U.S. Department of Health and Human Services

Centers for Disease Control and Prevention

National Institute for Occupational Safety and Health
Page 2 Health Hazard Evaluation Report 2013-0119-3219

Contents

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

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

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

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

Results and Discussion........................ 3

Conclusions........................................ 13

Recommendations............................. 13

Appendix A..........................................17

Appendix B..........................................19

References.......................................... 25

Acknowledgements........................... 29

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 2013-0119-3219 Page i

We evaluated lead exposure 

in an indoor firing range and 

gun store. We found lead in the 

air and on all surfaces tested, 

including employees’ skin. All 

employees had elevated blood 

lead levels. We found a health 

hazard for employees and 

customers. We recommended 

removing employees from lead 

exposure until the hazard was 

abated and blood lead levels 

decreased.

Highlights of this Evaluation

The Health Hazard Evaluation Program received a request from employees at a firing range 

and gun store. Employees were concerned about lead exposure.

What We Did

● We evaluated the firing range and gun store in December 2013. 

● We interviewed employees about their medical and work history and reviewed their 

medical records. The records included results of blood lead testing.

● We sampled air and surfaces for lead. 

● We evaluated the ventilation system performance. 

What We Found

● Three current or former employees reported 

symptoms of lead poisoning, and all employees 

had elevated blood lead levels when tested by 

the employer in November 2013. 

● Air sampling results for lead were below the 

California Occupational Safety and Health 

Administration’s permissible exposure limit. 

● We found lead on all tested surfaces in the 

range and in the showroom. Employees also 

had lead on their hands and shoes as they left 

work to go home. 

● The ventilation system had numerous 

deficiencies, and lead-contaminated air circulated 

throughout the building. 

What the Employer Can Do

● Switch to lead-free ammunition.

● Remove all employees with blood lead levels of 20 micrograms per deciliter or higher 

from exposure to lead until two blood lead levels taken a month apart drop below 15 

micrograms per deciliter. 

● Hire a ventilation engineer to modify or redesign the ventilation systems. 

● Remove lead contamination from the showroom. 

● Follow the medical surveillance requirements of the California Occupational Safety 

and Health Administration. 
Page ii Health Hazard Evaluation Report 2013-0119-3219

What Employees Can Do

● Talk to your doctor about your exposure to lead at work. 

● Do not eat, drink, or smoke inside the facility.

● Wash your hands with a lead-removing soap before leaving the facility. 

● Change your clothes and shoes before leaving work to decrease the amount of lead 

transferred to your car or home.
Page iii

Abbreviations

μg/m3 Micrograms per cubic meter

ACGIH® American Conference of Governmental Industrial Hygienists

BLL Blood lead level

Cal/OSHA California Occupational Safety and Health Administration

fpm Feet per minute

CFR Code of Federal Regulations

μg/dL Micrograms per deciliter

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

STEL Short-term exposure limit

TLV® Threshold limit value

TWA Time-weighted average

WEELTM Workplace environmental exposure level
Page iv Health Hazard Evaluation Report 2013-0119-3219
Page 1

Introduction

The Health Hazard Evaluation Program received a request for an evaluation from employees 

of a firing range and gun store in California. Employees were concerned about lead exposure. 

They reported being diagnosed with lead poisoning and being medically removed from 

the workplace by an occupational physician. We visited the facility in December 2013 

to interview employees and assess their exposure to lead. In December 2013, we sent a 

letter to employee and employer representatives outlining our preliminary findings and 

recommendations. In February 2014, we provided a summary of the environmental sampling 

results to the employer and employee representatives and personal sampling results were sent 

to each employee who participated in the evaluation. 

Facility Description

The firing range and gun store had five full-time employees (including the manager) and one 

part-time employee. Employees generally spent most of their work day at the sales counter 

in the showroom or in the office. They occasionally entered the ranges to assist shooters who 

were experiencing difficulty or to supervise league shooting. Range A (Figure 1) was used 

more frequently for public firearms practice. The part-time employee taught a concealed carry 

weapons class 3 days per week in the classroom and entered firing range B several times 

throughout each class to supervise shooters. Employees cleaned the showroom and range at 

the end of the day. On Saturday employees performed a deep cleaning of the firing ranges. The 

cleaning activities are described in detail in the results section of this report. They alternated 

between range A and range B, cleaning each range every other week.

Each range had a separate single-pass ventilation system that supplied outside air to the range 

and exhausted the air directly outdoors without recirculation. The areas of the facility other 

than the range were served by two recirculation ventilation systems. These systems are more 

fully described in the results and discussion section of this report.
Page 2 Health Hazard Evaluation Report 2013-0119-3219

Figure 1. Firing range and gun store layout.

