SHOOTING RANGE

Objectives, Intended Use and Limitations

The purpose of this checklist is to assist range owners and operators with creating a Hearing Conservation Program (HCP) that will both protect your employees and pass an OSHA audit per 29 Code of Federal Regulations (CFR) Part 1910.95.

If a shooting range has any employee ON RANGE during live gunfire, an HCP is mandatory. Typical affected employees are Range Safety Officers (RSOs), shooting instructors, maintenance personnel, etc. This checklist will assist in documenting both ON RANGE and OFF RANGE exposures, but assumes that OFF RANGE exposures are below the ACTION LEVEL of 85 dBA (8-hr Time-weighted Average). If your shooting range has OFF RANGE exposures >85 dBA (peak), structural deficiencies exist that require corrective action beyond the scope of this checklist. In this scenario, seek help immediately.

This checklist is designed around the NSSF Hearing Conservation Program template Version 2018-A. The template has been pre-loaded with the necessary data to effectively protect your ON RANGE employees and document this protection. No new, site-specific ON RANGE noise measurements are required. We know enough about gunfire noise to prescribe the maximum practical hearing protection – dual ear protection consisting of ear plugs with a minimum Noise Reduction Rating (NRR) of 32 and ear muffs with a minimum NRR of 34. Double ear protection (personal protective equipment or PPE) is required to reduce peak sound pressure levels from 170 decibels A-weighted (dBA) to <140 dBA (the maximum peak exposure level). This level of PPE also serves the purpose of mitigating exposure to average sound pressure levels (128 dBA) for indoor ranges published by the National Institute of Occupational Health and Safety (NIOSH). The multiple case studies performed by NIOSH generated a range of average exposures between

124 dBA and 128 dBA. The upper limit is used for the basis of Administrative Controls (maximum amount of time an employee can spend ON RANGE). Justifying the use of the lower limit is expensive and not recommended.

The NSSF template developed for use with this checklist includes calculations of hearing protection effectiveness for PPE with NRRs of 32 - 34. OSHA 1910.95 Appendix B specifies adjustments to NRRs under the assumption that the average employee doesn’t know how to properly insert an ear plug or wear ear muffs. These mandatory adjustments to NRR’s significantly impact the amount of time RSO’s and instructors can spend ON RANGE in any 24-hour period. The practical limit is about 4 hours. It is possible to improve on this limitation, with the best option working with a qualified professional to generate employee-specific Personal NRR’s not subject to mandatory NRR reductions. This approach may be especially useful for high-end electronic ear muffs that have a very low NRR due to poor protection against low frequencies, but very strong actual NRR’s in the frequencies associated with gunfire noise. Electronic ear muffs can be very useful when voice communication is required ON RANGE. However, this approach is not addressed in this checklist and associated templates – and without personal NRR’s that are employee specific, hearing PPE selections must be based on device-specific NRR’s with mandatory adjustments per OSHA 1910.95 Appendix B.

SHOOTING RANGE HEARING CONSERVATION CHECKLIST

HCP REQUIREMENTS

1. Create a written HCP document a. Written, Site-Specific Information and Policies (NSSF HCP Template Version 2018-A) i. Attachments - Monitoring Data --Published NIOSH Data for ON RANGE exposures --Site-specific OFF RANGE measurements - Calculated Employee Exposure Level - List of Approved hearing PPE - Training Log

2. Measure OFF RANGE noise levels and document

3. Calculate Employee Exposure Level a. This is done for you

4. Provide audiometric testing for ON RANGE employees

5. Train employees a. Includes posting OSHA 1910.95 (use the poster)

6. Keep records

STEPS TO CREATE AN HCP

1. Materials a. 3-ring Binder with Tabbed Dividers i. Tab 1: Range-Specific, Written HCP - Use NSSF HCP template Version 2018-A. ii. Tab 2: Exposure Measurements - NIOSH Data for ON RANGE Exposures - OFF RANGE Measurements iii. Tab 3: Calculated Employee Exposure Level iv. Tab 4: List of Available Personal Protective Equipment v. Tab 5: Employee Log - List of employees, employment dates, training dates, testing dates vi. Tab 6: Fit Testing Documentation (if applicable)

