Whether you own or run a public or private firing range, law enforcement or hobby, indoor gun range or outdoor gun range, you know there are a staggering number of regulations to consider. These include EPA and OSHA federal statutes, as well as your state’s laws.
It’s easy to assume any lead salvager, whatever size, knows how to deal with all the regulations and make sure their actions keep you safe. However, there’s a definable risk in hiring small-scale lead salvagers for your gun range, concerning possible fines OSHA can level if they’re not doing the proper cleanup. When you add the fact that small firms are often under-insured and without the resources to deal with this kind of liability, when their business goes under, your firing range could go down with it.
Fines can be enough to put almost any firm out of business, but especially a small one. In 2012, OSHA tagged an environmental organization in South Carolina for actions that “knowingly neglected to protect workers from overexposure to lead. Proposed fines total $480,000.”
Liability could also extend to your gun range if a company that doesn’t protect their own workers doesn’t protect your interests, whether knowingly or out of ignorance of the regulations. Should your employees end up exposed to hazardous levels of lead, you could well end up incurring massive fines, as well. And, if the small-scale lead salvager you’ve hired doesn’t have sufficient insurance, or alternatively, the resources to satisfy OSHA fines, your gun range could end up at risk.
It’s well worth taking the time to make sure any environmental firm you hire to salvage lead knows how to satisfy the regulations, keep their own and your employees safe and unharmed, and make sure your range is never at risk. Contact us today for more information.
Ways to improve your Health & Safety Plan (HASP) for Clean-up of Firing Ranges
There are a number of ways to improve your Health & Safety Plan (HASP) for Clean-up of Firing Ranges. This post includes three industry reference reports. The first one is:
#1 Range Maintenance and Cleaning Services Contract (p1-15)
The Range Maintenance and Cleaning Services Contract is an actual template from Lead Hazard Awareness and Maintenance CGTTP 4-11.6 for company use to update periodic maintenance services and range cleaning. Prior to Contractor Set-Up, the contractor follows these minimum requirements including but not limited to an additional applicable state, federal regulations, and any applicable DOD or DHS policies.
a. Contractor posts signs containing the minimum following language:
CAUTION LEAD WORK AREA NO EATING DRINKING OR SMOKING KEEP OUT!!
b. Signs posted at main entrance doors to the range and remain in place for duration of cleaning activities.
c. Secure area in front of range entrance doors with “CAUTION” tape.
d. Establish separate decontamination and waste collection areas (one per range).
e. Close all doors and vents to outside air sources including main door to each range area.
f. Establish and maintain air change every 15 minutes (each range remains under negative pressure at all times during cleaning operations) utilizing the Contractor’s HEPA filtered negative air pressure equipment and/or the ranges’ ventilation systems.
g. Contractor utilizes air monitoring equipment to record levels of airborne lead from both inside and outside the work zone.
Cleaning and Maintenance Synopsis:
Contractor completes cleaning and maintenance activities following schedule utilizing most current industry standards. Contractor completes and returns documentation as required by contract. Non-scheduled emergency cleaning services will be on as needed basis but will not exceed Level 1 planned cleaning requirements.
Firing range cleaning includes each firing line and report of results for each firing line. Ventilation system’s mechanics checked; clean air filter grates and replace air ventilation system; segregate used filters into containers; empty traps at deflector bases into waste container, de-cake deceleration chamber, turn over deflector plates, and clean out three lane granulated trap per Table One. Loose brass picked up and placed into designated container. (The USCGA empties containers of brass on as-needed basis.) Note: Under NO CIRCUMSTANCES are live rounds or casings placed into the waste stream.
HEPA vacuum dust and loose debris from trap area including end wall. Remove exhaust grates for access to main sub-floor ventilation trunk and HEPA vacuum visible/reachable areas of underground trunk per Table One.
