lumped’ together with others which are not strictly museums (under the Act). And this very issue is one of the major reasons the LSAFM is in this crisis of permanent deactivation of firearms when truly it should be exempted from the NSW Firearms Act.

How should Museums be defined under Clause 59, Museum Firearms Permit

LSAFM believes any museum with firearm artefacts which meet the following criteria should be exempt from the NSW Firearms Act because they are truly museums acting in the interests of society in a secure operating environment.

The mandatory requirements for recognition as a museum (under Clause 59) should be as follows:

  1. Acquires, preserves, researches, documents, interprets, exhibits, safeguards and enhances the understanding of objects of scientific or historical interest for the purposes of study, research, education and public enjoyment;
  2. Is a not-for-profit, participatory institution strengthening scholarship and collaboration through networks and educational services;
  3. Has a collections assessment of significance with documented culture and heritage;
  4. Has a written constitution inclusive of the museum’s charter, goals and policies;
  5. Has a management structure with Custodial accountabilities and a clear succession pathway;
     
  6. Is sufficiently financed to enable the on-going development of the museum;
  7. Has adequate premises to fulfil its functions of collection, research, storage, conservation, education, preservation for future generations and display;
  8. Has conforming security processes and systems in place safeguarding the general public, museum staff and museum collections; and,
  9. Is regularly open to the public.

Submissions to the Inquiry close on 17th May.

For more information see:

https://www.parliament.nsw.gov.au/committees/listofcommittees/Pages/committee-details.aspx?pk=264#tab-submissions

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New Amendment to NSW Firearms Regulation Misses an Opportunity for Positive Change

On 30th August, the NSW Government released an Amendment to the 2017 Firearms Regulation as it relates to museum firearm permits.

The main change is the provision allowing the Police Commissioner in certain circumstances to grant a museum an exemption from having its pistols and prohibited firearms permanently deactivated.

Over the past 9 months, the Lithgow Small Arms Factory Museum (LSAFM) was prominent in its opposition to the 2017 Regulation. We argued for the reinstatement of temporary deactivation which existed prior to 2017 along with designated security systems being in place.

We also pointed out inconsistencies in the Regulations and the opportunity for Government to recognise the role of firearms museums.

We fundamentally disagree with the direction of the Amendment. It provides museums with no assurance. It treats them with tokenism and moreover, it does not seize the opportunity to bring positive change to the regulatory environment.

There are many other worrying aspects of the Amendment.

Firstly, permanent deactivation remains the underlying rule of the Amendment.

Secondly, one person (the Police Commissioner) has the absolute power over how a museum operates or doesn’t.

And thirdly, there is no detail of the process and onus of proof which museums will be required to show.

What we now have is an Amendment that requires museums to argue their case as to why they should be given an exemption from permanent deactivation at the time of permit renewal for which there is no detail.

There is no certainty in any of this.  A museum could well provide details of onus of proof only to see the Police Commissioner ‘revoke the exemption if satisfied the exemption is no longer reasonable in the circumstances’ – whatever that means.

What disappoints us is that the last 9 months has been futile and even though we were in a consultative period with the Government, we were only given the opportunity to exchange views after the Government had already made up its mind.

To us, the Amendment is about more regulation and interference. This is just more bureaucracy and archaic thinking in having museums justify their existence without any guarantee”.

We pointed out to the Government that the regulatory model for museums needed to change from one of regulation to one where the onus and responsibility is placed on museums to operate within strict operating guidelines.

Further, the Regulation needed to avoid being open to interpretation. We put forward specific requirements around museum definition, security standards and conformance so that the rules were clear.

We are told there are 63 museum permits across the State which alarms us since we believe not all would fulfil the museum definition and/or not all would meet the strict security requirements.

The regulatory framework has not lived up to what we and the general public would come to expect. This is precisely why Regulations that are open to interpretation end up requiring added regulation.

Organisations like ours are therefore penalised for the incompetence of others. There is enormous ignorance as to what constitutes a firearms museum and this is a very sad fact which lawmakers are happy to ignore, but in so doing are not doing their job.

We pointed out to the Government some of the Regulation’s inconsistencies and suggested the regulatory process be re-considered and overhauled, if required, as part of the museum Regulation review. Examples of this being the discrepancies in the definition and treatment of handguns, issuing of museum permits where associated firearms are not registered in the Permit holder’s name, and the blurriness of definition between collectors, RSLs and museums.

