Zach Snow is manager of shooting promotions for the National Shooting Sports Foundation. Among his responsibilities are acting as NSSF’s liaison to the shooting range community and servicing the needs of range members of NSSF. He supervises NSSF’s seminars and workshops for ranges and has coordinated the development of the NSSF Range Compliance Consultant Program.
Are you prepared for that unexpected visit? This new NSSF member benefit can help!
Has your range business received a visit from a regulatory agency such as the Environmental Protection Agency (EPA) or the Occupational Safety and Health Administration (OSHA)? If not, the first question you need to ask yourself is, “Are we prepared for an unexpected visit?” The old-school thinking as a range owner or operator is one that in many ways needs to change. Now, more than ever, ranges need to change the mentality from “if they come” to “when they come.”
Over the last year I have fielded an increased number of calls and emails regarding scenarios of ranges dealing with OSHA. For many it’s a moment of panic and fear that they have not been doing what is required to stay compliant. As a business owner, you have only one valid approach if you wish to avoid experiencing that panic and fear: be proactive, so “when they come” you and your staff are prepared.
The increased number of OSHA fines issued to indoor ranges, combined with the inquiries we’re receiving from ranges dealing with OSHA, prompted the launch of NSSF’s Lead Management & OSHA Compliance training workshops. To date, three workshops have been held in cities across the country, including St. Louis, Mo., Atlanta, Ga., and Delaware, Ohio. The plan is to hold at least two more in the fall and winter. The positive feedback from the 150-plus attendees has proven the value of this workshop. It’s one that all indoor range owners and operators should attend. However, the wealth of information attendees take home with them, along with their list of changes that some need to make, can be a bit overwhelming.
NSSF commends the indoor range businesses that are stepping up to the plate to address this hot topic. Gaining more knowledge on the regulatory requirements and taking corrective action to implement programs required by OSHA protects and ensures a bright future for your business. To further assist indoor ranges with this intimidating task, NSSF has created a Range Compliance Consultant Program.
Similar to NSSF’s FFL Compliance Program, this compliance program offers guidance from advisors who will perform an on-site mock OSHA audit.
Erica Moncayo brings her MBA education and position as an OSHA-authorized General Industry trainer and her five-plus years of experience in addressing and abating OSHA citations, through which she saved her clients more than $100,000 in fines. Moncayo was instrumental in assisting the New Mexico Department of Health in creating a brochure published in NIOSH E-news in advocacy of advising the public about the hazards of lead in the indoor shooting range industry.
Upon the completion of the mock audit of your indoor range and retail business, you can expect to receive the following Health and Safety Programs within 30 days. These programs are custom-written plans specific to each participating indoor range after the mock audit has been performed.
- Hearing Conservation Program
- Respirator Program
- Personal Protective Equipment (PPE) Program
- Hazardous Communication Program
- Lead Management Program
- Medical Surveillance Program (assistance with setting up a contractor to obtain blood lead levels, audiograms and respirator fit tests, all of which are significant items in completion of the programs)
- Standard Operating Procedures
- General Industry (to include, but not limited to, slips, trips and falls, First Aid, Emergency Actions Plans)
- Employee training upon delivery of all programs
NSSF covers 50 percent of the cost associated with this program, so an OSHA mock audit only costs the indoor range member $2,500. Keep in mind that $2,500 is the smallest fine you could potentially receive from OSHA if or when they come knocking and you’re not prepared.
To take advantage of this program ranges will need to have attended one of the NSSF Lead Management & OSHA Compliance Workshops or must be registered for an upcoming workshop. Exceptions to this rule will be reviewed and determined on a case by case scenario. In the event that multiple ranges are requesting assistance through this program, those who have attended a workshop will receive top priority in scheduling. For more information on the program or to schedule an in-store and range OSHA mock audit please contact Zach Snow at 203-426-1320 or by email firstname.lastname@example.org
As you ponder whether you’re prepared for that unexpected visit, remember that NSSF is here to help. If you have doubts about your compliance, then you need to take advantage of these resources. Become more educated by attending NSSF’s next Lead Management & OSHA Compliance Workshop. Utilize the team of experts through NSSF’s Range Compliance Consultant Program. The ball is in your court. Now is the time to act.