Health Hazard Evaluation Report 2016-0232-3285 Page 1

Evaluation of Lead Exposure at an Indoor Law 

Enforcement Firing Range

HHE Report No. 2016-0232-3285

August 2017

Michael Grant, ScD

Judith Eisenberg, MD, MS

Mark Methner, PhD, CIH

U.S. Department of Health and Human Services

Centers for Disease Control and Prevention

National Institute for Occupational Safety and Health
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Contents

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

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

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

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

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

Conclusions........................................ 14

Recommendations............................. 14

Appendix A ........................................ 18

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

Appendix C ........................................ 26

References.......................................... 28

Acknowledgements........................... 35

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 2016-0232-3285 Page i

We evaluated lead exposures 

in an indoor law enforcement 

firing range. We found lead in 

the air, but below occupational 

exposure limits. We also found 

lead on all surfaces tested 

including instructors’ skin and 

footwear. All instructors had 

detectable blood lead levels. 

We recommended testing 

and balancing the ventilation 

system, improving hand 

hygiene, and starting a lead 

exposure monitoring program.

Highlights of this Evaluation

The Health Hazard Evaluation Program received a request from the employer at a federal law 

enforcement indoor firing range. The employer was concerned about lead exposure among 

firearms instructors. We evaluated the firing range in December 2016 during a weapons 

qualification course.

What We Did

● We observed work practices, including shooting, cleaning firearms, range hygiene, and 

range cleanup.

● We measured instructors’ and shooters’ airborne 

exposures to lead.

● We determined lead, copper, and zinc concentrations 

on surfaces inside and outside the range.

● We determined whether instructors had lead 

contamination on their hands and footwear when 

they left the range.

● We evaluated ventilation system performance.

● We interviewed all four firearms instructors about 

work history and practices, lead-related medical 

history, and recreational lead exposure sources. 

● We reviewed instructors’ previous blood lead level 

test results.

● We collected venous blood samples from 

instructors to measure current blood lead levels.

What We Found

● Air sampling results for lead were below occupational exposure limits. 

● We found lead and copper on all tested surfaces. We found zinc on most tested surfaces.

● Instructors had lead on their hands and footwear as they left work to go home. 

● All instructors wore their work clothes and shoes home. This potentially exposes family 

members to lead.

● Instructors and shooters used dry sweeping methods to remove lead-dust and lead-dust 

contaminated objects from in front of the firing line at the end of the day.

● The ventilation system was not performing according to guidelines from the National 

Institute for Occupational Safety and Health.

● The venous blood samples we collected showed that instructors had blood lead levels 

between 3.4 and 11 micrograms per deciliter. Levels above 5 micrograms per deciliter 

are considered elevated. 
Page ii Health Hazard Evaluation Report 2016-0232-3285

What the Employer Can Do

● Hire a firing range ventilation specialist for all range ventilation maintenance. Test and 

balance the system.

● Implement and manage a lead safety program that follows the Occupational Safety and 

Health Administration lead standard [29 CFR 1910.1025]. 

● Keep and maintain Occupational Safety and Health Administration injury and illness logs.

● Remove all materials being stored in firing lanes because they disrupt airflow in the range.

● Repair the target retrieval system.

● Have employees use wet cleaning methods and avoid dry sweeping debris, casings, and 

lead dust from the floor of the range. 

● Provide instructors with clothes and shoes to wear only at work, no-slip style 

disposable shoe covers, two lockers to separate street clothes from work clothes, and 

on-site laundry service to prevent take-home exposures.

What Employees Can Do

● Do not dry sweep debris, casings, and lead dust from the floor of the range. Continue to 

use the bullet casing sweeper.

● Use a lead-removal cleaning solution for all surface cleaning activities.

● Enter and exit the range through the appropriate entry or exit door. 

● To avoid tracking lead dust out of the range and possibly into your home:

○ Use no-slip style disposable shoe covers and dedicated work shoes 

○ Use dedicated work clothes and shoes kept in a locker at the workplace and 

laundered either on-site or by a lead-certified laundry service.

● Wash hands with lead-removal soap each time you leave the range. Wash hands with 

regular soap and water before eating while at work. 
Health Hazard Evaluation Report 2016-0232-3285 Page iii

Abbreviations

μg/m3 Micrograms per cubic meter

μg/dL Micrograms per deciliter

ACGIH® American Conference of Governmental Industrial Hygienists

AHU Air handling unit

BLL Blood lead level

cfm Cubic feet per minute

CFR Code of Federal Regulations

FOH Federal Occupational Health

LOD Limit of detection

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 2016-0232-3285 Page 1

Introduction

The Health Hazard Evaluation Program received a request from the employer at a federal 

law enforcement indoor firing range in Washington, DC. The employer was concerned about 

lead exposure to firearms instructors. We visited the building in December 2016 to interview 

instructors and assess their exposure to lead, copper, and zinc. In December 2016, we sent 

a letter to instructor and employer representatives outlining our preliminary findings and 

recommendations. In January 2017, we provided a summary of the environmental sampling 

and blood lead results to the employer and instructor representatives. Personal sampling 

results were sent to each instructor and shooter who participated in the evaluation.

