Indoor Firing Ranges and OSHA Compliance Part One – Lead

firing-range

Indoor firing ranges have been visited by OSHA recently under the National Emphasis Program for Lead.  Firing ranges and gun clubs generally fall under SIC Codes 7997 and 7999.  Both codes are listed in the National Emphasis Program.

Many gun club and firing ranges are small businesses without full time safety managers and their owners are not familiar with OSHA regulations required for their businesses. We have received many phone calls from concerned firing range owners in the past six months so I want to use this post to outline some basic OSHA compliance requirements that may apply to your business.

Lead

The first OSHA compliance issue that I will discuss is the OSHA Lead Standard.  The General Industry Standard 1910.1025 applies to firing ranges/shooting ranges and gun clubs.  The Lead Standard is exposure driven, which means that certain parts of the standard apply if employee exposure levels exceed either the OSHA Action Level (AL) of 30 ug/m3 or the OSHA Permissible Exposure Level (PEL) of 50 ug/m3.  You can think of the Action Level as the level at which you are required by law to take action.  Certain parts of the standard will kick in at this level but others will not.  Virtually the entire standard will apply if employee exposure levels reach the PEL.  In order to determine employee exposures, you need to do air sampling for lead.  Sampling should be conducted for multiple job tasks, but at a minimum, on workers who enter the range, perform cleaning activities in the range, and those who change out HVAC filters.

Once you conduct your sampling and receive your results you should do the following:

  1. Notify employees of their results.  This includes employees that do the same tasks that were not monitored.  The best way to handle this is to have a short team meeting to present and explain the results and have employees sign a summary of the sampling results to show that they received them.
  2. Determine compliance requirements based on the sample results, and implement these requirements.

Compliance requirements will fall under three categories, results less than the Action Level, results at or above the Action Level but below the PEL, and results at or above the PEL.

What You Have to Do When Lead Results are Below the AL

  • Train employees on Appendix A & B of the Lead Standard
  • Resample periodically to ensure that levels are below AL and PEL.  This is especially important if you have changes in the range (ventilation, number of ranges, etc.).
  • Personal protective equipment should be provided if necessary (disposable gloves and clothing if employees are exposed to lead dust during cleaning or changing of HVAC filters).
  • Follow good housekeeping procedures-HEPA vacuuming, etc. Dry sweeping and compressed air are not allowed for cleaning of lead dust.  Lead waste should be placed in sealed bags and disposed of based on state environmental requirements.

What You Have to do When Lead Results at or are Above the AL but less than the PEL

  • Train employees on Appendix A & of the Lead Standard
  • Resample for lead every six months.
  • Personal protective equipment should be provided if necessary (disposable gloves and clothing if employees are exposed to lead dust during cleaning or changing of HVAC filters).
  • Respirators should be provided if requested.
  • Medical Surveillance is required, and medical removal provisions apply if employees have elevated blood lead levels.
  • Follow good housekeeping procedures-HEPA vacuuming, etc. Dry sweeping and compressed air are not allowed for cleaning of lead dust.  Lead waste should be placed in sealed bags and disposed of based on state environmental requirements.

What You Have to do When Lead Results are at or Above the PEL

  • Train employees on Appendix A & of the Lead Standard
  • Resample for lead every three months.
  • Implement a lead compliance program to help reduce lead exposures in the workplace.
  • Personal protective equipment must be worn (disposable gloves and clothing and respirators).
  • Change facilities with showers must be provided and employees cannot wear lead contaminated clothing home.
  • Hand washing facilities and separate lunch rooms must be provided to ensure that employees do not accidentally ingest lead.
  • Medical Surveillance is required, and medical removal provisions apply if employees have elevated blood lead levels.
  • Follow good housekeeping procedures-HEPA vacuuming, etc. Dry sweeping and compressed air are not allowed for cleaning of lead dust.  Lead waste should be placed in sealed bags and disposed of based on state environmental requirements.

Additional safety and health resources for indoor firing ranges:

NIOSH indoor firing range page

NIOSH Workplace Solutions for Firing Ranges

If you need additional help with lead requirements for your firing range, contact us.

In Part Two of this blog post I will discuss other OSHA compliance issues which apply to firing ranges.

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