WA gun Ranges under attack, the new angle attacking 2A

[lamrith]

Just got an email from NRA-ILA outlining new proposed regs that will be damaging to Ranges here in WA.

The website version of the email is here:
https://www.nraila.org/articles/20170817/washington-department-of-labor-and-industries-targeting-shooting-ranges

I will say as a member of a local sportsman's club I can atest to this being a very real issue.  One local range was forced to remove a bench form firing line as well as paint all benches and must clean the benches constantly (I thought I heard daily).

[bearpaw]

http://www.lni.wa.gov/Safety/Rules/WhatsNew/LeadSafety/pdfs/LeadRuleFirstDraft170629.pdf

Washington: Department of Labor & Industries Targeting Shooting Ranges
 
At the request of Public Health, Seattle & King County, the Washington Department of Labor and Industries has released a “first draft” of a new statewide regulatory scheme targeting lead and lead exposure in the workplace. As drafted, these proposed regulations will impose complicated and expensive burdens on shooting ranges and retailers, potentially making it difficult for many to continue operations.

Shooting ranges are vital to the safe practice and exercise of our constitutionally protected Second Amendment right to self-defense, and maintaining access to shooting ranges is a top priority for NRA. To view the 50-page proposed regulations, click here: http://www.lni.wa.gov/Safety/Rules/WhatsNew/LeadSafety/pdfs/LeadRuleFirstDraft170629.pdf

Existing federal and state law already provides extensive regulation of lead in the workplace. In addition to the federal requirements under the Occupation Safety and Health Administration (OSHA), Washington also has regulations in place regarding workplace lead exposure and has enforced these regulations through inspections and citations. The 50-page draft regulation proposes new and much more demanding requirements that significantly exceed compliance under existing law without providing any clarification on the need for these additional requirements. Furthermore, there have been no economic impact studies on the effect these regulations will have on small businesses. 

Your NRA will continue to actively participate as a stakeholder in the development of these new rules in meetings with the Department of Labor and Industries and representatives from other industries. We will provide ongoing input on the impact the proposal will have on gun ranges, retailers, and our shooting community.  Please stay tuned to your email inbox and www.nraila.org for further updates on the status of the proposal.

[porcupine]

Worked in an industry for 30 years where I was required to get a yearly blood test for lead exposure and I NEVER had a report of an elevated level. Where's the documentation to support the problem they're trying to fix? A little hygiene after shooting, reloading, handling shooting supplies and firearms and before eating, smoking, and applying cosmetics should be part of our daily routine. There are a few folks at the ranges I shoot at that can't seem to shoot without having a cup of coffee at hand and as much as I see that as a bad habit. they are adults.

[Windwalker]

 
Thanks for the info-
Sent it to our local Club President.

[Blacklab]

Why doesn't this surprise me. Back door money grab. So very frustrating.

Thanks for the heads up.

[Knocker of rocks]

I will say as a member of a local sportsman's club I can atest to this being a very real issue.  One local range was forced to remove a bench form firing line as well as paint all benches and must clean the benches constantly (I thought I heard daily).

 
Thanks for the info-
Sent it to our local Club President.

As a L&I rule, it only applies to places of employment.  So any club which uses just volunteer club members as staffing would not be impacted.  But regardless of that, given the information becoming available regarding lead in shooting ranges, especially in door locations, any shooting range should take lead exposure very seriously.  Considering the removal of lead in ordinary life, it is a much easier task to find the vectors from which an over-exposed person received their lead poisoning.  In such cases, and even in the case of occupational over-exposure, it's not the long arm of the law that clubs and companies should be concerned about, but civil action instead.

 

Why doesn't this surprise me. Back door money grab. So very frustrating.

Thanks for the heads up.

I would disagree with that simple assessment vociferously.  First the Seattle Times detailed the issues at the Wades remodel, the watershed issues the EPA found and the health problems the ironworkers had developed.  That morphed into a full scale series.  Given the media actions and new environmental health studies in was inevitable that L&I would be involved.

http://projects.seattletimes.com/2014/loaded-with-lead/about/

None of this has a thing to do with the 2A

[Airnip]

This a paste from OSHA hazardous waste personal protection equipment guidelines.

Personal Monitoring
The selective monitoring of high-risk workers, i.e., those who are closest to the source of contaminant generation, is highly recommended.  This approach is based on the rationale that the probability of significant exposure varies directly with distance from the source.  If workers closest to the source are not significantly exposed, then all other workers are, presumably, also not significantly exposed and probably do not need to be monitored.

end paste

  I have to wonder if firing range employees are already being blood tested and found to have elevated lead levels?

  My understanding is as lead is heated it puts particulate air borne that could be inhaled. Propelled by gunpowder doubt lead pellets are separating a significant lead hazard in the breathing zone of a shooter.

  Cold lead is a health hazard if it is ingested. Maybe janitor type workers could use personal protective equipment beyond hand washing?
Depends on the threshold action level of measurable lead particulate in the dust being cleaned.

