Emergency Preparedness Training is required for almost every business, professional organization, and employer through multiple organizations such as OSHA, CDP, CDC, professional licenses, insurance requirements and permits. Considering most businesses are required to pass regular inspections and provide documented procedures, training, and equipment, it has always shocked me that of all these businesses, many firearms trainers are somehow able to operate with less training and safety guidelines than a hairdresser. Due to the lack of regulation, and the overall public assumption that there must be requirements in place, I make it a point to inform my students how important it is to research instructors.
This led to a very common social media conversation last week about “red flags” for firearms training. I commented a few of the things I tell my students to watch for and apparently upset some instructors. Although I was aware that several trainers and organizations teach instructors to ask their students about emergency medical training in order to assign them medical response duties, I guess I didn’t realize just how commonplace it had become. I was not only shocked at the level of instructors that were upset at my comment and speaking up to defend the practice, but at the lack of substance or accountability in their arguments. At first, I thought I must have miscommunicated my concern, they must have thought I was against ever asking students to assist in an emergency, when I only meant the EXPECTATION for students to provide the needed emergency response they are responsible for assuring as a professional trainer.
After several exhaustive conversations it became clear that this practice has become a bigger concern than I ever expected. Not only is it much more prevalent than anticipated, but many instructors were so defensive about doing it that they weren’t even willing to discuss ideas to provide better safety for their students. Since opening the new training facility, I’ve been developing new Instructor Development Courses and will definitely be adding an Emergency Planning Curriculum, but for now I thought this was a good opportunity to share some information and have an open discussion about the differences between Safety Assessments, Safety Plans, and Safety Briefings, along with the specific considerations and expectations of each. Spending most of my adult life as a Police Officer, Firefighter and Emergency Medical Responder, in addition to many training programs and job duties over the years involving the development and evaluation of emergency management plans for schools and businesses, I’m hoping I can shed some light on the subject and maybe open the door to change. I’d also be interested in hearing from previous and potential students to clarify the expectations students have when they show up to our classes.
Let’s start by acknowledging that OSHA has standard requirements of almost all businesses/employers requiring specific emergency response plans to be on file and available to all employees. KDHE requires inspections and documented comprehensive safety plans including business legalities, licenses, certifications, insurance, utilities, weather hazards, hazmat, fire prevention, evacuation plans, mandatory training requirements, and strict limitations on the ratio of kids to adults. The local gun ranges are also heavily regulated for air quality, occupancy, fire prevention, eye/ear protections, lead exposures, clean water regulations, staffing training & requirements, emergency medical supplies, and ADA requirements.
When an individual firearms instructor chooses to run their business in a private field instead of one of these heavily regulated businesses, they can often avoid the otherwise legal requirements all the other businesses are forced to comply with. Apparently, this has led to forgetting that these measures are considered normal business practices and expected as a professional. Of course, the first defense to not providing adequate staffing with appropriate Emergency Medical training is the cost, which is exactly why the public ranges, being held to all the government mandates, are more expensive to work with. Teaching on private property is not necessarily a bad thing (and sometimes the only option), but it is more important for the student to research the instructor’s credentials, insurance and emergency procedures when nobody else is overseeing it. I have personally avoided these situations whenever possible because of the increased personal liability and responsibility when conducting training at a location where you are solely responsible for providing all staffing and safety measures. It does require a lot more planning, preparation, and usually expense, but there are several realistic adjustments we can implement to minimize the risk to our students, and ourselves.
Any training or event ran by a business, SHOULD include a safety assessment, emergency plan, and some type of safety “briefing” in order to prevent, mitigate, and manage potential risk.
SAFETY ASSESSMENT:
Once the curriculum and location have been determined, all aspects should be carefully evaluated for any potential hazards so safety planning can include any necessary preventative measures. At this point there are several fairly easy adjustments that can be made- class size can be limited according to space or staffing concerns, relays or coach/pupil methods can be used to minimize shooters while maximizing safety, curriculum altered, locations changed, dates/times adjusted for weather concerns, shelters and equipment identified, communication/transportation planned, emergency procedures developed, and legal or insurance documents obtained according to the specifics (most instructor insurance policies will require documentation of each specific training location).
