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Our mission: To promote, protect and preserve hunting and the shooting sports.
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It's mission: To promote, protect and preserve hunting and the shooting sports.
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Using Risk Assessment to Assist Range Design and Operations

Using Risk Assessment to Assist Range Design and Operations

By Lloyd R. Norris, WSO-CSM/CSSO, Loss Control Specialist II
Risk Management Division, Broward County Occupational Health and Safety

(This article is reprinted from the Third National Shooting Range Symposium, 1996 with permission from International Association of Fish and Wildlife Agencies, Wildlife Management Institute and U.S. Fish and Wildlife Service.)

Introduction

Risk assessment is the means by which potential liability can be determined in the design and operation of a target range.

Ideally, risk assessment should be a major function of the initial range design prior to actual construction. However, this is an ongoing process due to range expansion, additional activities and unforeseen liabilities.

This presentation is intended as a general guideline for target ranges. Assessment of risks will vary depending on the type of range activity: rifle, pistol, shotgun, archery, etc. Risk/liability may also vary based on whether the range is an indoor or an outdoor facility.

The information presented herein is basically applicable to most target ranges, and implementation of a risk assessment program can begin prior to construction or at any time during the operation of the range. Potential liability is never ending.

The views and recommendations expressed in this presentation are based on current regulations, investigations and practical experience of the writer. Broward County does not assume any liability for the use or misuse of any material contained in this presentation.

Target range risk assessment

Let's look at risk assessment specifics for target ranges. The liabilities of a target range will generally fall into four main categories:

 1. range design.

 2. employee.

 3. public/patron.

 4. environmental.

Range design

The initial design of the target range should be based on professional guidelines and accepted standards. Any additions or changes should be done using the same criteria.

Employees

Employees must be protected from the standpoint of safety and health. Use of personal protective equipment must be mandatory. Please see the following categories for employee protection.

Hearing protection requirements: Hearing protection requirements through Occupational Safety and Health Administration (OSHA CFR29 1910.95) are as follows:

- Hearing protection must be supplied based on Table G-16 exposure. (See Table G-16 in following pages.) Administrative or engineering controls may also be needed. Maximum-rated Noise Reduction Rating (NRR) protection for ear muffs and/or ear plugs is recommended.

- Each employee must have "hearing conservation training" based on 1910.95(c).

- Employees must be given an audiogram to establish a baseline and annual testing to determine if hearing loss has occurred.

Eye protection: Polycarbonate lenses with side shields offer the best protection, ANSI (American National Standards Institute) approved.

Airborne lead protection: Under OSHA, guidelines for airborne lead (OSHA CFR29 1910.1025) are as follows:

- Employee exposure to lead should be monitored by air sampling, personal blood/lead testing.

- Lead exposure can be controlled by engineering of air flow, work practice (timing of work shift) and the use of respirators, if needed.

- Employees may also be subject to the Federal Hazard Communication Standard (CFR29 1910.1200), Respirator Protection Program (OSHA CFR29 1910.134) or similar state right-to-know laws depending on their exposure to lead particulates. This would probably be more applicable to an indoor range operation. Seek the advice of an expert for your range.

Lifting training: Training employees to avoid injury due to lifting heavy objects is determined by the type of shooting range. An outdoor range for skeet, trap and sporting clays may involve handling many cases of clay targets. Employees should be trained in proper lifting techniques.

Forklift operating safety: If forklift and pallets are used to transport clay targets, then employees must be trained in forklift operations.

Slips and falls: Employees and patrons are subject to tripping hazards which can result in serious injuries. Walkways should be kept clear; target bases should be recessed or highly visible; ladders and stairs should be placed in storage areas, and clay launching towers must meet OSHA regulations with respect to stairs and handrails.

 

Inclement weather: Lightning and rain can create an extremely dangerous hazard for employees and patrons at an outdoor range. Electric pull cords operated in wet conditions can be dangerous. Step-down transformers should be used on this type of equipment. A lightning detector should be used to close an outdoor shooting range. Reportedly, lightning can strike anywhere within a 6-mile range even though the storm area is not visible.

