Interim advice for NRA affiliated Clubs that operate Indoor Ranges 

COVID-19

National Rifle Association

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Background:

The Government guidance for grassroots sports/gym leisure facilities is available here

https://www.gov.uk/guidance/working-safely-during-coronavirus-covid-19/providers-of-grassroots-sport-and-gym-leisure-facilities

The guidance is very detailed but places the responsibility for sport specific guidance on NGBs.

Key points:

  • Indoor sports facilities in England may reopen from 25th July provided that the operator can do so safely and follow public health guidance
  • Local restrictions will apply and devolved Governments will publish guidance for Scotland, NI, Wales
  • Volunteers are to be afforded the same level of protection as workers or customers. This will apply to all Club operated indoor ranges and may present issues
  • The range operator must develop a site specific Covid-19 risk assessment, following the guidance and do this in conjunction with volunteers that are involved in the operation of the facility
  • The guidance provides a lot of detail around handwashing, hygiene, social distancing, surface cleaning that will already be familiar to Club officials/range operators
  • Operators will have to restrict access to the facility as a way to manage throughput, avoid breaches of social distancing and optimise the existing ventilation systems in place, whilst not causing harm to range users through lead contamination
  • Ventilation of the facility plays an important part in mitigating the spread of Covid-19. Section 5 of the guidance details specific requirements including the importance of fresh air circulation and limiting occupancy to allow 100 sqf per person
  • Range operators will need to fully understand the ventilation system for their range and its characteristics in order to comply with guidance provided by the CIBSE (Chartered Institution of Building Services Engineers) that is included in the Government guidance. https://www.cibse.org/coronavirus-covid-19/emerging-from-lockdown
  • CIBSE recommends that areas that lack a direct supply of outside air be prohibited from use- this may apply to parts of many indoor ranges
  • CIBSE recommends that operators using “specialised ventilation systems” seek further advice from the “Institute of Local Exhaust Engineers”. https://www.cibse.org/Institute-of-Local-Exhaust-Ventilation-Engineers
  • Indoor ranges rely on a laminar air flow pulled down the range with an extraction system rated 10% greater than the inlet producing a negative pressure down range. The air systems are to be switched on 20 minutes before use of the range and left on 30 minutes after use to remove dust and gasses after firing ceases. The consequence of this system is that Covid-19 in aerosol could be carried down the range and deposited onto targets, filters and range structures exposing users to Covid-19 when targets are changed or during the close down procedures when the extractor fan is still running. Operators will need to include in the risk assessment. In addition range operators should consider not handling contaminated filters for a fixed period of time to allow Covid-19 to “expire”, currently 72 hours
  • Range operators will need to consider the broader implications of Covid-19 on the existing operational and maintenance procedures (including cleaning) as part of the risk assessment process. For example, allow ventilation systems to run 24/7 and increase airflow and ventilation maintenance frequency
  • Indoor ranges may be located in buildings or structures that do not allow the implementation of the Guidelines, for example tunnel ranges or subterranean ranges with no doors/windows to the outside. On ranges where the only doors/windows are located near the firing point end of the range, ventilation may be difficult
  • Operators will have to consider mandating the use of PPE to protect volunteers and users, for example use of face masks and shields, gloves, aprons etc during set up, use and close down of the range
  • Contractors visiting the range to provide maintenance services will require separate risk assessment and procedures
  • Range waste including targets should be treated as if contaminated with Covid-19 which can remain on surfaces for up to 3 days
  • Operators will need to decide if retail activity such as ammunition sales, firearm rental, can be delivered safely
  • Operators will need to decide if training can be delivered safely

 

 

Nic Couldrey

20th July 2020

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