On September 17, 2020 the United States Department of Justice (DOJ) reported that a federal grand jury sitting in Charlotte has returned a criminal indictment, charging David Stuart Lutz, the Director of Public Works for the City of Brevard, with environmental crimes related to the handling, transportation, and storage of hazardous waste.
This crime violated the Resource Conservation and Recovery Act, (RCRA) by illegally directing DPW employees to dig up soil known to be hazardous for lead, from the backstop of the City of Brevard’s firing range, without the use of any of the required protective equipment or procedural safeguards. The indictment further alleges that Lutz directed the employees to transport the contaminated soil in City-owned vehicles, without the requisite hazardous waste manifest. As alleged in the indictment, Lutz further instructed the employees to move the contaminated soil to the DPW Operations Center and store it there, even though the area is not permitted as a treatment, storage, or disposal location for hazardous waste, such as lead.
Lead, which is found in ammunition, is a toxic substance and has the characteristics of “hazardous substance” under the RCRA. Lead exposure, according to the indictment, can seriously harm human health. “Well documented adverse effects of lead exposure include damage to the brain and nervous system, slowed growth and development, lower IQ, learning and behavior problems, hearing and speech problems,” the document states.
MT2 is the Firing Range Lead Management Authority; we are OSHA/EPA Experts and are often sought-after industry-wide to advise top ranges as well as federal and state organizations on structuring their approach for their firing range lead reclamation with Best Management Practices.
In the DOJ report, we see several aspects of the case that are critical to point out and understand:
1. Personal Protective Equipment (PPE)
“without the use of any of the required protective equipment or procedural safeguards” – handling lead-impacted range waste is much more involved than sending employees out to dig up soil and backstops. There must be lead-safety protocols and proper PPE worn.
MT2 operates from our network of regional offices offering full 50 state coverage with OSHA and EPA
certified work teams. We always adhere to the required protective equipment or procedural safeguards to protect your range and our workers.
2. Proper Paperwork
“The indictment further alleges that Lutz directed the employees to transport the contaminated soil in
City-owned vehicles, without the requisite hazardous waste manifest.”
Recently the NSSF featured an interview with one of our Senior Firing Range Engineers on the topic of Lead Impacted Waste Disposal-Proper Documentation & Manifests
3. Transporting Lead-Impacted Waste
“As alleged in the indictment, Lutz further instructed the employees to move the contaminated soil to the DPW Operations Center and store it there, even though the area is not permitted as a treatment, storage, or disposal location for hazardous waste, such as lead.”
Our CEO wrote an article for the NSSF on this very topic: “Lead-containing Material Disposal Considerations For Firearms Ranges.” This informative article also includes our infographic which describes the “cradle-to-grave” process which is very handy to refer to!
Many laws are now in place about lead management. Firearm safety is not only about the gun. Even during COVID-19, we have had to adapt and increase our safety precautions so that our workers and firing range clients are protected!
MT2 is the #1 Nationwide Professional Firing Range Lead Reclamation, Maintenance, Cleaning & Construction Contractor for both Indoor and Outdoor Shooting Ranges.
MT2 Firing Range Services Uses Exclusive PATENTED Technologies That NO Other Gun Range Services Contractor Can Perform.
Contact us today to get the lead off your range to protect your shooters, employees & the environment.