Methods

The objectives of this evaluation were to determine the extent and routes of exposure to lead 

in the range and store and to make recommendations to minimize exposure. We observed 

workplace conditions and work processes and practices. We reviewed exposure records from 

the workers’ compensation carrier; records from a March 2013 California Occupational 

Safety and Health Administration (Cal/OSHA) inspection; and employee medical records, 

including blood lead levels (BLLs). We interviewed all employees present during the 

evaluation and asked them individually about health issues and job duties. We obtained 

a complete medical history to help detect unrecognized occupational illnesses. We also 

interviewed two employees who had been medically removed for lead poisoning. 

We collected personal and area air samples and analyzed them for lead according to National 

Institute for Occupational Safety and Health (NIOSH) Method 7303 [NIOSH 2014].

We collected surface and hand wipe samples for lead using premoistened SKC Inc. 

Ghostwipes or a commercially available dust wipe (Full Disclosure® Instant Wipes, SKC 

Inc.). Surface wipe samples were collected using the procedure in NIOSH Method 9102 

[NIOSH 2014]. Hand wipe samples were collected by a NIOSH investigator wiping the 

employees’ dominant hand for 30 seconds. Some of these samples were evaluated only using 

a Full Disclosure® kit which is a qualitative screening method for the presence of lead, while 

others were quantitatively analyzed according to NIOSH Method 9102 [NIOSH 2014]. 
Page 3

We inspected the air handlers, supply air diffusers, return air grilles, ductwork, and exhaust 

outlets for the two showroom air handling systems (Appendix A, Figure A1) and for the 

two in the firing ranges (Appendix A, Figure A2). We removed a few ceiling tiles near the 

wall that separates the ranges from the showroom to examine ductwork and determine if the 

wall extended up to the roof. We used qualitative and quantitative methods to characterize 

the airflow in and around the firing ranges. We used a Rosco Laboratories Inc. Model 1500 

aerosol generating machine to generate “smoke” to visualize airflow patterns within the 

two ranges. We generated the smoke at the following five locations along the length of each 

range: behind the firing line, at each shooting position, 5 feet downrange, 15 feet downrange, 

and at the front of the bullet trap. We determined whether the ranges were under positive 

or negative pressure relative to the showroom by using ventilation smoke tubes in the 

connecting doorways.

We used a TSI VelociCalc® Plus Model 8386A anemometer to measure the air velocity 

(in feet per minute [fpm]). We measured air velocity at the firing line, at three distances 

downrange (5 feet, 10 feet, and 20 feet from the firing line), and at the front of the bullet 

trap. At each firing lane position, we took single measurements at six locations in a grid 

pattern centered in the standing shooter’s breathing zone. We followed the same procedure 

at the other measurement locations downrange and at the bullet trap. We averaged the 

measurements for each location, and show the results on a schematic diagram (Appendix A, 

Figure A2). 

Results and Discussion

Observations

We found many areas in the facility containing porous materials that could hold on to lead 

dust. The showroom had carpet throughout, as did the inside of the firing ranges behind 

the firing line. We learned that the carpet was last replaced in 2004. With the exception of 

vacuuming, the employees could not recall when it was last cleaned. The ranges had porous 

material throughout, including spongy soundproofing material. According to the employees it 

had never been cleaned or replaced. 

Clean and dirty areas of the employee changing/restroom area were not separated and the 

partitioning wall between this and the storage area did not extend above the drop ceiling 

(Figure 1). The changing area contained separate sealed bins for each employees’ clean and 

dirty clothes, as well as a sink and toilet. The area had no shower. We saw lead-contaminated 

rags in an open bin (Figure 2) and used coveralls hanging in the storage room (Figure 3). 

Employees used these dirty coveralls each night for range cleaning, and once a week for the 

deep cleaning and bullet trap scraping. The coveralls were laundered by the company every 

other week. The tools used for deep cleaning were covered loosely with a black plastic bag 

and kept in the storage room.
Page 4 Health Hazard Evaluation Report 2013-0119-3219

Figure 2. Lead contaminated rags in an open bin in the storage room located directly outside of the 

employee changing/restroom area. Photo by NIOSH.

Figure 3. Employee coveralls in the storage room. Photo by NIOSH.
Page 5

Before closing at night, the employees secured all of the firearms in the showroom and 

then cleaned the facility. They wiped down the counters and shelves with D-Lead® wipes 

and rags. Employees then donned company issued washable coveralls, disposable booties, 

nitrile gloves, and an N95 filtering facepiece respirator for nightly range cleaning. They 

used a squeegee to push all of the spent bullet casings (“brass”) to one area and collected the 

brass in a bucket. Next, they used a high-efficiency particulate air filtered vacuum cleaner 

backpack to vacuum in front of the firing line. Finally, they used a carpet attachment for 

the vacuum cleaner to clean the carpet behind the firing line. They put the used booties, 

respirator, and gloves in a sealed trashcan in the storage room. They hung the coveralls on a 

rack in the storage room and then proceeded to the changing area to put on their personal clothes.