None of this has occurred and the opportunity to make a positive change is lost. We are saddled with a second-rate system, where it will get down to an individual who, in all likelihood knows little about how museums operate, making a call on a museum’s future.

The LSAFM will continue to actively press its claims for reform as we sincerely believe museum accountability is far superior and a better practice than regulatory paperwork.

 

Links:

Firearms Regulation Clause 59 (Museum Firearms Permit) Amendment

https://www.legislation.nsw.gov.au/#/view/regulation/2017/442/part6/sec59

 

Posted by Custodian in Uncategorised, 5 comments

Role Of Museums In Public Policy

“In our specialty of firearms, many have little understanding of how museums operate and what they possess and some do not see past the end of a barrel. To them, museum firearms are about gun control – that’s it. A rather tenuous and irresponsible connection which brands museums as some ‘gun happy’ bunch. The misunderstanding is frightening.”

R Benedet, President Lithgow SAF Museum

Museums are places of cultural significance. They are icons in society whose objects are priceless. Museums across Australia work each day to provide important educational experiences to diverse audiences that make a difference in people’s lives. Museums enrich communities and preserve unique culture and history for all Australians.

We know from various empirical evidence of the overwhelming positivity exhibited by the general public towards museums. Further, museums are viewed as educational assets belonging the wider community.

But how good are museums in influencing public policy issues as they affect day to day operations of museums. How do museums champion a cause in the name of community interest or how are they organised to show strong leadership and be proactive in advancing the work of Museums for the benefit of the diverse audience they serve.

A current case for us is the issue surrounding the current Firearms Regulation which we have fought against over the past 6 months. We made clear our position at ministerial and departmental circles and have assembled a significant support base which has helped our cause significantly.

Leading the charge on behalf of museums across the State is something we have taken on in the absence of any other avenue.   Our case symbolises a vitally important but reactive stance – responding to an issue after the event.

But what of museums being in a leadership role, being proactive and influencing key policy decisions through insightful knowhow and carefully thought through initiatives.

A number of questions surface immediately – how do museums do this; do they have the critical mass to influence; do they have the technical nous to educate the uneducated; do they have the time and inclination; and, are they respected for their views.

Museums have no choice – they must stamp their authority. They must engage in public policy where their services really matter.

Like other industries, museums are affiliated with an ‘association’. In our case, it is the broad-based Australian Museums and Galleries Association (AMaGA), even though there is no specific collegiate organisation with a firearms collection focus.

In our specialty of firearms, many have little understanding of how museums operate and what they possess and some do not see past the end of a barrel. To them, museum firearms are about gun control – that’s it. A rather tenuous and irresponsible connection which brands museums as some ‘gun happy’ bunch. The misunderstanding is frightening.

This is why we and the Gunnedah Museum ‘stepped up to the plate’ and defended our industry in the midst of those who have other agendas.

It is work in progress but we’ve managed to convey meaning to the work of museums in firearms even if that is not through the established ‘association’ channels. Convincing regulators with a mindset for more regulation as their answer to everyday issues has been our focus.

But in reality, that is only part of the job we must do.

The other and perhaps more important part is in in shaping public policy. In our case, areas such STEM, industrial heritage, precision-based production technologies, tourism, funding programs and digital systems are some of the things we need to express a position on.

The history of firearms involves innovative skills and techniques which in today’s society may be ‘lost’ but the learnings are very much still relevant.  And they are learnings from mass production processes which influence science, mathematics, engineering, metrology, materials, machining & cutting technology, production systems and forensic ballistics.

Furthermore, our museum has a role to play in digitalisation competencies and security and public safety systems.

As a privately-run museum, we find that time is against us – there are so many other things to attend to and our resources are spread thinly as it is. Nonetheless, there are things we need to have ‘our say’ on and our aim is to venture into this space more and more.

With the affiliation we have made with Gunnedah Museum and others on the Firearms Regulation issue, there is a definite need for us all to work as a group and from this we are hopeful we can elevate our public stance in a proactive way.

Posted by Custodian in Uncategorised, 1 comment

Should Governments be Allowed to Destroy Museum Firearms Collections in the Name of Public Safety?

