Why Gun Range Owners and Managers Need a Health & Safety Plan (HASP) for Lead Clean-up of Firing Ranges- Its Not DIY
MT2.com | Firing Range Lead Reclamation & Environmental Remediation Services – #1 and Largest Nationwide Professional Environmental Soil Remediation & Firing Range Lead Reclamation Maintenance Contractor for both Indoor & Outdoor Firing Ranges
Lead can be toxic! Lead contaminates air, soil, water, wildlife, and people. The hazards of lead at an outdoor shooting range are very complex and astute range owners and managers will bring in a respected firing range services contractor to help implement a smart plan of action.
The direct exposure of lead to the environment creates varied sources of lead contamination. Lead removal includes both recently spent bullets and “historic lead”. Historic lead is lead left in the ground for a period of time throughout the history of the range. According to the Environmental Protection Agency (EPA), lead reclamation at an outdoor shooting range has 4 major steps:
After the reclamation, proactively sustaining the range’s environmental and regulatory status requires a plan. The EPA recommends an Environmental Stewardship Program (ESP); a regulatory compliant plan that protects wildlife and natural resources.
Recently a news story came out about Pacific Rod and Gun Club in California who lost a long court battle regarding cleaning up lead impacted materials on their range. This highlights the need to keep ranges under a lead management plan and to avoid shooting into open water bodies. Contact MT2 for a free assessment and recommendations for lead reclamation Best Management Practices. Avoid becoming another closed club and part of a multi-million dollar cleanup!!
MUST #2: You MUST minimize all threats from lead hazards during reclamation, remediation, and beyond.
Remediation of lead can introduce additional lead exposures and hazards. During the entire reclamation process and beyond, it is important to
Must #3: You MUST have a Health and Safety Plan (HASP)
Compliant and safe shooting range lead reclamation requires highly trained, certified contractors with specialized equipment. It is imperative to hire a contractor who understands and institutes a comprehensive Health and Safety Plan (HASP) that is specific to your site. A proper HASP ensures protection of wildlife, soil, water, and people throughout the reclamation process. A properly executed HASP that is RCRA and Clean Water Act (CWA) compliant, also protects range owners from potential liabilities.
A solid HASP can be established after an on-site inspection determines necessary reclamation steps specific to your range. A HASP will include steps such as
The National Institute for Occupational Safety and Health (NIOSH) and the Occupational Safety and Health Agency (OSHA) partnered with the National Shooting Sports to create the Lead Management and OSHA Compliance for Indoor Shooting Ranges. The plan outlines maintenance considerations for indoor ranges:
Lead-contaminated ventilation filters are considered hazardous and require regulatory-compliant disposal.
Cleaning a bullet trap typically requires additional controls, training, and PPE.
Lead-contaminated waste water, PPE slated for disposal, and HEPA filters are considered hazardous and require regulatory-compliant disposal.
Lead-contaminated filters are considered hazardous and require regulatory-compliant disposal.
Lead-contaminated waste water is considered hazardous and requires regulatory-compliant disposal.
* Recordkeeping and retention either required by law or strongly advised. Protect yourself and the range: Keep thorough records.
You’ve read about the hazards of lead (Pb). You have a responsibility to manage these hazards at a shooting range and feel ready to begin an Environmental Protection Agency (EPA) Environmental Stewardship Program (ESP) that protects and conserves resources from those lead hazards. You’re finally ready to clean up the shooting range!
A comprehensive Health and Safety Plan (HASP) is essential when removing lead! Along with protecting consumers and workers, a through and well-executed HASP also helps to assure regulatory compliance to avoid inadvertent environmental damage and potential hefty legal sanctions. Range clean-up may involve water and soil remediation first; then a plan to safely recover and reclaim spent bullets once that remediation is complete.
Did you know? OSHA Standard 29 CFR 1926.62(g)(2)(vi) requires that an employer give written notification to the laundry service if laundry is potentially contaminated with lead!
MT2 is well known industry wide for being the nation’s #1 largest professional provider of the full scale of outdoor/indoor range environmental and maintenance services; proven at over 2,000 ranges in all 50 states from our nationwide office network. Including our comprehensive OSHA training program, knowledge of EPA regulations and our “Never Generate Hazardous Waste Guarantee. Specializing in: Lead: Reclamation, Screening & Treatment to MAXIMIZE Your Lead Value! Environmental: EPA & OSHA Consulting; Remediation Maintenance: Filters/Ventilation, Rubber, Traps, Decontamination Construction: Renovation, Design/Build, Improvements, Closure.
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