OSHA Compliance

Critical Gun Range Operational and Waste Management Requirements – Discussion with Nationally Recognized Experts to Take the Worry Out of OSHA Compliance for Your Firing Range. 

Meet Dale Krupinski:
CIH, CSP OSHA/Health & Safety
MT2 Firing Range Services

Qualifications Summary Mr. Krupinski is a former OSHA inspector now focused on assisting ranges in achieving full OSHA compliance. He has nearly 20 years’ safety and health management experience for lead/metals and firing range operations. Areas of expertise include OSHA compliance assessments, training, and program development in areas, such as but not limited to: air, ventilation, occupational noise, lead dust management, personal protective equipment, respiratory protection, confined spaces, lockout/tagout, machine guarding, electrical safety, and toxic/hazardous substances exposure monitoring. Dale’s combined OSHA Program familiarity from the inside and his extensive experience in supporting ranges to establish OSHA and safety compliant programs as well as his support to ranges undergoing OSHA actions makes him a highly sought-after expert.  

Range Guru: So we’d like to welcome this wide variety of range owners, managers and those associated with range operations to this training. MT2 is really pleased to be able to host this with two of the nation’s leading experts. First of all hear from Dale Krupinski who is a CIH and CSP. Dale is a former OSHA inspector, now focused on assisting ranges and achieving full OSHA compliance. He has nearly 20 years of safety and health management experience for lead and metals and fire range operations and Dale’s a critical component of our offering to the fire range industry.

Following that, Robert Anderson who’s our Vice President for Range Operation Services will speak on the RCRA. Mr. Anderson has 20 years direct hands on experience, managing a wide range and variety of hazardous ways, specifically in implementing RCRA programs at over 1,000 ranges from coast to coast and in nearly all 50 states.

And the nice thing about that is his extensive hazardous waste experience includes handling over a million tons of lead-impacted fire range waste from regular maintenance to cleaning, filters, maintenance, remediation and closure as well as the ability to professionally handle over three millions pounds of recycled lead, all without any compliance issues. So I think we assembled a very top notch panel. We look forward to receiving your questions.

MT2 Firing Range Services is recognized industry-wide for being the nation’s number one largest professional provider of full scale outdoor and indoor range cleaning, environmental maintenance, construction, design build services. We have an extensive network through our nation-wide offices with dedicated regional crews which allow us to serve clients in all 50 states through our regional offices.

So, let’s get started with the panel discussion, Dale Krupinski.

Dale Krupinski: I’d first like to start out with noise hazards. I think we all realize as we age, we lose our hearing. And this is a loudness issue that can be corrected simply by adjusting your hearing aid and turning the volume up. In contrast, noise-induced hearing loss is a clarity issue. Okay? So you have damage to your inner ear to the point where you cannot perceive certain frequencies and you won’t get the message correctly. So hopefully, this illustration is a great example of clarity issues, associated with noise-induced hearing loss.

And what happens is  noise is funneled in from the outer ear. Those vibrations are transferred to the snail-like organ here on the inner ear called the cochlea. If you look at the cochlea, a healthy ear of a 76 year old man will have all these little hairs that line the inner linings of the cochlea as a corkscrew to the center. These hairs pick up frequencies from high frequencies in the very beginning to low frequencies at the very end. So, when you’re exposed to massive amounts of noise and high noise levels, it will look something like this 59 year old man’s ear.

If you look closely, there’s a range here without the hairs. Okay? Temporary noise exposure, the hairs lay down, you may get your ears that ring and they can go back and adjust. But, time after time of repeat exposure or really excessive exposure, it will kill off those hairs and they will be destroyed. And consequently, you will not be able to kick up those frequencies. And this illustration of the 59 year old man, these are higher frequencies, associated with consonants.

So if you can’t pick up consonants, you won’t be able to recognize speech and have a very difficult time understanding speech later on in life. And again, hearing aids cannot rectify this issue. Turning up the volume will not help this issue. You’ve lost those frequencies forever.

Noise-induced hearing loss is a 100% permanent but it is preventable, fortunately. It causes no pain, doesn’t really leave any scars. It’s hard to detect in earlier stages. And when combined with a ototoxin like lead, your risk of hearing loss is greatly increased. So lead actually makes the risk quite a bit more in combination with high noise environments.

So, federal OSHA regulates noise under 29 CFR 1910.95. This is an exposure-driven standard and requires exposure monitoring. And you’re going to need this monitoring to figure out to what extent the standard applies to you and make a determination of whether or not your hearing protection is adequate. And you can’t make those decisions without having the exposure date.