Range Description

Law enforcement officers performed their semiannual qualifying shoots in this indoor firing 

range to maintain their sidearm weapons certification. The range was staffed by four full-time 

instructors who oversaw the certification of approximately 400 officers. Instructors typically 

work 10-hour shifts. Although this range hired a safety officer in 2015, it did not have a 

comprehensive lead safety program in place. During our visit, instructors split their time 

between the classroom, office, and firing range. Typically, one instructor oversaw the weapon 

cleaning and maintenance training just outside of the range area (Figure 1). During shooting, 

three instructors stood on the range behind the shooters. One instructor remained in the range 

observation booth, also known as the tower, providing instructions to the shooters. This range 

used frangible and nonfrangible (duty) ammunition. Frangible ammunition is designed to 

disintegrate on impact to minimize penetration into the target whereas duty ammunition is 

designed to remain intact to maximize target penetration. Duty ammunition contained mostly 

lead, while frangible bullets contained mostly copper and some zinc.

The range had 14 firing lanes and a dedicated ventilation system (Figure 1). The range 

ventilation system is described in the results and discussion section. The weapons cleaning 

area is adjacent to the range and is supplied by a separate ventilation system that also serves 

the main building. The break room and office areas for instructors are in a separate part of the 

building and are also supplied by the main building ventilation system.
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Figure 1. Layout of the firing range and weapons cleaning area.

Methods

The objective of this evaluation was to determine if the firearms instructors were exposed to lead 

above recommended levels and if this was evidenced by elevated blood lead levels (BLLs). To 

achieve this objective, we (1) measured instructor and shooter airborne lead concentrations during 

weapons qualification; (2) determined the lead concentrations on surfaces inside and outside of 

the range; (3) determined whether instructors had lead contamination on their hands and footwear 

when leaving the range; (4) evaluated the ventilation system performance as it relates to National 

Institute for Occupational Safety and Health (NIOSH) guidelines; (5) determined work practices 

could increase instructors’ lead exposure; and (6) measured current blood lead levels. 

During our visit, we observed work practices during a weapons qualification course, 

including shooting, cleaning firearms, range hygiene, and range cleanup. We collected 

personal air samples from four instructors and five shooters over 1 day. Each sample was 

analyzed for lead, copper, and zinc according to NIOSH Method 7303 [NIOSH 2017]. 
Health Hazard Evaluation Report 2016-0232-3285 Page 3

We collected surface wipe samples for lead, copper, and zinc in the range, offices, and 

breakroom using premoistened Palintest® Dust Wipes according to NIOSH Method 9102 

[NIOSH 2017]. We used a disposable template to collect each wipe sample over an area of 

100 square centimeters. Hand wipe samples were collected on the four instructors prior to 

leaving work for the day. We had the instructor wipe the palm and back surfaces of each hand 

for a total of 30 seconds. We collected footwear sole wipe samples on the four instructors 

prior to leaving the range area for the day, after walking across the adhesive mat leaving the 

range. We had instructors wipe the sole of one shoe for 30 seconds. Hand and footwear sole 

wipe samples were evaluated using a Full Disclosure® qualitative colorimetric screening 

method for the presence of lead.

We reviewed blueprints and inspected the range ventilation system including the air handling 

units (AHUs) and ductwork (Figure 1). We also inspected the exhaust outlets from the roof 

of the range. We used qualitative and quantitative methods to characterize the airflow in and 

around the firing range. We also checked airflow direction at each doorway leading to and from 

the range to determine whether the range was under positive or negative pressure relative to the 

cleaning and preparation area. We used ventilation smoke (Degree Controls, Inc.) to visualize 

airflow patterns within the range. We also used an electronic micromanometer (Shortridge 

Instruments, Inc. AirData Multimeter Model ADM-860C) to measure air velocity. We focused 

on the following locations: (1) the perforated air supply wall; (2) just behind the firing line at 

each shooting stall; (3) approximately 15 feet downrange at the close quarters combat firing 

line; (4) approximately halfway downrange; and (5) at the front of the bullet trap. 

All four instructors were invited to participate in blood lead testing and confidential medical 

interviews. The interviews covered work tasks and practices, possible sources of recreational 

lead exposure, and lead-poisoning related symptoms. Venous blood samples were drawn to 

measure lead levels; these results are the basis for the information presented below in Results 

and Discussion. We also performed a finger stick to measure the levels of lead with a portable 

blood-lead testing device so that we could examine its utility compared to venous blood 

sampling for lead. Results of the finger stick testing are in Appendix C.

We reviewed BLLs on the four instructors from tests conducted by the Federal Occupational Health 

(FOH) clinic in July 2016. We also reviewed current lead-related training materials. The site did not 

maintain Occupational Safety and Health Administration (OSHA) Forms 300 Log of Work-Related 

Injuries and Illnesses. We also reviewed all lead training materials given to instructors. 

Results and Discussion

Workplace Observations

During our visit, shooters were engaged in a 9-mm handgun qualification exercise. The 

exercise consisted of classroom activities, firearm cleaning, and target shooting. Each 

shooter fired a total of 594 rounds. Of the 594 rounds fired, 418 (70%) were copper frangible 

ammunition, and 176 (30%) were duty ammunition.
Page 4 Health Hazard Evaluation Report 2016-0232-3285

Required personal protective equipment worn during qualification for both shooters and 

instructors consisted of ear plugs and earmuffs (double hearing protection) and safety glasses. 

Instructors wore duty uniforms. Shooters wore duty uniforms or off duty clothes if they came 

in outside of a work shift. Instructors and shooters had access to a locker room with shower 

facilities, but instructors reported that they did not use it. An adhesive floor mat at the exit of 

the range was meant to clean the bottom of footwear when people left the range. We noticed 

the mat needed to be changed multiple times per day and appeared to lose effectiveness 

quickly because of buildup from foot traffic in and out of the range (Figure 2). 

