Health Hazard Evaluation Report 2016-0079-3289 Page 1

Evaluation of Ventilation and Employee 

Exposures to Lead at an Indoor Firing Range

HHE Report No. 2016-0079-3289

September 2017

Mark M. Methner, PhD, CIH
Page 2 Health Hazard Evaluation Report 2016-0079-3289

Contents

Highlights...............................................i

Abbreviations ..................................... iii

Introduction......................................... 1

Methods ............................................... 2

Results .................................................. 3

Discussion ............................................ 7

Conclusions.......................................... 8

Recommendations............................... 8

Appendix A.......................................... 10

References.......................................... 18

Acknowledgements........................... 23

The employer is required to post a copy of this report for 30 days at or near the 

workplace(s) of affected employees. The employer must take steps to ensure 

that the posted report is not altered, defaced, or covered by other material.

The cover photo is a close-up image of sorbent tubes, which are used by the HHE 

Program to measure airborne exposures. This photo is an artistic representation that may 

not be related to this Health Hazard Evaluation. Photo by NIOSH.
Health Hazard Evaluation Report 2016-0079-3289 Page i

We evaluated employee 

lead exposures at an indoor 

public firing range. We found 

a clean, well maintained and 

organized operation. No 

airborne overexposures to lead 

were found. The ventilation 

system operated within 

performance guidelines. Small 

amounts of lead were found 

on some surfaces and on 

one employee’s hands upon 

arrival for work. Increased use 

of a lead removal solution for 

surface and floor cleaning 

and lead removal hand wipes 

should reduce the possible 

spread of lead contamination. 

Highlights of this Evaluation

The Health Hazard Evaluation Program received a request from an employer representative 

at an indoor firing range. The request concerned potential employee exposure to lead 

during routine tasks and range cleaning activities. The employer also wanted to know if the 

ventilation system met the National Institute for Occupational Safety and Health guidelines. 

We evaluated the firing range in June and October 2016.

What We Did

● We observed the work area and employee work practices, including range cleaning and 

use of personal protective equipment.

● We collected full-shift and task-based personal air 

samples on employees and area air samples 

for lead.

● We tested surfaces inside and outside the range 

for lead.

● We tested employees’ hands for lead before 

and after range cleaning, and at the end of the 

workday before they left the range.

● We evaluated the range ventilation system.

● We reviewed the company’s respiratory 

protection program, medical monitoring 

program, and standard operating procedures 

related to lead cleanup.

What We Found

● Employees were not overexposed to airborne lead. 

● The firing range and areas outside of the range 

appeared clean and well maintained.

● Employees used appropriate personal protective 

equipment during range cleaning tasks.

● In general, more lead was found on surfaces inside the range than outside the range. 

● One employee had lead on their hands on arrival at work and before cleaning the range. 

● The ventilation system was performing according to guidelines from the National 

Institute for Occupational Safety and Health.

● The company demonstrated a strong commitment to proper health and safety practices 

as well as maintaining written standard operating procedures and policies to protect 

employees and customers from lead exposure.
Page ii Health Hazard Evaluation Report 2016-0079-3289

What the Employer Can Do

● Clean surfaces and floors that employees and customers routinely contact more 

frequently with a lead removal solution. To keep contamination as low as possible, 

cleaning efforts should focus on certain areas such as the armorer workbench, tables 

inside the range, customer lounge tables, and the floor outside the range exit door.

● Require employees to use lead removing wipes frequently, especially when exiting the 

range, after range cleaning, and after handling firearms or ammunition.

● Consider using a lead-certified laundry service or providing a dedicated onsite, washer 

and dryer to clean employee uniforms. This will help prevent take-home exposures.

What Employees Can Do

● Clean your hands with lead-removing wipes or lead removing soap each time you leave 

the range. Clean your hands with regular soap and water before eating while at work. 

● Wear nitrile gloves when handling ammunition at work and outside of work, and use 

lead removal wipes on your hands after you remove your gloves.

● Shower before leaving work, especially after conducting weekly “deep” range cleaning tasks.
Health Hazard Evaluation Report 2016-0079-3289 Page iii

Abbreviations

μg Micrograms

μg/dL Microgram per deciliter

μg/m3 Micrograms per cubic meter

cm2 Square centimeter

ACGIH® American Conference of Governmental Industrial Hygienists

BLL Blood lead level

CFR Code of Federal Regulations

HEPA High efficiency particulate air

MERV Minimum efficiency reporting value

NIOSH National Institute for Occupational Safety and Health

OEL Occupational exposure limit

OSHA Occupational Safety and Health Administration

PEL Permissible exposure limit

REL Recommended exposure limit

TLV® Threshold limit value

TWA Time-weighted average
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Health Hazard Evaluation Report 2016-0079-3289 Page 1

Introduction

The Health Hazard Evaluation Program received a request from an employer representative 

at a public indoor firing range. The request concerned potential employee exposure to 

lead during routine range tasks and weekly range cleaning. Other concerns included the 

performance of the ventilation system and whether lead was migrating from the range 

to other areas of the building. In June 2016, we met with the employer and an employee 

representative to discuss the request, conducted a walk-through survey of the range to 

speak with employees and observe their work practices, collected full-shift personal and 

area air samples for lead, and reviewed the company’s health and safety policy documents. 

In October 2016, we collected task-based and full-shift personal air samples for lead on 

employees during routine range tasks and weekly range cleaning activities. We also collected 

hand wipe samples for lead from employees before and after weekly range cleaning and also 

at the end of the work shift. Only one range, consisting of 10 firing lanes, was in use during 

both site visits. On the days we collected samples, the company indicated that the number of 

customers using the range was normal. We did not evaluate bullet trap cleaning because it 

was performed by a contractor. A summary letter outlining preliminary findings was sent to 

the employer and employee representatives after each site visit.

Background

The newly constructed building opened in February 2016 and has two 10-lane firing ranges, each 

with its own ventilation system and crumb rubber bullet trap; a retail sales area and customer 

lounge; classrooms, locker rooms, and restrooms; an armory/repair area; and a martial arts studio. 

