Exposure to Lead and Noise at Indoor Firing Ranges

April 2008
NIOSH Docket Number 128

This NIOSH Alert presents five case reports that document lead and noise exposures of law enforcement officers and students. The Alert examines firing range operations, exposure assessment and control methods, existing regulations, and exposure standards and guidelines.

Final Document

NIOSH Alert Preventing Occupational Exposure to Lead and Noise at Indoor Firing Ranges; 4/1/09 [PDF – 839 KB]

Materials Under Evaluation

Draft NIOSH Alert, Preventing Occupational Exposures to Lead and Noise at Indoor Firing Ranges; 11/01/07 [PDF – 9,510 KB]

Notice of Draft Document Available for Public Comment; 73 FR 20927; 04/17/08 [PDF – 83 KB]

Submissions in Order of Receipt

Submission to the docket from Geiger (OPNAV Safety Liaison Office Code N09FB) – 04/12/08 [PDF – 631 KB]

Submission to the docket from Metcalf (Metcalf Range Consulting ) – 04/22/08 [PDF – 1,003 KB]

Submission to the docket from Burke (Penn State University) – 05/02/08 [PDF – 184 KB]

Submission to the docket from Grady (Washington State Department of Labor & Industries/DOSH) – 05/02/08 [PDF – 217 KB]

Submission to the docket from Cameron (California Department of Justice) – 05/07/08 [PDF – 3,730 KB]

Submission to the docket from Melville (Global Well-being Services) – 05/07/08 [PDF – 202 KB]

Submission to the docket from Sharrow (Anchorage School District) – 05/07/08 [PDF – 161 KB]

Submission to the docket from Veckman (Comprehensive Environmental Assessments) – 05/07/08 [PDF – 154 KB]

Submission to the docket from private person – 05/09/08 [PDF – 459 KB]

Submission to the docket from Mullins (Navy and Marine Corps Public Health Center Occupational & Environmental Medicine Directorate (OEM)) – 05/20/08 [PDF – 339 KB]

Submission to the docket from Rabin (Massachusetts Department of Labor) – 05/29/08 [PDF – 251 KB]

Submission to the docket from Greiner (Meggitt Training Systems) – 06/24/08 [PDF – 222 KB]

Submission to the docket from Dozois (Massachusetts Consultation Program) – 06/26/08 [PDF – 405 KB]

Submission to the docket from Woods (Fibertec Industrial Hygiene Services, Inc.) – 06/26/08 [PDF – 230 KB]

Submission to the docket from Bott (Range Ventilation Design, Inc.) – 06/30/08 [PDF – 258 KB]

Submission to the docket from DiBartolomeis (California Department of Public Health) – 06/30/08 [PDF – 2,990 KB]

Submission to the docket from Patterson (National Association of Shooting Ranges) – 06/30/08 [PDF – 2,320 KB]

Submission to the docket from McGlothlin (NGB-ARS) – 12/15/08

NIOSH Response to public comments – 5/12/09 [PDF – 58,010 KB]

Peer review

Title: NIOSH Alert: Preventing Occupational Exposure to Lead and Noise at Indoor Firing Ranges

Subject: Analysis of and control technologies for law enforcement officer exposure to lead and noise.

Purpose: To provide general design and work practice recommendations to occupational safety and health professionals, industrial hygienists, law enforcement agencies and officers, and shooting range associations and operators in order to reduce or eliminate health hazards and maintain safe operation of firing ranges.

Timing of Review: Early 2006

Primary Disciplines or Expertise Needed for Review: Industrial hygiene

Type of Review: Individual

Number of Reviewers: 9

Reviewers Selected by: NIOSH

Public Nominations Requested for Reviewers: No

Opportunities for the Public to Comment: No

Peer Reviewers Provided with Public Comments Before Their Review: No

Peer Reviewers:

Lynne Coe-Levitt, C.I.H.
Organizational Affiliation: Industrial Hygienist, Safeguards and Security, Idaho National Laboratory, Idaho Falls, ID
Recommended by: NIOSH

Kitty Gelberg, Ph.D., M.P.H.

Chief, Epidemiology and Surveillance Section, Bureau of Occupational Health, New York State Department of Health, Troy, NY
Recommended by: NIOSH

David Harrington, M.P.H.