Figure 2. Adhesive floor mat at range exit door used to remove footwear contamination. The mat is 

covered with footprints. Photo by NIOSH.

At the time of our visit, the target retrieval system was broken. The target retrieval system 

was an automatic pulley system that shooters use to place the targets downrange and to 

bring the targets back to the firing line. The controls for this system were located at the firing 

line. Because the retrieval system was broken, shooters and instructors had to go into the 

contaminated area downrange from the firing line, which could add to their exposure to lead 

dust through skin contact and dermal absorption. At different times during the qualification 

exercises, we observed shooters walking downrange, pushing the target hangers with their 

bare hands, and moving them downrange (Figure 3). Neither shooters nor instructors wore 

gloves during these tasks.
Health Hazard Evaluation Report 2016-0232-3285 Page 5

Figure 3. Shooters moving the target retriever downrange by hand. Photo by NIOSH.

Instructors reported that lanes 1, 2, and 12–14 were not used. We observed that lanes 1–3 

and 12–14 were not used during qualification exercises. We observed material being stored 

in these unused lanes (Figure 4). Two pedestal fans were placed on each side of the range in 

lanes 1 and 14. Instructors reported that they used these fans during warmer weather because 

the range did not have air conditioning.

Figure 4. Material being stored in the shooting lanes of the range. Photo by NIOSH.
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We observed shooters and instructors dry sweeping the range with brooms (Figure 5). Debris 

from the floor was swept onto a dust pan and dumped into a bucket at the end of the work day. 

We also observed instructors using a bullet casing sweeper (Figure 6). Casings were collected 

between shooting exercises and at the end of the day using the bullet casing sweeper and 

dumped into a bucket near the control tower for disposal. No gloves or respiratory protection 

were worn by instructors or shooters during cleaning activities. The bullet trap collected rounds 

and used a conveyor system to deposit rounds into a drum outside of the building (Figure 7). 

Instructors reported that a contractor periodically collected the contents of this drum.

Figure 5. Instructors and shooters dry sweeping the floor with brooms downrange from the firing line 

at the end of the day. Photo by NIOSH.

Figure 6. Bullet casing sweeper stored on the range behind the firing line in lane one. Photo by NIOSH.
Health Hazard Evaluation Report 2016-0232-3285 Page 7

Figure 7. Drum outside the building used to collect spent rounds fired into the bullet trap. Photo by NIOSH.

Air Sampling

We took nine personal air samples for lead, copper, and zinc. Full-shift personal air samples 

were collected on four instructors. Task-based personal air samples were collected on five 

shooters while they were shooting and cleaning weapons at the range.

Table 1 presents the personal air sampling results for lead, copper, and zinc. The instructors’ 

full-shift personal air samples for lead ranged from 5.2 to 13 micrograms per cubic meter of 

air (μg/m3). These samples were below the OSHA, NIOSH, and American Conference of 

Governmental Industrial Hygienists (ACGIH®) occupational exposure limit (OEL) of 

50 μg/m3. The five shooters’task-based personal air samples for lead ranged from 28 to 

46 μg/m3. The task-based results cannot be compared to the full-shift OELs but suggest that 

shooters could exceed the OEL for lead if they worked longer hours under similar conditions.

The instructors’ full-shift personal air samples for copper ranged from 9.8 to 35 μg/m3. 

Shooters’ task-based personal air samples for copper ranged from 47 to 86 μg/m3. The 

particulate likely contains a mix of particles of varying sizes including inhalable, respirable, 

and metal fume particles. All full-shift samples were below the OSHA, NIOSH, and ACGIH 

OEL of 1,000 μg/m3 for copper dust. All full-shift samples were also below the OSHA and 

NIOSH OEL of 100 μg/m3, and ACGIH OEL of 200 μg/m3 for copper fume. The task-based 

results cannot be compared to the full-shift OELs but suggest that shooters would not exceed 

the OEL for copper if they worked longer hours under similar conditions.
Page 8 Health Hazard Evaluation Report 2016-0232-3285

The instructors’ full-shift personal air samples for zinc ranged from not detected to 4.5 μg/m3. 

Shooters’ task-based personal air samples for total zinc ranged from 0.32 to 0.63 μg/m3

. All 

samples were well below the lowest OEL of 2,000 μg/m3

 for respirable zinc oxide particulate 

(Table 1). The task-based results cannot be compared to the full-shift OELs but suggest that 

shooters would not exceed the OEL for zinc if they worked longer hours under similar conditions.

Table 1. Personal air sampling results for lead, copper, and zinc (μg/m3)

Job title Sample duration

(minutes)

Lead 

concentration

Copper 

concentration

Zinc 

concentration*

Instructor 520 13 35 4.5

Instructor 520 5.2 19 [0.13]

Instructor 518 9.8 9.8 Not Detected

Instructor 520 7.0 15 [0.17]

Shooter 364 29 47 [0.33]

Shooter 363 43 84 0.63

Shooter 360 28 62 [0.32]

Shooter 354 46 86 0.56

Shooter 354 39 76 0.50

OSHA PEL 50 1,000 (dust)

100 (fume)

5,000 (zinc oxide fume 

or respirable dust)

NIOSH REL 50 1,000 (dust)

100 (fume)

5,000 (zinc oxide fume 

or total dust)

ACGIH TLV 50 1,000 (dust)

200 (fume)

2,000 (zinc oxide fume 

or respirable dust)

PEL= Permissible exposure limit

REL = Recommended exposure limit

TLV = Threshold limit value

*The minimum detectable concentration for zinc was 0.1 μg/m3 for instructors and shooters.