For weekly deep cleaning, the employee donned the same coveralls used for the nightly range 

cleaning, disposable booties, nitrile gloves, and an N95 filtering facepiece respirator. During 

the deep cleaning, we observed the employee wearing a personal hat into the range. The 

employee’s head, face, and neck were exposed. The employee placed a rubber band around 

each wrist to seal the gap between the sleeve of his/her coverall and his/her glove. The 

employee then got a cart with cleaning supplies from the storage room. Next, the employee 

removed the filters from the three range exhaust ventilation units and replaced them with 

new filters. The employee used a scraping tool to remove the dust and oil build up from the 

bullet trap. The employee used a push broom to sweep the dust and oil into the pit below the 

bullet trap and back into the airspace behind the bullet trap. The employee then applied motor 

oil to the bullet trap with a paint roller. The employee returned the tools to the cart, placed a 

black plastic bag over the broom and scraping tool, and returned the cart to the storage room. 

Next, the employee removed the respirator, washed his/her hands and face, and removed 

the coveralls and placed them back on the hanger in the store room. After this, the employee 

changed into work or street clothes to work at the showroom counter.

Document Review

In the year before our visit, the workers’ compensation insurance carrier and Cal/OSHA 

collected full-shift personal air samples for lead. Both organizations documented airborne 

lead exposures above the permissible exposure limit of 50 micrograms per cubic meter 

of air. Cal/OSHA also documented numerous violations of the lead standard, including 

(1) lack of exposure monitoring; (2) failure to perform quarterly measurements of the 

ventilation system’s effectiveness; (3) poor housekeeping (including dry sweeping); (4) 

allowing employees to consume food and beverages in the work area; (5) lack of a changing 

room with separate storage facilities for work and street clothes; (6) lack of a lunchroom; 

(7) having employees launder lead contaminated clothing at home; (8) failure to conduct 

required medical surveillance; (9) lack of a written lead hazard management program; (10) 

failure to implement engineering controls to reduce exposure to airborne lead; and (11) 

failure to provide appropriate protective clothing. Cal/OSHA also noted several violations 

of the respiratory protection standard including lack of (1) a written respiratory protection 

program; (2) medical clearance to wear a respirator; (3) fit testing; (4) maintenance and care 

of respirators; and (5) training of employees prior to respirator use. Cal/OSHA also reported 

that the range had been inspected in 2007 with similar findings and that no changes had been made. 
Page 6 Health Hazard Evaluation Report 2013-0119-3219

Medical Record Review

The employer tested employee BLLs for the first time in November 2013. All six employees 

had elevated BLLs, defined as greater than or equal to 10 micrograms of lead per deciliter 

of blood (μg/dL) [CDC 2012a]. Employee BLLs ranged from 19.9–40.7 μg/dL. A detailed 

discussion of the health effects of lead and of the occupational exposure limits is in Appendix 

B. Table B1 discusses the evidence regarding health effects of lead in adults, while Table B2 

provides health-based medical surveillance recommendations for lead-exposed employees by 

BLL.

No employees had undergone the medical surveillance required by Cal/OSHA. The physician 

who evaluated employees to determine their fitness to wear a respirator did not mark the 

clearance form to convey whether employees were medically cleared or for the exact level of 

respirator they were to use. Copies of each employee’s breathing test result and the respirator 

medical clearance questionnaire were sent to the employer. We noted that these results 

contained confidential medical information from each of the employees that should not have 

been shared with the employer. The employer should have only received an “approved” or 

“rejected” medical clearance form on each employee. 

Confidential Medical Interviews

We interviewed five of six current employees, including the general manager. One employee 

was not present during the evaluation. Length of employment at the facility ranged from 

7 months to 13 years. All employees reported recreational use of firearms. One employee 

also works part-time as a firearms instructor for local law enforcement. Two employees 

reported past employment as correctional officers, which required periodic range shooting. 

One employee reported onset of symptoms consistent with chronic lead poisoning, including 

lethargy, fatigue, and muscle and joint aches since beginning work at the facility. The other 

four employees reported no symptoms related to work. 

We also interviewed two employees on medical removal, who reported that they had sought 

medical care when they developed symptoms consistent with lead poisoning. BLLs were 

drawn as part of their medical evaluation and were elevated. They were removed from work 

by the physician. They reported that new employees were hired to replace them, but that 

workplace conditions had not changed. 

Air Sampling

The six full-shift personal air samples had concentrations ranging from 5.5–19 micrograms 

of lead per cubic meter of air (μg/m3), below the Cal/OSHA limit of 50 μg/m3, but above the 

California Department of Public Health recommended limit range of 0.5–2.1 μg/m3 (Table 

1) [CDPH 2009; Cal/OSHA 2014]. Employees worked varied shift lengths. Two task-based 

personal air samples for lead were 54 μg/m3 (55 minutes for nightly range maintenance) and 

64 μg/m3 (52 minutes for the weekly range cleaning). Cal/OSHA does not have an exposure 

limit for short-term or task based air samples.
Page 7

Table 1. Full-shift personal air sampling results

Job title/task Sample duration

(minutes)

Lead concentration

(μg/m3)

Day 1

Manager 562† 19

Showroom employee 316 8.5

Showroom employee 260 5.5

Showroom employee* 449 16

Day 2

Manager 409 9.1

Showroom employee 395 7.0

Cal/OSHA action level — 30

Cal/OSHA PEL, NIOSH REL, ACGIH TLV — 50

ACGIH = American Conference of Governmental Industrial Hygienists

PEL = Permissible exposure limit

REL = Recommended exposure limit

TLV = Threshold limit value

*This employee cleaned the range nightly.