HEPA vacuum dust and loose debris from ceiling, dividers, walls, entire floor, booths/baffles, deflectors, trap area, podium, floor exhaust grates, any stored items or equipment and other horizontal surfaces in range and adjacent to lobby areas. Utilizing mops or rags treated with 6% high phosphate detergent, Tri Sodium Phosphate (TSP), triple wipe the following, rinsing between each series:
- entire floor
- trap area
- floor exhaust grates
- any stored items or equipment and
- any other porous-free surfaces in the range and adjacent lobby areas.
Used mops, rags and other cleaning materials placed in appropriate container. Perform all cleaning work from a clean to dirty sequence working from the lobby areas to the gallery areas to the range areas and then the trap areas. Maintain cleanliness and avoid re-contaminating cleaned areas.
Measure and record airflow at the firing line, in each shooting lane at a height of one foot, three feet and five feet using a currently calibrated anemometer. Report results in writing in (CFM) Cubic feet per minute of air flow to the COTR or Weapons Officer. Final air flow readings no less than initial levels recorded at any location. (The USCG reserves the right to view any sampling.)
Report and document any observed problems and/or out-of-scope maintenance required to the COTR or Weapons Officer.
WASTE DISPOSAL PROCEDURES
DOT-shippable containers for any of the waste generated on-site by the Contractor. The waste segregated by category type in metal 55 or 30 gallon drums labeled with appropriate information. Contractor responsible for removal of all drums of recyclable materials, defined below, to a recycling facility pre-approved by the COTR. Hazardous waste drums moved to the Hazardous Waste Central Accumulation building (LT90DB) by the Contractor.
The remainder of this report reviews applicable documents, technical requirements, HEPA Filters, Spill and Releases, Contractor Furnished Items, Materials, Equipment and Services, and Contractor Access to Government-Owned Facilities, Equipment and Services, General Information, Management, and Check-in/out Requirements.
The details involved cleaning firing ranges establishes your HASP be improved and ready for problems occurring on-the-spot.
#2 Statement of Work (SOW) Template for a Small Arms Range (Department of the Navy)
The second Statement of Work (SOW) Template for a Small Arms Range Remedial Investigation and Feasibility Study (RI/FS) contain 23 pages of history, charts, and highlights areas you fill out to submit your report. This report covers more than firing range problems; it gives information for Chemical Warfare Material (CWM) and advises the contractor to immediately withdraw upwind from the work area, secure the site and contact the Navy RPM.
Documentation, written in detail, includes types of small arms ammunition projectiles, clay targets, and propellants. Descriptions property multiple sites (if more than one) and RI documents (including a Draft, Draft Final and Final RI Work Plan with the required appendices.)
Basic RI Work Plan describes general technique for performing the MC work site, including at a minimum:
- Site preparation, including vegetation removal and removal of surface metallic debris;
- MC sampling;
- Geographical Information Systems (GIS) and data management; and
- Investigation-derived waste (IDW) management.
Site Health & Safety Plan (HASP) prepares and submits by the contractor. The HASP contains an Activity Hazard Analysis (AHA) for each site-specific task conducted.
This report reveals plans for Project Management, Schedule, Meetings and Project Coordination, and Pre-Bid and Kickoff Meetings.
#3 Developing a Health & Safety Plan for Hazardous Field Work in Remote Areas (Journal of Occupational and Environmental Hygiene, December 2006).
And the last report, “Developing a Health and Safety Plan for Hazardous Field Work in Remote Areas” gives information of the traditional HASP required by the Occupational Safety and Health Administration (OSHA) Hazardous Waste standard designed for fixed hazardous waste site on which three zones are clearly delineated, allowing zones for staging, restricted entry, and decontamination.
The approach to creating HASP displayed in figures and written in documents on the potential contamination of coastal and marine environments by the expeditions. The resource goes into detail about liability and safety; the creation of HASP; HASP’s creation of the Document; the Document and its questions; and ending with a discussion.
These resources confirm you choose a contractor to clean your gun range under a comprehensive HASP program. Before hiring a contractor, interview and ask as many questions as possible regarding the contractor’s experience with HASP. Follow up with references to ensure you hired the best contractor and his team eliminates lead in your firing ranges.
To talk more about this please contact us. Thank you for your time and consideration.