Att B - Example HHE report

Attachment B: HHE local health department brochure evaluation, Example HHE report

Evaluation of Employee Exposure to Lead and
Other Chemicals at a Police Department

Kenneth W. Fent, PhD, CIH
John Gibbins, DVM, MPH
Todd Niemeier, MS, CIH

Report No. 2012-0083-3189
July 2013

U.S. Department of Health and Human Services
Centers for Disease Control and Prevention
Health Hazard Evaluation Report 2012-0083-3189
National
Institute for Occupational Safety and Health

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Contents
Highlights................................................i
Abbreviations...................................... iv
Introduction.......................................... 1
Methods................................................ 2
Results & Discussion............................. 5
Conclusions......................................... 15
Recommendations............................. 15
Appendix............................................. 20
References........................................... 22
Acknowledgements............................ 27

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.
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Highlights of this Evaluation
The Health Hazard Evaluation Program received a request from a police department in Ohio.
Employees were concerned about exposure to lead from the firing range, mold in second
floor offices, and ventilation in the illicit drug storage room.

What We Did
●● We visited the facility in March and June 2012.
●● We talked with employees about health concerns they related to work.
●● We inspected the second floor ceiling for water intrusion and mold.
●● We evaluated the firing range’s ventilation and
filtration system.
●● We tested surfaces in the firing range and parking
garage for lead.
●● We tested surfaces in the property room for
illicit drugs.
●● We measured employee exposures to ethyl
cyanoacrylate during cyanoacrylate fuming and
carbon black during fingerprint dusting.

What We Found
●● Most employees we talked with had health
symptoms they felt were related to the workplace.
●● One employee had a higher than normal level of
lead in his/her blood.

We identified problems in
the firing range ventilation
system. We found lead
contamination in the parking
garage and illicit drug
contamination in the property
room. We recommend not
using the firing range until its
ventilation system has been
redesigned and cleaning
surfaces in the garage and
property room.

●● We saw no signs of current water intrusion or mold.
●● Air from the hallway and above the ceiling flowed into the second floor offices.
●● The firing range did not meet all of the ventilation design elements recommended by
the National Institute for Occupational Safety and Health.
●● We found lead on surfaces inside the parking garage. The firing range was the main
source of this lead.
●● We found illicit drugs on some surfaces in the property room. Work surfaces had lower
levels than undisturbed surfaces such as elevated shelving.
●● We did not find ethyl cyanoacrylate vapor or carbon black particles in the air.

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What the Employer Can Do

●● Redesign the firing range or use another firing range that meets National Institute for
Occupational Safety and Health recommendations. Do not use the firing range until it
has been redesigned.
●● Provide officers with non-lead bullets and lead-free primer.
●● Sample the air for lead when officers use bullets or primer containing lead. Use
the results to determine which elements of the Occupational Safety and Health
Administration lead standard to follow.
●● Clean surfaces where lead or illicit drugs were found.
●● Hire a contractor to balance the second floor ventilation system.
●● Set schedules for changing air filters in the local exhaust ventilation systems and
vacuum cleaners.
●● Start a health and safety committee that includes employee, employer, and union
representatives. Hold regular meetings.
●● Encourage employees to report health symptoms they think may be related to work.

What Employees Can Do
●● Wear nitrile gloves when cleaning guns, handling spent cartridge cases, or working in
the parking garage or firing range.
●● Wear nitrile gloves when handling illicit drug evidence and doing criminology
procedures.
●● Clean hands with soap and water or with lead-decontamination wipes after firing guns
or doing other work that could expose your hands to lead, even if you wear gloves.
●● Become active in the health and safety committee.
●● Report work-related health concerns to your supervisor.

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Mention of any company or product does not constitute endorsement by NIOSH. In
addition, citations to websites external to NIOSH do not constitute NIOSH endorsement
of the sponsoring organizations or their programs or products. Furthermore, NIOSH is not
responsible for the content of these websites. All web addresses referenced in this document
were accessible as of the publication date of this report.

