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June 9, 2021
Making Sense of the Compliance Puzzle with Dale Krupinski & Jason Smith
Start talking about compliance, and almost every range operator and retailer immediately thinks about ATF Form 4473, bound books and waiting periods. There’s another type of compliance, however, that many people overlook until it gets them into trouble: OSHA and EPA regulations, waste management and lead management. Complying with these regulations requires shooting range owners and operators to understand federal requirements as well as variations in state requirements.
Knowledge is Power – Be Prepared
At the 2021 NSSF Range-Retailer Business ExpoTM, attendees will have the opportunity to attend three sessions on compliance. One session, “OSHA Compliance Connection Part 1,” will provide information about the Occupational Safety & Health Administration, its inspection process, common range violations and the range’s rights and responsibilities. The “OSHA Compliance Connection Part 2” session will address lead and noise management for shooting ranges. And the “EPA Compliance Connection” session will discuss complying with the Resource Conservation and Recovery Act’s hazardous waste requirements, federal requirements and the variations in state requirements.
Mitch Tyler, owner of SafeSide Tactical in Lynchburg and Roanoke, Va., said that even though most FFLs are aware of ATF regulations, the regulations from OSHA, EPA and some of the state agencies are just as important.
“The ATF has the most in black and white,” Mitch said. “You operate under their compliance guidelines and they do an inspection every two years, you get feedback from them, and you do better the next time. From what we hear about how OSHA works, it’s not as much a ‘Hey, let’s improve this area’ sort of approach. It’s much more punitive.”
For instance, Mitch said, these agencies can impose fines for civil liability or criminal liability. In addition, items that may be addressed by OSHA or EPA are not always entirely clear.
“It seems like there are a lot of unknowns on the waste and the OSHA regulatory sides,” he said. “I think that anyone who’s getting into the industry or even who’s been in it for nine years like I have will get something out of these sessions.”
The value of the sessions, Mitch said, likely will cover the cost of the whole event for him.
“That means one $10,000 fine that I don’t have to get,” he said, “because I heard someone explain it better this time than I did six years ago. That makes the event cost of getting four of us down there and in a hotel for a few days look really small. It’s an investment in the future of our business that we will gain from attending and that we’re going to take back and implement quickly and thoroughly. Then, when and if the time comes that we have an OSHA investigation, that part will be set.”
Tracy Fornwalt, Partner at Morr Indoor Range in Lancaster, Pa., said that understanding the regulations imposed by these agencies is an incredibly important part of the business.
“We need to make sure that we’re following all the right practices and staying in compliance,” she said. “Any education on this topic is very helpful.”
Tom Hudson, owner of CrossRoads Shooting Sports in Johnston, Iowa, called OHSA and EPA compliance a “black hole.”
“To try to understand and navigate those regulations on your own in our industry is virtually impossible,” he said. “If we were some type of manufacturing plant, there would be a trade organization or other professional standards, or maybe industry certifications to work on. But we don’t have industry certifications that you can achieve to study that kind of material.”
If he were a property engineer, for instance, Tom said, or an industrial hygienist, he would have a path toward learning what he needed to know and then could apply it to his range.
“But we don’t have that in the shooting range industry,” he said. “You don’t know where to begin.” He said the NSSF does a great job of helping to frame out and sift through the minutia of what range owners need to know when organizing events such as the Range-Retailer Business Expo.
Although ATF will not be presenting a session at the Expo, attendees still will be able to get information about ATF compliance concerns. The NSSF is providing the ATF Miami Field Division with an exhibitor booth so they can connect with FFLs who are attending the Expo and address any questions they may have. One of NSSF’s FFL consultants—John Clark—will be attending the Expo as well, and he also can address ATF compliance questions that attendees may have.
OSHA Compliance Connection Part 1 — Is your range prepared for an OSHA inspection?
This seminar will take place at 11:15 a.m. on July 12. Dale Krupinski will cover citations that OSHA routinely issues to shooting ranges for health and safety violations, including penalties of more than $100,000 that they have issued recently to multiple ranges around the country. Attendees at this seminar will find out more about OSHA, their inspection process, common range violations and the range’s rights and responsibilities.
OSHA Compliance Connection Part 2 — Lead and Noise Management for Firing Ranges.
This seminar will take place on Tuesday, July 13, at 3:00 p.m. Dale Krupinski will talk about exposure assessments to both lead and noise for staff members. OSHA requires these assessments; it’s not enough to just hand out earmuffs and respirators. Attendees at this session will learn how best to manage their noise and lead responsibilities.
EPA Compliance Connection — Establishing a Hazardous Waste Disposal Plan.
This seminar will be on Monday, July 12, at 2:15 PM. Jason Smith will discuss how the Resource Conservation and Recovery Act (RCRA) requires range owners and operators to understand federal requirements for hazardous waste disposal, as well as variations in state requirements. Attendees will be able to review a state-by-state compliance matrix to help them identify state requirements and how they differ from federal requirements. The seminar will include strategies for effective waste management and required record keeping.
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NSSF’s Range-Retailer Business Expo will take place July 12-14 in West Palm Beach, Florida. The event will offer three days of high-quality education and networking opportunities, along with an exhibit hall full of vendors specific to your business. Learn more and register at nssf.org/expo.
https://www.nssf.org/expo-2021/
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