Expert Report

Potential Health Risks to DOD Firing-Range Personnel from Recurrent Lead Exposure (2012)

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There is overwhelming evidence that the Occupational Safety and Health Administration's (OSHA) general industry standards for lead exposure, set more than 30 years ago, are inadequate to protect worker populations. This report was conducted at the request of the Department of Defense (DOD), whose employees at military firing ranges are exposed to lead recurrently when they handle ammunition, conduct maintenance on ranges, and breathe lead dust released into the air by gunfire. According to the 1978 OSHA standards, employees should not be exposed to lead concentrations in the air of more than 50 micrograms per cubic meter of air (µg/m3) in order to limit blood lead levels to 40 micrograms per deciliter of blood (µg/dL), a level judged by OSHA at that time to adequately protect workers from adverse health effects. However, a large body of research conducted since 1978, including recent evaluations performed by the U.S. National Toxicology Program and the Environmental Protection Agency, offers compelling evidence that nervous system, kidney, heart, reproductive and other health problems can be caused by blood lead levels between 10 and 40 µg/dL or even lower levels. In addition, DOD firing ranges often fail to meet the 30-year old OSHA standard for lead concentrations in air, frequently exceeding 50 µg/m3 on Army, Navy, and Air Force firing ranges. Given these findings, DOD should review its guidelines and practices for protecting workers from lead exposure, including consideration of lowering acceptable blood lead levels to more stringent levels.

Key Messages

  • A review of the epidemiologic and toxicologic data provide overwhelming evidence that the OSHA standard provides inadequate protection for DOD firing-range personnel and for any other worker populations covered by the general industry standard. Specifically, the premise that maintaining blood lead levels under 40 µg/dL for a working lifetime will protect workers adequately is not valid.
  • There is sufficient evidence to infer causal relationships between BLLs under 40 µg/dL and adverse neurologic, hematopoietic, renal, reproductive, and cardiovascular effects.
  • There is compelling evidence of developmental effects in offspring exposed to lead in utero and during breastfeeding, and this raises additional concerns about exposures of women of childbearing age.
  • Data collected for the last 5 years show that the OSHA PEL for lead of 50 µg/m3 was frequently exceeded on Army, Navy, and Air Force firing ranges, in some cases by several orders of magnitude. Blood lead level data on firing-range personnel were not available from either the Army or the Navy, but the Air Force reported that available blood lead levels of its firing-range personnel were all under 40 µg/dL.
  • Given the finding that the OSHA lead standard is inadequate, DOD should review its guidelines and practices for protecting workers from lead exposure on firing ranges, including consideration of lowering acceptable blood lead levels to more stringent levels.