b. Copy of 1910.95

c. Cell Phone with sound meter app for OFF RANGE screening

2. Create the written HCP a. Using NSSF template i. TAB 1: Fill in the Company Name where appropriate and location the HCP will be located (same area

as Lead Management Plan, Safety Plan, etc.) + date HCP created ii. Monitor Noise

1. Using ATTACHMENT A (TAB 2) for Documentation: a. Use a cell phone with a sound level meter app to screen OFF RANGE areas adjacent

to the range. If any measurement is =/> 85 dBA – seek help from a qualified professional immediately (such as a Certified Industrial Hygienist with experience in noise or an audio engineer). OFF RANGE noise with peak levels =/> 85 dBA means there is something wrong with your building that is allowing noise to escape in to areas occupied by unprotected employees/customers.

2. The cell phone is for screening only. If you get a reading of 85 dBA OFF RANGE, the next step is to create an 8-hour TWA – and that will require professional assistance.

iii. Using TAB 4 (Attachment C) for guidance 1. Find at least 2 ear muffs with NRR of at least 34 and two ear plugs with NRR of at least 32 and

make available to your ON RANGE employees at no cost

iv. Using TAB 5 (Attachment D) 1. Create a list of ON RANGE employees and provide online training and document date of

training. Keep training certificate in the employee file. 2. For each ON RANGE employee, send to professional audiometric testing provider for baseline

testing (and annually thereafter – no more than a year later) a. Maintain audiometric testing report in CONFIDENTIAL employee folder b. Keep records for duration of employment and for 2 years after last date of employment

v. Post a copy of OSHA 1910.95 in the employee notification area

ON RANGE1

The National Institute for Occupational Safety and Health (NIOSH) received an employee request for a health hazard evaluation of a Special Weapons Assault Team (SWAT) in January 2002. The department was concerned about noise exposures and potential hearing damage from weapons training on their indoor and outdoor firing ranges. NIOSH investigators conducted noise sampling with an acoustic mannequin head and 1/4 -inch microphone to characterize the noise exposures that officers might experience during small arms qualification and training when wearing a variety of hearing protection devices provided by the department. The peak sound pressure levels for the various weapons ranged from 156 to 170 decibels (dB SPL), which are greater than the recommended allowable 140 dB SPL exposure guideline from NIOSH. The earplugs, ear muffs, and customized SWAT team hearing protectors provided between 25 and 35 dB of peak reduction2. Double hearing protection (plugs plus muffs) added 15-20 dB of peak reduction2.

William J. Murphy & Randy L. Tubbs (2007) Assessment of Noise Exposure for Indoor and Outdoor Firing Ranges, Journal of Occupational and Environmental Hygiene, 4:9, 688-697, DOI: 10.1080/15459620701537390

NIOSH investigators conducted live-fire noise exposure evaluations [Kardous et al. 2003; NIOSH 2003; Murphy 2007] of Federal and local law enforcement officers at indoor and outdoor firing ranges to characterize salient acoustic parameters associated with weapons noise and to provide guidelines for safe exposure (Figure 3). Measurements were conducted on a representative cross section of law enforcement firearms (the Beretta .40-caliber pistol, Remington 12-gauge shotgun, and Bushmaster M4 .223-caliber assault rifle). Indoor and outdoor measurements were also obtained for the Smith and Wesson .357-caliber revolver, the Colt .45-caliber and 9-mm pistols, the Glock .40-caliber pistol, the Heckler & Koch H&K 53 and H&K 36 assault rifles, and Colt AR15 .223-caliber rifles. Measurements were conducted using a ¼-inch Bruel & Kjaer model 4136 microphone, digital audio tape recorders with a 48 kHz sampling rate or were acquired directly to a computer laptop using 96 kHz data acquisition board. Analyses on the digitized waveforms were conducted using software tools built in Matlab. Peak sound pressure levels ranged from 155–168 dB SPL. Figure 4 shows the peak sound pressure levels generated from various weapons at an indoor firing ranges. A-weighted, equivalent (averaged) levels ranged from 124–128 dBA. Hearing protectors were evaluated using the Institut de Saint-Louis (ISL) artificial head mannequin built specifically for measuring impact and impulse noise. Earmuffs with safety glasses had a peak reduction of 18 dB. The mean peak reduction for earmuffs was 26 dB, while earplugs alone provided a mean peak reduction of 24 dB. The mean peak reduction for the combined earmuff and earplugs was 44 dB2.