Areas outside the ranges, such as the retail sales area and customer lounge, were cleaned daily by 

employees using a solution of D-Lead® and water. “Sticky mats” were in place at the doorway 

between each range and the retail sales area. Daily cleaning inside the range by some employees 

included using a floor squeegee to gather spent shell casings and picking them up by hand while 

wearing nitrile gloves. Other daily cleaning tasks included vacuuming and mopping the floor and 

wet-wiping tables and other surfaces. Employees conducted a weekly “deep” cleaning and 

maintenance of the range from the firing line to the bullet trap using a high efficiency particulate 

air (HEPA) filtered vacuum, wet floor scrubber, and a lead removal solution (D-Lead). The 

weekly cleaning took about 1.5 to 2 hours to complete and was performed before the ranges were 

opened to customers. Details on the cleaning methods and the personal protective equipment 

worn by employees are provided in the Results section of this report.

We evaluated the following job titles:

1. Retail sales leader. This employee managed the sales counter, merchandise area, and

retail showroom, and assisted customers with weapon and accessory purchases. This

employee occasionally entered the firing range to let shooters test fire weapons.

2. Range safety officer. This employee monitored shooters inside the range, providing

instruction on proper firing technique and weapons handling practices, inspected

weapons and ammunition for compliance with range policies on type and caliber,

and helped shooters clear weapon jams or other malfunctions. Other duties included
Page 2 Health Hazard Evaluation Report 2016-0079-3289

occasional range cleaning activities, such as operating a HEPA-filtered floor vacuum 

or wet floor scrubber.

3. Sales counter person. This employee handled transactions involving the purchase of weapons,

accessories, ammunition, and range time. This employee also conducted surface cleaning 

activities inside the showroom and customer lounge using a lead removal solution. Other 

duties included range cleaning using a HEPA-filtered floor vacuum or wet floor scrubber and 

wiping surfaces inside and outside the range with a lead removal solution.

Methods

The objective of this evaluation was to determine if the range employees were exposed to 

lead above recommended levels. To achieve this objective, we (1) measured employees’ personal 

exposures to lead in air during routine work tasks and during weekly range cleaning; (2) measured 

airborne lead concentrations behind the firing line and in the center of the retail sales area; (3) 

measured lead on surfaces inside and outside the firing range; (4) measured lead on the hands 

of employees upon arrival at work right before range cleaning activities, immediately after 

range cleaning activities, and at the end of the workday; (5) evaluated the ventilation system 

performance per National Institute for Occupational Safety and Health (NIOSH) guidelines; and 

(6) determined if work practices could increase employee lead exposure.

Full-shift and task-based personal air samples were collected for lead according to NIOSH 

Method 7306 [NIOSH 2017]. In June 2016, for full-shift air sampling, one sample was collected 

(either personal or area) for approximately 8 hours (Table 1). In October 2016, during weekly 

range cleaning activities, each person had two sequential air samples collected for lead. The first 

sample was collected for the duration of a specific weekly range cleaning task, followed by a 

separate second sample collected for the remainder of the shift. These two samples were used to 

determine an employee’s lead exposure during a weekly cleaning task and then to calculate the 

employee’s full-shift time-weighted-average (TWA) exposure to airborne lead (Table 2). 

Surface wipe samples for lead were collected at locations inside and outside the range using 

commercially available, colorimetric dust wipes (Full Disclosure® Instant Wipes, SKC Inc.) 

following NIOSH Method 9102 [NIOSH 2017]. These wipes are designed to produce a color 

change (turn pink/red) when lead is present above 18 micrograms (μg). We used a disposable 

100-square centimeter (cm2

) template to collect each surface wipe sample. For irregularly shaped 

areas such as a windowsill where a template could not be used, we estimated the sampling 

area. We used this same surface wipe sampling approach to collect a sample for laboratory 

measurement of lead on employees’ hands. To collect a hand wipe sample we asked employees to 

wipe their palms, between their fingers, and the backs of their hands for 30 seconds.

We visually inspected the air handlers, supply air diffusers, ductwork, and exhaust outlets 

for the firing range and used qualitative and quantitative methods to evaluate the airflow. 

We used a Rosco Laboratories Inc. Model 1500 aerosol generating machine to generate a 

propylene glycol-based aerosol “smoke” to visualize airflow patterns within the range. We 

generated smoke behind the firing line, at each shooting position, and at the front of the bullet 

trap. We used ventilation smoke tubes to determine if the firing range was under negative 
Health Hazard Evaluation Report 2016-0079-3289 Page 3

pressure relative to the retail showroom and other adjacent areas, meaning that air flowed into 

the firing range from surrounding areas. We used a Shortridge Instruments, Inc. electronic 

micromanometer to measure the air velocity in feet per minute at the firing line for each 

firing lane. We took three measurements (at 1 foot, 3 feet, and 5 feet above the floor) and 

averaged the measurements for each of the 10 lanes.

We observed work practices and use of personal protective equipment and reviewed the 

company’s written respiratory protection program and medical surveillance program.

Results

Air Sampling

Personal full-shift lead concentrations during routine work activities ranged from not 

detected (less than 0.3 micrograms per cubic meter of air [μg/m3]) to 0.57 μg/m3 (Table 1), 

and none exceeded the Occupational Safety and Health Administration (OSHA) permissible 

exposure limit (PEL), the NIOSH recommended exposure limit (REL), or the American 

Conference of Governmental Industrial Hygienists (ACGIH) threshold limit value (TLV) for 

lead, all of which are set at 50 μg/m3. The highest area air lead concentration (0.95 μg/m3) 

was from a sample collected inside the range on a table behind the firing line. Lead was not 

detected in an area air sample collected in the center of the showroom.

