April 17, 2018
Lead-Impacted Waste Disposal Part I – Documentation
Properly documenting how your firearms range disposes its lead waste is a crucial component of your business’ everyday processes. We spoke with MT2 Firing Range Services’ Senior Range Engineer Rob Anderson to learn more about how this documentation can be best accomplished. This first of two parts will focus on your range’s disposal manifest.
Zach Snow(ZS): Rob, would you give us an overview of what a manifest is and how it is used?
Rob Anderson (RA): A manifest is a document that tracks the disposal of waste, and it is important because it is part of your range’s “cradle-to-grave” processes. It is the document that follows, records and serves as the final documentation for the cradle-in other words, it tracks the lead-impacted waste originating with the generator, then documents all steps of the transportation process until it goes to the disposal facility (the “grave”).
The manifest is a tool used by regulators to enforce regulations. It is also a tool used by generators to substantially prove that they are correctly following the rules. So, it’s a critical document for the range owner whose range is the generator of the waste. That owner can provide their manifest to regulators who come to their facility and question their lead waste management practices.
ZS: What information should be contained on such a manifest?
RA: A manifest will have the name of the generator, i.e., the name of the firing range. (It’s important to note that the waste that comes from your site is your waste. Do not let a contractor performing lead recovery at your site tell you that because they are doing the work, that they are the generator of the waste. That is not true.) There is also a section where the waste is identified, which includes the type of waste being disposed of and the type and quantity of containers are containing the waste. As an example, a manifest could indicate that you have one drum of personal protective equipment (PPE), one cubic-yard box of spent filters, one five-gallon bucket of cleaning solvent used to clean the firearms, etc. These items would be laid out line-by-line to detail exactly what the waste is.
Finally, every manifest will have a line for the transporter. This is the person/agency qualified to transport the type of waste that the range has documented on the manifest. The transporter of hazardous waste must be a certified carrier, and such certification typically requires a DOT number.
ZS: Where do you get the hazardous waste forms? Is it something you order from the EPA as a download?
RA: You can obtain what’s known as standard, blank or generic hazardous waste and nonhazardous waste manifests as printed forms from a waste disposal facility, both those that handle hazardous and nonhazardous waste disposal. Manifests are typically multi-copy carbon copy, so not downloadable off the internet. However, every landfill I have talked to can provide blank manifests. They can also provide pre-printed manifests.
ZS: What distinguishes a bill of lading from a manifest?
RA: A bill of lading has information similar to that of a manifest, in that it identifies where the waste is coming from, who is transporting it and where it’s going. It also specifies the type and quantity of the material. What it does not do, though, is recognize the nature of the material. A bill of lading is typically used for goods that hold a specific value, what we like to call “commercial value.” By definition, a bill of lading is not used in the transportation of lead and other hazardous firearms range waste, rather a bill of lading is involved in the transport of goods.
An excellent example for a firing range is when you have lead recovery being performed on your site. There you are collecting a recoverable type of lead that is being put onto a truck and transported to a recycler. That particular lead is transported under a bill of lading, because the material that’s being transported is a recyclable material. It’s considered a good because it holds commercial value. Regarding disposal, there is no other item than a manifest. If somebody shows you anything other than a standard manifest for disposal of your waste, they are not providing you appropriate documentation. A bill of lading is not an appropriate document for showing waste transportation and disposal, nor is a cover letter from the owner of the disposal site company.
MT2 Firing Range Services is a leading provider of indoor and outdoor firing range lead reclamation and maintenance contractor. Now in its 18th year, MT2 offers full-scale outdoor and indoor firing range environmental, maintenance and construction services at more 2,000 ranges nationwide, and for law enforcement, military and commercial ranges in all 50 states.