Public/patron

- Hearing protection should be required for all shooters and observers on the firing line. Protection offered by the range management should be the highest NRR (noise reduction rating) for hearing muffs or plugs.

- Safety eye protection should also be mandatory. If offered by range management, the glasses should be of good quality and afford good eye protection by design. ANSI-approved safety glasses with polycarbonate lenses and side shields offer good protection for shooters. Manufacturers and suppliers of safety glasses can make recommendations based on your needs.

- Patrons should be well informed that loaded firearms are not permitted except on firing lines.

- Protect patrons as far as feasible from tripping hazards. The firing line and access to targets should be free of this hazard at all times.

- The range must be designed and supervised to prevent the public from entering fallout areas such as a sporting clay course or advancing on any range without permission from the range officer.

- No alcoholic beverages permitted on the premises. Post signs and enforce.

- Well-trained, vigilant range personnel can be an asset to the range operation. Know and enforce the rules and be diplomatic when dealing with patrons.

- Special use organizations may be granted permission to use the target range. Adequate insurance provided by the group and range supervision is absolutely necessary.

- Each patron should sign a waiver/release of liability form. Get legal advice as to the

terminology in this form.

Environmental

Currently air, ground and water contamination from lead is the major concern of target ranges with respect to the environment. Plans for a new range to be built should comply with those environmental agencies having jurisdiction in that area. Failure to pre-plan before construction could result in fines, lawsuits or costly retrofitting.

Older ranges which have never been considered for lead disposal or contamination should be reviewed without delay. There are numerous acceptable solutions on the market today for the range owner to choose from. Remedial steps should be taken and an ongoing monitoring program should be instituted.

Occupational Safety and Health Administration Excerpts

 

Please note: Mr. Norris provided the following OSHA excerpts, which are printed exactly as provided below. If you have further questions, contact Mr. Norris at Broward County Risk Management Division, 115 S. Andrews Ave., A-510, Ft. Lauderdale, FL 33301; 954-357-7221.

 

Created by FastRegs software, FastRegs Version 2.1.2

Developed by OSHA-Soft, Inc.

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Starting with: ¤ 1910.95

Updated through: June 95

1910.95  Occupational noise exposure

(a) Protection against the effects of noise exposure shall be provided when the sound levels exceed those shown in Table G-16 when measured on the A scale of a standard sound level meter at slow response. When noise levels are determined by octave band analysis, the equivalent A-weighted sound level may be determined as follows:

Equivalent sound level contours. Octave band sound pressure levels may be converted to the equivalent A-weighted sound level by plotting them on this graph and noting the

A-weighted sound level corresponding to the point of highest penetration into the sound level contours. This equivalent A-weighted sound level, which may differ from the actual A-weighted sound level of the noise, is used  to determine exposure limits from Table 1.G-16.

(b)

(1)  When employees are subjected to sound exceeding those listed in Table G-16, feasible administrative or engineering controls shall be utilized. If such controls fail to reduce sound levels within the levels of Table

G-16, personal protective equipment shall be provided and used to reduce sound levels within the levels of the table.

(2)  If the variations in noise level involve maxima at

intervals of one second or less, it is to be considered continuous.

 

 

~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~

Starting with: ¤ 1910.95 ©

Updated through: June 95

 

c) Hearing conservation program.

(1) The employer shall administer a continuing, effective hearing conservation program, as described in paragraphs (c) through (o) of this section, whenever employee noise exposures equal or  exceed an 8-hour time-weighted average sound level (TWA) of 85 decibels measured on the A scale (slow response) or, equivalently, a dose of fifty percent. For purposes of the hearing conservation program, employee noise exposures shall be computed in accordance with Appendix A and Table G-16a and without regard to any attenuation provided by the use of personal protective equipment.

(2) For purposes of paragraphs (c) through (n) of this section, an 8-hour time-weighted average of 85 decibels or a dose of 50 percent shall also be referred to as the action level.