Table 1. Full-shift personal and area air samples for 

lead, June 2016 

Sampling 

time 

(minutes)

Concentration 

(μg/m3)

Personal air samples

Range safety officer 481 [0.57]

Retail sales leader 487 [0.39]*

Sales counter person 479 ND†

OSHA PEL 

NIOSH REL 

ACGIH TLV 

50

50

50

Area air samples

Inside range on table 

behind firing line 

474 [0.95]‡

Center of showroom 474 ND‡

*Values in brackets mean the concentration was 

between the minimum detectable concentration of

 0.3 μg/m3 and the minimum quantifiable concentration 

of 1.0 μg/m3. There is more uncertainty associated with 

these values.

†Not detected. Concentration is below the minimum 

detectable concentration of 0.3 μg/m3.

‡Value is for an area air sample and should not be 

compared to any PEL, REL, or TLV.
Page 4 Health Hazard Evaluation Report 2016-0079-3289

Personal air sample results for lead during weekly range cleaning activities were similar to 

those obtained during routine work activities, and none exceeded any occupational exposure 

limit (OEL) for lead (Table 2). The sequence of cleaning tasks was as follows: 

1. Gather spent shell casings using a floor squeegee and pick up with hands while 

wearing nitrile gloves.

2. Clean floor using a Nilfisk® Model S2 HEPA-filtered vacuum.

3. Clean floor using an Ecoflex® model SC750 wet scrubber.

4. Repaint ballistic baffles and perform general range maintenance.

Table 2. Task and full-shift personal air samples for lead during and after weekly range cleaning, 

October 2016 

Employee tasks Sampling time 

(minutes)

Task-specific 

concentration 

(μg/m3)

Full-shift TWA 

concentration 

(μg/m3)

Operating HEPA filtered floor vacuum 110 5.2 1.4

Sales counter activities 328 [0.15]

Repainting ballistic baffles 97 2.8 1.1

Maintenance, receiving, inventory 215* [0.29]

Picking up spent shell casings 99* [0.40]† [0.40]

Operating wet floor scrubber 104 [0.77] [0.33]

Range safety officer 320 [0.19]

OSHA PEL

NIOSH REL

ACGIH TLV

50

50

50

*Indicates person worked a partial shift before leaving the building. 

†Values in brackets mean the concentration was between the minimum detectable 

concentration of 0.3 μg/m3 and the minimum quantifiable concentration of 0.9 μg/m3 for 

task-specific samples. For full-shift samples, the minimum detectable concentration was 0.1 μg/m3

and the minimum quantifiable concentration was 0.3 μg/m3. There is more uncertainty associated 

with these values.

The highest task-based exposure (5.2 μg/m3) occurred when performing weekly range 

cleaning using the HEPA-filtered floor vacuum. Employees were required to wear nitrile 

gloves during daily cleaning inside and outside the range. For daily and weekly cleaning 

inside the range, employees were required to wear nitrile gloves and disposable shoe covers. 

N95 filtering facepiece respirators were available for voluntary use. All employees wore the 

respirators during weekly cleaning activities.

Surface Sampling

Table 3 presents the results for lead on employees’ hands before and immediately after 

weekly range cleaning, and at the end of the workday. One employee’s handwipe sample 

collected upon arrival for work and prior to beginning range cleaning activities showed a 

color change indicating the presence of lead. Another employee’s handwipe sample collected 
Health Hazard Evaluation Report 2016-0079-3289 Page 5

after range cleaning also produced a color change indicating the presence of lead, and two 

out of three handwipe samples collected at the end of this employee’s work shift showed a 

color change. The amount of lead measured on these samples ranged from 3.6 μg per wipe to 

65 μg per wipe. The highest amount of lead on any handwipe was measured on one employee 

upon arrival at work.

Table 3. Colorimetric and quantitative handwipe sample results for lead, October 2016

Tasks Before 

range cleaning

After 

range cleaning

At end of 

work shift†

Color* μg/wipe Color μg/wipe Color μg/wipe

Operating wet floor scrubber and 

serving as range safety officer

Yes 65‡ No 5.3 Yes 32

Operating HEPA floor vacuum and 

working at sales counter activities

No 7.5 Yes 26 No 3.6

Painting baffles and conducting 

building maintenance

No 4.1 No 7.7 Yes 28

*Limit of detection is estimated to be 18 μg/wipe sample to produce a color change.

†Employees cleaned their hands with lead removal wipes (D-Lead) following the collection of the

handwipe sample after range cleaning but before starting the remainder of their work shift.

‡Total mass of lead on the handwipe after the employee wiped both hands for 30 seconds.

Of the 10 surface wipe samples collected inside and outside the firing range, only three produced a 

color change indicating the presence of lead (Table 4). These samples were also analyzed for lead 

with results ranging from 0.25 μg/100 cm2

 at the sales counter to 85 μg/100 cm2 on a windowsill 

inside the range. All of these levels are much lower than surface contamination measured at other 

indoor firing ranges investigated by NIOSH [1999, 2013, 2014].

Table 4. Colorimetric and quantitative surface wipe 

samples for lead, June 2016

Locations Detected* Amount 

(μg/100 cm2) 

Inside range

Windowsill Yes 85

Floor, 6 feet behind firing line Yes 29

Ammunition loading table No 2.8

Outside range

Armorer workbench Yes 24

Floor outside range exit door No 7.5

Range safety officer desktop No 7.3

Table top in customer lounge No 0.95

Desktop in martial arts studio No 0.67

Table top in employee 

break room

No 0.56

Sales counter near 

cash register

No 0.25

*Limit of detection is estimated to be 18 μg/wipe sample

to produce a color change.
Page 6 Health Hazard Evaluation Report 2016-0079-3289

Ventilation Assessment 

A recirculating air handler provided climate control to the showroom, classrooms, martial 

arts studio, and other non-range areas. A separate air handler provided conditioned air to the 

range and exhausted air from the range to the outdoors. On the basis of ventilation smoke 

tube testing we determined that the range was under a slight negative air pressure relative to 

adjacent areas, meaning that air flowed from these surrounding areas and into the range, a 

ventilation design that is desired. 