It’s deeply disturbing that Governments can introduce legislation that can destroy collections in museums.

CZ Model 75, factory engraved nickel plated with gold fittings – Browning Hi-Power Model 35, factory engraved, gold and silver plated, previously owned by Dubbo gunsmith Caesar Hatti – Colt Mk IV Series 70 Gold Cup, gold inlaid International Shooters Edition
The NSW Government’s 2017 Regulation would have these valuable, rare and beautiful works of the engraver’s art destroyed by highly visible external welding

As museum custodians, we find it hard to believe that any right-minded person could sign off on legislation that destroys any collection. And we’re not alone. The reactions of shock and anger from all around the world evidenced in comments in our online petition make it obvious that most people understand what our Government seemingly can’t.

The destruction of historical items is to be deplored. Whoever thought that this is acceptable is not of a sound mind. They should be condemned just as the Taliban who destroyed the Buddhas were condemned.

– Anon, UK

Thinking about the reasoning behind this Regulation, it’s hard to make sense of it on any level.

The ideology that prompts Governments to interfere with museum collections fails to recognise that firearms in museums are a different matter. They are no longer weapons, but artefacts – a record of our history and a part of our story, and as such, must remain in their original state so that future generations can view and study them.

Does the Government really believe they are ridding the nation of objects so evil that, even in museums, the repositories of truth and authenticity, they must be destroyed for the sake of humanity?

And how is this any different from the religious and political motivations of Middle Eastern extremists as they smashed their way through ancient statues that they found offensive to their beliefs, leaving a trail of devastation in their wake that shocked and robbed the world.

During both World Wars, museum collections were so valued that, amid the chaos, they were hidden away to protect them from the ravages of war. It’s sad to think LSAFM may have to give its essential collection away to protect it from our own Government.

Or is there other reasoning behind it? With most of the larger museums in the State being either Government owned or funded, Museums may have been seen as an easy target to satisfy the desire to turn the screw on the State’s gun laws.

However, this is an issue that is quite aside to implementing gun control measures to ensure public safety.

It’s likely that instances of theft of firearms from museums is very low, given the difficulty of finding official statistics concerning this. Much, much rarer must be instances of crimes committed with firearms stolen from museums.

Museum objects are valuable in more ways than one, and museums are very conscious of the measures they must take to prevent theft of any item in their collections. Museums that display a large number of firearms, are also well aware of the burden they bear in the interests of public safety.

So what is the rationale of targeting museums with this latest legislation?

When we met the Police Minister in early February he told us that our museum advertises the fact that it has firearms and it is open to the public. But does this equate to increased risk to the public?

Firearms dealers and retailers are in the same position, yet they are not targeted like museums.

Prior to the Regulation Amendment, modern (post 1900) firearms displayed in museums legally required temporary deactivation by removal of internal components such as firing pins or springs or by trigger locks. And Museums don’t have an issue with this. They don’t want their valuable firearms to be stolen either.

What must be remembered is that firearms in museums haven’t been used for years. As any firearms user knows, this presents a personal risk to those who steal a gun, source a missing part, and fire it. The danger is greatly compounded when missing components are replaced by any available part – especially if the firearm is self-loading, semi, or full automatic.

Criminals and terroritst will target easier marks if they want to steal firearms.

Thinking about it in terms of what will be gained and lost …

Should LSAFM comply with the Regulation, some of the items that would completely lose their integrity are so rare there are only a handful of examples in the world. In some cases they are one-of-a-kind; their internal workings demonstrating a link in the technological endeavours of their makers.

When going through papers left by the Museum’s previous Custodian, we found his correspondence with an English researcher regarding a Bren Gun conversion that was crushed under the Government’s 1996 gun buyback scheme. So rare and valuable to researchers was this Bren, that this expert knew it by serial number!

When informed that it was destroyed during the Buyback he wrote back:

‘There were two in the world … now there’s one.’

LSAFM has hosted a number of researchers over the years, but not all of them firearms aficionados:

A writer who had very little knowledge of firearms visited to see how the action of the Smith & Wesson M&P revolver works. He’d found that this would have been the weapon of choice for his fictional detective, and wanted to ensure technical accuracy in his writing.