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Abbreviations
µg/100 cm2
Micrograms per 100 square centimeters
2
µg/ft
Micrograms per square foot
µg/dL
Micrograms per deciliter
BLL
Blood lead level
cm Centimeters
cm2
Square centimeters
HEPA
High-efficiency particulate air
HUD
Department of Housing and Urban Development
HVAC
Heating, ventilating, and air-conditioning
MERV
Minimum efficiency reporting value
mm Millimeters
ND
Not detected
2
ng/100 cm
Nanograms per 100 square centimeters
NIOSH
National Institute for Occupational Safety and Health
OEL
Occupational exposure limit
OSHA
Occupational Safety and Health Administration
THC Tetrahydrocannabinol

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Introduction
The Health Hazard Evaluation Program received a request from employees at a police
department in Ohio. The request concerned lead exposures in and around the firing range,
a history of water intrusion and mold growth on the ceiling tiles in the juvenile office,
and lack of ventilation in the property room where illicit drugs were stored. We made two
site visits to the police department to evaluate exposures, work conditions, and employee
health concerns.
The police department was in a two-story building. Our evaluation focused mainly on the
second floor and basement. The second floor contained offices (including the juvenile office)
and a crime lab. The basement contained a parking garage, property room, and firing range.
The juvenile office had a drop ceiling with tiles that were reported to have mold growth at
one time. The juvenile office was staffed by three to four officers, mainly during the first
shift. The crime lab was in a section of the old jail. Two box fans had been strapped to the
windows in the crime lab to provide exhaust ventilation by directing air outdoors. The crime
lab had a Sirchie model FR600 cyanoacrylate fuming chamber with a recirculating highefficiency particulate air (HEPA) filter and a DeFumigator™ model FR300 carbon-bed
filtration system, a Mystaire Misonix tabletop exhaust hood with recirculating carbon-bed
filtration, and a Microzone Corporation model EPH-2-4 fingerprint powder downdraft table
with HEPA filtration. The crime lab was used by one or two officers, and generally for no
more than a few hours per week.
The firing range was next to
the parking garage. It had five
lanes, but only the three center
lanes (lanes 2–4) were used for
weapons qualifications (Figure
1). The range dimensions were
86 feet deep × 19 feet wide ×
7.5 feet tall. Equipment and
tables were placed along the
walls uprange and downrange
(in the areas of lanes 1 and
5). The firing line was 16
feet from the rear wall. Five
ceiling-mounted supply air
diffusers were positioned 7
Figure 1. Inside of firing range.
feet behind the firing line. Air
was exhausted from the range
via a sidewall exhaust ventilation system 32 feet downrange from the firing line (38 feet
uprange of the bullet trap). The exhaust ventilation filtration system (Figure 2) contained
a minimum efficiency reporting value (MERV)-8 pre-filter and MERV-14 primary filter.

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The exhaust air discharged
directly into the garage.
The prefilter was changed
quarterly, and the primary
filter was changed biannually
by a heating, ventilating, and
air-conditioning (HVAC)
contractor.
Approximately 100 officers
used the firing range. Officers
reported that targets were
placed downrange of the
exhaust fan and that officers
stood at the firing line directly
Figure 2. Exhaust ventilation system for the firing range that disadjacent to the exhaust fan to
charges air into the parking garage.
fire their weapons. Officers
qualified one time per year by
firing 60 rounds with a handgun and shotgun. Duty ammunition that contained lead was used
for qualification. At all other times, clean-fire ammunition containing lead-free primer and a
total metal jacket was used. After several qualifications, the department’s bomb team used a
Nilfisk model CFM S2 HEPA vacuum to clean the floors and bullet trap in the range while
wearing a DuPont™ Tyvek® suit and a respirator. The employer did not know the type of
respirator worn. A range officer emptied the dust collected by the vacuum as needed. Officers
reported that personal protective equipment was not worn when emptying the vacuum.
The property room was also adjacent to the parking garage. The property room did not
contain an exhaust ventilation system, but did have a recirculating ceiling-mounted steam
heater and a wall-mounted air-conditioning unit. One or two officers could spend 2 hours
or more per day inside the property room documenting, storing, retrieving, or inventorying
criminal evidence. The automotive maintenance employee’s office was also adjacent to the
garage. This employee maintained the patrol vehicles parked in the garage.

