In the previous post, I discussed the OSHA National Emphasis Program on Lead and how it has been applied frequently to indoor firing ranges recently. These targeted inspections have caught many small business owners of firing ranges by surprise since many of these owners have very little experience with or knowledge of OSHA regulations. In this post I will discuss other common OSHA compliance issues that apply to firing ranges. These are all issues that are fair game once OSHA arrives at your facility.
The majority of OSHA inspections at firing ranges and gun clubs result from the National Emphasis program on lead. These are unannounced inspections. During an OSHA inspection, the compliance officer will tour the facility, review programs and records, interview employees, and may take pictures, video, and air samples. Being prepared for an inspection will result in a much better outcome if OSHA does visit your facility. The following are some compliance issues that generally affect firing ranges and gun clubs, although other standards may also apply based on your facility.
- Lead –See previous post.
- Noise Exposure-Noise sampling should be conducted to determine if noise levels are above 85 dB as an eight hour time weighted average. If they are, baseline and annual audiometric testing should be performed and hearing protection should be provided for employees. A hearing conservation program must also be implemented if noise results are 85 dB or greater.
- OSHA Recordkeeping-Your facility is required to keep OSHA logs if you had 10 or more employees at any time last year. This includes part-time employees and generally includes temporary employees as well. See OSHA’s recordkeeping page for more information and download the forms here. OSHA will ask to review the past 3-5 years of OSHA logs plus the current year. If there are no injuries for the year, you still need to complete the form. Just fill out the form and zero out the totals. Remember to post the 300 A summary form from February 1-April 30 each year.
- OSHA Poster– the OSHA poster should be posted in a conspicuous place (such as a break room) at the work site where employees can review it.
- Emergency Action Plan-You need to ensure that all of your exits are unlocked while the building is occupied, that exit signs are in place, and that exits and exit routes remain unblocked. You should develop an emergency action plan to address potential workplace emergencies. This OSHA E-Tool will assist you in developing your emergency action plan.
- Fire extinguishers-Fire extinguishers should be properly maintained and inspected, and should not be blocked. Employees should have a basic understanding of how to use fire extinguishers. Hands-on training is required if employees are required to use them as part of their job duties.
- Electrical Safety-Ensure that basic electrical safety rules are followed. Common OSHA violations are for things like missing ground pins, broken outlet covers, overloaded circuits, extension cords used as permanent wiring, missing blanks in unused openings in panel boxes, and unlabeled panel boxes. Make sure your business corrects any electrical safety hazards.
- Personal Protective Equipment -OSHA requires employers to do a PPE Hazard Assessment to determine what PPE is needed for each task performed at the facility. A written certification of this assessment must be maintained. Employees must also be trained on the limitations of PPE, how to wear it, take it on and off, care for it, inspect it and use it.
- Hazard Communication-OSHA requires employers whose employees use chemicals in the workplace to have a written hazard communication program. Safety Data Sheets (formerly called material safety data sheets) and a list of chemicals must be maintained for all chemicals in the workplace. All chemicals must be labeled. Recent changes to this standard will change many of the requirements including training, MSDSs, labels, and other compliance issues. For more information see our post on GHS and Hazcom.
- Accident Reporting and First Aid-Employees should be trained on accident reporting procedures. First aid supplies should be maintained on site and if there is no medical facility or EMS station that can provide emergency care in close proximity (OSHA has defined this as 3-4 minutes away), employees should be trained to render first aid.
- General safety or orientation training should be provided for your employees. The training should cover basic OSHA requirements like accident reporting, PPE, first aid, emergency action plans, fire extinguishers, electrical safety, hazard communication, noise, and lead. Other topics may also be required based on your facility.
If you need additional help with OSHA compliance for your firing range, contact us.