You may think that the job is done when your contractor rolls off of your property and tells you they will handle the lead and lead-waste… but as a matter of fact, you could be facing a painful EPA investigation by taking their word for it. Lead contaminated soil and waste (paper, PPE, filters, debris etc.) is commonly determined to be RCRA hazardous waste.
Employee Health: Since the Federal Occupational Safety and Health Administration (OSHA) is responsible for employment health and safety, OSHA has jurisdiction over control of toxic waste in firing ranges when it comes to employee health. OSHA conducts inspections to assess employee practices and training regarding the handling of heavy metal (arsenic and lead) contamination in firing ranges.
Environmental Protection: The Environmental Protection Agency (EPA), which is responsible for environmental safety, enforces environmental laws aimed at preventing heavy metal and lead contamination of water and soil resources. The EPA issues Best Management Practices (BMPs) which recommend site practices for firing ranges to minimize the impact of lead on the environment. The EPA does not enforce its recommendations through criminal prosecutions, but implementation relies on civil law suits brought either by the government or by private parties who claim injury from toxic contamination. This is the same pattern of toxic torte suits that follow from other forms of contamination, like industrial pollution or bad drugs.
The advantage of BMP Implementation: Implementation of BMPs will reduce liability for potential civil lawsuits. In addition, BMPs encourage the recycling of lead and other valuable metals from the gun range environment which can provide an economic benefit to the business.
Criminal Enforcement-What are the legal standards imposed by OSHA:
- Employees exposed to lead wear contamination protective clothing.
- That the protective clothing be removed and isolated after the shift.
- Shower facilities for employees have to be provided.
- Employees must be required to thoroughly wash their hands and faces before eating and drinking.
- All surfaces must be maintained free of lead accumulations.
- Employees must be fully educated about the effects of lead poisoning and the methods of prevention.
- Respirators have to be provided and fit-tested for employees.
- Protective clothing has to be maintained and replaced as needed.
- Employees must be tested for lead poisoning regularly and be provided with written medical information about blood lead levels.
OSHA cites gun range for workplace lead exposure in San Antonio
Shockingly enough, dangerous levels of lead exposure can occur very quickly. Exposing employees and customers to gun lead impacts health and can result in costly fines. The Nardis Gun Club in San Antonio had only operated for just over a year when OSHA inspected and found 13 citations all classified as serious. Despite being experienced entrepreneurs in other businesses for more than 40 years, the owners were not prepared with proper procedures to minimize lead exposure.
OSHA has outlined the dangers of lead exposure very clearly in their report.
“Lead exposure can cause multiple serious health hazards that have lifelong consequences – but it’s easily preventable,” said Kim Nelson, OSHA’s area director in Toledo. “Eliminating exposure, using engineering controls and personal protective equipment such as clothing and respirators as well as properly cleaning lead dust and particles can limit worker exposure and prevent them from transporting lead contamination home.”
This quote from OSHA clearly demonstrates the importance of maintaining a safe environment. Also noted, eliminating the exposure to lead is possible with proper cleaning. Obviously, consulting with a professional to mitigate exposure to safety violations is a wise choice for gun range owners. Owners can also mitigate exposure by following a few safety guidelines issued by OSHA outlined below.
- Monitor employee exposure to leads
- Train staff on chemical hazards
- Provide protective clothing
- Provide showers and separate lunch rooms to avoid contamination and exposure to lead
Employees and customers that frequent gun ranges deserve a life free from lead exposure. Owners can easily decrease lead exposure for their employees by following housekeeping procedures and safety standards. Consulting a professional is an ideal method to minimize hazardous risk that impacts health and can result in fines.
Safety Hazards and Lead: OSHA Cites Gun Range for Workplace Lead Exposure
Compliance with OSHA standards is mandatory when you are running a business, such as an indoor shooting range. Indoor firing ranges, however, have certain concerns that go hand-in-hand with health and safety concerns. Shooting events, in fact, are one of the greatest concerns in regard to human exposure to lead and other contaminants. There are numerous means of being exposed to lead on the shooting range. Shooting releases aerosols and, according to industry research, an estimated 34 to 70% of these are deposited in the respiratory tract.
These researchers were quick to caution, however, that “suggesting the health risk based upon total mass significantly overestimates the accumulated dose and therefore the health risk.” In other words, not all of the lead that enters the respiratory tract in aerosol form is overly problematic from a health perspective. Never the less, there are other mechanisms of lead exposure on the shooting ranges.
Unfortunately, there is more bad news associated with lead exposure than good news. There are not just primary concerns when it comes to lead exposure and shooting ranges but also secondary concerns. OSHA, for example, is particularly concerned about secondary lead exposure in the families of workers involved in range cleanup. One study of public safety officers who practiced on the range ≥ 12 times a year reported a “greater percentage of miscarriages in their partners (24% vs. 0%).” Furthermore, despite having relatively low blood levels of lead “(mean BPb was 7.6 μg/dl (SD = 6.8, range: 2.7-51.7), 12% percent of the respondents showed an increase in neuropsychiatric symptoms.” Comparatively, two caretakers from that same range were found to have “29.6 μg/dl and 51.7 μg/dl BPb.” The implication would be that prolonged exposure results in greater risk.
Improper range cleanup procedure is one of the primary reasons OSHA cites gun ranges for workplace lead exposure. In September 2015, for example, Kremer’s Guns LLC, in Celina, Ohio received 23 safety violations. In part, OSHA found that workers were not adequately trained to deal with the hazardous substances they were coming in contact with and were provided essentially no protective gear such as respirators and protective clothing. There were no shower provisions and some workers were even wearing the same clothes home that they wore on the range, thus unknowingly endangering not only themselves but also their families. Ironically, this was not the first citation that Kremer Guns had received from OSHA. Do not let your shooting range make the same mistake.
Contact us and let’s discuss what you need to be doing to ensure your employees are safe and your business is protected from the possibility of serious fines from OSHA.