Q&A — 22 January 2014

Q&A: The Most Common Issue Cited by OSHA

Q. What is the most common issue or violation cited by OSHA for shooting ranges?

Hannah Niane, H-Marie Miller Associates LLC, Panama City, Fla.


A. In general, shooting ranges fall under the purview of general industry regulatory requirements that are enforced by the Occupational Safety and Health Administration (OSHA) under  Title 29 Federal Code of Federal Regulations (29 CFR) Part 1910. During fiscal year 2013 (October 1, 2012 through September 30, 2013), of the 10 most frequently cited standards, seven may pose potential risks in shooting ranges and therefore are citable during an OSHA inspection. The specific hazards and associated information follow:

  1. Hazard communication (29 CFR 1910.1200)
  2. Respiratory protection(29 CFR 1910.134)
  3. Electrical components and  wiring (29 CFR 1910.303) [related OSHA Safety and Health Topics page] and  (29 CFR 1910.305)
  4. Powered industrial trucks (forklifts) (29 CFR 1910.178)
  5. Machine guarding (29 CFR 1910.212)
  6. Lead exposure (www.osha.gov/SLTC/lead/index.html)
  7. Noise (29 CFR 1910.95)

Now, let us expand this list to include another potential hazard: falls from heights. It is reasonable to assume that employees may fall from heights when working from portable and fixed ladders. In evaluating the safe use of ladders in a shooting range, the range owner may wish to determine whether there exists a risk of employees falling from a ladder when performing such tasks as changing lighting and filters and/or adjusting target-retrieval rails. Think about it!

When conducting the job-hazard analysis for any tasks involving the use of either portable or fixed ladders, consider the integrity of the working surface and the requirement to carry materials while someone is ascending or descending the ladder. Would one use an unsupported portable ladder inside the shooting range where lead particulate on the floor may present slippery conditions? What about the employee who changes the filters from the air-handling unit housed on the roof of the building?

Range owners may use the following ladder safety checklist to verify employees are working safely when using ladders. For additional information on ladder safety, visit osha-lady.com.

Hannah Niane, alias OSHA Lady, is an entrepreneur and member of the National Shooting Sports Foundation Range Action Specialists team. Since 2008, Niane has provided expert guidance and training through her company, H-Marie Miller Associates LLC, which is located in Panama City, Fla. She has served on the panel of experts at NSSF Lead Management/OSHA Compliance Workshops. You can visit her website at www.osha-lady.com for additional product information and service.


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