The range ventilation system delivered up to 40,000 cubic feet per minute of air to the range, 

recirculating approximately 80% of the indoor air. The ventilation system had a minimum 

efficiency reporting value (MERV) 8 prefilter, a MERV 15 secondary filter, and a MERV 17 

HEPA final filter. The maintenance employee monitored the condition of the air filters daily via 

a computerized sensor system that measured the air pressure drop across each filter. Air filters 

were changed when the pressure drop reached a predetermined point, usually every 3 months 

for the prefilter and secondary filter. The MERV 17 final filter was designed to last about a year 

before changing. Personal protective clothing that staff, usually two employees, were required 

to wear during an air filter change-out included a full body Tyvek® suit with hood, N95 filtering 

facepiece respirator, nitrile gloves, and disposable shoe covers. All employees involved in deep 

range cleaning tasks and filter change-out kept an extra set of footwear onsite that was stored in 

their locker and used solely during these activities. We did not evaluate employee exposure during 

a filter change-out during either site visit because the filters were not ready to be changed.

A bank of radial-style, perforated diffusers covered a plenum at the junction between the ceiling 

and wall. The diffusers ran the entire length of the back wall behind the firing line and provided 

supply air to the shooting lanes. The distance from the radial diffusers to the firing line was about 

16 feet, and the height from the floor to the bottom of the radial diffuser was about 7 feet. This 

push-pull ventilation design is intended to control airborne contaminants by uniformly moving 

clean air across the firing line and towards the crumb rubber bullet trap and overhead slot exhaust 

inlets located 25 yards downrange. This ventilation approach is discussed in the NIOSH guideline 

for firing ranges [NIOSH 2009]. We confirmed this airflow pattern using ventilation smoke.

We averaged the air velocities measured at 1 foot, 3 feet, and 5 feet off the floor of the firing 

line in each of the 10 shooting lanes. The average air velocities per lane ranged from 56 feet per 

minute to 88 feet per minute. The overall average for all 10 lanes was 70 feet per minute, within 

the NIOSH recommended guideline of 50 to 75 feet per minute for firing ranges [NIOSH 2009].

Workplace Observations and Program Review

The company has a health and safety committee consisting of two employer representatives 

and two employee representatives. All employees are provided a company-issued uniform 

that consisted of a short sleeve polo shirt with a pin-on name tag and long khaki pants. 

Employees provided their own footwear. The respiratory protection program and the medical 

surveillance program contained all the necessary elements established by the Occupational 

Safety and Health Administration. 
Health Hazard Evaluation Report 2016-0079-3289 Page 7

Discussion

Employee exposures to airborne lead during routine work activities and weekly range 

cleaning were well below any OEL. These low airborne exposures can be attributed to the 

design and maintenance of the firing range ventilation system and maintaining the range 

under a negative air pressure compared to adjacent areas. Overall, the employer demonstrated 

a strong commitment to health and safety by creating and following detailed policies, 

programs, and standard operating procedures that appear to be effective in minimizing lead 

migration and contamination outside of the range.

Surface sampling inside and outside the range identified some locations with higher lead 

levels than others, likely due to specific work tasks or customers’ actions. For example, 

the highest amount of lead found on any surface outside the range was on the armorer’s 

workbench, a location where firearms were cleaned and repaired. Another route of lead 

transfer and subsequent surface contamination could involve customers transferring lead 

to surfaces inside and outside the range. For example, if a customer has lead on their hands 

from handling ammunition or a lead-contaminated firearm, and then exits the range without 

cleaning their hands and sits and touches a table in the lounge, a transfer of lead from the 

customer’s hands could occur. Another example could be customers tracking lead from 

the range to the retail sales area on the soles of their shoes despite the use of sticky mats, 

a control that does not remove 100% of lead present on footwear (Table 4). All of these 

scenarios could result in a buildup of lead contamination over time. 

Packages of D-Lead hand cleaning wipes were available for employee and customer use 

inside and outside the ranges, but we were not aware of a company policy regarding their use. 

A one-gallon dispenser of D-Lead hand soap was present at the sink inside the range supply 

area, and employees were required to wash their hands before exiting the range. Our finding 

of some lead on the hands of all employees at the end of the work shift suggests they were 

not thoroughly cleaning their hands during or at the end of the workday. The presence of lead 

on one employee’s hands upon arrival for work may be due to activities occurring outside 

of work. Another employee had a detectable amount of lead on their hands after conducting 

weekly range cleaning activities despite wearing nitrile gloves. There were no visible tears 

in the gloves upon inspection at the end of range cleaning, so the origin of the contamination 

is unknown. Because the gloves only extend to the wrist, it is possible that the exposed skin 

just above the wrist could have contacted a contaminated surface and been captured by the 

handwipe sampler. Regardless of the reason for the contamination, the finding of lead on 

employees’ hands illustrates the importance of hand hygiene at various times during the day 

and before leaving the workplace. As a precaution, hands and skin above the wrist should be 

thoroughly cleaned with lead removal wipes even when gloves are worn.

We reviewed the company’s written documents related to their policies and programs on 

occupational lead exposure and found them to be well written and easy to understand. 

We were informed that the company had a health and safety committee that included 

managers and employees and met quarterly. Finally, we reviewed, the medical monitoring 

and surveillance program for employees that was based on OSHA guidelines for medical 

monitoring of employees exposed to lead. For example, the company enrolled all employees 
Page 8 Health Hazard Evaluation Report 2016-0079-3289

in a blood lead monitoring program administered by a local occupational health provider and 

established pre-employment blood lead levels (BLLs) as a baseline with additional blood 

lead samples collected every 6 months.

The company provided N95 filtering facepiece respirators for voluntary use and adhered to 

the OSHA guidelines outlined in the Code of Federal Regulations (CFR) (29 CFR 1910.134, 

Appendix D). The company also conducted employee training on the hazards of lead each 

year in accordance with the OSHA hazard communication standard (29 CFR 1910.1200).