The minimum quantifiable concentration for zinc was 0.29 μg/m3 for instructors and

0.42 μg/m3 for shooters.

[ ] = Estimated concentration; this concentration was between the minimum detectable 

concentration and minimum quantifiable concentrations.

Surface Sampling

Table 2 presents the surface sampling results for lead, copper, and zinc. We detected lead and 

copper on all sampled surfaces throughout the building. The target hanger, which is always 

handled without gloves, had the highest level besides the floor samples. We detected zinc 

on all sampled surfaces except the microwave. The presence of contamination on top of the 

cubicle divider in the office area indicates that lead, copper, and zinc were being transferred 

from the range into the main building. 
Health Hazard Evaluation Report 2016-0232-3285 Page 9

Table 2. Surface wipe sample results for lead, copper, and zinc (micrograms per 100 square 

centimeters)

Sample location Lead 

concentration

Copper 

concentration

Zinc 

concentration

Break room

Keypad and handle of the microwave* [0.72] 1.2 Not detected

Refrigerator handle* 12 27 220

Instructor office area

Top of cubicle divider in office area* 1,000 700 540

Range area

Floor, hallway outside the door to the 

staging area

150 220 47

Table, weapon cleaning area 66 160 47

Floor, weapon cleaning area near exit door 2,000 3,000 110

Desk top, viewing area 60 60 9.9

Lane 10 barricade handle* 530 390 57

Ammunition loading bench top 470 430 16

Lane 9 target hanger* 1,800 590 61

Floor, range, in front of sticky mat 4,100 6,700 190

Floor, lane 9, 10 feet downrange from 

shooting stall

1,800 4,100 130

Minimum detectable concentration 0.2 0.1 2.0

Minimum quantifiable concentration 0.77 0.24 7.3

*Estimated 100 square centimeters. The disposable templates were not compatible with the shape

of the surface.

[ ] = Estimated concentration; this concentration was between the minimum detectable and 

minimum quantifiable concentrations.

We found lead on the hands of the four instructors after they left the range area for the day. All 

colorimetric tests were positive; the limit of detection is 18 micrograms of lead per wipe. All 

instructors reported washing their hands with regular soap and water multiple times that day, but 

never with the lead removal soap or wipes. No instructors had washed their hands immediately 

prior to our sample collection. Lead was also present on the soles of the instructors’footwear 

after leaving the range area for the day. Lead dust can contaminate surfaces and be transferred 

onto an instructor’s hands, and then be transferred from their hands to their mouth. Any lead 

dust on hair, skin, clothes, or shoes may be transferred to surfaces inside personal vehicles, 

homes, and to other family members who come into contact with contaminated surfaces.

Ventilation System Evaluation

We accessed the ventilation system from the catwalk above the range. We located all air 

supply and exhaust ducts. Outdoor air enters the system through two 36-inch by 36-inch 

inlets. Supply air is delivered to the perforated air supply wall by twelve 26-inch by 8-inch 

ducts using four individually controlled AHUs. According to blueprints, the system is 

designed to deliver a total of 12,000 cubic feet per minute of air (cfm). The perforated air 
Page 10 Health Hazard Evaluation Report 2016-0232-3285

supply wall is approximately 10 feet behind the firing line and is designed to direct air in a 

uniform manner toward the firing line and downrange past the shooter (Figure 1).

Approximately 10 feet downrange, 10 exhaust grilles approximately 6 inches by 70 inches in 

size, are located approximately 15 feet above the floor (Figure 8). These grilles exhaust air to 

the outdoors through four 24-inch by 18-inch ducts designed to exhaust 1,000 cfm each, using 

two individually controlled AHUs. Four 30-inch by 24-inch grilles are further downrange, at the 

bullet trap. Each is designed to return 2,000 cfm of air to the AHU. This return air, along with 

outdoor air from the outdoor air intakes, supplies the makeup air to the perforated air supply 

wall. All AHUs filter the air using a three-stage filter arrangement. The first stage contains a 

minimum efficiency reporting value 11 filter, the second stage contains a minimum efficiency 

reporting value 12 filter, and the third stage contains a high efficiency particulate air filter. The 

employer reported that the filters are replaced by the cleaning contractor. Stage one is replaced 

monthly, stage two is replaced every 6 months, and stage three is replaced annually.

Figure 8. Exhaust grilles above the floor approximately 10 feet downrange from the firing line. 

Photo by NIOSH.

All six of the three-stage filter banks are monitored for pressure drop across the filter 

arrangement. Gauges in the control tower show the pressure drop and monitors also have 

pre-alarm and final alarm indicators. The pre-alarm is an amber light indicating that filters 

need to be changed soon. The final alarm is a red light indicating that the filters need to be 

changed immediately. The final alarm shuts down all of the AHUs.