So, if you’re over the Hearing Conservation Level of 85 decibels on a eight hour time weighted average, so you’d leave a meter on the worker for the entire day and if the average comes out to be 85 or over, then you’re triggered to have a written program, a initial annual training with hearing tests and you need to provide a selection of plugs and muffs for employees to use.

If you’re over the permissible Exposure Limit or PEL of 90 decibels for an eight hour time weighted average, hearing protection is required and you also need to implement administrative controls such as worker rotations to reduce the time on the range or engineering controls such as sound-absorbing materials lining your range or maybe watching the range. Rather than sitting on a chair behind the firing line, you can watch it in a control tower or from a viewing room to minimize the range time.

As I mentioned before, you’re allowed to be exposed to 90 decibels for eight hours. That’s what this table illustrates here at the very top. If you look closely at the table, your allowable exposure time will have as the volume goes up in increments of five decibels. So again, 90 is for eight hours, 95 is for four hours of allowable exposure time. 100 is for two hours et cetera.

This can get a little tricky because often your range staff may not work exactly eight, six or four hours. So what do you do? I personally think it’s easier to use noise dose. And when you’re looking at dose, consider this. You’re allowed to be exposed to a 100% dose in a given day. Okay? You may get that dose in an hour if it’s super loud or you may get it in 12 hours. You’re allowed to be exposed to a 100% dose in the given day.

And a 100% dose is equal to 90 decibels over eight hour time weighted average. So it’s equal to the PEL. 50% dose is equal to the hearing conversation of 85 decibels averaged over an eight hour. Like I said, I introduced this concept of dose because I personally think it’s easier to look at it from a dose standpoint. So when you’re reporting it to your managers or you’re communicating to the workers, keep 100% dose in mind.

When you record dose via a noise dosimeter here that I’ve shown you, the microphone portion clips onto the lapel or the worker. The box hangs from the waist. It sits there all day and at the end of the day, I would come out there and read the readings within the box and I’ll tell you that day whether or not you’re above or below the OSHA allowable limits.

So now, I’d like to switch gears and take a look at lead. The two primary routes for lead exposure are inhalation and then ingestion. Okay? So I want to make a special note of that little pile of yellowish orangeish dust next to the dime. Hopefully you all can see that. That’s about 500 micrograms of lead oxide. So 500 micrograms of lead oxide. It will fit nicely on Roosevelt’s nose. Let’s keep that quantity in mind as we go forward with talking about lead.

The hazards of lead have been known since ancient Greek times, both short-term exposure and long-term exposure can harm the human body. Short-term exposure at high concentrations like a torch cutting a metal trap could cause seizures, coma and even death. Long-term exposure will affect the central nervous system. It often will manifest itself in wrist drop or a foot drop. It can also affect kidneys, reproductive systems and blood-forming systems. And again, lead is considered to be an ototoxin and will accelerate the risk of noise-induced hearing loss.

And lastly, the IARC folks listed lead as a probable carcinogen to humans. So those are some of the hazards that are commonly known and accepted with lead exposure. Federal OSHA regulates lead using two different standards. So the normal range operations will be covered by 29 CFR 1910.1025. If you’re doing range lead reclamation or decommissioning, it will be covered by OSHA’s construction standard under 1926.62. Both these standards are exposure-data driven, just like noise. You’re required to collect the exposure monitoring data to figure to what extent the rules and regulations apply to you plus you want to use that to evaluate your control. So exposure monitoring is critical.

If you’re below the action level, you’re going to have minimum requirements such as keeping surfaces clean and providing two appendices to your workforce. Appendix A is a hazard fact sheet on lead, talking about the hazards of lead. And Appendix B explains the OSHA standard more in a plain language point of view compared to the actual written standard itself.

If you’re over the action level of 30 micrograms of lead per cubic meter of air, measured on a eight hour time weighted average, that’s going to trigger training, medical surveillance and a semi-annual exposure monitoring.

If you’re over the Permissible Exposure Limit or PEL of 50 micrograms per cubic meter of air, measured on a eight hour time weighted average, the entire standard applies to you. Specifically, you need to label your range as a dangerous lead hazard as you see on this photo here plus you’ll need to add showers and change rooms and monitor lead exposures on a quarterly basis. The standard does speak to surface contamination. Unfortunately, all that the standard says is that services shall be maintained as free as practicable of lead accumulations.

So what does this mean?

DOWNLOAD YOUR FREE COPY OF THE INDUSTRY REPORT:

“The Firing Range Owner’s Guide to Never Generating Lead Hazardous Waste! 6 Important Facts a Firing Range Must Consider Before Hiring a Lead Reclamation & Cleanup Company.”