Another who freelanced for the National Sound & Film Archives, held more fascination for sounds firearms make. Our secure storage area became a de-facto sound booth complete with sensitive sound recording equipment. He recorded, as we cocked hammers, worked actions, and removed and replaced magazines in various firearms. Those recordings are now held in the NSFA, and are no doubt being used for various purposes.

Our own current research on the Lithgow and Slazenger sporting rifles – the little guns that put food on the table for many families after World War II – requires that we examine minute internal details of components to ascertain the reasons behind the change from the Model 1A to 1B.

It could be that there is no physical difference, the change in designation being an attempt to escape bad publicity following an incident in which the safety of the rifles was questioned … or was the rifle slightly modified then renamed because of a safety issue? How would we know unless we can fully strip down a number of both models for careful inspection.

Then there’s the donors – the very people who had a passion and belief who passed their collection onto a museum for safe keeping and display. The legacies from those individuals will, in many cases, be for the scrapheap.

Our decision makers must give more thought to what they are destroying.

Museums are inter-generational institutions. Whatever their collections contain, their responsibility for the care of their collection spans not only the current generation of scholars, writers, researchers and the public, but those of the future as well.

Governments will be harshly judged by future generations if they rob them of the opportunity to see and study their heritage.

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Changes to NSW Firearms Regulation Targets Museums

In November 2017, the NSW Government amended the Firearms Regulation in a way that can deeply impact museum’s firearms collections.

in the firing line … museum stands to lose valuable historic artefacts

The new legislation, it seems, was ‘rushed through’, without proper consultation with advisory groups. It was never communicated to the various stakeholders affected and to this day, many are unaware of the new laws.

LSAFM only found out about the new Regulation when another regional volunteer-led museum had firearms confiscated in early February 2019, and contacted us for advice.

How has the Firearms Regulation changed …

Basically the 2017 Regulation for Museums states that all pistols, self-loading longarms, sub-machine guns or machine guns are to be rendered permanently inoperable.

The irreversible destruction includes:

  • inserting a steel rod traversing the length of the barrel and welding it at the muzzle and chamber;
  • welding the barrel to the receiver;
  • removing the firing pin and welding the hole;
  • removing internal springs;
  • welding internal components;
  • welding any bolts and external hammers; and
  • welding the trigger in a fixed position.

All other firearms, such as bolt action rifles and older antiques, remain temporarily inoperable. But they may well be next in line if this insidious legislation is not overturned. Collectors should also be concerned.

What has prompted this

We are at a loss to understand why Museums have been targeted. We have not been given any details as to why the Regulation was introduced.

The fact the Regulation has been in force since late 2017 without any knowledge of its existence suggests some other motive.

We are not aware of any firearms being stolen from Museums which may have prompted all of this.

Draft Amendment to the Regulation

When we heard of the changes, we requested an urgent meeting with the New South Wales Minister for Police. We met with him on the 11th February.

The Minister tabled a draft Amendment to the Regulation, as it affects Museums. We are told the Minister for Police has written to each Museum seeking comment on the draft Amendment.

There are two key provisions of the draft Amendment:

  1. All prohibited firearms are to be ‘permanently inoperable’
  2. The Commissioner has the right to issue exemptions on a firearm by firearm basis

What’s at issue …

There are a number of issues at stake for Museums with firearm exhibits.  They include:

  1. Devaluation of the historical, educational and commemorative value of firearm exhibits. The firearms will become worthless in terms of museum artefact, visitor experience, research and historical merit, ballistics investigations and educational value;
  2. The cultural, scholarly, and scientific significance of heritage firearms collections will be seriously compromised, as will our understanding of the technological evolution of such firearms within defence industries and wartime economies;
  3. The treatment under the law of Museums being ‘lumped in’ with shooters, dealers, collectors and farmers fails to appreciate the dissimilarity of the work of Museums, and their contribution to communities relative to those other categories;
  4. The move to render any firearms ‘permanently inoperable’ will ‘sap the energy’ out of Museums and their volunteers. All of this goes against the grain of a museum, destroying its authenticity and rendering its collection irredeemable; and,
  5. The proposal to have the Commissioner determining exemptions creates uncertainty for Museums. It doesn’t make sense that issuing an exemption would suddenly guarantee that a firearm is safer or less prone to being stolen.