Occupational Health Branch, California Department of Health Services, Oakland, CA
Recommended by: NIOSH

Lyman Lindstrand, C.I.H.
National Training Center, U.S. Department of Energy, Albuquerque, NM
Recommended by: NIOSH

Travis Parsons
Senior Safety and Health Specialist, Occupational Safety and Health Division, Laborers’ Health and Safety Fund of North America (LHSFNA), Washington, DC
Recommended by: NIOSH

Rick Patterson
Executive Director, National Shooting Sports Foundation, Newtown, CT
Recommended by: NIOSH

Tiina Reponen, Ph.D.
Department of Environmental Health, University of Cincinnati, Cincinnati, OH
Recommended by: NIOSH

Benjamin Smith
Federal Law Enforcement, Department of Homeland Security, Cheltenham, MD
Recommended by: NIOSH

Ira Wainless
Senior Industrial Hygienist, Occupational Safety and Health Administration, U.S. Department of Labor Washington, DC
Recommended by: NIOSH

Peer Reviewers’ Comments:

The Alert was reviewed by nine external reviewers from academia, government, industry, and professional organizations. No major structural changes to the Alert were required to address the external reviewers’ comments. Most of the reviewers’ suggested editorial and content modifications to the Alert to improve its clarity and accuracy. The major changes recommended are summarized below:

  • Expand the OSHA standard on Lead to include information regarding biological monitoring and medical surveillance. One reviewer felt that the OSHA requirements are weak and NIOSH should recommend more stringent monitoring requirements in the Alert based on recent scientific findings.
  • Expand on the details provided on several of the case reports. Several reviewers indicated that some case studies may not be representative of actual conditions inside firing ranges and requested more information on the recommendations provided to alleviate the risks from exposure to lead and noise.
  • Improve the section on ammunition substitution to include information on frangible bullets. Two reviewers indicated that the ammunition substitution section can be improved by discussing recent developments and commercial use of new types of bullets with low or no lead emissions.
  • Improve the engineering controls recommendations to include information on new state of the art backdrop systems and the use of electronic simulation.
  • Include information about work practices in the hierarchy of controls recommendations section. Two reviewers felt that work practices should be incorporated more tightly into administrative controls.
  • Expand on exposure and medical health monitoring by including additional sections from the OSHA 1910.1025 to provide more details on employee monitoring and medical surveillance.
  • One reviewer felt that the Alert did not address the issue of cost and economic feasibility of the recommendations provided in this Alert, especially for smaller firing ranges and whether the costs associated with implementing some or all of the recommendations would be economically prohibitive.

Response to Peer Reviewers’ Comments:

The Alert was reviewed by nine external reviewers from academia, government, industry, and professional organizations. No major structural changes to the Alert were required to address the external reviewers’ comments. Most of the reviewers suggested editorial and content modifications to the Alert to improve its clarity and accuracy. The major recommendations and associated modifications are summarized below:

  • Expand the OSHA standard on Lead to include information regarding biological monitoring and medical surveillance. The authors included additional information on recent scientific studies that suggest more stringent monitoring and medical surveillance recommendations than required by the OSHA regulations for reference purposes.
  • Expand on the details provided on several of the case reports. The authors explained the limited availability of case studies on exposure to firing ranges and added additional information to the existing cases to describe some of the recommendations and solutions provided to reduce exposures.
  • Improve the section on ammunition substitution to include information on frangible bullets. The authors added additional information on alternative types of bullets to the Alert.
  • Improve the engineering controls recommendations to include information on new state of the art backdrop systems and the use of electronic simulation. The authors added information on the new systems to the Alert.
  • Include information about work practices in the hierarchy of controls recommendations section. The authors modified the Administrative Controls section to include discussions on work practices that the users of firing ranges can implement to protect the safety and health of workers at the ranges.
  • Expand on exposure and medical health monitoring by including additional sections from the OSHA 1910.1025 to provide more details on employee monitoring and medical surveillance. The authors added detailed suggestions from the OSHA standard to the Alert as recommended by the reviewer.
  • One reviewer felt that the Alert did not address the issue of cost and economic feasibility of the recommendations provided in this Alert, especially for smaller firing ranges. The authors added comments to discuss that the Alert provides a range of recommendations and solutions that can be incrementally adopted by range users and operators based on cost and resources available.