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Is Your Firing Range in Compliance with OSHA, EPA & RCRA with Required Regular Maintenance?
When Was the Last Time Your Firing Range had the Lead Removed? Are you willing (and able) to take this risk just to save a little money?
Keep in mind: under certain specific circumstances, range solid waste impacted with lead can be a RCRA Hazardous Waste. What does this mean for your range?
Improperly managed range soil or other backstop material, along with incorrectly collected, containerized and stored lead bullets or shot can trigger RCRA hazardous waste requirements and obligations for your range.
o Does your range cleanup and contractor crew really know what they are doing?
o Can they accurately communicate and prove to you, the range Owner/Operator, how they are keeping you out of a possible compliance nightmare situation with potentially thousands of dollars in fines and penalties?
Sections 7002 and 7003 of the RCRA statute allow EPA, states or citizens to use civil lawsuits, to compel cleanup of or other action for “solid waste” (e.g., spent lead shot) posing actual or potential imminent and substantial endangerment. Since the risk of lead migrating increases with time, making ranges that have not removed lead more likely candidates for government action or citizen lawsuits under RCRA Section 7002 and 7003, ranges are advised to maintain a schedule of regular lead removal.
You may think that the job is done when your contractor rolls off of your property and tells you they will handle the lead and lead-waste… but as a matter of fact, you could be facing a painful EPA investigation by taking their word for it. Lead contaminated soil and waste (paper, PPE, filters, debris etc.) is commonly determined to be RCRA hazardous waste.
Your range may be liable for the negligent actions of the contractor you choose.
The Environmental Daily Advisor reported that there are 7 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.” Think about it, did you know this can be a criminal offense?
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?
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.
This is what is commonly known as: “Cradle (generating the hazardous waste) to Grave” (disposal of the hazardous waste)
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.
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.
1. Contractor must be able to document, with audited financials, sufficient company assets that could allow it to sustain defending a claim or actual violation without going bankrupt.
(Suggested is minimum $500,000 and preferred is $1,000,000)
2. 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.
3. Comprehensive contract with FULL owner-indemnification to protect and defend against all contractor activities and a list of 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 for all transport and disposal. Do NOT take the contractor’s word for it. Get it in writing.
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.
MT2 is the #1 and Largest Nationwide Professional Lead Reclamation Contractor for BOTH Indoor & Outdoor Firing Ranges.
MT2’s patented ECOBOND® lead treatment technology, prior EPA approved, has been used on over 10 million tons of waste; providing 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, serving over 1,000 public and private indoor and outdoor firing ranges nationwide since 2000.
MT2 carries $8,000,000 of General AND Lead Pollution Liability & Worker’s Comp Insurance
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.
Over the past decade, MT2 has recycled over 10 MILLION tons of lead, returning over $4 Million dollars to ranges owners without a single regulatory violation, while working closely with range owners to implement firing range Best Management Practices (BMPs).
No one can complete your project quicker than MT2!
Getting the lead out since 2000! Our extensive field experience, outstanding safety record, and advanced ECOBOND® technology has positioned MT2 as a national leader in providing Firing Range Services, Remediation, and overall Construction Services. This has been proven in all 50 states on over 1,000 projects involving over 1,000,000 tons of hazardous and environmentally impacted soil, waste, and debris. More About MT2 >
In the beginning, God created the heavens and the earth... The earth is the Lord’s and all it holds, the world and those who live there.
Our Passion: MT2 personnel are passionate about cleaning and restoring our environment, protecting people from the hazards of lead, and in serving and protecting those who serve and protect us, whether in the military or in law enforcement.
Our Vision: To be the premier specialty environmental services company known for our high level of service and integrity with a higher purpose.
Our Mission: MT2's mission is to deliver a competitive service experience to our clients, characterized by excellence in performance, safety, and environmental protection; producing a sustainable rate of return to shareholders; and established on a foundation of principles and values commensurate with our calling.