Overall, the company policies and operation appear to be well thought out and demonstrate a 

best practices approach on how to operate a firing range. However, despite employee 

exposures being well below OELs, the possibility of take-home and household member 

exposure to lead is always a possibility. To reduce the chances of take-home lead exposure, 

additional protective measures such as showering before leaving work and laundering 

uniforms through a lead-certified laundry service or onsite are strategies that may be worth 

implementing. For more information and a detailed discussion of the health effects of lead, 

recommended medical monitoring, and the dangers of take-home lead to household 

members, see Appendix A. 

Conclusions

No employees were overexposed to airborne lead. However, we did find lead on surfaces and 

employees’ hands. This indicates that unrecognized sources of lead (including from 

customers and their ammunition or firearms) may be present. Such a finding, especially in a 

newly constructed building, justifies the need for increased surface cleaning to keep 

contamination as low as possible and also to use D-Lead handwipes frequently. The 

ventilation system performance met NIOSH guidelines. The company adhered to the OSHA 

lead standard and the type and availability of personal protective equipment was appropriate 

for the work performed by employees.

Recommendations

On the basis of our findings, we recommend the actions listed below. We encourage this 

firing range to use the labor-management health and safety committee to discuss our 

recommendations and develop an action plan. Those involved in the work can best set 

priorities and assess the feasibility of our recommendations for the specific situation at this 

firing range.

Our recommendations are based on an approach known as the hierarchy of controls. This 

approach groups actions by their likely effectiveness in reducing or removing hazards. 

In the case of this firing range, the main exposure control used a mechanical ventilation 

system to effectively keep airborne lead concentrations well below the PEL, therefore the 

recommendations that follow focus on dermal routes of exposure.
Health Hazard Evaluation Report 2016-0079-3289 Page 9

Administrative Controls

The term administrative controls refers to employer-dictated work practices and policies 

to reduce or prevent hazardous exposures. Their effectiveness depends on employer 

commitment and employee acceptance. Regular monitoring and reinforcement are necessary 

to ensure that policies and procedures are followed consistently.

1. Create a written program that describes the use of lead removal wipes.

2. Increase the number of signs identifying locations of lead removal wipes. These signs 

should also remind customers and employees to use the wipes, especially when exiting 

the range. 

3. Clean surfaces and floors that employees and customers routinely contact more frequently 

with a lead removal solution (e.g., armorer workbench, tables inside range, customer 

lounge tables, floor outside range exit door) to keep contamination as low as possible.

4. Educate employees about the importance of cleaning their hands and wrists with 

lead removal wipes frequently throughout the day (especially after handling firearms 

and ammunition, touching surfaces inside the range, before eating or drinking, after 

removing gloves), and before leaving the building at the end of the work shift.

5. Educate employees about the importance of wearing nitrile gloves when handling lead 

outside of work (e.g., reloading ammunition) and cleaning hands with lead removal 

wipes when done.

6. Encourage employees to shower before leaving work.

7. As a precaution against take-home lead exposure, consider using a lead-certified laundry 

service or provide an onsite, dedicated washer and dryer to clean employee uniforms. 
Page 10 Health Hazard Evaluation Report 2016-0079-3289

Appendix A: Occupational Exposure Limits and 

Health Effects of Lead

NIOSH investigators refer to mandatory (legally enforceable) and recommended OELs for 

chemical, physical, and biological agents when evaluating workplace hazards. OELs have 

been developed by federal agencies and safety and health organizations to prevent adverse 

health effects from workplace exposures. Generally, OELs suggest levels of exposure that 

most employees may be exposed to for up to 10 hours per day, 40 hours per week, for a 

working lifetime, without experiencing adverse health effects. However, not all employees 

will be protected if their exposures are maintained below these levels. Some may have 

adverse health effects because of individual susceptibility, a pre-existing medical condition, 

or a hypersensitivity (allergy). In addition, some hazardous substances act in combination 

with other exposures, with the general environment, or with medications or personal habits of 

the employee to produce adverse health effects. Most OELs address airborne exposures, but 

some substances can be absorbed directly through the skin and mucous membranes.

Most OELs are expressed as a TWA exposure. A TWA refers to the average exposure during 

a normal 8- to 10-hour workday. Some chemical substances and physical agents have 

recommended STEL or ceiling values. Unless otherwise noted, the STEL is a 15-minute 

TWA exposure. It should not be exceeded at any time during a workday. The ceiling limit 

should not be exceeded at any time.

In the United States, OELs have been established by federal agencies, professional 

organizations, state and local governments, and other entities. Some OELs are legally 

enforceable limits; others are recommendations. 

● The U.S. Department of Labor OSHA PELs (29 CFR 1910 [general industry]; 29 CFR

1926 [construction industry]; and 29 CFR 1917 [maritime industry]) are legal limits.

These limits are enforceable in workplaces covered under the Occupational Safety and

Health Act of 1970.

● NIOSH RELs are recommendations based on a critical review of the scientific and technical

information and the adequacy of methods to identify and control the hazard. NIOSH

RELs are published in the NIOSH Pocket Guide to Chemical Hazards [NIOSH 2010].

NIOSH also recommends risk management practices (e.g., engineering controls, safe work

practices, employee education/training, personal protective equipment, and exposure and

medical monitoring) to minimize the risk of exposure and adverse health effects.

● Another set of OELs commonly used and cited in the United States is the ACGIH

TLVs. The TLVs are developed by committee members of this professional

organization from a review of the published, peer-reviewed literature. TLVs are not

consensus standards. They are considered voluntary exposure guidelines for use by

industrial hygienists and others trained in this discipline “to assist in the control of

health hazards” [ACGIH 2017].
Health Hazard Evaluation Report 2016-0079-3289 Page 11

Outside the United States, OELs have been established by various agencies and organizations 

and include legal and recommended limits. The Institut für Arbeitsschutz der Deutschen 

Gesetzlichen Unfallversicherung (Institute for Occupational Safety and Health of the German 

Social Accident Insurance) maintains a database of international OELs from European Union 

member states, Canada (Québec), Japan, Switzerland, and the United States. The database, 

available at http://www.dguv.de/ifa/GESTIS/GESTIS-Internationale-Grenzwerte-fürchemische-Substanzen-limit-values-for-chemical-agents/index-2.jsp, contains international 

limits for more than 2,000 hazardous substances and is updated periodically. 

