I am a member of a league that shoots static steel targets. I also went out and bought some plates to use for practice. The league uses only AR plate, 400 or 500 bnh. The targets I purchased are also AR plate, I believe they are AR400. The reason for using the AR plate is that the hard plate does not "dimple" like standard carbon steel. Those dimples allow the bullets to ricochet in all directions. In addition, standard A36 plate will also "dish or cup" from being shot repeatedly on the same side. I have seen 9mm's loaded with lead bullets put dimples in standard A36 steel plate(3/8" thick), so while the 9mm major and 38 super loads certainly do quite a bit of damage to non-hardened plate, even lead bullets can be a problem.
If I were the owner of a fab shop, or even an employee making targets on the side, I would insist on supplying only the AR 400 or 500 plate, just to stay away from liability issues.