†Ordinarily this employee only works 8-hours, however due to our visit the manager worked longer 

than his normal shift.

Table 2. Full-shift area air sampling results 

Area Sample duration

(minutes)

Lead concentration

(μg/m3)

Day 1

Classroom, by bullet trap entrance door 481 20

Employee changing area 502 1.9

Behind showroom counter 219* 19

Storage room 497 2.3

Day 2

Classroom, by bullet trap entrance door 484 19

Behind showroom counter 486 15

Inside range A 486 183

Storage room 457 1.3

Employee changing area 455 1.1

*The sampling pump stopped after 219 minutes.

We took 11 area air samples in the firing ranges and showroom (Table 2). Outside of the 

ranges, the highest lead concentration was in the classroom, where concealed carry weapons 

classes were taught. The second highest lead concentration was behind the showroom 

counter, where employees spend the majority of their day.
Page 8 Health Hazard Evaluation Report 2013-0119-3219

Table 3. Wipe sampling results

Sample type and location Lead detected

with laboratory

analysis

(yes/no)

Lead detected

with Full

Disclosure®

(yes/no)

Area surface wipe samples

Prior to employee arrival

Purchasing counter Yes No

Counter above where targets are stored Yes Yes

Rental counter Yes No

Cashier keyboard* Yes Yes

Long gun purchase counter Yes No

Air intake by purchasing counter* Yes Yes

Clean towel after arrival from laundry Yes No

After employee arrival

Carpet outside of range B Yes Yes

Carpet in front of the entrance Yes Yes

Door handle to range A* Yes Yes

Door handle to range A after Hygenall®* Yes No

Handle of doorknob to women’s restroom* Yes Yes

Office, owner’s computer keyboard* Yes Yes

Office, air intake grill* Yes Yes

Break room table Yes Yes

Break room table, after cleaning with D-Lead Yes Yes

Classroom, counter next to water fountain Yes Yes

Women’s customer restroom sink* Yes Yes

Ceiling tile near range* Yes Yes

Skin/clothing surface wipe samples

Employees’ left shoulder immediately after arrival* Yes No

Employee uniform clothes bin Yes Yes

Employee clean/street clothes bin Yes Yes

Employees shirt worn under coveralls during range 

cleanout* Yes —†

Employee shirt, at the start of the shift* Yes No

Employees hands, before going to lunch* Yes No

Sole of employee shoe before going home for the day* Yes Yes

Limit of detection 0.4 ~20

*Estimated 100 cm2

†Not evaluated with the Full Disclosure kit.
Page 9

Surface Sampling

We detected lead on surfaces throughout the facility and on employees’ shoes as they 

prepared to leave from work, hands after they had washed them, and on their personal 

clothing as they started their shift (Table 3). We also detected lead on the handle of the coffee 

pot, on the sink in the employee break room, inside the downspout from the roof, on plant 

leaves outside of the range, on all three air supply diffusers in the showroom, and on the 

return air intake for the showroom. Surface lead contamination can contribute to overall lead 

body burden because lead dust can get on employee’s hands and then be transferred from 

their hands to their mouth. Employees likely transferred lead to their vehicles and homes on 

their clothing, shoes, and exposed skin. Wipe samples on all air supply diffusers and return 

air grilles confirmed distribution of contaminated air from the ranges into the rest of the building.

Ventilation System Evaluation

Firing ranges A and B, the showroom and office, and the storage, employee break room, and 

classroom area, were each served by separate ventilation systems. Unconditioned supply 

air was delivered to each firing range by a single 24-inch square plenum duct equipped 

with five 13 × 7-inch rectangular diffusers. These diffusers were spaced unevenly along the 

plenum (Appendix A, Figure A2). The plenum was mounted at ceiling height (9 feet) along 

the back wall of each range and approximately 12 feet behind the firing line. This plenum 

configuration was designed to direct air toward the firing line and downrange past the 

shooter. 

Air was exhausted from each range at two areas downrange of the firing line. At the first, 

approximately 15 feet downrange, a 20-inch square exhaust outlet containing a minimum 

efficiency reporting value (MERV) 4 filter was positioned 10 feet above the floor. Further 

downrange, approximately 40 feet from the firing line, two 20-inch square exhaust outlets 

were suspended 10 feet above the floor in front of the bullet trap. Exhaust air passed through 

MERV 4 type filters before delivery outdoors. 

