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John MH wrote:

Cj10 wrote:response from the Training Safety Officer at STANTA, via Landmarc East on his issue:

"Range Officer Qualifications from the NRA are only for fixed ranges. Gt Carr and Robins Lodge are field firing ranges and the NRA qualification does not cover these ranges. We have been running a significant RISK by letting civilians fire on Field Firing ranges and at our recent Range Safety Inspection Team (RSIT) inspection we were advised to stop and only allow civilians onto ranges where they met the qualifications to be RCOs."

Shame the decision is erroneous .

RCO’s are authorised by qualification to conduct live firing on Field Firing/Live Training Ranges when operated as gallery ranges, i.e. from fixed firing positions at defined targets.This is stated in paragraph 1.2 c i of the NRA RCO Instruction Manual. This Manual was approved by the MOD, and any amendments must be approved by the MOD.

Matter is on the agenda for the NRA's Gerneral Council meeting on 5 September.

Ceri

It would appear that this does not align with the regulations in Pamphlet No. 21 (Regulations for Training with Armoured Fighting Vehicles, Infantry Weapon Systems and Pyrotechnics), Para 1036 does state that a SA(B)(90) (assuming that is the nearest thing in the Military to an NRA RCO Qualification (although not the same as the course is longer and more comprehensive)) qualified RCO is permitted to plan and conduct practices from the fixed firing point only on a Individual Battle Shooting Range (usually a Field Firing Range).

The problem is the Range Safety Inspection Team are the Subject Matter Experts (SME) and their interpretation of what the NRA Qualification equates too may be different to what the NRA thinks in its manual, whether 'MoD' approved or not. In the hierarchy of documentataion its Pamphlet 21 that will take precedence and not a document that is not authored and controlled by the MoD. There is no mention of Civilian RCO Qualifications in Pam 21 and it clearly states that the rules and procedures for the use of MOD land ranges by organised bodies such as the police, civilian clubs and civilian contractors are contained in JSP 403 Volume 1.

If the MoD SME do not think that the NRA qualification equates to an SA(B)(90) then you would not be covered by Para 1036, remembering of course that this document refers to Military Personnel only.

One for the NRA to pursue with the MoD.

John

The online version of JSP 403 II only has page numbers, not para no's - do you know which page this is on?

Thanks

It's not in JSP 403, its in Pam 21. JSP 403 has no mention of restictions on the use of Field Firing Areas by Civilians, Pam 21 applies to the MoD only but Para 1036 may be an area where some similarity exists so that could be a starting point for negotiation to allow the RSIT to reconsider their advice.

Pam 21 is not available on the WWW.

Ah! Nothing is ever simple with the MoD, is it?! sign01

John,

If every TSO was to take such a narrow interpretation of the agreement the NRA has with the MOD on civilian RCO use of FFAs we would not be able to use any such ranges across the country.

Even other local military personnel believe this TSO has got it wrong, but he won't change his decision.

We've not gone through Mercer this time, based on lessons learnt, and have communicated directly with the Trustees. The Defence Land Range Safety Committee has historically been content with the NRA RCO qualification being appropriate for FFAs, in the circumstances I have previously described. Hopefully both bodies will be able to move this forward.

Ceri

Your approach to the Trustees may filter down to those responsible within the NRA to prioritise there workload but there is currently only one point of contact who deals with the MoD.

Its nothing to do with a narrow interpretation its all about tolerable risk and what people or organisations are prepared to accept (the MoD is nowadays risk averse), if you are given advice by a competent body that you should do something and then don't you will be standing into danger if an unlikely event occurs and you chose to do nothing to prevent it. Its unfortunate that the ALARP position would be to stop all civilian shooting on MoD Ranges as it cannot be demonstrated that there is a benefit to the MoD from such activities, thankfully the powers that be are somewhat more pragmatic but when pushed and challenged they will have to justify whether they did all that was ALARP to reduce the risk in the event of an incident.

I've been advised that there are actually two people dealing with the MoD within the NRA, I would imagine that its work in progress and that they will provide an update to the clubs who have sort help and advice when there is something to report and that they are still waiting a reply from the MoD. That is just my guess on things at the moment and not necessarily what is actually happening.

The mod are waiting for the NRA John. Certainly as far as the sarts issue anyway

John MH wrote:I've been advised that there are actually two people dealing with the MoD within the NRA, I would imagine that its work in progress and that they will provide an update to the clubs who have sort help and advice when there is something to report and that they are still waiting a reply from the MoD. That is just my guess on things at the moment and not necessarily what is actually happening.

John,

As of yesterday the NRA had done nothing with the RCO FFA issue. Still waiting for Mercer to deliver on his personal undertakings to my Club from nine months ago. Hence us taking the Trustee route this time around.

If you don't communicate you create a vacuum, which will be filled with rumour. Even if you have nothing substantive to say you simply provide a message outlining discussions are still in progress, which helps to manage people's expectations.

Ceri

Cj10 wrote:John,

If every TSO was to take such a narrow interpretation of the agreement the NRA has with the MOD on civilian RCO use of FFAs we would not be able to use any such ranges across the country.

Even other local military personnel believe this TSO has got it wrong, but he won't change his decision.

We've not gone through Mercer this time, based on lessons learnt, and have communicated directly with the Trustees. The Defence Land Range Safety Committee has historically been content with the NRA RCO qualification being appropriate for FFAs, in the circumstances I have previously described. Hopefully both bodies will be able to move this forward.

Ceri

Ceri
This is an item that needs to be addressed and resolved between the NRA and the MOD. IMO having representatives from individual shooting clubs directly banging on the door of the trustees will not help our situation. In addition your continuous reference of the NRA as ‘Mercer’ is only going to make matters worse and do nothing to progress matters in the right direction. Like it or not the NRA is the association that represents our sport in these matters and has direct communication with the relevant personnel in the MOD. The bottom line is if we want the NRA to assist us and hopefully rectify the situation then we need to work together.
We must also realise that we as civilians are in a privilege position to have the use of these ranges. In addition as ‘civilian’ shooters we are way down in the list of the MOD’s priorities and any matters that do arise will take time to resolve, BUT we must learn to be patient. This situation will not be rectified overnight and whilst I agree that we have to keep the pressure on and keep such matters in the public eye, we must also conduct ourselves in more professional manner, airing our personal feelings in the public domain will not help our plight and will not go unnoticed by those who could be assisting us.
Dave

John MH wrote:It's not in JSP 403, its in Pam 21. JSP 403 has no mention of restictions on the use of Field Firing Areas by Civilians, Pam 21 applies to the MoD only but Para 1036 may be an area where some similarity exists so that could be a starting point for negotiation to allow the RSIT to reconsider their advice.

Pam 21 is not available on the WWW.

Apologies, the reference above was out of date as a new Pam 21 was updated and issued in April 2014. However,the intent of the note at para 1036 in the previous issue still remains and is stated on page 1-14 under the types of Range SA(90)(B) qualified personnel are allowed to supervise. The new reference details have been forwarded to the relevant person as it may be of some use.

Whilst the regulations in Pam 21 are only applicable to the MoD this quote clearly puts into context what they aim to achieve:

This pamphlet covers the planning, conduct and supervision of training with Inf WS, AFV and pyrotechnics. The application of the regulations is mandatory; they are approved best practice, enabling realistic and demanding training whilst ensuring that risks are reduced to As Low As Reasonably Practicable (ALARP).