Indoor Firing Ranges and OSHA Compliance Part Two

range

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.

  1. Lead –See previous post.
  2. 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.
  3. 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.
  4. 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.
  5. 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.
  6. 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.
  7. 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.
  8. 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.
  9. 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.
  10. 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.
  11. 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.

GHS and OSHA’s Revised Hazcom Standard: What You Need to Know

GHS Labeling

After all the talk, it’s finally here.  In this blog post I will discuss the revisions to OSHA’s Hazcom standard and how and when to comply.

GHS stands for “Globally Harmonized System”.  Developed by the United Nations, the idea was that how chemical information is handled needed to be standardized world-wide.  On March 26, 2012, OSHA published the revised Hazard Communication Standard, which is aligned with GHS Revision 3.  This final rule will take effect on May 25, 2012.

Major Changes in the Hazard Communication Standard include:

  1. Hazard classification: The revised standard provides specific criteria for classification of health and physical hazards, as well as classification of mixtures.
  2. Labeling: Chemical manufacturers and importers will be required to provide a label that includes a harmonized signal word, pictogram, and hazard statement for each hazard class and category. Precautionary statements must also be provided.
  3. Safety Data Sheets: Will now have a specified 16-section format and the name changes from Material Safety Data Sheet (MSDS) to Safety Data Sheet (SDS).
  4. Information and training: Employers are required to train workers by December 1, 2013 on the new labels elements and safety data sheets format to facilitate recognition and understanding

Let’s take a closer look at these changes.

Hazard Classification

Previously referred to as “hazard determination”, manufacturers and importers of chemicals are now required to perform hazard classification on their products.  In doing so, they must follow the requirements in Appendix A and B of the revised standard (both mandatory).  This is not a new requirement, but in the past this section of the standard was performance based, and it is now prescriptive.  This may mean that some companies will have to repeat this process in accordance with the guidance in Appendix A and B in order to be in compliance with the revised standard.   Employers are not required to classify chemicals unless they choose not to rely on the classification performed by the chemical manufacturer or importer for the chemical to satisfy this requirement.
Labeling

As of Dec. 1, 2015*, all labels will be required to have:

1. Pictograms
2. A signal word
3. Hazard and precautionary statements
4. The product identifier and supplier identification

*Employers have until June 1, 2016 to ensure that in-house labels have been updated.  All employees must be trained on new labeling requirements and pictograms by Dec. 1, 2013.  As of Dec. 1, 2015, manufacturers and importers may not ship products without the new labels.  Here’s an example of the new label:

Pictograms are mandatory to convey warnings to employees.  Here are the pictograms that you will need to incorporate into your labeling system and training program:
OSHA is requiring a red border on these pictograms so they will need to be printed in color.
Safety Data Sheets
Material Safety Data Sheets (MSDSs) become Safety Data Sheets (SDSs).  These new SDSs have a specific format, which must be followed to be compliant with the revised standard.

Section 1: Identification-includes product identifier; manufacturer or distributor name, address, phone number; emergency phone number; recommended use; restrictions on use.

Section 2: Hazard(s) identification-includes all hazards regarding the chemical; required label elements.

Section 3: Composition/information on ingredients-includes information on chemical ingredients; trade secret claims.

Section 4: First-aid measures-includes important symptoms/ effects, acute, delayed; required treatment.

Section 5: Fire-fighting measures-lists suitable extinguishing techniques, equipment; chemical hazards from fire.

Section 6: Accidental release measures-lists emergency procedures; protective equipment; proper methods of containment and cleanup.

Section 7: Handling and storage-lists precautions for safe handling and storage, including incompatibilities.

Section 8: Exposure controls/personal protection-lists OSHA’s Permissible Exposure Limits (PELs); Threshold Limit Values (TLVs); appropriate engineering controls; personal protective equipment (PPE).

Section 9: Physical and chemical properties-lists the chemical’s characteristics.

Section 10: Stability and reactivity-lists chemical stability and possibility of hazardous reactions.

Section 11: Toxicological information-includes routes of exposure; related symptoms, acute and chronic effects; numerical measures of toxicity.

Section 12: Ecological information

Section 13: Disposal considerations

Section 14: Transport information

Section 15: Regulatory information

Section 16: Other information-includes the date of preparation or last revision.

Note:  Since Sections 12-15 are enforced by other agencies, OSHA will not enforce these sections of the SDS.  Employees must be trained on the new SDS format by Dec. 1, 2013. New SDSs are required by June 1, 2015.

Written Program

Your written program must be revised to comply with the new standard including training, labeling, SDS management, and hazard classification.  Other updates may also be necessary if some of these required changed also change how you manage your Hazcom program.  Written programs must be updated  by June 1, 2016.

Other Hazcom Requirements

Other requirements of Hazcom stayed pretty much the same with the exception of some wording changes.  You can see the side-by-side comparison of the new standard and old standard here.

Summary

If you are an employer (that does not manufacture or import chemicals, but uses chemicals in the workplace), here’s what you need to do and when:

  1. Train employees on new labeling system, pictograms, and SDS format (by 12/1/13).
  2. Ensure that only new format SDSs are maintained (by 6/1/15).
  3. Ensure that products are not received without new labels (by 12/1/15).
  4. Update your labeling system using the new GHS system (by 6/1/16).
  5. Update your Hazcom program to reflect changes (by 6/1/16).
  6. Provide any additional training (such as updates to the Hazcom program-by 6/1/16).

If you manufacture or import chemicals, in addition to the above, you must also:

  1. Ensure that chemicals are properly classified according to the revised standard (by 6/1/15).
  2. Prepare SDSs in proper format (by 6/1/15).
  3. Prepare updated labels (cannot ship with old labels after Dec. 1, 2015.)