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

of lead and copper exposures resulting from firing range use. Firing ranges should be under 

slight negative pressure relative to adjacent areas to minimize migration of air contaminants 

to other areas within the building. The air curtains at both doors between the range and 

the weapons cleaning area (Figure 1) are designed to limit contaminants from moving into 
Health Hazard Evaluation Report 2016-0232-3285 Page 11

the weapons cleaning area by allowing the supply air to move across the entrance and exit 

doors. Smoke tests at these doors revealed air moving away from the air curtains and moving 

downrange. This suggests that the air curtains were effectively operating as designed. Figure 

A1 in Appendix A shows airflow patterns and velocities inside the firing range. We found 

that the velocities in many lanes were low relative to NIOSH recommendations [NIOSH 

2009]. NIOSH recommends that all air supplied to the range be distributed evenly across 

all areas of the range to prevent areas of turbulence. Air velocity at the firing line should be 

between 50 and 75 feet per minute. Air velocity downrange past the firing line should be a 

minimum of 30 feet per minute in each lane and should be evenly distributed. Based on these 

recommendations, only lanes 7 and 11 had acceptable firing line velocities. Air velocities 

downrange from the firing line were not uniform and many were measured to be less than 

30 feet per minute. Results of the smoke test further supported the finding that the velocities 

in many lanes were low relative to NIOSH recommendations (Appendix A, Figure A1). 

The arrows in Figure A1 show the direction of airflow that was visualized with the smoke 

machine. Air moved from the perforated air supply wall towards the firing line but at the 

firing line we observed areas of turbulence around the shooting stalls. Approximately halfway 

downrange we observed that the air slowly mixed but was hardly moving downrange at all. 

At the bullet trap we observed very little air movement. We also noticed a note on the control 

panel stating “exhaust #1 not working” which is consistent with our findings showing a 

reduction or lack of air movement on the right side of the range (Figure 9). 

Figure 9. Note taped to the control panel for the ventilation system stating “exhaust #1 not working.” 

Photo by NIOSH.

Review of Current Lead-related Training Materials

Initial training on lead health hazards is covered in approximately 2 hours of the 10-day 

firearms instructor training program [FLETC 2015]. The training covers current OSHA 
Page 12 Health Hazard Evaluation Report 2016-0232-3285

standards for lead, exposure routes, health effects of lead in adults and children, and proper 

work practices. It was reported that all personnel using the range are required to sign a 

one-page document each year that reviews safe range behavior. This document does not cover 

lead hazards. No lead hazard refresher training is currently in place for instructors or shooters.

Medical Interviews and Blood Lead Level Testing

All four instructors participated in confidential medical interviews and BLL testing during the 

December 2016 site visit. The median duration of employment as an instructor at this range was 

12 years (range: 6–18 years). Instructors reported that they spend 2–6 hours on average on the range 

each workday. None of the instructors reported ever requiring medical treatment for lead poisoning.

All four instructors had detectable BLLs that ranged between 3.4–11 micrograms per deciliter 

(μg/dL), with two above the current NIOSH surveillance case definition that defines a lead level 

≥ 5 μg/dL as elevated (Appendix B) [NIOSH 2015]. All four instructors had at least one previous 

BLL test by the local FOH clinic in July 2016. At that time, all four had BLLs ≥ 5 μg/dL (range 

6–25 μg/dL). Each instructor’s December 2016 BLL was lower than their July 2016 level. 

Although there were elements of a lead monitoring program in place, it did not appear to be 

part of a comprehensive program as mandated by OSHA. Instructors appeared to request BLLs 

at their own discretion depending on their perceived level of lead exposure risk. Instructors 

had their BLLs done through the local FOH clinic. These results were reviewed by an FOH 

physician and reported back to the individual. There was no formal communication back to the 

employer notifying them of elevated lead levels and the need to take any action.

The range was not cleaned in December 2015 as scheduled because the cleaning contractor 

had gone out of business. As a result, instructors began doing more of the range cleaning 

activities. The range safety officer reported that requests were made to evaluate whether the 

system was operating effectively. The requests were addressed by a heating, ventilation, and 

air-conditioning technician and not by a company with experience with maintaining firing 

range ventilation systems. Performing more range cleaning duties and overall impression 

of an ineffective range ventilation system, led to the perception of increased lead exposure 

risk. This prompted the two instructors with BLLs > 10 μg/dL at the December 2015 testing 

to have their BLLs rechecked in April 2016. The April 2016 BLLs for these two instructors 

were 25 and 26 μg/dL. The two instructors removed themselves from the range for 2 months. 

They returned after their BLLs had dropped to 14 μg/dL in July 2016. The decision to return 

to work was made by the instructors themselves. The physicians reviewing the BLL results 

did not communicate their findings with the employer.

All instructors were asked about ways to improve training about workplace lead exposures. 

Three of the instructors mentioned annual refresher training on lead. They reported not 

having reviewed lead safety since their initial instructor certification class. 

Our interviews indicated that workplace programs and practices, including dry sweeping the 

floor, inconsistent use of lead removal soap for handwashing, and dry wiping range table 

surfaces, could contribute to increased lead exposure. We observed all of these practices 

during our visit. All instructors reported that lead removal soap was available in the range 
Health Hazard Evaluation Report 2016-0232-3285 Page 13

but use was inconsistent. All instructors reported having engaged in some type of range 

cleaning activity in the previous 3 months, ranging from daily to once a month in frequency. 

All instructors reported cleaning the downrange area, and three reported cleaning the gun 

cleaning tables, dry sweeping the range floor, and collecting casings for disposal. Some 

instructors reported cleaning tables using wet methods; glove use practices were 

inconsistent. It was mentioned that the target retrieval system needed to be repaired so 

instructors would not have to move the targets manually.

