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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.
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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.
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