MT2 “Liability Defender” Compliance & Performance Promise

Your Choice of a Lead Reclamation Contractor Could Expose Your Firing Range to EPA Hazardous Waste Fines up to $50,000 per DAY and Potential Criminal Charges. (penalties double for subsequent violations)

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.

5 critical validations you must demand from your firing range lead reclamation contractor to protect you and your range:

For your protection, your lead reclamation contractor must have sufficient assets and environmental liability coverage to protect range ownership from claims or occurrences of violations, penalties and cleanup expenses due to contractor negligence…even if it is not intentional! These points are critical because a contract indemnification from a BANKRUPT contractor is not worth the paper it’s written on. Why would they go bankrupt? Because of OSHA or EPA violations and fines that they could not pay or resulting from: Under capitalization, Shoddy regulatory compliance, Volatility of lead pricing or Under-bid projects.

1. Contractor must be able to document, with audited financials, sufficient company assets that could allow it to sustain defending you against a claim or actual violation without going bankrupt. (Suggested is minimum $500,000 and preferred is $1,000,000)
2. Comprehensive insurance package:
   -Min. $5 Million General AND Pollution Liability. Pollution Liability is 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. Comprehensive contract with FULL owner-indemnification to protect and defend against all contractor activities and a list of all prior regulatory agency violations, fines or penalties from any Agency.
4. Minimum 5 years (preferably 10 years) of continuous operating history with business registrations with minimum five prior similar projects successfully completed in the last 3 years.
5. Comprehensive written work and safety/health plans specific to the range and a detailed waste-management plan describing actual activities to occur, and providing certification and DOT Manifests for all transport and disposal. Do NOT take the contractor’s word for it. Get it in writing.
   {Upon request, MT2 will immediately provide you with ALL of 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.

You Operate a Firing Range. We Get the Lead Out!

MT2 Firing Range Services is recognized industry wide for being the nation’s #1 largest professional provider of the full scale of outdoor and indoor gun range cleaning, environmental, maintenance and construction design/build services.
We have a Lead Management Plan that gets the job done right the 1st time with zero-tolerance for regulatory violations.
Clients who work with us have the peace of mind that their project will be effortlessly scheduled, successfully completed with minimal down-time for their range, and quickly receive a check for the absolute highest value for their reclaimed lead!
MT2 guarantees to pay you between 60% – 80% of LME for your lead at the time of service – no one pays more than MT2!

• MT2’s patented ECOBOND® lead treatment technology, prior EPA approved, has been used on over 15 Million tons of lead 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 $10,000,000 of General AND Lead Pollution Liability & Worker’s Comp Insurance.
• Over the past decade, MT2 has recycled over 15 MILLION tons of lead, returning over $5,000,000 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!

Research sources:
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