What Is a Best Management Practice and
How Does It Apply to Shooting Ranges?
A Best Management Practice (BMP) is usually
based on an approach or technology that has
been shown to work and to be effective for the
purpose intended. The United States Environ-
mental Protection Agency (EPA) uses BM.Ps to
specify standards of practice where a regulation
may not be descriptive enough to do so. A BMP
should also be as inexpensive as possible and the
equipment or technology should be readily-
available. A BMP may be adopted based on a
survey of practices (shooting ranges in this case)
that have had successful experiences with an
approach or technology.
BMPs for outdoor shooting ranges are actions
that range owners/operators can take to mini-
mize the impact of lead on the environment.
Lead at outdoor shooting ranges may pose, in
certain situations, a threat to the environment if
BMPs. including reclamation and recycling, arc
not implemented in a timely manner.
What Is the EPA Best Management
Practices for Lead at Outdoor Shooting
Ranges manual?
The Best Management Practices for Lead at
Outdoor Shooting Ranges manual provides owners
and operators of outdoor rifle, pistol, trap, skeet and
sporting clay ranges with information on lead
management at their ranges. The manual explains
how environmental laws are applicable to lead
management and presents successful BMPs available
to the shooting range community. These practices
have been proven to effectively reduce lead
contamination. Since each range is unique in both the
type of shooting activity and its environmental
setting, site-specific solutions are not provided in the
manual. Rather, range owners or operators may use
the manual to identify and select the most appropriate
BMP(s) for a range. The manual does not address
range layout or design to meet range safety or
competition requirements. It is also not intended for
closing ranges. Range owners/operators are directed
to other comprehensive reference materials available
on that subject, from the National Rifle Association of
America, National Shooting Sports Foundation and
other shooting associations.
Owners/operators of ranges may want to assign
the implementation of this BMP Manual to a specific
team or committee if possible. Delegating this
responsibility to a specific team or committee helps to
assure that the work gets accomplished.
The manual is organized as follows:
Chapter I provides the background on why lead is
of concern to human health and the environment.
It includes a discussion of how environmental
laws impact shooting ranges and the importance
of an integrated BMP program to manage lead;
Chapter II discusses range physical and
operational characteristics to be considered when
selecting a successful BMP program;
Chapter III addresses BMPs for rifle/pistol
ranges, trap and skeet ranges, and sporting clay
ranges. In this chapter, the manual explores
possible solutions to prevent, reduce and/or
remove lead contamination for each type of range;
The Appendix provides current (as of May 2000)
contacts for lead reclamation and recycling
companies, other sources of information on lead
management, bullet trap manufacturers and key
RCRA regulator}' interpretations.
How Is Lead Shot Regulated Under the
Resource Conservation and Recovery Act
(RCRA)?
Lead shot is not considered a hazardous waste
subject to RCRA at the time it is discharged
from a firearm because it is used for its intended
purpose. As such, a RCRA permit is not
required to operate a shooting range. However,
spent lead shot (or bullets) are subject to the
broader definition of solid waste written by
Congress and contained in the statute itself. As
such, spent shot and bullets are potentially
subject to RCRA statutory authority including
section 7002 and 7003.
In general, the following points should serve as
guidance in understanding RCRA and how it
applies to your range.
1. The lead, if recycled, Is considered a
scrap metal pursuant to 40 Code of
Federal Regulations (CFR)
261.6(a)(3)(ii) and is therefore exempt
from RCRA regulation.
2. After the removal contractor or
reclaimer applies standard BMPs to
separate the lead from soil, the soil may
be placed back on the range without
further treatment.
3. The collected lead shot or bullets are
excluded from RCRA regulation, and need
not be manifested, nor
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does the range need to obtain a RCRA
generator number (i.e., the range is not a
hazardous waste "generator"), provided that
the leadshot is recycled or re-used. The
transporter does not need to have a RCRA
I.D. number . However, ranges should retain
records of shipments of lead from the range,
and the facilities to which they were sent, in
order to demonstrate that the lead was
recycled.
4. Sections 7002 and 7003 of the RCRA statute
allow the USEPA, states or citizens, using a
civil lawsuit, to compel cleanup of "solid
waste" (e.g., leadshot) posing actual or
potential imminent and substantial
endangerment. Such action can be sought
whether the range is in operation or closed,
and is based solely on a determination that
real or potential harm is being posed by the
range to public health and/or the environment.
Since the risk of lead migrating increases
with time, ranges that have not removed
leadshot are more likely candidates for
government action or citizen lawsuits under
RCRA Section 7003. Therefore, ranges are
advised to maintain a schedule of regular lead
removal.
Benefits of Lead Management
Lead removal and implementation of other
BMPs will allow the range to: minimize
contamination of the range and potential
impacts to human health and the
environment; reduce liability with regard to
potential agency or citizen lawsuits; possibly
benefit economically from the recycling of
lead; enhance its role as a good steward of
the environment; and increase customer
satisfaction.
Want More Information?
For a copy of the USEPA Best
Management Practices for Lead at Outdoor
Shooting Ranges, please complete the informa-
tion below and fax or mail to:
Leadshot Coordinator
RCRA Compliance Branch
U. S. Environmental Protection Agency
Region2
290 Broadway- 22nd Fl.
NewYork,NY 10007-1866
Fax: (212)637-4949
E-Mail: LeadshotRegion2@epa.gov
The manual will also be placed on the world
wide web at www.epa.gov/region2/waste/
leadshot.
Name:
United States Environmental
Protection Agency - Region 2
EPA-902-F-00-001
Do You Use Best Management
Practices for Lead at Your
Outdoor Shooting Range?
Address:
Phone:
Cover photo by: Mr. Jack Hoyt
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