OSHA requires an employer to furnish employees a place of employment free from 

recognized hazards that cause or are likely to cause death or serious physical harm 

[Occupational Safety and Health Act of 1970 (Public Law 91–596, sec. 5(a)(1))]. This is true 

in the absence of a specific OEL. It also is important to keep in mind that OELs may not 

reflect current health-based information.

When multiple OELs exist for a substance or agent, NIOSH investigators generally 

encourage employers to use the lowest OEL when making risk assessment and risk 

management decisions. NIOSH investigators also encourage use of the hierarchy of controls 

approach to eliminate or minimize workplace hazards. This includes, in order of preference, 

the use of (1) substitution or elimination of the hazardous agent, (2) engineering controls 

(e.g., local exhaust ventilation, process enclosure, dilution ventilation), (3) administrative 

controls (e.g., limiting time of exposure, employee training, work practice changes, medical 

surveillance), and (4) personal protective equipment (e.g., respiratory protection, gloves, eye 

protection, hearing protection). Control banding, a qualitative risk assessment and risk 

management tool, is a complementary approach to protecting employee health. Control 

banding focuses on how broad categories of risk should be managed. Information on control 

banding is available at http://www.cdc.gov/niosh/topics/ctrlbanding/. This approach can be 

applied in situations where OELs have not been established or can be used to supplement 

existing OELs.

Lead

Inorganic lead is a naturally occurring, soft metal that has been mined and used in industry 

since ancient times. It comes in many forms (e.g., lead acetate, lead chloride, lead chromate, 

lead nitrate, lead oxide, lead phosphate, and lead sulfate). Lead is considered toxic to all 

organ systems and serves no useful purpose in the body.

Occupational exposure to inorganic lead occurs via inhalation of lead-containing dust and 

fume and ingestion of lead particles from contact with lead-contaminated surfaces. Exposure 

may also occur through transfer of lead to the mouth from contaminated hands or cigarettes 

when careful attention to hygiene, particularly hand washing, is not practiced. In addition to 

the inhalation and ingestion routes of exposure, lead can be absorbed through the skin, 

particularly through damaged skin [Filon et al. 2006; Stauber et al. 1994; Sun et al. 2002]. 

Workplace settings with exposure to lead and lead compounds include smelting and refining, 

scrap metal recovery, automobile radiator repair, construction and demolition (including
Page 12 Health Hazard Evaluation Report 2016-0079-3289

abrasive blasting), and firing ranges. Occupational exposures also occur among workers who 

apply or remove lead-based paint and among welders who burn or torch-cut metal structures. 

Blood Lead Levels

In most cases, an individual’s BLL is a good indication of recent exposure to lead because 

the half-life of lead (the time interval it takes for the quantity in the body to be reduced by 

half its initial value) is 1–2 months [Centers for disease Control and Prevention 2013a; 

Lauwerys and Hoet 2001; Moline and Landrigan 2005]. Most lead in the body is stored in 

the bones, with a half-life of years to decades. Measuring bone lead, however, is primarily 

done only for research. Elevated zinc protoporphyrin levels have also been used as an 

indicator of chronic lead intoxication; however, other factors, such as iron deficiency, can 

cause an elevated zinc protoporphyrin level, so monitoring the BLL over time is more 

specific for evaluating chronic occupational lead exposure.

BLLs in adults in the United States have declined consistently over time. The geometric 

mean BLL went from 1.75 micrograms per deciliter of whole blood (μg/dL) in 1999–2000 to 

1.09 μg/dL in 2011–2012 [Centers for Disease Control and Prevention 2015b]. The NIOSH 

Adult Blood Lead Epidemiology and Surveillance System uses a surveillance case definition 

for an elevated BLL in adults of 5 μg/dL of blood or higher [Centers for Disease Control and 

Prevention 2015a]. Very high BLLs are defined as BLLs ≥ 40 μg/dL. From 2002–2011, 

occupational exposures accounted for 91% of adults with very high BLLs (where exposure 

source was known) [Centers for Disease Control and Prevention 2013b]. This underscores 

the need to increase efforts to prevent lead exposures in the workplace. 

Occupational Exposure Limits

In the United States, employers in general industry are required by law to follow the OSHA 

lead standard (29 CFR 1910.1025). This standard was established in 1978 and has not yet been 

updated to reflect the current scientific knowledge regarding the health effects of lead exposure. 

Under this standard, the PEL for airborne exposure to lead is 50 μg/m3 of air for an 8-hour 

TWA. The standard requires lowering the PEL for shifts that exceed 8 hours, medical 

monitoring for employees exposed to airborne lead at or above the action level of 30 μg/m3

(8-hour TWA), medical removal of employees whose average BLL is 50 μg/dL or greater, 

and economic protection for medically removed workers. Medically removed workers cannot 

return to jobs involving lead exposure until their BLL is below 40 μg/dL. 

