Psst! Outdoor firing range here! Just letting you know that I appreciate that you’ve set up that Environmental Stewardship Program (ESP) to protect range participants, wildlife, and the environment from the serious hazards of lead. Now let’s look at outdoor firing range services.
I want you to know that my wildlife and I are breathing easier since you:
- Removed, remediated, reclaimed, and recycled the lead from my soil
- Decontaminated and controlled the flow of my water.
- Set up environmental controls such as ground covers, berms, and sand.
This means I’ll all be around for generations to come! I heard some community members talking about me. They have been observing all of the measures that you took to achieve environmental compliance. Now they believe that you care about the safety of the environment; as well as the people in and around the range! Nice job! I’m sure they’ll keep watch, but they sounded very pleased that you are now environmentally compliant.
That Health and Safety Plan (HASP) that you designed for me prevented additional damage to the environment and kept the hazards to people in check as you worked toward compliance. Your HASP will be a great guideline to maintain compliance on a daily, monthly, and annual basis. These are your Best Management Practices (BMP). FYI, your BMP includes an ESP and a HASP to satisfy requirements of the EPA, OSHA, NIOSH, CDC, not to mention state and local requirements and well…I know it’s a lot so thank you for maintaining my health and safety!
Also, I have noticed that the agencies in charge of regulatory enforcement recommend hiring certified lead reclamation/environmental remediation experts. This may be the easiest and most reliable way to assure that you satisfy and even exceed all regulatory requirements. These certified contractors already have the expertise, experience, and equipment. And, weighted against punishments you could receive for environmental law violations; why wouldn’t you hire an expert?
Did you know? Lead is a finite resource. That means there is only a certain amount of lead available. Recovering spent lead and sending it for reclamation and/or recycling can be a win-win for the environment and the range due to being able to recycle it for a fee!
Once you’ve cleared the water and soil of lead contamination from historic lead that was left in the environment, it’s time to maintain compliance. Best Management Practices (BMP) for an outdoor firing range are sustained practices which best reduce the impact of lead hazards on people and on the environment.
Did you know? The longer lead stays in the ground, the more likely it is to degrade and migrate to surrounding soil and into the water.
Newly spent lead that is recovered promptly is considered scrap metal; and is exempt from Resource Conservation and Recovery Act (RCRA) handling. Recycling/reclamation of the spent lead is an easy way to avoid a remediation issue and possibly benefit monetarily from ongoing clean-up.
Human lead exposure from the outdoor firing range is often the result of poor hygiene practices. Requiring best hygiene practices every day at the range will protect shooters at the range and prevent toxic lead from traveling to their homes on contaminated clothing, hair, and skin.
- Do not permit eating, chewing gum or tobacco, or drinking at the range. Lead dust that settles on the hands and face can be ingested. Wipe hands with lead removal wipes and wash thoroughly before eating, etc. Do not permit lead-contaminated clothing such as coveralls and PPE in break areas.
- It is best to have employees shower and change to street clothes before returning home. Provide coveralls that can be removed after shooting. Your range may have a separate laundry facility for washing lead-contaminated clothing. Remember: Lead-contaminated laundry water is considered hazardous waste and must be treated in accordance with all applicable laws.
Daily housekeeping may be required. Even outside, solid surfaces such as picnic tables can accumulate toxic lead. Just as with an indoor range, wet-mopping and HEPA filter vacuuming are the only approved lead clean-up methods.
Another way to regulate employee lead contact is with administrative controls such as employee scheduling. Limiting exposure in highly concentrated areas can reduce individual exposure to lead. Additionally, you must continue to provide properly fitting and functioning Personal Protective Equipment (PPE). Lead-contaminated HEPA filters (from both vacuums and PPE) and mop water are considered hazardous and require environmentally compliant disposal. Proper, legally required signage must be visible every day.
Monthly exposure monitoring:
Surprisingly, maintaining acceptable ambient air lead levels for outdoor firing ranges may require ventilation controls. Fixed external structures that inhibit airflow will necessitate ventilation controls.