The ventilation systems used to condition the air within the showroom and office area, and 

classroom, break room, and storage area, consisted of a two recirculating style, dual mode air 

handling units capable of using natural gas for heating and a roof-mounted condenser coil for 

cooling. Outdoor air was supplied to the unit through a rooftop vent stack that also provided 

combustion air needed when operating in heating mode. However, the unit also used air 

from the area between the building’s interior drop ceiling and the underside of the roof. 

Conditioned air was supplied to the building through insulated flexible ducts in the space 

above the drop ceiling. Multiple supply diffusers and return grilles were located in the drop 

ceiling (Appendix A, Figure A1). 
Page 10 Health Hazard Evaluation Report 2013-0119-3219

Achieving the correct balance between air supply and exhaust is important in limiting the 

risk of lead exposures resulting from firing range use. Firing ranges should be under slight 

negative pressure relative to adjacent areas so that no airborne contaminants migrate from the 

range. Our observations of air movement in range A indicate that a higher volume of air was 

being supplied than was exhausted and that range A was under positive pressure relative to 

the airspace over the showroom and to range B. This means that lead dust generated in range 

A could migrate to these adjacent spaces through openings we observed in the wall above 

the drop ceiling (Figure 4) and to range B through several holes in the wall that divided the 

two ranges (Figure 5). Appendix A, Figure A2 shows airflow patterns and velocity inside 

the firing ranges. We generated smoke in the airspace above the showroom and in range A 

and range B to visualize air movement. We observed that air moved from each range into 

the airspace above the showroom where it was drawn into the air handling unit that supplies 

conditioned air throughout the building.

Figure 4. Hole between the firing ranges and showroom, above the ceiling. Photo by NIOSH.
Page 11

Figure 5. Large hole in the wall that divided ranges A and B. Photo by NIOSH.

Air flow velocities in range A were variable. Some firing lines did not meet the NIOSH 

recommended minimum average air velocity of 50 fpm while others exceeded the 

recommended 75 fpm at the firing line [NIOSH 2009]. Air velocity measurements varied 

considerably among the lanes, indicating turbulent air at the firing line, which was confirmed 

visually by smoke. The downrange air velocity measurements were also variable. Many areas 

downrange did not meet the recommended 30 fpm minimum air velocity [NIOSH 2009]. 

Visual smoke tests confirmed areas of backflow and stagnant air.

The measurements for range B showed that the range operated under negative pressure 

relative to adjacent areas such as the airspace above the showroom (Appendix A, Figure A2). 

Air velocity measurements at the firing line in range B were above the NIOSH minimum 

recommended average air velocity of 50 fpm, and the airflow was less turbulent than in 

range A. However, air velocities further downrange did not meet the NIOSH recommended 

minimum average air velocity of 30 fpm [NIOSH 2009].

It is desirable to have laminar airflow (streamlined airflow without cross currents or eddies) 

downrange, especially near the firing line. Even if the range is pressurized correctly and air 

moves downrange at the minimum velocity of 50 fpm (at the firing line), range users may 

receive excessive exposures to lead if cross currents or eddies create backflow of air and 

bring lead-contaminated air back into their breathing zones. Backflow was evident when we 

observed airflow patterns with the smoke machine. The location of the air supply diffusers on 

the plenum behind the firing line created eddies that resulted in two zones of recirculated air. 

One zone recirculated the air between the supply diffuser and the firing line, and then back 

again to the rear wall and supply diffuser. The second zone carried air from each shooting 

lane at the firing line to an area several feet downrange and then back up into the breathing 

zones of those standing at the firing line.
Page 12 Health Hazard Evaluation Report 2013-0119-3219

We also noted little downrange air movement at multiple areas between the firing line and 

the bullet trap. This finding may be a result of the placement of the exhaust hood openings, 

which were 10 feet above the floor. We observed little capture of the smoke generated at a 

height that roughly corresponded to the muzzle of a firearm (approximately 4 feet above the 

floor). Therefore, it appeared that at the current exhaust airflow rates, all exhaust inlets are 

too high to adequately capture gun emissions. As a result of this inadequate airflow, lead dust 

from gun emissions falls out of the horizontal downrange airflow, and then builds up on the 

floor. We found no evidence that the ventilation system had ever been evaluated for proper 

performance. Cal/OSHA requires measurements such as capture velocity, duct velocity, or 

static pressure every 3 months to demonstrate the effectiveness of ventilation systems in 

controlling lead exposure [Cal/OSHA 2014].

We inspected the filters in each firing range exhaust outlet and noticed these filters have a 

MERV value of 4. This inadequate level of filtration would allow lead-contaminated air to 

be released outside the building. In addition, during the weekly range cleanout, we noticed 

that the filter in one of the range exhausts had been dislodged, allowing unfiltered air to be 

exhausted (Figure 6). The filters inside the range ventilation system should be equipped with 

side and face gaskets to prevent lead-contaminated air from bypassing the filter. Without 

these gaskets, lead can accumulate in the ducts and on the fan, which reduces the efficiency 

and affects the balance of the system.