 

~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~

Starting with: ¤ 1910.95 (g)

Updated through: June 95

 

(g) Audiometric testing program.

(1) The employer shall establish and maintain an audiometric testing program as provided in this paragraph by making audiometric testing available to all employees whose exposures equal or exceed an 8-hour time-weighted average of 85 decibels.

(2) The program shall be provided at no cost to employees.

(3) Audiometric tests shall be performed by a licensed or certified audiologist, otolaryngologist, or other physician, or by a technician who is certified by the Council of Accreditation in Occupational Hearing Conservation, or who has satisfactorily demonstrated competence in administering audiometric examinations, obtaining valid audiograms, and properly using, maintaining and checking calibration and proper functioning of the audiometers being used. A technician who operates microprocessor audiometers does not need to be certified. A technician who performs audiometric tests must be responsible to an audiologist, otolaryngologist or physician.

(4) All audiograms obtained pursuant to this section shall meet the requirements of Appendix C: Audiometric Measuring Instruments.

 

(5) Baseline audiogram.

(i) Within six months of an employee's first exposure at or above the action level, the employer shall establish a valid baseline  audiogram against which subsequent audiograms can be compared.

(ii) Mobile test van exception. Where mobile test vans are used to meet the audiometric testing obligation, the employer shall obtain a valid baseline audiogram within one year of an employee's first exposure at or above the action level. Where baseline audiograms are obtained more than six months after the employee's first exposure at or above the action level, employees shall wearing hearing protectors for any period exceeding six months after first exposure until the baseline audiogram is obtained.

(iii) Testing to establish a baseline audiogram shall be preceded by at least 14 hours without exposure to workplace noise. Hearing protectors may be used as a substitute for the requirement that baseline audiograms be preceded by 14 hours without exposure to work place noise.

(iv) The employer shall notify employees of the need to avoid high levels of non-occupational noise exposure during the 14-hour period immediately preceding the audiometric examination.

(6) Annual audiogram. At least annually after obtaining the baseline audiogram, the employer shall obtain a new audiogram for each employee exposed at or above an

8-hour time-weighted average of 85 decibels.

 

~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~

Starting with: ¤ 1910.95 (i)

Updated through: June 95

(i) Hearing protectors.

(1) Employers shall make hearing protectors available to all employees exposed to an 8-hour time-weighted average of 85 decibels or greater at no cost to the employees. Hearing protectors shall be replaced as necessary.

(2) Employers shall ensure that hearing protectors are worn:

 (i)  By an employee who is required by paragraph (b)(1) of this  section to wear

personal protective equipment; and

 (ii)  By any employee who is exposed to an 8-hour time-weighted average of

85 decibels or greater, and who:

(A)  Has not yet had a baseline audiogram established pursuant to paragraph (g)(5)(ii); or

(B)  Has experienced a standard threshold shift.

 

 (3) Employees shall be given the opportunity to select their hearing protectors from a variety               of suitable hearing protectors provided by the employer.

 (4) The employer shall provide training in the use and care of all hearing protectors provided to employees.

 (5) The employer shall ensure proper initial fitting and supervise the correct use of all hearing protectors.

 

~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~

Starting with: ¤ 1910.95 (k)

Updated through: June 95

 

(k) Training program.

(1) The employer shall institute a training program for all employees who are exposed to noise at or above an 8-hour time-weighted average of 85 decibels and shall ensure employee participation in such program.

(2) The training program shall be repeated annually for each employee included in the hearing conservation program. Information provided in the training program shall be updated to be consistent with changes in protective equipment and work processes.

(3)  The employer shall ensure that each employee is informed of the following:

  (i) The effects of noise on hearing;

  (ii) The purpose of hearing protectors, the advantages, disadvantages and attenuation of various types, and instructions on selection, fitting, use and care; and

  (iii) The purpose of audiometric testing, and an explanation of the test procedures.