In the United States, other guidelines for lead exposure, which are not legally enforceable, are 

often followed. Similar to the OSHA lead standard, these guidelines were set years ago and 

have not yet been updated to reflect current scientific knowledge. NIOSH has a REL for lead of 

50 μg/m3averaged over an 8-hour work shift [NIOSH 2010]. ACGIH has a TLV for lead of 50 

μg/m3(8-hour TWA), with worker BLLs to be controlled to, or below, 20 μg/dL. ACGIH 

designates lead as an animal carcinogen [ACGIH 2001]. In 2013, the California Department of 

Public Health recommended that Cal/OSHA lower the PEL for lead to 0.5 to 2.1 μg/m3 (8-hour 

TWA) to keep BLLs below the range of 5 to 10 μg/dL [Billingsley 2013].
Health Hazard Evaluation Report 2016-0079-3289 Page 13

Neither NIOSH nor OSHA has established surface contamination limits for lead in the 

workplace. The U.S. Environmental Protection Agency and the U.S. Department of Housing 

and Urban Development limit lead on surfaces in public buildings and child-occupied 

housing to less than 40 micrograms of lead per square foot [EPA 1998; HUD 2012]. OSHA 

requires in its substance-specific standard for lead that all surfaces be maintained as free as 

practicable of accumulations of lead [29 CFR 1910.1025(h)(1)]. An employer with 

workplace exposures to lead must implement regular and effective cleaning of surfaces in 

areas such as change areas, storage facilities, and lunchroom/eating areas to ensure they are 

as free as practicable from lead contamination. 

Health Effects

The PEL, REL, and TLV may prevent overt symptoms of lead poisoning, but do not protect 

workers from lead’s contributions to conditions such as hypertension, renal dysfunction, 

reproductive, and cognitive effects [Brown-Williams et al. 2009; Holland and Cawthorn 

2016; Institute of Medicine 2012; Schwartz and Hu 2007; Schwartz and Stewart 2007]. 

Generally, acute lead poisoning with symptoms has been documented in persons having 

BLLs above 70 μg/dL. These BLLs are rare today in the United States, largely as a 

result of workplace controls put in place to comply with current OELs. When present, acute 

lead poisoning can cause myriad adverse health effects including abdominal pain, hemolytic 

anemia, and neuropathy. Lead poisoning has, in very rare cases, progressed to 

encephalopathy and coma [Moline and Landrigan 2005]. 

People with chronic lead poisoning, which is more likely at current occupational exposure 

levels, may not have symptoms or they may have nonspecific symptoms that may not be 

recognized as being associated with lead exposure. These symptoms include headache, joint 

and muscle aches, weakness, fatigue, irritability, depression, constipation, anorexia, and 

abdominal discomfort [Moline and Landrigan 2005]. 

The National Toxicology Program recently released a monograph on the health effects of 

low-level lead exposure [NTP 2012]. For adults, the National Toxicology Program concluded 

the following about the evidence regarding health effects of lead (Table A1).
Page 14 Health Hazard Evaluation Report 2016-0079-3289

Table A1. Evidence regarding health effects of lead in adults

Health area NTP 

conclusion

Principal health effects Blood lead 

evidence

Neurological Sufficient Increased incidence of essential tremor Yes, < 10 μg/dL

Limited Psychiatric effects, decreased hearing, 

decreased cognitive function, increased 

incidence of amyotrophic lateral sclerosis

Yes, < 10 μg/dL

Limited Increased incidence of essential tremor Yes, < 5 μg/dL

Immune Inadequate Unclear

Cardiovascular Sufficient Increased blood pressure and increased risk 

of hypertension

Yes, < 10 μg/dL

Limited Increased cardiovascular-related mortality 

and electrocardiography abnormalities

Yes, < 10 μg/dL

Renal Sufficient Decreased glomerular filtration rate Yes, < 5 μg/dL

Reproductive Sufficient Women: reduced fetal growth Yes, < 5 μg/dL

Sufficient Men: adverse changes in sperm parameters 

and increased time to pregnancy

Yes, ≥ 15–20 μg/dL

Limited Women: increase in spontaneous abortion 

and preterm birth

Yes, < 10 μg/dL

Limited Men: decreased fertility Yes, ≥ 10 μg/dL

Limited Men: spontaneous abortion Yes, ≥ 31 μg/dL

Inadequate Women and Men: stillbirth, endocrine 

effects, birth defects

Unclear

Various organizations have assessed the relationship between lead exposure and cancer. 

According to the Agency for Toxic Substances and Disease Registry [ATSDR 2007] and 

the National Toxicology Program [NTP 2011], inorganic lead compounds are reasonably 

anticipated to cause cancer in humans. The International Agency for Research on Cancer 

classifies inorganic lead as probably carcinogenic to humans [IARC 2006]. According 

to the American Cancer Society [ACS 2011], some studies show a relationship between 

lead exposure and lung cancer, but these results might be affected by exposure to cigarette 

smoking and arsenic. Some studies show a relationship between lead and stomach cancer, 

and these findings are less likely to be affected by the other exposures. The results of studies 

looking at other cancers, including brain, kidney, bladder, colon, and rectum, are mixed.

Medical Management

To prevent acute and chronic health effects, a panel of experts convened by the Association 

of Occupational and Environmental Clinics published guidelines for the management of 

adult lead exposure [Kosnett et al. 2007]. The panel recommended BLL testing for all leadexposed employees, regardless of the airborne lead concentration. These recommendations 

do not apply to pregnant women, who should avoid BLLs > 5 μg/dL. Removal from lead 

exposure should be considered if control measures over an extended period do not decrease 

BLLs to < 10 μg/dL or an employee has a medical condition that would increase the risk of 

adverse health effects from lead exposure. These guidelines were endorsed by the Council of 

State and Territorial Epidemiologists and the California Department of Public Health in 2009 
Health Hazard Evaluation Report 2016-0079-3289 Page 15

and the American College of Occupational and Environmental Medicine in 2010 [ACOEM 

2010; CDPH 2009; CSTE 2009]. The Council of State and Territorial Epidemiologists 

published updated guidelines in 2013 to reflect the new definition of an elevated BLL in 

adults of 5 μg/dL [CSTE 2013]. The California Department of Public Health recommended 

keeping BLLs below 5 to 10 μg/dL in 2013 [Billingsley 2013] and updated their medical 

management guidelines in 2014 [CDPH 2014]. In 2015, NIOSH designated 5 μg/dL of whole 

blood, in a venous blood sample, as the reference BLL for adults. An elevated BLL is defined 

as a BLL ≥ 5 μg/dL. In 2016, the American College of Occupational and Environmental 