We asked about practices that could expose household members to lead carried home from 

the workplace (also known as take-home lead). None of the instructors reported having 

dedicated work clothes or shoes, using no-slip style disposable shoe covers, or showering 

before leaving the building at the end of a shift. Three instructors stated they never showered 

when arriving home from work, while one stated they always did. Three instructors reported 

they always changed out of their work clothes when arriving home, while one responded 

“sometimes” to this question. Only one instructor reported household members having their 

BLL measured since the instructor started work at this building. This instructor reported that 

no household members had a detectable BLL. Three instructors reported that their initial 

instructor training regarding workplace lead hazards was adequate but that there is no formal 

refresher training for lead hazards. One instructor commented that they did not feel that lead 

exposure was a significant health issue. A detailed discussion of lead’s health effects and the 

dangers of take-home lead to household members is available in Appendix B.

We also asked about possible non-occupational sources of lead exposure. One instructor 

reported engaging in recreational shooting about once a month and remodeling a home built 

prior to 1978 (the U.S. Consumer Product Safety Commission banned lead-based paints 

from use in residential housing that year). No other instructors reported other non-work 

related sources of lead exposure. Some examples of these activities include collecting lead 

material for recycling, making their own leaded fishing lures, fueling aircraft that use leaded 

aviation gasoline, making pottery or other ceramics that use a lead-containing glaze, doing 

their own auto body work or handling car batteries, or working at another firing range either 

as paid employee or volunteer.

Adverse health effects associated with elevated lead levels include high blood pressure 

and decreased kidney function [NTP 2012]. Although two instructors reported high blood 

pressure, which can occur at a BLL < 10 μg/dL, none reported other possible lead-related 

health effects. Decreased kidney function, anemia, severe unexplained abdominal pain, or 

infertility issues tend to occur at much higher BLLs.

Just before our December 2016 visit, a safety officer was hired to oversee the lead exposure 

monitoring program, find a new range cleaning contractor, and maintain the OSHA injury 

and illness logs. A new range cleaning contractor had been hired but had not yet performed 

its first service at the time of our site visit. This may explain the lead contamination we 

found on surfaces throughout the range. Work practices like dry sweeping, infrequent 

handwashing, and a lack of disposable shoe covers may have contributed to contamination 

throughout the building.
Page 14 Health Hazard Evaluation Report 2016-0232-3285

Conclusions

A health hazard from exposure to lead exists in this firing range to all personnel who use this 

range. At risk personnel include instructors who work on the range each work day along with 

officers who visit the range quarterly for their required qualification shoots. All four 

instructors had detectable BLLs with two > 5 μg/dL, which NIOSH defines as elevated. Lead 

was detected on surfaces throughout the building, in the breathing zone of instructors and 

shooters, and also on instructors’ hands and footwear as they left work to go home. A 

combination of ventilation system issues, insufficient range cleaning services, poor 

handwashing practices, and the lack of a comprehensive lead exposure monitoring program 

may have contributed to detectable BLLs among instructors. The ventilation system was not 

performing according to NIOSH recommendations. Lack of dedicated work clothes and shoes, 

use of available shower facilities, and on-site laundry service also increased the risk of takehome lead. Although adhesive floor mats are present, they must be used in combination with 

other methods to reduce the risk of take-home lead and contamination throughout the building.

Recommendations

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

a labor-employer health and safety committee or working group 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 

indoor law enforcement 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. 

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. Consult a ventilation engineer with experience in designing firing range systems

to repair or modify the ventilation system. The system should supply conditioned

air to the range according to NIOSH specifications. The NIOSH website has useful

information about firing range ventilation at http://www.cdc.gov/niosh/topics/ranges/.

2. Conduct a test and balance evaluation of the system after it is repaired or modified.

Perform a smoke test to visualize airflow patterns and the direction of air movement.

a. All air supplied to the range should be distributed evenly across all areas of the

range to prevent areas of turbulence.
Health Hazard Evaluation Report 2016-0232-3285 Page 15

b. Air velocity at the firing line should be between 50 and 75 feet per minute.

c. Air velocity downrange past the firing line should be a minimum of 30 feet per 

 minute in each lane and should be evenly distributed.

d. The ventilation system should exhaust more air than it supplies (about 10%).

3. Make sure the ventilation system is operating whenever the range is used or being cleaned.

4. Inspect the walls between the range and the adjacent office area. Seal any holes, gaps, 

or cracks that could allow lead-contaminated air to migrate from the range to other 

parts of the building.

5. Repair the target-retrieval system so that personnel no longer have to walk through a 

contaminated area to change and move targets.

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. Institute a lead exposure monitoring program according to the OSHA lead standard 

[29 CFR 1910.1025]. This standard provides requirements for engineering controls, 

exposure monitoring, work practices, housekeeping, and personal protective 

equipment to reduce occupational exposures to lead. Follow the medical surveillance 

program outlined in Appendix B in addition to all requirements of the OSHA standard.

2. Enter and exit the range through the appropriate entry or exit door. This will prevent 

tracking contamination from the range into the weapons cleaning and staging areas. 

3. Require each instructor or shooter to wash hands with lead removal soap each time 

they leave the range. 

4. Use lead removal soap prior to the use of any abrasive hand cleaner. Make sure 

employees are aware that abrasive cleaners can remove the outer layer of skin and 

could increase lead absorption. 