 

 

Created by FastRegs software, FastRegs Version 2.1.2

Developed by OSHA-Soft, Inc.

~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~

Starting with: ¤ 1910.1025

Updated through: June 95

 

1910.1025 lead

(a) Scope and application

(1)  This section applies to all occupational exposure to lead, except as provided in

paragraph (a)(2).

(2)  This section does not apply to the construction industry or to agricultural operations

covered by 29 CFR Part 1928.

(b) Definitions "Action level" means employee exposure, without regard to the use of respirators, to an airborne concentration of lead of  0 micrograms per cubic meter of air (30 mg/m­3) averaged over an 8-hour period.

(c) Permissible exposure limit (PEL)

(1)  The employer shall assure that no employee is exposed to lead at concentrations greater than fifty micrograms per cubic meter of air (50 mg/m­3) averaged over an 8-hour period.

(d) Exposure monitoring

(1) General.

(i)   For the purposes of paragraph (d), employee exposure is that exposure which would occur if the employee were not using a  respirator

(ii)  With the exception of monitoring under paragraph (d)(3), the employer shall collect full shift (for at least seven continuous hours) personal samples including at least one sample for each shift for each job classification in each work area.

(iii)  Full shift personal samples shall be representative of the monitored employee's

regular, daily exposure to lead.

(2)  Initial determination. Each employer who has a workplace or work is standard shall determine if any employee may be exposed to lead at or above the action level.

(3)  Basis of initial determination.

(i)   The employer shall monitor employee exposures and shall base initial determinations on the employee exposure monitoring results and any of the following, relevant

considerations:

(A)  Any information, observations or calculations which would indicate employee exposure to lead;

(B)  Any previous measurements of airborne lead; and

(C)  Any employee complaints of symptoms which may be attributable to exposure

to lead.

¤ 1910.1025 lead.

(6) Frequency

(i) If the initial monitoring reveals employee exposure to be below the action level the measurements need not be repeated except as otherwise provided in paragraph (d)(7) of this section.

(ii) If the initial determination or subsequent monitoring reveals employee exposure to be at or above the action level but below the permissible exposure limit the employer shall repeat monitoring in accordance with this paragraph at least every six months. The employer shall continue monitoring at the required frequency until at least two consecutive measurements, taken at least seven days apart, are below the action level at which time the employer may discontinue monitoring for that employee except as otherwise provided in paragraph (d)(7) of this section.

(iii) If the initial monitoring reveals that employee exposure is above the permissible exposure limit the employer shall repeat monitoring quarterly. The employer shall continue monitoring at the required frequency until at least two consecutive measurements, taken at least seven days apart, are below the PEL but at or above the action level at which time the employer shall repeat monitoring for that employee at the frequency specified in paragraph (d)(6)(ii), except as otherwise provided in paragraph (d)(7) of this section.

(7)   Additional monitoring

Whenever there has been a production, process, control or personnel change which may result in new or additional exposure to lead, or whenever the employer has any other reason to suspect a change which may result in new or additional exposures to lead, additional monitoring in accordance with this paragraph shall be conducted.

(8)  Employee notification

(i) Within five working days after the receipt of monitoring results, the employer shall notify each employee in writing of the results which represent that employee's exposure.

(ii) Whenever the results indicate that the representative employee exposure, without regard to respirators, exceeds the permissible exposure limit, the employer shall include in the written notice a statement that the permissible exposure limit was exceeded and a description of the corrective action taken.

(e)      Methods of compliance

(1) Engineering and work practice controls.

(i) Where any employee is exposed to lead above the permissible exposure limit for more than 30 days per year, the employer shall implement engineering and work practice controls (including administrative controls) to reduce and maintain employee exposure to lead in accordance with the implementation schedule in Table I below, except to the extent that the employer can demonstrate that such controls are not feasible. Wherever the engineering and work practice controls which can be instituted are not sufficient to reduce employee exposure to or below the permissible exposure limit, the employer shall nonetheless use them to reduce exposures to the lowest feasible level and shall supplement them by the use of respiratory protection which complies with the requirements of paragraph (f) of this section.

