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Owning and operating a gun range is a rewarding and enjoyable business. Teaching the shooting public proper gun handling and safety is an important undertaking and can ultimately save lives. The range owner’s responsibility is very broad and encompasses both the patrons and the employees of the business. Without following the guidelines and protocols established by OSHA that are provided to keep employees safe and healthy, a range owner can find themselves subject to monetary fines as reported earlier this year in the story “Gun range fined $15,000, accused of not protecting staff from lead exposure”
Rather than feeling uneasy that your range may be fined, we encourage you to keep a checklist of best-practices that you follow to make sure you are compliant. Here are a few points to keep in mind:
The OSHA guidelines are clear, as spelled out in 29 CFR 1910.1025. A written plan must be established that complies with the federal regulations designed to educate, monitor and remediate any lead exposure over the permissible exposure limits (PEL). This plan must be updated at least annually. Finding a firing range lead reclamation firm that will keep you compliant with the regulations and rules is an easy way to mitigate any problems down the road.
The last thing that any responsible business owner wants to see is his employees suffering a physical injury at the workplace. When it comes to lead exposure, extra diligence is required because the employee may not be the only person affected by lead exposure. Lead dust can stick to clothing and be transported to the employees’ home. Removing clothing can release the lead dust into the air and endanger family members, and as everyone knows, young children are one of the most susceptible groups to lead poisoning.
Gun ranges must keep detailed records on the monitoring of lead in both the facility and employees. The employees must be routinely tested to ensure their blood lead levels are below the established threshold. Proper air monitoring must be conducted regularly and documented. The bottom line is that complying with OSHA rules for your range employees is much easier and less costly than dealing with any fines that will impact your business and your reputation.
For your protection, you must always maintain on-site written records of your lead and contaminated waste disposition!
· Certain responsibilities include but are not limited to:
Determining the nature of the waste – Is it hazardous or non-hazardous?
To determine where the waste can go, you must first determine if it is hazardous or non-hazardous for purposes of disposal. Under most circumstances, a Toxicity and Characteristic Leachability Procedure (TCLP) test is performed. If TCLP testing is not performed, the waste is considered a hazardous waste, unless proven otherwise. Depending on the TCLP test results, you now know what type of waste you have, and can now consider options on how to properly dispose of it. (California residents, please note that a different analytical method applies).
Note: Even if your lead waste “passes” the TCLP test, it is still considered lead waste and is deemed “special waste” by (Subtitle D) landfills. They may accept your waste, but only under a different program than what they provide under municipal services. Do not EVER throw your lead waste into the regular garbage!
· Properly managing waste while it is onsite
At a minimum, all generators must ensure that their waste is properly containerized, labelled, and staged while awaiting transport to the disposal facility.
· Documentation
The generator is responsible for documenting the amount and type waste that they have generated. It is also their burden to ensure that their waste was managed, transported, and disposed of appropriately. This is done by maintaining thorough documentation of the “cradle to grave” process. A fully-signed manifest contains most of the important information that should be retained for such records. (link here for more info on manifests).
MT2 is the #1 and Largest Nationwide Professional Firing Range Lead Reclamation and Maintenance Contractor for both indoor & outdoor ranges. MT2’s proven record of services includes: complete firing range maintenance & improvements, lead remediation services, lead reclamation, OSHA & environmental consulting, operational maintenance and range closure.
MT2’s 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 an Environmental or firing range lead reclamation project quicker and safer than MT2. Contact us today for a free firing range analysis, complete our online range questionnaire.
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