In Mexico, people smelt range lead and wheel weights in the backyard, with no protective gear of any kind. The New York Times recently commented on crude lead extraction methods employed in impoverished Mexican neighborhoods where people have no idea how easily lead contamination spreads. With recent media focus on lead poisoning, no range owner can afford connection to stories like this Seattle Times piece on police range lead poisoning, or this story on the lead dangers encountered on any of America’s 6,000 shooting ranges.
There is little regulation governing environmental control on gun ranges, but lead contamination contracted on gun ranges impacts both customers and range employees who can then carry contamination home to their families. Unless a conclusive blood-test shows an employee has lead poisoning, OSHA typically will not examine a gun range, yet this OSHA press release documents a long list of safety violation citations and penalties incurred by an Illinois gun range in 2012. Proposed penalties in this case totaled a whopping $111,000.
The onus for safety will fall squarely on range owners. Failure to clean the range will eventually necessitate costly remediation; delaying will invite litigation from customers, employees, and outside contractors, including any under-qualified site cleaners hired for reclamation activity.
Reclamation companies must demonstrate an understanding of how lead is concentrated over a range site, especially if the site is hilly, rocky, full of clay or otherwise difficult to clean. If the range is indoors, the company needs expertise in cleaning ventilation systems. If a company cannot give an accurate estimation of the types of cleaning needed, the time cleaning will take, and the frequency with which the site will need cleaning, it will ultimately deliver a larger-than-expected bill.
A top-notch reclamation company should work within the shooting range schedule rather than disrupt guest activities during normal working hours. They should work field-by-field in order to accommodate any special events, and should explain how reclamation activity will affect existing vegetation. Disruptions in guest activity and surprise landscaping jobs can result in significant loss of revenue.
Reclamation companies must be insured and bonded; they are responsible for preventing blow-off or run-off of lead particles from the site. A reclamation company must show responsibility for possible deleterious
4 critical validations you must demand from your contractor to protect you and your range:
1. Contractor must be able to document (audited financials) sufficient & substantial company equity that could sustain defending a claim or actual violation without going bankrupt. (min. recommended $500,000)
2. Comprehensive insurance package:
Minimum $5Million; General AND Pollution Liability (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. List of prior regulatory violations, fines or penalties from ANY Agency and well documented contract with FULL indemnification.
4. 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.
Upon request, MT2 will immediately provide you with the above documentation.
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