He was only acting.
Think about it. He was handed a prop, told it was safe and was directed to fire it at the camera.
It's not different than if he was handed a knife, told it was a dummy with a retracting knife when it was, in fact real, and then stabbed another actor by accident.
No he wasn't.
He was standing around, practicing drawing the gun from his holster and pointing it at the camera while the director and cinematographer were still setting up the camera.
Nobody was paying attention to Baldwin, as they were all focused on doing their own jobs to set up for the scene.
Baldwin hadn't been "directed" to do anything yet.
-PJ