Responding to a lead poisoning outbreak during construction and renovation at an indoor firing range

1. Responding to a lead poisoning outbreak during construction and renovation at an indoor firing range Ryan Kellogg and Steve Whittaker Local Hazardous Waste Management Program Public Health – Seattle & King County

2. Outline • Lead in firing ranges • The Incident • Lead’s health effects • Blood lead levels in perspective • Vulnerable populations • Public Health challenges • Looking forward Source: www.buzzle.com/articles/lead-the-element.html

3. Lead in bullets • Projectile: • Elemental lead • Primer: • Lead styphnate • Lead peroxide • Lead nitrite Source: http://science.howstuffworks.com/revolver2.htm

4. Lead on the range Abrasion Combustion Impact Source: http://snovalleystar.com/2013/03/06/police-gun-range-is-under-fire-for-age-and-residue Source: http://www.njnoordhoek.com/?p=735

5. Typical range

6. Initial reports • WA Lead Registry gets two elevated BLL reports from gun range employees • Employee interviews: • Demolition and construction project • “Tons of sand with lead” moved and sifted • Fiberglass insulation removed Used with permission, confidential informant

7. Registry refers to WA OSHA • History of lead violations • Multiple contractors on-site • More help needed • WA OSHA opens inspections on 11/13/12 • Air & wipe sampling → high lead levels on surfaces and in breathing zones, lead passing through exhaust ducts • Inadequate ventilation!

8. Blood Lead Levels (BLLs)

9. Public Health’s involvement • WA OSHA makes a referral to PHSKC - concerned about lead exposures to the public • Can PHSKC close the range until construction is completed?

10. Ladies Night! Source: http://lowcountrybikers.com/cristin-katie-visit-the-gun-range Source: www.reedsindoorrange.com Source: http://adweek.blogs.com/Adfreak/page/339/

11. Cluster and environmental evaluation • Interviewed 100+ workers • Surface sampling (public areas) – 1,000s ug/ft2 • Contamination of multiple surfaces • High air lead levels – 100s ug/m3 • Contamination in vehicles, homes, hotel rooms • Elevated BLLs in a contractor’s children and spouse

12. Public Health challenges • Health Officers in WA (and most other states) have broad statutory authority to protect public health • Lack of regulatory procedure or precedent to guide action, and compel: • cooperation of business owner • temporary closure to protect the public • collection of data to assess public exposure risk • sharing of industrial hygiene data collected by owner’s consultants

13. Public Health challenges • No regulatory limits to protect public from lead in air • Requires close consultation/concurrence with Federal and State agencies • High political valance on federal lead regulation • Worker exposure limits based in 70’s science • No internal PH capacity to collect personal breathing zone samples • Local permit requirements (where they exist) do not stipulate lead exposure controls • Gun ranges are hazardous!

14. Looking forward • Specify surface- and air- lead levels that ensure BLLs <5 mg/dl: • Integrated Exposure Uptake Biokinetic Model (IEUBK) modeling to predict BLLs from inhalation and hand-to-mouth exposures • Consider vulnerable population receptors (women of childbearing age / pregnant women / children) • Increase awareness of lead hazards in the shooting public

15. Looking forward • Promote “best practices” – shooter behavior: • No smoking, eating, or other hand-to-mouth activities • Wash skin after shooting • Wear long sleeves and pants • Clean footwear when leaving the range • Wash range clothing separately

16. Looking forward • Promote “best practices”– range operations: • Jacketed or lead-free ammunition • Lead-free primers in bullets • Replace sand berms with solid bullet traps (with proper disposal of sand!) • Adequate ventilation, tested regularly • Clean range surfaces daily - with confirmation sampling • Routine blood lead testing of employees, regardless of air lead levels. Medical removal at 10 ug/dL

17. Public Health actions • Educate range operators and shooters who consider lead exposure as “normal” • Explore state and local options to address policy and procedural gaps • Incorporate health standards in existing permits (i.e., business licenses) • State regulations to authorize local Health permits of businesses that cause potentially harmful conditions for customers • Ground state and local policies in current evidence base on lead exposure risks • Assure stable funding for lead registries

18. Acknowledgements • DOH: • Rad Cunningham • Glen Patrick • WA OSHA: • Gina Colby • Venetia Runnion • John Stebbins • Ecology: • Trudy Harding • Dave Misko • ATSDR: • Mary Jean Brown • Karen Larson • PHSKC: • Stella Chao • Jeff Duchin • Carina Elsenboss • Hilary Karasz • Mike Kinzer • Ngozi Oleru • Will Perry • Sharon Schoenfeld-Cohen • Olivia Stapleman • Nicole Thomsen • Dennis Worsham • Lead Registry: • Todd Schoonover

19. BLL (mg/dL) Adult blood lead levels in perspective 60 OSHA’s medical removal 50 OSHA’s return to work 40 ABLES case definition for adults / CA medical management trigger 10 CA pregnancy guideline 5 1.4 Adult U.S. geometric mean

22. Gun Range Incident Timeline Construction starts Construction complete? Temporary ventilation 2012 Feb 2013 Oct Nov Apr Mar Jan Dec Sept-Oct 2012 Ecology consulted on berm disposal Range EEs move sand berm, “mine” for lead Pressure washing / disposal on veg. Range EEs remove fiberglass insulation Construction contractors hired Dec-Jan 2013PHSKC wipe samples – public area – 1000s ppm Feb-Apr 2013 Lawsuits! Oct-Nov 2012 Poor ventilation while open to public PHSKC requests closure, then data before reopening (denied) Contamination of vehicles, tools, homes, hotel rooms, family members Range EE BLLs:48 and 40 µg/dl DOSH no longer requires PPE for Range EEs PHSKC initiates surge response Lead registry makes referral to DOSH Media coverage Wipe sampling:100,000s ppm ATSDR Consulted 10/12/12 DOSH opens inspection Final ventilation system installed 13 Range EE BLLs:15 to 58 ug/dl Range hires IH consultant DOSH: Lead in air exhausts, on surfaces, ↑PBZs 12 contractor & subcontractor BLLs:16 - 153 ug/dl PHSKC requires signage 11/30/12 DOSH contacts PHSKC 03/06/13 PHSKC demobilizes Two shooting bays closed – poor ventilation Men’s restroom closed. High lead on floor Lead abatement contractor hired – surfaces cleaned Improvements to ventilation Ladies Night Exposure Assess.