Figure 6. Dislodged, buckled air filter inside one exhaust outlet in range A. Photo by NIOSH.

Customers of the facility, including children, are likely exposed to lead, given the conditions 

that we found. We reported our findings to the county public health officer and to the 

California Department of Public Health so that action could be taken to protect the public.
Page 13

Conclusions

A health hazard from exposure to lead exists in this firing range and gun store. The 

ventilation system was not performing as recommended by NIOSH. Multiple openings 

between the ranges and the wall separating them from the showroom allowed lead dust 

to migrate to the air handling units that serve the showroom and office/classroom area. 

Housekeeping practices are insufficient, and the medical surveillance program does not 

contain all the required elements. The risk of lead exposure is not limited to employees, but 

extends to customers and children who visit the facility.

Recommendations

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

firing range to use a labor-management health and safety committee or working group to 

discuss our recommendations and develop an action plan. Those involved in the work should 

have input to set priorities and assess the feasibility of our recommendations for the specific 

situation at the firing range. 

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

(Appendix B). This approach groups actions by their likely effectiveness in reducing or 

removing hazards. In most cases, the preferred approach is to eliminate hazardous materials 

or processes and install engineering controls to reduce exposure or shield employees. Until 

such controls are in place, or if they are not effective or feasible, administrative measures and 

personal protective equipment may be needed. 

Elimination and Substitution

Eliminating or substituting hazardous processes or materials reduces hazards and protects 

employees more effectively than other approaches. Prevention through design, considering 

elimination or substitution when designing or developing a project, reduces the need for 

additional controls in the future.

1. Use lead-free ammunition. Use of ammunition that does not contain lead will not 

eliminate the need to clean and dispose of contaminated items; however, it would 

prevent additional buildup of lead in the range and showroom. While lead-free 

ammunition may pose some health risks, it is preferable to leaded ammunition. The 

measures recommended below to control lead exposure will also help prevent possible 

adverse effects regardless of the type of ammunition.
Page 14 Health Hazard Evaluation Report 2013-0119-3219

Engineering Controls

Engineering controls reduce employees’ exposures by removing the hazard from the process 

or by placing a barrier between the hazard and the employee. Engineering controls protect 

employees effectively without placing primary responsibility of implementation on the employee. 

1. Ask a ventilation engineer with experience in designing firing range systems to repair, 

modify, or design an appropriate ventilation system for the firing range. The NIOSH 

website has useful information about firing range ventilation at http://www.cdc.gov/

niosh/topics/ranges/. 

2. Address the range ventilation system as the top priority. Do a test and balance 

evaluation after the system is repaired, modified, or designed. Do a smoke test in each 

range to make sure air is moving downrange with as little turbulence/eddy currents as 

possible. Research possible grants for making range improvements.

3. Seal all openings between the showroom wall and the ranges to prevent lead dust from 

entering the airspace used by the air handling unit serving the showroom/office area. 

Persons doing this work must be informed of the presence of lead and take appropriate 

precautions such as wearing personal protective equipment (i.e., respirators, gloves, 

coveralls) to prevent exposure.

4. Use appropriately rated filters on all exhaust outlets. NIOSH recommends either a 

high-efficiency particulate air filter or MERV 18 or 19 rated filters [NIOSH 2009]. 

Administrative Controls

The term administrative control 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. Comply, at a minimum, with all aspects of the Cal/OSHA general industry safety 

orders, California Code of Regulations, Title 8, section 5198, Lead [Cal/OSHA 2014], 

which mandate numerous practices to reduce employee lead exposures. The firing 

range is required by law to comply with this standard. This requirement includes 

providing annual training to employees about lead, posting signs regarding lead work 

areas, and carrying out medical surveillance and air sampling, among many other actions.

2. Follow the guidelines for medical surveillance of employees in Appendix B. These 

guidelines are also available online at http://www.cdph.ca.gov/programs/olppp/

Documents/medgdln.pdf. 

3. Post signs that comply with California Proposition 65 regarding hazards of lead 

exposure. These signs are available at http://oehha.ca.gov/prop65/background/

p65plain.html.

4. Use a healthcare provider who is familiar with current scientific information about the 

hazards of lead exposure, the Cal/OSHA lead and respiratory protection standards, and 
Page 15

respirator use. The American College of Occupational and Environmental Medicine 

provides guidelines about the confidentiality of medical information in the workplace 

at http://www.acoem.org/Confidentiality_Medical_Information.aspx. 

5. Remove all employees with a BLL above 20 μg/dL from any lead exposure 

immediately. Consider return to work after two BLLs < 15 μg/dL a month apart. With 

medical removal, the employee should retain full pay and benefits. Employees should 

not have to file for workers’ compensation, which provides reduced wages. 

6. Provide uniforms that are laundered frequently by a company that knows how to 

remove lead from clothing. Provide employees shoes or disposable shoe covers to 

wear while working in the showroom. Require employees to change into clean clothes 

and shoes that have not been worn in the building before leaving. 

