Your Choice of a Lead Reclamation Contractor Could Expose Your Firing Range to EPA Hazardous Waste Fines up to $37,500 per DAY and Potential Criminal Charges.
Are you willing (and able) to take this risk just to save a little money?
Your range may be liable for the negligent actions of the contractor you choose.
The Environmental Daily Advisor reported that
there are RCRA Violations That Can Send You to Jail and the #1 reason is one that should cause major concern, because if your contractor does this, you may be liable!
It is: “Transport hazardous waste to a non-permitted facility.”
Did you ask the contractor on your last lead reclamation project how they would be handling YOUR lead waste or if the lead recycling facility they took YOUR lead to, is properly permitted?
For your protection, you must always maintain on-site written records of your Lead and Contaminated Waste Disposition!
When these violations come up, there may also be the additional consequence of an enforcement action for costly cleanup and remediation including Regulatory fines and penalties. Recent firing range environmental cases and projects have shown that a typical OSHA or EPA regulatory fine is in the range of $250,000-$500,000.
Additionally, when the EPA has to step in, range cleanups with their oversight involved can be in the $5,000,000-$8,000,000 range.
A range owner ALWAYS retains responsibility for ALL lead waste and materials derived from their range regardless if they assumed their chosen contractor would take care of it.
When dealing with the environmental hazards of lead, you simply CANNOT assign the risk away. You always retain significant liability and risk for your waste.
Remember, as the range owner or operator, you are the generator of lead-impacted waste.
4 critical validations you must demand from your contractor to protect you and your range:
1. Contractor must be able to document (audited financials) sufficient & substantial company equity that could sustain defending a claim or actual violation without going bankrupt. . (min. recommended $500,000)
2. Comprehensive insurance package:
Minimum $5 Million; General AND Pollution Liability
(the ONLY coverage for lead and hazardous materials).
Recent Certificate of Insurance and range named as additionally
insured and include Worker’s Comp and auto liability.
3. List of prior regulatory violations, fines or penalties from ANY Agency and well documented contract with FULL indemnification.
4. Minimum 5 years (preferably 10 years) of continuous operating history with business registrations with minimum 5 prior similar projects successfully completed in the last 3 years.
Upon request, MT2 will immediately provide you with the above documentation.
Rest assured: MT2 is committed to stand with you to
defend your firing range from the liability of lead hazards.
MT2 NEVER Generates Hazardous Waste. GUARANTEED.
- MT2 is the Leading Nationwide Professional Lead Reclamation Contractor for BOTH Indoor & Outdoor Firing Ranges.
- MT2’s patented ECOBOND® lead treatment technology, prior EPA approved, has been used on over 12 Million tons of waste. It provides a unique solution eliminating the need to generate hazardous waste, saving money and minimizing range owner liability.
- MT2, as the Nation’s leading provider of environmental and maintenance firing range services, has served approximately 1,000 public and private indoor and outdoor firing ranges for military, law enforcement and municipalities nationwide in all 50 States since 2000. MT2 is committed to protecting law enforcement officers who protect and serve our communities.
- MT2 carries $9,000,000 of General AND Lead Pollution Liability & Worker’s Comp Insurance
Over the past decade, MT2 has recycled over 10 MILLION tons of lead, returning over $4,000,000 dollars to ranges owners without a single regulatory violation, while working closely with range owners to implement firing range Best Management Practices (BMPs).
MT2’s proven record of firing range services include: complete range maintenance & improvements, lead remediation services, lead reclamation, OSHA & environmental consulting, operational maintenance and range closure. Our zero-tolerance for regulatory violations gives range owners the peace of mind that their project will be successfully completed on a guaranteed schedule.
No one can complete your project quicker than MT2!
EPA fines: https://www.epa.gov/enforcement/rcra-corrective-action-enforcement-authorities
EPA Hazardous Waste Cleanup: https://www.epa.gov/enforcement/waste-chemical-and-cleanup-enforcement
RCRA Violations: http://envirodailyadvisor.blr.com/2012/08/7-rcra-violations-that-will-send-you-to-jail
Transporting Hazardous Waste: http://www.epa.gov/enforcement/criminal-provisions-resource-conservation-and-recovery-act-rcra