Environmental controls all routine maintenance. Proper monitoring and cleaning of ventilation systems, including filters, will assure lead-free air flow. The frequency depends on multiple factors. A new system may be tested monthly for the first few months to assure complete and adequate ventilation. The ventilation system must be tested any time something changes that can impact the amount of lead dust produced. After that, annual monitoring may suffice.
Filter changes and vent cleanings are use-dependent; but are, at a minimum, required annually. Left unchanged; lead filters can expose personnel to additional lead exposure. Filters used in the control and cleaning of lead are considered hazardous waste and must be disposed of accordingly.
Along with annual blood-testing; water and soil analysis; personal space air testing; and personnel training, you should be prepared for workplace inspections by regulatory agencies. They may:
- examine the range and interview personnel
- assess environmental controls and PPE
- do their own exposure monitoring
- examine your medical and other records
- make suggestions and/or take corrective action as necessary
Since you are attending to every requirement; this inspection should be a lead-free breeze!
Cleaning Backstops on Your Firing Range
This step is vital as these structures provide the needed containment for bullets in outdoor ranges. Neglecting the backstops could encourage continued wear and increase the possibility for ricochet of the bullets from the build-up of lead shots. When removing the soil in earthen barriers and berms, the EPA recommends reclamation of the soil in contact with the lead.
Cleaning Sand Traps on Your Firing Range
Sand traps act similarly to backstops and berms. Cleaning them depends on the design, but cleaning involves sifting the sand to separate the sand from the pellets. After filtering, replace the sand back into the trap.
Preventing Lead Runoff at Your Firing Range
Water is another potential source of lead poisoning from outdoor ranges, and it may affect aquatic life forms if no measures exist. Deposits on the soil may find their way into water sources when it rains as surface runoff. Engineering controls minimize flow, but greener solutions such as planting grass that reduces the migration of the lead deposits also works.
Lead clean-up services should happen periodically because of the risk exposure to the users and workers in these areas. Enlisting the services of a professional goes a long way in achieving your goals.
Factors to Consider when Hiring a Firing Range Contractor for Your Firing Range
It is best to hire a professional because of the stringent standards and measures in place. Whether it is outdoor or indoor, the potential for lead poisoning in these ranges makes them a very critical place to work. These are some key factors to consider before you enlist the services of a contractor.
- The firm must have the necessary experience in constructing or remediation services. Companies like these often work with law enforcement or private ranges. So, before you hire one, check their portfolio for any successful projects. The experience is necessary for project development.
- Construction contractors must include a team of architects and engineers capable of meeting the building standards of firing ranges including soil erosion plan, wetlands, sound pollution, lead remediation, and cleanup measures.
- The firm should exhibit proper project management capability. This step involves adhering to quality standards as per the building and construction guidelines and complying with any environmental programs, especially those concerning lead remediation. You can review their quality control QA and QC plans
- In addition to compliance with environmental regulations, the contractor must meet the construction specifications through regular site visits and monitoring to ensure that work continues accurately and on schedule. The right contractor takes oversight seriously, and even when subcontracting, the subcontractor must meet all the requirements to carry out the project in a timely, accurate, and budget-specific manner.
- A good firing range contractor offers a range of services aside from construction including lead reclamation, erosion control, demolition and debris removal.
Critical validations you must demand from your contractor to protect you and your range:
- 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)
- Comprehensive insurance package:
- Minimum $5Million 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.
- 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.
- 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.
- 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, & disposal, Do NOT take the contractor’s word for it. Get it in writing.
Upon request, MT2 will immediately provide you with the above documentation.
MT2 Firing Range Services is the #1 largest most cost-effective nationwide professional indoor & outdoor firing range lead reclamation & maintenance contractor providing the highest value for your recycled lead.
Now in our 18th year in business,
MT2 Firing Range Services is a recent Inc. 5,000 fastest growing company and is well-known industry wide for being the nation’s #1 largest professional provider of the full scale of outdoor/indoor firing range environmental/maintenance/construction services at over 2,000
ranges nationwide for Law Enforcement, Military and Commercial ranges in all 50 states. When your range needs Outdoor Firing Range Services, no one reclaims more lead or finishes a project faster than MT2!!