7. Do not reuse contaminated coveralls. Either use clean coveralls each time range 

maintenance is done and have coveralls laundered after each use, or use disposable coveralls. 

8. Do not allow food or beverages in the facility until lead-free areas where they can 

safely be stored and consumed are created.

9. Ensure employees wash their hands with a lead-removing soap before leaving the facility. 

10.Remove porous material, including noise proofing material and carpeting, from 

the firing range and rooms adjacent to the range, and replace it with materials that 

can be cleaned more easily. Persons performing this work must be informed of the 

presence of lead and take appropriate precautions such as wearing personal protective 

equipment (i.e., respirators, gloves, coveralls) to prevent lead exposure. Contact 

the County Health Department, Environmental Health Division, or the California 

Environmental Protection Agency to determine if these items and the used air filters 

need to be treated as hazardous waste for disposal.

11.Identify and remove lead from all surfaces within the building excluding the area 

downrange from the firing line. Include the ventilation system that serves the 

showroom, offices, and classroom. Persons doing this work must be informed of the 

presence of lead and take appropriate precautions such as wearing personal protective 

equipment (i.e., respirators, gloves, coveralls) to prevent exposure.

12.Install an employee shower and a clean clothes changing room. Separate these 

areas from the storage room. Design the changing room and shower area so that 

once employees shower, they cannot re-enter the potentially contaminated changing 

area. Clean items should be stored in changing rooms separate from areas where 

contaminated work items are stored.

13.Consult a certified industrial hygienist to repeat air and surface wipe sampling after 

implementing these changes to evaluate their efficacy.

14.Encourage employees to talk to their healthcare provider about their exposure to lead 

and about the possibility of take-home contamination with lead. Encourage employees 

to have family members and other individuals who live with employees or regularly 

ride in their vehicles get their BLLs tested.
Page 16 Health Hazard Evaluation Report 2013-0119-3219

Personal Protective Equipment

Personal protective equipment is the least effective means for controlling hazardous 

exposures. Proper use of personal protective equipment requires a comprehensive program 

and a high level of employee involvement and commitment. The right personal protective 

equipment must be chosen for each hazard. Supporting programs such as training, changeout schedules, and medical assessment may be needed. Personal protective equipment should 

not be the sole method for controlling hazardous exposures. Rather, personal protective 

equipment should be used until effective engineering and administrative controls are in place.

1. Provide personnel doing nightly range maintenance, changing ventilation system air 

filters, and scraping the bullet trap with appropriate protective outer clothing, which 

may be disposable. If nondisposable clothing is provided, have it laundered after each 

use by a company that knows how to remove lead from clothing. If disposable clothing 

is worn it may need to be disposed of as hazardous waste; consult your state or local 

environmental regulatory authorities to help make this determination.

2. Develop and implement a respiratory protection program that, at a minimum, meets 

the requirements of Cal/OSHA general industry safety orders, California Code 

of Regulations, Title 8, section 5144, Respiratory Protection. See the Cal/OSHA 

consultation service educational unit guide “Respiratory Protection in the Workplace, 

A Practical Guide for Small-Business Employers” at http://www.dir.ca.gov/dosh/dosh_

publications/respiratory.pdf.

3. Provide personnel doing nightly range maintenance, changing ventilation system 

air filters, and scraping the bullet trap with appropriate NIOSH certified respiratory 

protection until engineering or other controls can keep exposures below occupational 

exposure limits. Appropriate respirators can be determined using the NIOSH 

Respirator Selection Logic, available at http://www.cdc.gov/niosh/docs/2005-100/

pdfs/05-100.pdf. 
Page 17

Appendix A: Figures

Figure A1. Schematic drawing of the facility showing the locations of ventilation systems outside the 

firing ranges.
Page 18 Health Hazard Evaluation Report 2013-0119-3219

Figure A2. Airflow and air velocity inside the firing ranges.
Page 19

Appendix B: Occupational Exposure Limits and 

Health Effects

NIOSH investigators refer to mandatory (legally enforceable) and recommended 

occupational exposure limits (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 time-weighted average (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.

● Other OELs commonly used and cited in the United States include the TLVs, which 

are recommended by ACGIH, a professional organization, and the workplace 

environmental exposure levels (WEELs), which are recommended by the American 

Industrial Hygiene Association, another professional organization. The TLVs and 

WEELs are developed by committee members of these associations from a review of 

the published, peer-reviewed literature. These OELs are not consensus standards. TLVs 

are considered voluntary exposure guidelines for use by industrial hygienists and others 
Page 20 Health Hazard Evaluation Report 2013-0119-3219

trained in this discipline “to assist in the control of health hazards” [ACGIH 2014]. 

WEELs have been established for some chemicals “when no other legal or authoritative 

limits exist” [AIHA 2014].

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/Gefahrstoffdatenbanken/GESTIS-InternationaleGrenzwerte-für-chemische-Substanzen-limit-values-for-chemical-agents/index-2.jsp, contains 

international limits for more than 1,500 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.

