Quote Originally Posted by Jesim1 View Post

The big issue with this loophole though is that anyone wanting to start a minirange does not have to have any training, experience, or even an FAC certificate themselves, they can just start a range, buy multiple live ammo guns, and then hand them to the public - and that surely has to be wrong?
They don't need an FAC to run a FAC range even if it's not a mini. I took an indoor range through HO Approval and certification for up to .45 and 600ft-lb, air, rim and centre fire. I didn't have an FAC then.

The structure of many ranges is that they aren't run by one person. They are often clubs run by committees and it's the Secretary who is legally responsible, but they don't need an FAC either.

The FEO will review members of clubs that have HO approval and want to use firearms but there's no training. It's really down to the fact that the liability will fall onto the Sec if proper processes aren't followed, even if they're insured.