5. Stop dry sweeping and only use either a wet method (a lead removal solution at the 

manufacturer’s suggested concentration) or a high efficiency particulate air filtered 

vacuum, followed by a wet cleaning, to clean potentially contaminated surfaces. 

a. Brooms should never be used, even with dust suppression compounds.

b. The specialized bullet casing sweeper should be the only dry method used to 

 collect casings from the floor.

c. Use a wet floor scrubber to clean downrange from the firing line at the end of the day.

6. Do not store materials in the firing lanes or operate pedestal fans in the range because 

they can disrupt airflow and affect the ability of lead particulate to move downrange. 

All air movement in the range should be uniform and directed downrange toward the 

bullet trap. When the ventilation system has been repaired it should supply conditioned 

air to the range and pedestal fans will no longer be needed. 
Page 16 Health Hazard Evaluation Report 2016-0232-3285

7. Institute annual lead hazards refresher training. 

8. Reduce risk of take-home lead and cross-contamination in the building by providing 

instructors with dedicated work clothes and shoes, separate lockers for street clothes 

and work clothes, and on-site laundry (or contract a laundry service qualified to handle 

lead-contaminated garments). Display the OSHA Quick Card on Take-home Lead 

Prevention in a highly visible location (available at 

https://www.osha.gov/Publications/OSHA3680.pdf). Provide copies of the card to 

personnel when they sign the required receipt of safety information form before each 

use of the range. 

9. Implement and enforce a policy where all persons entering the range area wear 

no-slip style disposable shoe covers. Figure 1 shows suggested locations for shoe 

cover supply and disposal.

a. Maintain a supply of shoe covers at the entrance to the range area so that shoe 

 covers can be put on just after entering the range area from the hallway in the 

 main building.

b. Provide a shoe cover disposal bin on the range side of the exit door to the weapons 

 cleaning area. Shooters can remove shoe covers before stepping onto the adhesive 

 mat while passing through the door to the weapons cleaning area. 

c. Maintain a second shoe cover supply on the weapons cleaning area side of the 

 exit door. Shoe covers can be put on after exiting the range area before moving 

 around the weapons cleaning area. 

d. Provide a second shoe cover disposal bin at the outer door to the range area so 

 that shoe covers can be disposed of just before exiting the range area into the 

 main building.

e. Make sure that all shoe cover disposal bins have lids that close.

10.Encourage the safety officer to provide frequent reminders to instructors engaging in 

daily range cleaning activities on the proper methods to use (e.g., wet cleaning and 

high efficiency particulate air filtered vacuuming).

11.Begin keeping OSHA Form 300, Log of Work-Related Injuries and Illnesses.

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

implementing changes to evaluate their efficacy in reducing lead exposure. 

13.Encourage instructors to talk to their healthcare provider about their exposure to lead 

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

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

ride in their vehicles to get their BLLs tested.

14.Ensure personnel and contractors doing range maintenance, changing ventilation 

system air filters, and scraping the bullet trap are compliant with the OSHA lead 

standard [29 CFR 1910.1025].
Health Hazard Evaluation Report 2016-0232-3285 Page 17

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. Encourage the use of disposable nitrile gloves by shooters while cleaning their 

weapons and during range cleanup activities. Do not use natural rubber latex gloves 

because they can result in allergic reactions for some people.

2. Instruct shooters and instructors to wear disposable nitrile gloves whenever handling 

the broken target retrieval system. This includes pushing and pulling the target while 

downrange as well as changing the targets.

3. Wear and change no-slip style disposable shoe covers according to the new policy 

described under Administrative Controls. 
Page 18 Health Hazard Evaluation Report 2016-0232-3285

Appendix A: Diagram of the Firing Range

Figure A1. Range diagram showing air velocities at different locations on the range and the locations 

of supply and exhaust registers. The arrows show the direction of airflow that was visualized with the 

smoke machine.
Health Hazard Evaluation Report 2016-0232-3285 Page 19

Appendix B: 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 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.

● 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].

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 
Page 20 Health Hazard Evaluation Report 2016-0232-3285

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.

Background on 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 

abrasive blasting), and firing ranges [Koh et al. 2015]. Lead exposure and resultant elevated 

BLLs in those who use and staff firing ranges have been well described in the literature and 

in previous NIOSH health hazard evaluations [Institute of Medicine 2012; Laidlaw et al. 

2017; NIOSH 2013, 2014]. Occupational exposures also occur among workers who apply or 

remove lead-based paint and among welders who burn or torch-cut metal structures. 
Health Hazard Evaluation Report 2016-0232-3285 Page 21

Blood Lead Levels

In most cases, an individual’s BLL is a good indication of recent exposure to lead because the halflife 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 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. Recent compilations of BLLs in employees obtained during an HHE at a firing range 

along with surveillance data from Washington state showed increased BLLs in not just the range 

employees but their family members as well [Centers for Disease Control and Prevention 2014].

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/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, 20 μg/dL. ACGIH 

designates lead as an animal carcinogen [ACGIH 2017]. In 2013, the California Department of 

Public Health recommended that California 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].

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 
Page 22 Health Hazard Evaluation Report 2016-0232-3285

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 OSHA PEL, NIOSH REL, and ACGIH TLV may prevent overt symptoms of lead 

poisoning, but do not protect workers from lead’s contributions to conditions such as 

hypertension, renal dysfunction, or 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 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 B1).
Health Hazard Evaluation Report 2016-0232-3285 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 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 [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. In 2015, NIOSH designated 5 μg/dL of whole 

blood, in a venous blood sample, as the reference BLL for adults. This definition created for 

surveillance purposes, defined an elevated BLL is defined as a BLL ≥ 5 μg/dL [NIOSH 2015]. 