Medicine released a position statement titled “Workplace Lead Exposure,” which reinforces 

the guidelines and recommendations above [Holland and Cawthorn 2016]. Table A2 

incorporates recommendations from the expert panel guidelines and those from the California 

Department of Public Health, the American College of Occupational and Environmental 

Medicine, and the Council of State and Territorial Epidemiologists. 
Page 16 Health Hazard Evaluation Report 2016-0079-3289

Table A2. Health-based medical surveillance recommendations for lead-exposed employees

Category of exposure Recommendations

All lead exposed workers •	 Baseline or preplacement medical history and physical 

examination, baseline BLL, and serum creatinine

BLL < 5 μg/dL •	 BLL monthly for first 3 months placement, or upon change in 

task to higher exposure, then BLL every 6 months; if BLL 

increases ≥ 5 μg/dL, evaluate exposure and protective 

measures, and increase monitoring if indicated

BLL 5–9 μg/dL •	 Discuss health risks

•	 Minimize exposure

•	 Consider removal for pregnancy and certain medical conditions

•	 BLL monthly for first 3 months placement or every 2 months for 

the first 6 months placement, or upon change in task to higher 

exposure, then BLL every 6 months; if BLL increases ≥ 5 μg/dL, 

evaluate exposure and protective measures, and increase 

monitoring if indicated

BLL 10–19 μg/dL •	 Discuss health risks

•	 Decrease exposure

•	 Remove from exposure for pregnancy

•	 Consider removal for certain medical conditions or 

BLL > 10 μg/dL for extended period

•	 BLL every 3 months; evaluate exposure, engineering controls, 

and work practices; consider removal. 

•	 Revert to BLL every 6 months after 3 BLLs < 10 μg/dL

BLL 20–29 μg/dL •	 Remove from exposure for pregnancy

•	 Remove from exposure if repeat BLL measured in 4 weeks 

remains ≥ 20 μg/dL

•	 Annual lead medical exam recommended

•	 Monthly BLL testing

•	 Consider return to work after 2 BLLs < 15 μg/dL a month apart, 

then monitor as above

BLL 30–49 μg/dL •	 Remove from exposure

•	 Prompt medical evaluation

•	 Monthly BLL testing

•	 Consider return to work after 2 BLLs < 15 μg/dL a month apart, 

then monitor as above

BLL 50–79 μg/dL •	 Remove from exposure

•	 Prompt medical evaluation

•	 Consider chelation with significant symptoms

BLL > 80 μg/dL •	 Remove from exposure

•	 Urgent medical evaluation

•	 Chelation may be indicated

Adapted from Kosnett et al. 2007, CSTE 2013, and CDPH 2014. 
Health Hazard Evaluation Report 2016-0079-3289 Page 17

Take-home Contamination

Occupational exposures to lead can result in exposures to household members, including 

children, from take-home contamination. Take-home contamination occurs when lead dust is 

transferred from the workplace on employees’ skin, clothing, shoes, and other personal items 

to their vehicle and home [Centers for Disease Control and Prevention 2009, 2012]. 

The Centers for Disease Control and Prevention considers a BLL in children of 5 μg/dL or 

higher as a reference level above which public health actions should be initiated and states 

that no safe BLL in children has been identified [Centers for Disease Control and 

Prevention 2013a].

The U.S. Congress passed the Workers’ Family Protection Act in 1992 (29 U.S.C. 671a). 

The Act required NIOSH to study take-home contamination from workplace chemicals and 

substances, including lead. NIOSH found that take-home exposure is a widespread problem 

[NIOSH 1995]. Workplace measures effective in preventing take-home exposures were (1) 

reducing exposure in the workplace, (2) changing clothes before going home and leaving 

soiled clothing at work for laundering, (3) storing street clothes in areas separate from work 

clothes, (4) showering before leaving work, and (5) prohibiting removal of toxic substances 

or contaminated items from the workplace. NIOSH noted that preventing take-home 

exposure is critical because decontaminating homes and vehicles is not always effective. 

Normal house cleaning and laundry methods are inadequate, and decontamination can 

expose the people doing the cleaning and laundry. 
Page 18 Health Hazard Evaluation Report 2016-0079-3289

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Keywords: North American Industry Classification System (NAICS) 713990 (All Other 

Amusement And Recreation Industries); Ohio; Firing Range, Lead, Exposure, Ventilation, 

Surface Contamination, Hand Wipes
Health Hazard Evaluation Report 2016-0079-3289 Page 23

The Health Hazard Evaluation Program investigates possible health hazards in the workplace 

under the authority of the Occupational Safety and Health Act of 1970 (29 U.S.C. § 669(a)

(6)). The Health Hazard Evaluation Program also provides, upon request, technical assistance 

to federal, state, and local agencies to investigate occupational health hazards and to prevent 

occupational disease or injury. Regulations guiding the Program can be found in Title 42, Code 

of Federal Regulations, Part 85; Requests for Health Hazard Evaluations (42 CFR Part 85).

Disclaimer

The recommendations in this report are made on the basis of the findings at the workplace 

evaluated and may not be applicable to other workplaces.

Mention of any company or product in this report does not constitute endorsement by NIOSH.

Citations to Web sites external to NIOSH do not constitute NIOSH endorsement of the 

sponsoring organizations or their programs or products. NIOSH is not responsible for the 

content of these Web sites. All Web addresses referenced in this document were accessible as of 

the publication date.

Acknowledgments

Analytical Support: Maxxam

Desktop Publisher: Shawna Watts 

Editor: Ellen Galloway 

Logistics: Donnie Booher, Kevin Moore

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have also received a copy. This report is not copyrighted and may be freely reproduced. 

Recommended citation for this report:

NIOSH [2017]. Evaluation of ventilation and employee exposures to lead at an 

indoor firing range. By Methner MM. Cincinnati, OH: U.S. Department of Health and 

Human Services, Centers for Disease Control and Prevention, National Institute for 

Occupational Safety and Health, Health Hazard Evaluation Report 2016-0079-3289, 

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