Below we provide the OELs and surface contamination limits for lead, as well as a 

discussion of the potential health effects from exposure to lead.

Background

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 
Page 21

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 [Stauber et al. 1994; Sun et al. 2002; Filon et al. 2006]. 

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

scrap metal recovery; automobile radiator repair, construction, and demolition (including 

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 [Lauwerys and Hoet 2001; Moline and Landrigan 

2005; CDC 2013a]. 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. In the last 10 years 

alone, the geometric mean BLL went from 1.75–1.23 μg/dL [CDC 2013b]. The NIOSH Adult 

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

an elevated BLL in adults of 10 μg/dL of blood or higher [CDC 2012a]. 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 [CDC 2013c]. This high level 

of occupational exposure 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 an REL for 
Page 22 Health Hazard Evaluation Report 2013-0119-3219

lead of 50 μg/m3 averaged 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, 30 μg/dL. 

The ACGIH designates lead as an animal carcinogen [ACGIH 2014]. In 2013, the California 

Department of Public Health recommended that Cal/OSHA lower the PEL for lead to 0.5–2.1 

μg/m3 (8-hour TWA) to keep BLLs below the range of 5–10 μg/dL [Billingsley 2013].

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

the workplace. The U.S. Environmental Protection Agency and 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 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, 

and reproductive and cognitive effects [Schwartz and Hu 2007; Schwartz and Stewart 2007; 

Brown-Williams et al. 2009; Institute of Medicine 2012]. 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, they concluded the following about the 

evidence regarding health effects of lead (Table B1).
Page 23

Table B1. 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 < 10 μg/dL

Limited Psychiatric effects, decreased hearing,

decreased cognitive function, increased

incidence of amyotrophic lateral sclerosis

< 10 μg/dL

Limited Increased incidence of essential tremor < 5 μg/dL

Immune Inadequate Unclear

Cardiovascular Sufficient Increased blood pressure and increased risk 

of hypertension

< 10 μg/dL

Limited Increased cardiovascular-related mortality 

and electrocardiography abnormalities

< 10 μg/dL

Renal Sufficient Decreased glomerular filtration rate < 5 μg/dL

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

Sufficient Men: adverse changes in sperm parameters 

and increased time to pregnancy

≥ 15–20 μg/dL

Limited Women: increase in spontaneous abortion 

and preterm birth

< 10 μg/dL

Limited Men: decreased fertility ≥ 10 μg/dL

Limited Men: spontaneous abortion in partner ≥ 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 [WHO 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 published guidelines for 

the management of adult lead exposure [Kosnett et al. 2007]. The complete guidelines 

are available at http://www.cdph.ca.gov/programs/olppp/Documents/medmanagement.

pdf [CDPH 2009]. The panel recommended BLL testing for all lead-exposed employees, 

regardless of the airborne lead concentration. The panel’s recommendations are outlined in 

Table B2. 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 
Page 24 Health Hazard Evaluation Report 2013-0119-3219

are endorsed by the Council of State and Territorial Epidemiologists [CSTE 2009] and the 

American College of Occupational and Environmental Medicine [ACOEM 2010]. The 

California Department of Public Health recommended keeping BLLs below 5 to 10 μg/dL in 

2013 [Billingsley 2013].

Table B2. 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 < 10 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 10–19 μg/dL •	 As above for BLL < 10 μg/dL, plus:

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

work practices; consider removal

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

BLL ≥ 20 μg/dL •	 Remove from exposure if repeat BLL measured in 4 weeks 

remains ≥ 20 μg/dL, or if first BLL is ≥ 30 μg/dL

•	 Monthly BLL testing

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

then monitor as above

Adapted from Kosnett et al. 2007

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 [CDC 2009, 2012b].

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 [CDC 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 25

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Page 28 Health Hazard Evaluation Report 2013-0119-3219

Keywords: North American Industry Classification System 713990 (All Other Amusement 

and Recreation Industries), lead, firing range, California
Page 29

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 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: Bureau Veritas North America

Desktop Publisher: Shawna Watts 

Editor: Ellen Galloway 

Industrial Hygiene Field Assistance: Wei Gong

Logistics: Donnie Booher and Kevin Moore

Availability of Report

Copies of this report have been sent to the employer and employees at the facility. The state and 

local health department and the Occupational Safety and Health Administration Regional Office 

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

This report is available at http://www.cdc.gov/niosh/hhe/reports/pdfs/2013-0119-3219.pdf.

Recommended citation for this report:

NIOSH [2014]. Health hazard evaluation report: lead exposure at a firing 

range and gun store. By Page E, Beaucham C, Methner M. Cincinnati, OH: U.S. 

Department of Health and Human Services, Centers for Disease Control and 

Prevention, National Institute for Occupational Safety and Health, NIOSH HHE 

Report No. 2013-0119-3219.
Delivering on the Nation’s promise:

Safety and health at work for all people through research and prevention

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