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 
Page 24 Health Hazard Evaluation Report 2016-0232-3285

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 

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 its medical 

management guidelines in 2014 [CDPH 2014]. In 2016, the American College of 

Occupational and Environmental Medicine released a position statement entitled “Workplace 

Lead Exposure,” which reinforces the guidelines and recommendations above [Holland and 

Cawthorn 2016]. Table B2 incorporates recommendations from the expert panel guidelines 

and those from the California Department of Public Health, American College of 

Occupational and Environmental Medicine, and the Council of State and Territorial 

Epidemiologists. 

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.
Health Hazard Evaluation Report 2016-0232-3285 Page 25

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 < 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. 
Page 26 Health Hazard Evaluation Report 2016-0232-3285

Appendix C: Portable Blood Lead Testing Device

The gold standard for BLL measurement is collection of a venous sample, which is analyzed 

in a laboratory. This method can be costly and does not provide an instantaneous result. 

Measuring lead in the workplace has been suggested, but interference from skin contamination 

with lead in the workplace has been a concern [Taylor et al. 2001]. To learn whether skin 

contamination concerns could be addressed, NIOSH researchers have assessed the effectiveness 

of cleansing methods. In one study, the traditional soap and water method for hand washing did 

not efficiently remove lead from skin [Filon et al. 2006]. In another, hand washing with a wipe 

that contains a pH balanced wetting agent and chelating agent was greater than 99% effective in 

removing lead from skin [Esswein et al. 2011]. This technology is available commercially. 

NIOSH researchers have an ongoing study at several workplaces to compare the BLLs from 

finger capillary samples that are analyzed by the LeadCare II® to venous BLLs analyzed at a 

reference laboratory and to compare the BLLs from finger capillary samples taken from a finger 

cleaned with soap and water to those of a finger cleaned with Hygenall®. As part of this project, 

we evaluated the LeadCare II® Test Kit, which measures lead in fresh whole blood from either a 

skin puncture or a venipuncture. We asked instructors who were having their blood collected for 

lead to allow us to collect a capillary blood sample from one finger on each hand. Prior to sample 

collection, one hand was cleaned with a PDI® castile soap towelette and rinsed with water, and 

the other was cleaned with a Hygenall (a lead removal soap) hand wipe and rinsed with water. 

Each instructor’s capillary blood sample results from the Test Kit were compared to the results 

of their venous BLL testing reported by our contract laboratory. For statistical analysis, we used 

the student’s paired t-test and Pearson’s correlation coefficient (the r value) to compare results for 

the two methods (Excel Microsoft Office 2013). Results with P values ≤ 0.05 were considered 

statistically significant. The LeadCare II instrument has a limit of detection (LOD) of 3.3 μg/dL. 

Two of the four venous samples analyzed by the Test Kit reported as less than the LOD. None of 

the capillary samples returned results less than the limit of detection. The contract laboratory’s 

LOD for venous BLL is 0.50 μg/dL and none of the samples were below it.

All four instructors participated in the research component. The mean venous BLL for all four 

instructors as analyzed by the contract lab was 7.0 μg/dL. The mean venous BLL for all four 

instructors analyzed by the Test Kit was 9.5 μg/dL for the venous blood sample, 7.7 μg/dL for 

the capillary blood sample drawn after the skin was cleaned by the lead removal soap wipe, 

and 7.25 μg/dL for the capillary blood sample drawn after the skin was cleaned with the castile 

soap. The mean capillary BLLs for the hand cleaned with the castile soap towelette were not 

statistically different from the mean venous BLL obtained from the contract laboratory (P = 0.59); 

similarly, the mean capillary BLLs for the hand cleaned with the lead removal soap wipe were not 

statistically different from the mean venous BLL obtained from the contract laboratory (P = 0.57).

This data will be pooled with data obtained using this research protocol in conjunction with other 

HHEs to see if the larger dataset would support use of the Test Kit for capillary blood samples in 

the field. The results we found with this limited sample set are consistent with previous results 

showing that venous blood tested with the Test Kit and venous blood tested in the laboratory had a 

mean difference of 1.2 μg/dL, which is clinically insignificant [Stanton and Fritsch 2007].
Health Hazard Evaluation Report 2016-0232-3285 Page 27

In May 2017, the U.S. Food and Drug Administration (FDA) issued a recall of all the 

LeadCare Testing Systems produced by Magellan due to concerns regarding its use in 

analyzing venous blood specimens. This recall included the Magellan Lead Care II unit 

that was used in our evaluation. The recall was due to the unit reporting falsely low results 

when analyzing venous blood specimens even though it still appeared to be accurate when 

analyzing fingerstick blood samples. The cause of this issue is currently being investigated by 

the company and the Centers for Disease Control and Prevention [FDA 2017].
Page 28 Health Hazard Evaluation Report 2016-0232-3285

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Keywords: North American Industry Classification System 922120 (Police Protection), 

Washington D.C., Lead, Firing Range, Frangible Bullet
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Health Hazard Evaluation Report 2016-0232-3285 Page 35

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

Medical Field Assistance: Deborah Sammons

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. 

Recommended citation for this report:

NIOSH [2017]. Evaluation of lead exposure at an indoor law enforcement firing range. 

By Grant MP, Eisenberg J, 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, Health Hazard Evaluation Report 2016-0232-3285, 

http://www.cdc.gov/niosh/hhe/reports/pdfs/2016-0232-3285.pdf.
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