[Airnip]

   Might have read the Seattle Times article x5 to answer my questions. Thank you Knocker for that.

  Apparently built up accumulation of lead dust indoors in air and surfaces in dirty firing ranges is health hazard known to affect untrained unprotected employees and the public.

Pasted here is the lead action threshold:

   The permissible level of airborne lead for an employee over an 8-hour period is 50 micrograms per cubic meter (mcg/m3). The acceptable level of lead on surfaces in the workplace is 200 micrograms per square-foot (mcg/foot2).

   

   

[JLS]

http://projects.seattletimes.com/2014/loaded-with-lead/1/

http://o.seattletimes.nwsource.com/html/localnews/2020353191_gunrangeleadxml.html

Lead poisoning dangers due to shooting ranges are very real.

[lamrith]

As a L&I rule, it only applies to places of employment.  So any club which uses just volunteer club members as staffing would not be impacted.

This is a quote from another forum in regards to that situation:
"ETA to revise my YES statement... Part of that is NO. If an RO accepts any benefit from the club in lieu for RSO duties, then they are considered paid and are not exempt."
This means that doing RSO duties to lower your membership means you are employed.  This is something common at many clubs.



For those that may be part of a range or club with a range, please take note of the following and let your club owners/board know.  This is also pulled from another forum.

Renton Fish & Game Club discovered that if you contact L & I for a voluntary check they will come out, do all the appropriate testing, let you know what needs to be corrected, and won't cite you for issues.
At that point they cannot come back for a "random" evaluation for one year.

The trick is, that you call them before that year is up, then the same thing happens.
RFGC has been doing that for three years now and the last visit was a couple of hours with no issues to fix.

[Knocker of rocks]

This is a quote from another forum in regards to that situation:
"ETA to revise my YES statement... Part of that is NO. If an RO accepts any benefit from the club in lieu for RSO duties, then they are considered paid and are not exempt."
This means that doing RSO duties to lower your membership means you are employed.  This is something common at many clubs.

That is labor law, and may or may not be correct.  It depends on both Washington state law and IRS codes.

Renton Fish & Game Club discovered that if you contact L & I for a voluntary check they will come out, do all the appropriate testing, let you know what needs to be corrected, and won't cite you for issues.
At that point they cannot come back for a "random" evaluation for one year.

The trick is, that you call them before that year is up, then the same thing happens.
RFGC has been doing that for three years now and the last visit was a couple of hours with no issues to fix.

That is likely a misstatemnt.  There is nothing in the VPP that trumps the mandate that L&I has to protect employees in Washington thru RCW 49.17 or OSHA. http://www.lni.wa.gov/safety/GrantsPartnerships/Partnerships/VPP/default.asp

[lamrith]

This is a quote from another forum in regards to that situation:
"ETA to revise my YES statement... Part of that is NO. If an RO accepts any benefit from the club in lieu for RSO duties, then they are considered paid and are not exempt."
This means that doing RSO duties to lower your membership means you are employed.  This is something common at many clubs.

That is labor law, and may or may not be correct.  It depends on both Washington state law and IRS codes.

Renton Fish & Game Club discovered that if you contact L & I for a voluntary check they will come out, do all the appropriate testing, let you know what needs to be corrected, and won't cite you for issues.
At that point they cannot come back for a "random" evaluation for one year.

The trick is, that you call them before that year is up, then the same thing happens.
RFGC has been doing that for three years now and the last visit was a couple of hours with no issues to fix.

That is likely a misstatemnt.  There is nothing in the VPP that trumps the mandate that L&I has to protect employees in Washington thru RCW 49.17 or OSHA. http://www.lni.wa.gov/safety/GrantsPartnerships/Partnerships/VPP/default.asp

Not sure why you are nitpicking things.  I am trying to help keep people informed here.

The information I am sharing is direct from people involved with the operation of said ranges and have been involved in this situation, they are sharing information to help protect our access to these resources.

[Knocker of rocks]

Propelled by gunpowder doubt lead pellets are separating a significant lead hazard in the breathing zone of a shooter.

The bullets trip down the barrel is supposed to aerosolize some lead, as does the primer( I don't understand the chemistry behind this).  But the majority of the lead becomes airborne at the backstop and is spread by the HVAC system.  Workers on the roof are also endangered, many times not even knowing they're on the roof of a gun range.  But in all cases the mph of L&I is small compared to the civil liability of lead exposure, especially if kids are involved.

Many of the big manufacturers claim to have very effective air handling systems, so much of the problem is likely the result of simply not doing things the correct way.

[csaaphill]

There was another link on that page about what Kate Brown did 
But yeah seems like they can't get the regs they want they will make their own and price people out.

[Oh Mah]

maybe they should spend this time putting an end to the pesticide pollution's instead of attacking the fire arms industry every way they scheme too.