For the LSAFM, or other museums with comprehensive firearms collections that form a large part of their visitor experience, the following issues are especially pertinent:

  1. Visitors will become disillusioned, disappointed and outright angry. It is only a matter of time that word of mouth and social media will lead to a dramatic drop in Museum visitations.
  2. The fact a Commissioner can determine the fate of the Museum takes away its freedom to operate, to preserve the integrity of the collection, and to plan for the future;
  3. The ‘taking away’ of the rights of volunteers in giving of their time and know-how in making the Museum a proud working environment and a place of significance is unforgiveable. For privately operated Museums, the enthusiasm and interest will wane as the impressiveness of the collection is destroyed;
  4. The destruction of key working elements of prototypes, first issues and rare examples is very worrying; and,
  5. The viability of the Museum is placed in jeopardy as firearms are no longer ‘Museum quality’ and/or the quantity and diversity of firearms on display are most likely to be reduced as a result of the Regulation.

The relevance of all of this goes to the heart of operating a sustainable Museum able to plan their business in their own right.

Despite the proposal for exemptions, this is on a firearm by firearm basis. There is no blanket permit exemption where the nature of Museums is fully understood by those making the laws.

Interestingly, the Regulation as it stands is more onerous on a Museum than either a firearms dealer or collector.

In the case of self-loading rimfire longarms, permanent inoperability is applied to Museums, but not collectors. Dealers can have any firearms covered by their licenses – including machine guns – without any requirement for deactivation.

Rather bizarre conditions given the stringent security systems Museums are required to have operating.

What’s the impact?

Only you know what the impact might be on your Museum.

From the perspective of the LSAFM, about 70% of our firearms are impacted and if we were to make these firearms ‘permanently inoperable’ it will cost significantly, while also destroying the considerable value of our firearms.

If this Regulation cannot be overturned the Museum will not be worth operating.

And the impact won’t just be felt at a Museum level, it will have a community impact, a regional impact, a tourism impact and an impact on current and future generations.

The right of the community to visit a Museum such as ours (or for that matter yours) will be taken away because a Museum with firearms is seen by law makers as risky and in need of onerous regulation.

Contrary to that, Museums have security systems and vigilantly ensure their currency for the protection of volunteers, visitors and the wider community.

Each Museum must assess its own position.

Is there a solution?

While each Museum has different artefacts, with some being larger than others in terms of firearm displays, the underlying solution is simple.

  1. Remove the wording ‘permanently inoperable’ and reinstate ‘temporarily inoperable’. This in turn would negate the need for having Commissioner exemption provisions;
  2. Isolate Museums from being integrated with users, sellers, buyers and collectors on the basis that Museums display firearms for community and stakeholder interest and future generations; and,
  3. Allow Museums the right to have a permit with a blanket exemption on the basis that required minimum security and safety systems be in place and regularly audited.

As we all know, the regulatory regime for Museums per the 1996 Act have been satisfactory and practicable.

As Museums, we are the first to support and enact all necessary security of our facilities. But agreeing to onerous conditions without any reasoning is a step too far.

How to respond

Each Museum needs to assess its position and submit comments and views on the draft Amendment (and Regulation) to the NSW Department of Justice.

In addition to this, Museums should consider making other representations, and as a guide, actions the LSFAM will be taking include:

  1. Engaging with the Department of Justice and Firearms Registry;
  2. Making the local State and Federal Member and relevant Government and Shadow Ministers aware of the implications and impact;
  3. Soliciting the support of key stakeholders and supporters, including our local Council;
  4. Soliciting support from local, national and international organisations which use our facilities for research, historical and educational purposes;
  5. Having paper-based and online petitions;
  6. Communicating through our blog and social media; and,
  7. Approaching select media outlets.

Having a united position on the Regulation and draft Amendment would be an ideal outcome. However, the main outcome must be that you understand the issues, the impact on your Museum, and respond accordingly.

Links

NSW Firearms Regulation Part 6 Clause 59 (excerpt) (Part (4)(a) specifies permanent deactivation of Category C and D firearms in museums)

NSW Firearms Regulation Part 3 Clause 36 (2) (explains deactivation methods for Category C and D longarms)

Draft Amendment of Firearms Regulation 2017 (tabled by NSW Police Minister during meeting with LSAFM in March 2019)

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