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

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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.

Required Elements for Initial Public Posting

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
Academic and Professional Credentials: C.I.H.
Organizational Affiliation: Industrial Hygienist, Safeguards and Security, Idaho National Laboratory, Idaho Falls, ID
Recommended by: NIOSH

Kitty Gelberg
Academic and Professional Credentials: Ph.D., M.P.H.
Organizational Affiliation(s): Chief, Epidemiology and Surveillance Section, Bureau of Occupational Health, New York State Department of Health, Troy, NY
Recommended by: NIOSH

David Harrington
Academic and Professional Credentials: M.P.H.
Organizational Affiliation(s): Occupational Health Branch, California Department of Health Services, Oakland, CA
Recommended by: NIOSH

Lyman Lindstrand
Academic and Professional Credentials: C.I.H.
Organizational Affiliation: National Training Center, U.S. Department of Energy, Albuquerque, NM
Recommended by: NIOSH

Travis Parsons
Academic and Professional Credentials:
Organizational Affiliation: 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
Academic and Professional Credentials:
Organizational Affiliation: Executive Director, National Shooting Sports Foundation, Newtown, CT
Recommended by: NIOSH

Tiina Reponen
Academic and Professional Credentials: Ph.D.
Organizational Affiliation: Department of Environmental Health, University of Cincinnati, Cincinnati, OH
Recommended by: NIOSH

Benjamin Smith
Academic and Professional Credentials:
Organizational Affiliation: Federal Law Enforcement, Department of Homeland Security, Cheltenham, MD
Recommended by: NIOSH

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

Charge to Peer Reviewers:

Dear Dr. Reponen:

I am writing to inquire if you would be willing to review a draft document for the National Institute for Occupational Safety and Health (NIOSH). The document to which I refer is “NIOSH Alert: Preventing Occupational Exposures to Lead and Noise at Indoor Firing Ranges.” You have been recommended to us as someone with relevant expertise and interest in this topic. The Alert is a 40 page document that aims to highlight the exposure issues inherent in operating indoor firing ranges and to provide recommendations for reducing hazardous exposure to lead and noise. This document is intended for occupational safety and health professionals, researchers, and users and operators of indoor firing ranges.

I am attaching the draft document, a separate pdf file with two figures for the document, and a review form for your consideration. If you are unable to review the document, just let me know that by return email. If you can review the draft Alert for us, please send your review directly to me, by email at wlotz@cdc.gov, or by regular mail at the address shown below. We would appreciate receiving your comments by April 28, 2006.

Your specific review is of particular importance to us in meeting our objectives for careful review by independent subject matter experts. To document our review, I need to get from you a summary of your professional background and expertise. This could be in the form of a biosketch, or even a CV, if that is easiest. I will also need a statement from you regarding any conflicts of interest, which can be provided on the form attached. You are welcome to send me these items by email or whatever means is most convenient for you. Thank you for your help in meeting our requirements for a rigorous external review of this important publication.
If you have any questions about this matter, or would like to discuss it further before deciding whether to review the document, please do not hesitate to contact me by phone at (513) 841-4143, or by email.

Thank you again for your help with our efforts to disseminate this important information about firing ranges. I look forward to receiving your review.

Sincerely yours,
W. Gregory Lotz, Ph.D.
Captain, U.S. Public Health Service
Associate Director for Science
Division of Applied Research and Technology
CDC/National Institute for Occupational Safety and Health
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