SAFETY PLANNING (EAP):
An Emergency Action Plan should be developed for the specifics of the event with consideration of any identified risk, hazards, regulations, liabilities, etc. It should dictate the necessary staff members and emergency equipment relative to the number of students, curriculum, location, and potential risk factors. Staff members should be assigned based on training, experience, analytical problem-solving skills, and be fully aware of and properly equipped for their assigned duties prior to the event. Often there are legal requirements and/or insurance regulations limiting the maximum number of students allowed on the firing line per Instructor/RSO. If all Instructors and Range Safety Officers are also crossed trained in at least First Aid/CPR/AED/Bleeding Control, have adequate emergency medical supplies on their body, effective communication devices and any necessary information, and each have a specific responsibility for a certain area or activity, this will also greatly reduce the number of staff members needed since they are all effectively backup for each other. There are usually opportunities to offer a free or discounted spot in the class in exchange for providing emergency medical response if needed. In rural locations or a private range, it’s a good idea to contact dispatch or any other emergency services prior to the event to let them know your exact location and any other important information to reduce confusion or unnecessary delays.
The safety plan should be reviewed with all staff prior to the event and address any last-minute changes or concerns, clarify responsibilities, who will take command, how breaks will be handled, backup plans, and assure that everyone has the needed supplies. It is recommended that emergency plans are provided to each staff member in writing to avoid any confusion or delays, which also makes it much easier to pass a task off to an untrained bystander if needed. Additional considerations should be made on an outdoor range to include heat/cold emergencies, diabetic emergencies, exhaustion, allergic reaction, as well as availability of an AED. Most of the responses I had on this topic were specifically regarding gunshot injuries, but other emergency situations are much more likely and talking through potential issues can better prepare everyone mentally/emotionally for a wider range of response while identify any missing forgotten issues like planning an evacuation route or safe area and securing firearms if needed. Making prior arrangements for adequate and appropriately trained staff relieves the need to pass on the responsibility and rely on whatever students happen to be in class that day as an emergency plan.
SAFETY BRIEFING:
A Safety briefing is provided to the students immediately prior to the event as a preventative measure. The purpose of the safety briefing is to advise participants of the training goals and expectations, as well as any potential hazards, emergency procedures, equipment (easily identifiable medical kits), and to introduce staff members. A good safety briefing assures participants you have planned for their safety, reduces confusion, and provides an opportunity for them to address any additional concerns they may have. The safety briefing should be kept short and sweet, specific to the information they need to remember. If not already done (it’s better to address this in private prior to the briefing) this is also an opportunity to identify anyone with emergency medical training that may be of assistance in the event of an incident, and any potential safety or medical concerns that could become a problem during the event. Keep in mind that students with extensive medical training may not react as expected in range environment, under different circumstances than they usually operate, and without being fully trained on the specifics of the emergency plan. It's best not to rely on an expected response from someone being put on the spot last minute, but in the event of an emergency, requests can and should be made of bystanders to assist as necessary and appropriate based on the the specific incident (their location, stress level, who is hurt, what is needed). Unexpectedly assigning them responsibilities during a safety briefing, without proper preparation and knowledge of safety plans, could easily add extra stress to their training experience and cause more confusion if they are needed to assist.
There are several resources available for emergency management training and planning documents, but each plan needs to be made specific to the details and concerns of the actual event. Acknowledging the expectations and limitations during the planning process allows for smaller adjustments to be made as plans are developed in order to assure proper safety measures are put in place. Of course, the safety planning required for a private field 30-minutes from emergency care, that provides no staff or resources, requires a lot more effort on the instructor’s part. It does not however remove the expectations, requirements, or liability to adequately provide for student safety at every event. Incidents on the range are rare, but they do happen, and the legal liability and expectation to provide the necessary safety planning and resources is very clear whether it is being enforced or not. We can do better. We need to do better.