Lessons to Be Learned

How an industry giant manages lead at its ranges

Henry Poulin, safety and environmental manager for Colt companies, says a good lead-management program isn't cost prohibitive.

By Douglas S. Malan

Everything about Colt's Manufacturing Company and Colt Defense is massive.

Housed together in a 263,000 square-foot facility, the West Hartford, Conn.-based operations comprise one of the largest gun factories in the world for the civilian, defense and law enforcement markets in the U.S. and worldwide. From pistols to machine guns, the Colt companies design, develop and manufacture some of the most technologically progressive firearms found anywhere.

Of course, a vital component of their operations involves managing the lead generated by firing millions of rounds each year in their indoor military, commercial and research ranges. For example, Colt Defense alone fired more than six million rounds, predominantly 5.56mm NATO, in 300 days in 2009. With the accompanying handgun loads of various calibers and brass casings, the companies have implemented an aggressive and comprehensive plan for managing and recycling their respective waste from a fired round.

Considering the scale of their operations, what can a typical indoor civilian range learn from these major gun manufacturers? Quite a bit actually.

Though the volume of lead produced by any civilian range is a fraction of the Colt ranges', the techniques and policies used by Colt are applicable to ranges of any size, just as OSHA regulations govern ranges of every size.

"Even for the common range operator, it's not just the ventilation, it's the hygiene component as well," said Henry Poulin, safety and environmental manager for the Colt companies. "A good lead-management program doesn't have to break the bank. It's education, soap and water."

By taking note of these points from Colt's state-of-the-art operations, range operators "can easily achieve compliance" with OSHA regulations, Poulin noted.

Conscientious sensitivity
The overall key to maintaining a safe shooting range is to reduce exposure to lead and use responsible lead-disposal methods to prevent any adverse impact on the environment. From the use of water traps to detailed cleaning policies and air- and water-filtration systems, the Colt companies employ several strategies that other range operators can emulate.

Above: A row of brass casings ready to be recycled. Below: The exterior of Colt's water trap. Bullets enter the square opening and then deflect off of heavy iron plates inside before coming to rest in a heavy-duty basket submerged in water.

"Colt has a culture of sensitivity to the health and environmental issues involved with lead," Poulin said. "We want people to understand what we do so they can improve their operations."

Lead compliance program
Beyond the OSHA requirements (see sidebar on page 20 for more details), Colt's policies include specifics for managing lead. First, all cleaning must be done wet using mops, towels and de-leading spray cleaner. Those materials should then be disposed of properly in receptacles approved to handle hazardous waste.

It's important to avoid using a broom or compressed air to clean surfaces because lead particles would be scattered. Range employees should be certified in lead training and should clean the range following a regular schedule and activity log. At every opportunity, range operators should make sure surfaces are smooth and flat for easier cleanup, and cloth upholstery should be avoided.

"Surfaces that customers come in contact with can be easily cleaned at any time," Poulin said. "Don't allow food and drinks anywhere near the operation [the actual shooting site]. That's another pathway for ingestion."

Range-equipment safety
Regularly checking the condition of your range's equipment is vital to controlling lead exposure.

"I know that sounds simple, but it's often overlooked," Poulin said. "A shooting range is a destructive environment. Take time to do the maintenance. What you're shooting into has to be looked at all the time."

Patrick Rittmon, the Colt Defense range master, explained the twice-daily process of monitoring the water traps' large iron plates to ensure that none are breached during heavy-duty gun testing.

"We hang our hat on our safety policies," said Rittmon, a retired gunnery sergeant in the Marine Corps. "All of the safety processes are just as important as shooting the gun."

Also, sand barriers are positioned behind water traps as an additional safeguard to protect from round penetration. Water runs through the shooting tubes to keep gunpowder from dispersing in the air or igniting.

Range operators should ensure that backstops or other suitable materials are in place to prevent round penetration in unwanted areas.

"Of course, fireproofing is a major consideration," Poulin emphasized.

Lead recycling and reclamation
The amount of lead waste and brass casings that Colt operations generate is staggering. Spent lead fills huge 55-gallon drums that are trucked away for recycling. Brass casings pile up several feet deep in cardboard boxes large enough for at least two adults to stand in without touching.

Indoor commercial ranges don't need to manage lead and brass on that scale, but they should make smart decisions about recycling the waste, Poulin notes.

"Make sure the facility you hire [to haul away the lead] is using the lead responsibly," he said. "For each shipment, we get back a certificate of recycling that indicates the lead has been sent to a smelter."

Lead and brass can be sold and recycled just like scrap metal, so some shooting ranges could see a monetary benefit to their efforts, depending on their volume of waste.

Patrick Rittmon, Colt Defense range master, says, "We hang our hat on our safety policies."

Ventilation control
OSHA requires some form of ventilation for all indoor shooting ranges. The Colt ranges use super high-efficiency HEPA filters that remove 99.999 percent of all lead particles from the air as their various guns are fired.

Air-quality monitoring, in general, can pose significant costs to range operators, but Poulin said there are some ways to mitigate the expense.

"If you're running the same type of operations, performing the same type of cleaning procedures and such as nearby ranges, you may be able to share air-quality data monitoring with those ranges" to comply with OSHA regulations, Poulin said.

The important thing is that the data is a match for your operation. He suggests checking with ranges in your area or going to www.wheretoshoot.org to locate similar ranges to inquire about data-sharing.