NIOSH recommended several noise abatement strategies and modifications to the firing range structure to reduce the transmission of airborne and structural borne sounds; the use of double-hearing protection to ensure maximum protection against impulsive noise, improper fitting and other incompatibility with other protective equipment; and the establishment of a hearing conservation program.

ATTACHMENT A: NOISE MONITORING DATA

1ON RANGE data published by the National Institute for Occupational Safety and Health (NIOSH) in lieu of site-specific data2NRR data may not be used without site-specific verification

Preventing Occupational Exposures to Lead and Noise at Indoor Firing Ranges DHHS (NIOSH) Publication No. 2009-136 This Alert presents five case reports that document lead and noise exposures of law enforcement officers and students. The Alert examines firing range operations, exposure assessment and control methods, existing regulations, and exposure standards and guidelines.

OFF RANGE

Area or Employee DurationSound Pres-sure Level (Peak)***

8-hr TWA Calculated or Measured****

Representative Employee* 8-hr Full Shift

Retail/Rental**

Office**

Storage Room**

*Measured by dosimeter

**Measured by sound level meter

***If peak SPL < 85 dBA, do not need to include employees exclusive to these areas in HCP; if peak SPL >/= 85 dBA, must calculate 8-hour TWA

****If 8-hour TWA < 85 dBA, do not need to include employees exclusive to these areas in HCP

Calculate Employee Exposure Level (OSHA 1910.95 Appendix A)

• D=100 C/To T is from Table G-16A§ For 128 dB = 0.041o D from Table A-1 = 50% dose for 85 TWA (Action Level)o 50 = 100 * (C/0.041)o C = 50/2439.02439 = 0.0205 hours = 1.23 minutes

Calculated Hearing Protection (OSHA 19105 Appendix B)

ATTACHMENT B: CALCULATED EMPLOYEE EXPOSURE LEVEL

[OSHA 1910.95] TABLE G-16 - PERMISSIBLE NOISE EXPOSURES (1)

Footnote(1) When the daily noise exposure is composed of two or more periods of noise exposure of different levels, their combined effect should be considered, rather than the individual effect of each. If the sum of the following fractions: C(1)/T(1) + C(2)/T(2) C(n)/T(n) exceeds unity, then, the mixed exposure should be considered to exceed the limit value. Cn indicates the total time of exposure at a specified noise level, and Tn indicates the total time of exposure permitted at that level. Exposure to impulsive or impact noise should not exceed 140 dB peak sound pressure level.

TABLE G-16A

Duration per day, in hours Sound level dBA slow response

8 90

6 92

4 95

3 97

2 100

1.5 102

1 105

0.5 110

0.25 or less 115

A-weighted sound level, L (decibel)

Reference, duration, T (hour)

80 32

81 27.9

82 24.3

83 21.1

84 18.4

85 16

86 13.9

87 12.1

88 10.6

89 9.2

90 8

91 7

92 6.1

93 5.3

94 4.6

95 4



96 3.5

97 3

98 2.6

99 2.3

100 2

101 1.7

102 1.5

103 1.3

104 1.1

105 1

106 0.87

107 0.76

108 0.66

109 0.57

110 0.5

111 0.44

TABLE A-1: CONVERSION FROM “PERCENT NOISE E POSURE” OR “DOSE” TO “8-HOUR TIME-WEIGHTED AVERAGE SOUND LEVEL” (TWA)