(ii) Where any employee is exposed to lead above the permissible exposure limit, but for 30 days or less per year, the employer shall implement engineering controls to reduce exposures to 200 mg/m­3, but thereafter may implement any combination of engineering, work practice (including administrative controls), and respiratory controls to reduce and maintain employee exposure to lead to or below 50 µg/m3.

 

Created by FastRegs software,  FastRegs Version 2.1.2

Developed by OSHA-Soft, Inc.

~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~

Starting with: ¤ 1910.134

Updated through: June 95

 

¤ 1910.134 Respiratory protection

(a) Permissible practice

(1) In the control of those occupational diseases caused by breathing air contaminated with harmful dusts, fogs, fumes, mists, gases, smokes, sprays or vapors, the primary objective shall be  to prevent atmospheric contamination. This shall be accomplished as far as feasible by accepted engineering control measures (for example, enclosure or confinement of the operation, general and local ventilation and substitution of less toxic materials).  When effective engineering controls are not feasible or while they are being instituted,  appropriate respirators shall be used pursuant to the following requirements.

(2) Respirators shall be provided by the employer when such equipment is necessary to protect the health of the employee. The employer shall provide the respirators which are applicable and suitable for the purpose intended. The employer shall be responsible for the establishment and maintenance of a respiratory protective program which shall include the requirements outlined in paragraph (b) of this section.

(3) The employee shall use the provided respiratory protection in accordance with instructions and training received.

(b) Requirements for a minimal acceptable program

(1) Written standard operating procedures governing the selection and use of respirators shall be established.

(2) Respirators shall be selected on the basis of hazards to which the worker is exposed.

(3) The user shall be instructed and trained in the proper use of respirators and their limitations.

(10) Persons should not be assigned to tasks requiring use of respirators unless it has been determined that they are physically able to perform the work and use the equipment. The local physician shall determine what health and physical conditions are pertinent. The respirator user's medical status should be reviewed periodically (for instance, annually).

(11) Respirators shall be selected from among those jointly approved by the Mine Safety and Health Administration and the National Institute for Occupational Safety and Health under the provisions of 30 CFR part 11.

(c) Selection of respirators. Proper selection of respirators shall be made according to the guidance of American National Standard Practices for Respiratory Protection Z88.2-1969.

 

~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~

Starting with: ¤ 1910.134 (e)

Updated through: June 95

 

(e) Use of respirators.

(1) Standard procedures shall be developed for respirator use. These should include all information and guidance necessary for their proper selection, use and care. Possible emergency and routine uses of respirators should be anticipated and planned for.

(2) The correct respirator shall be specified for each job. The respirator type is usually specified in the work procedures by a qualified individual supervising the respiratory protective program. The individual issuing them shall be adequately instructed to insure that the correct respirator is issued.

(3) Written procedures shall be prepared covering safe use of respirators in dangerous atmospheres that might be encountered in normal operations or in emergencies. Personnel shall be familiar with these procedures and the available respirators.

(5) For safe use of any respirator, it is essential that the user be properly instructed in its selection, use and maintenance. Both supervisors and workers shall be so instructed by competent persons. Training shall provide the men an opportunity to handle the respirator, have it fitted properly, test its face-piece-to-face seal, wear it in normal air for a long familiarity period and, finally, to wear it in a test atmosphere.

(i) Every respirator wearer shall receive fitting instructions including demonstrations and practice in how the respirator should be worn, how to adjust it and how to determine if it fits properly. Respirators shall not be worn when conditions prevent a good face seal. Such conditions may be a growth of beard, sideburns, a skull cap that projects under the facepiece or temple pieces on glasses. Also, the absence of one or both dentures can seriously affect the fit of a facepiece. The worker's diligence in observing these factors shall be evaluated by periodic check. To assure proper protection, the facepiece fit shall be checked by the wearer each time he puts on the respirator. This may be done by following the manufacturer's facepiece fitting instructions.