March 2014 Q&A — 05 March 2014

Q&A: How Has NSSF Membership Made Your Range Better?

Q. How have you used your NSSF membership to the betterment of your facility?

Jean Basore, Centerfire Shooting Sports, Olathe, Kan.

A. Centerfire Shooting Sports is a new range in Olathe, Kansas. When we found out about the First Shots program offered by NSSF we were very excited. This seemed like a great way to introduce new shooters to the sport as well as help introduce them to our new range. Tisma Juett was our contact at NSSF, and she provided us with a PowerPoint presentation, brochures, gift-bag items and ammunition for the class. To promote the event NSSF created a great video for our website. The video, along with in-store advertising, filled the First Shots class slots within weeks of announcing it. We held three First Shots Programs over a three-month period. All three events were very well received and most customers were asking, “What’s next?” Customer reviews after First Shots consistently stated they wanted more range time. That response helped us decide to do a First Shots Second Round class. The Second Round program was offered at a cost of $45 per person with Centerfire providing the guns, ammo, targets and range time. This was a complete sell-out. So many of the First Shots shooters have come back to our range to take other classes and become members that we view the program as a great success and are planning on offering First Shots again this spring. Continued thanks to all that NSSF does for it’s members.

Eric Stubbs II, Modern Outfitters, Meridian, Miss.

A. Modern Outfitters is a family-owned and -operated company, specializing in premium brands of outdoor apparel, firearms and shooting accessories. In addition to our retail store we have an indoor shooting range and custom rifle shop. We first joined NSSF after our initial trip to SHOT Show in 2010. We quickly realized that our industry was growing at a rapid rate, as were regulations to keep indoor shooting facilities safe and clean for both recreational shooters and staff. We attended the Lead Management and OSHA Compliance Seminar in St. Louis last fall. The caliber of knowledge and expertise in the meetings were unparalleled. To have the opportunity to interact with actual, former OSHA and EPA auditors and legal counsel was invaluable. My wife and I were also able to make some other important business contacts that aided us in the reclamation of brass and lead at our range. Other benefits of the workshop included the preparation of our company’s standard operating procedures and lead-management standards. Aside from the conference we enjoyed meeting and dining with other range owners from around the country; we shared ideas, strategies and changes for the future. I would recommend any range, firearms retailer or anyone in this particular industry join the NSSF and attend whatever sponsored functions fit their particular company.

Jack Thurmon, Nardis Gun Club, San Antonio, Texas

A. Nardis Gun Club in San Antonio had been open for just over a year when an OSHA field agent dropped in for an inspection. Though we’d been in other businesses for more than 40 years, we had never been visited or even contacted by OSHA. Even though we had no record of injuries or deaths, we found that our indoor range was on their target list. At the time we received no citations nor indication of any significant problems.  We were told it was a “random” inspection, but they later told us they had received directives from Washington to focus on industries with lead exposures and were provided a list of such businesses, which included our new indoor gun range.

The OSHA visit occurred about the same time that NSSF announced its new “Range Compliance Consulting Program” and five weeks before NSSF’s scheduled Lead Management and OSHA Compliance Workshop in New Orleans. Two weeks before the seminar, OSHA charged us with 13 citations, all of them rated “Serious,” with proposed penalties of over $20,000.

At that time, we discovered the unique role of NSSF among trade associations.  The proactive and supportive role that NSSF offers its membership is invaluable in dealing with the regulatory issues faced by all gun ranges.  After attending the New Orleans seminar, we were grateful for an expedited visit by Erica Moncayo to give us an audit of our OSHA and EPA exposures, which was insightful and of great value, with NSSF covering half the cost.

To meet our OSHA challenge head-on, Zach Snow, NSSF Manager, Shooting Promotions, offered additional assistance by referring and sharing the costs of the Environmental Regulatory Practice Group of the McNair Law Firm.   The firm is a true specialist in this arena and partners with NSSF in managing an aggressive defense against this regulatory threat.

Most of the citations brought against us were, in my opinion, from the nebulous to the ridiculous. The “serious” classifications made them much more onerous because of the implications that classification has with future exposures.   Ethan Ware and Kip McAlister of the McNair Firm were intensely engaged in researching and tackling each of the OSHA allegations.  They repeatedly negotiated each point with OSHA, in person and by phone.  They reduced the 13 citations to six, with only two retaining the “Serious” label, and the penalties were reduced by over 60 percent to $8,000.  Greater relief may have been available through litigation, but we couldn’t justify that risk.

The legal resources available through NSSF encouraged us to engage a rigorous defense against the citations, which appeared to be arbitrary.  While we dealt with a government agency with unlimited regulatory power, NSSF helped us level the playing field. NSSF’s contribution to the stability of our gun range is greatly appreciated.

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