112 0.38

113 0.33

114 0.29

115 0.25

116 0.22

117 0.19

118 0.16

119 0.14

120 0.125

121 0.11



122 0.095

123 0.082

124 0.072

125 0.063

126 0.054

127 0.047

128 0.041

129 0.036

130 0.031

Dose or percent noise exposure TWA

10 73.4

15 76.3

20 78.4

25 80

30 81.3

35 82.4

40 83.4

45 84.2

50 85

55 85.7

60 86.3

65 86.9

70 87.4

75 87.9

80 88.4

81 88.5


82 88.6

83 88.7

84 88.7

85 88.8

86 88.9

87 89

88 89.1

89 89.2

90 89.2

91 89.3

92 89.4

93 89.5

94 89.6

95 89.6

96 89.7

97 89.8


98 89.9

99 89.9

100 90

101 90.1

102 90.1

103 90.2

104 90.3

105 90.4

106 90.4

107 90.5

108 90.6

109 90.6

110 90.7

111 90.8

112 90.8

113 90.9

114 90.9

115 91.1

116 91.1

117 91.1

118 91.2

119 91.3

120 91.3

125 91.6

130 91.9

135 92.2

140 92.4

145 92.7

150 92.9

155 93.2


160 93.4

165 93.6

170 93.8

175 94

180 94.2

185 94.4

190 94.6

195 94.8

200 95

210 95.4

220 95.7

230 96

240 96.3

250 96.6

260 96.9

270 97.2

280 97.4

290 97.7

300 97.9

310 98.2

320 98.4

330 98.6

340 98.8

350 99

360 99.2

370 99.4

380 99.6

390 99.9

400 100

410 100.2


420 100.4

430 100.5

440 100.7

450 100.8

460 101

470 101.2

480 101.3

490 101.5

500 101.6

510 101.8

520 101.9

530 102

540 102.2

550 102.3

560 102.4

570 102.6

580 102.7

590 102.8

600 102.9

610 103

620 103.2

630 103.3

640 103.4

650 103.5

660 103.6

670 103.7

680 103.8

690 103.9

700 104

710 104.1


720 104.2

730 104.3

740 104.4

750 104.5

760 104.6

770 104.7

780 104.8

790 104.9

800 105

810 105.1

820 105.2

830 105.3

840 105.4

850 105.4

860 105.5

870 105.6

880 105.7

890 105.8

900 105.8

910 105.9

920 106

930 106.1

940 106.2

950 106.2

960 106.3

970 106.4

980 106.5

990 106.5

999 106.6

GOAL is to provide choices enabling employees to achieve comfortable and properly fit hearing protection. That means different sizes and shapes of expanding foam ear plugs for ON RANGE use (because this type offers best NRR among ear plugs) and large-volume, shooting-specific ear muffs of either different sizes or adjustable for all sizes.

ON-RANGE (employee must pick one each of ear plug and earmuff)Brand NRR Type Size NotesPro For Sho 34

Ear Muff

Small Provided at no cost to employee*Pro For Sho 34 Large Provided at no cost to employeeWalkers EXT Range Shooting Folding Muff 34 One-Size Fits

All Provided at no cost to employee

FSL Decimate Earmuffs 34 Approved – but employee must buy their own muffs.

MSA Sordin Supreme Pro Electronic 18 [30]

• Use NRR of 30 (applicable NRR at gunfire frequencies)

• Employee must pay for own muffsNon-Approved List

</= 34

• Employee may request review of muffs to be added to approved list

• Employee must pay for own muffs and Personal Attenuation Rating if NRR <34

Honeywell Howard Leight MAX® Pre-Shaped Uncorded

33

Ear Plug**

Available at no cost to employee

Honeywell Howard Leight Laser Lite® Uncorded

32 Available at no cost to employee

Moldex SparkPlugs® Uncorded 33 Available at no cost to employee

3M™ E-A-R™ Taper Fit 2™ Uncorded 32 Available at no cost to employee

3M™ E-A-Rsoft™ Yellow Neons™ Uncorded 33 Available at no cost to employee

3M™ E-A-R™ Classic™ Plus Size Uncorded 33

Available at no cost to employee

“Small” Size is not approved due to low NRR of 29

1ON RANGE employees must wear double hearing protection

*At least two options with different fits must be made available to employees at no cost for both ear muffs and ear plugs

**This number of options may not be required – but idea is to have different shapes/sizes/material types with NRR’s of 32-33 that can fit different types of ear canals

ATTACHMENT C: APPROVED HEARING PROTECTION OPTIONS (EXAMPLE!)

Documents

SHOOTING RANGE