Methods
During our March 2012 visit we met with employer and employee representatives to
discuss the health hazard evaluation request. The police department provided us with a
copy of a consultant’s lead assessment in the firing range and parking garage and the HVAC
contractor’s report summarizing the preventive maintenance on the HVAC system. We held
confidential interviews with 12 of 15 employees who worked in the firing range, basement
property room and maintenance areas, and second floor juvenile and detective offices and
administrative areas. We asked about their work history, health concerns, medical history,
and the department’s occupational health surveillance program. We reviewed medical records
from two of five employees who reported seeking medical care for their symptoms.
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During the March 2012 visit we inspected the plenum (the space above the suspended
ceiling) in the juvenile office and other second floor offices for evidence of water intrusion
or mold growth. Because the ceiling tiles in the juvenile office were sealed, we removed a
ceiling tile in the adjacent waiting area and used a Fluke® Ti55 FlexCam thermal imaging
camera to identify cooler areas in the ceiling as an indicator of water damage or water
intrusion. We inspected the firing range and its exhaust ventilation system. We used Gastec
Corporation ventilation smoke tubes to visualize the movement of gun smoke within
the firing range. We also used a TSI condensation particle counter in the parking garage
approximately 20 feet downstream from the exhaust ventilation discharge grilles to measure
airborne submicron particulate levels while the firing range was in use. For comparison, we
measured the particulate in the exhaust air when the firing range was not in use. We used
SKC Inc. Full Disclosure® colorimetric wipes to test surfaces in the firing range, garage, and
automotive maintenance office for lead contamination. These wipes produce a color change
if lead is present. We measured relative humidity and airflow direction (relative to adjacent
areas) in the property room and second floor office area. Relative humidity was measured
with a TSI Q-trak™ Plus, and airflow direction was determined with a Gastec Corporation
ventilation smoke tube. Finally, an officer showed us the crime lab in the old jail where
criminology equipment and techniques were used.
On the basis of our March 2012 findings we returned to the police department in June 2012
to evaluate in more detail the exhaust ventilation and filtration system in the firing range, lead
contamination in the basement, and potential illicit drug contamination in the property room.
We also sampled the air for ethyl cyanoacrylate during cyanoacrylate fuming inside the crime
lab and carbon black particulate (a component of Sirchie HI-FI silk black fingerprint powder)
during fingerprint dusting of a vehicle inside the parking garage. The officer who did the
cyanoacrylate fuming wore nitrile gloves when handling the cyanoacrylate strips. The officer
who did the fingerprint dusting wore nitrile gloves and a National Institute for Occupational
Safety and Health (NIOSH)-approved N95 filtering facepiece respirator (3M model 1860).
Table 1 provides a summary of the surface and air sampling methods we used during our
June 2012 visit. Templates (10 centimeters × 10 centimeters) were used for sampling flat
surfaces. For irregularly shaped surfaces, we estimated approximately 100 square centimeters
(cm2) and wiped the surface in a manner similar to that used for flat surfaces.

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Table 1. Summary of the air and surface sampling methods used in June 2012
Analyte(s)

Sampling media

Flow rate or
surface area

Method

No. of
samples

SKC Full Disclosure®
wipes

100 cm2

Colorimetric
change and
NIOSH 7303*

18

Cotton swab prewetted
with
buffer solution

100 cm2

Microbead
immunosorbent
assay [Smith et
al. 2010]

12

XAD-7 sorbent tube

0.2 Lpm

OSHA 55†

5‡

25-mm IOM sampler with
preweighed
PVC filter

2 Lpm

NIOSH 0600*

1§

BGI 4L respirable dust
cyclone¶, 37-mm cassette
with preweighed PVC filter

2.2 Lpm

NIOSH 0500*

1§

Surface sampling
Lead

Illicit drugs
(heroin, THC,
methamphetamine,
and cocaine)
Air sampling
Ethyl cyanoacrylate
Carbon black

IOM = Institute of Medicine
Lpm = liters per minute
mm = millimeters
PVC = polyvinylchloride
THC = tetrahydrocannabinol
*NIOSH Manual of Analytical Methods [NIOSH 2013]
†Occupational Safety and Health Administration (OSHA) Sampling and Analytical Methods [OSHA
1985]
‡Collected three area air samples and two personal air samples worn by one officer during
cyanoacrylate fuming of evidence.
§Personal air samplers worn by one officer on the same shoulder during fingerprint dusting of a
vehicle.
¶BGI Incorporated (Waltham, Massachusetts)

To evaluate the ventilation system in the firing range we used an aerosol generating machine
(Rosco Laboratories Inc. model 1500) to generate “theatrical smoke” (actually a submicron
liquid aerosol). The smoke was used to visualize airflow patterns in each of the firing lanes.
Smoke was generated at four points along the length of the range: the firing line, 17 feet
downrange, 32 feet downrange, and at the bullet trap. We also used a TSI VelociCalc®
Plus air velocity meter to measure airflow at the firing line and at three points downrange
from the firing line (17 feet, 32 feet, and at the bullet trap). Triplicate measurements were
collected in each lane along the firing line at two different heights (approximately 3 feet and
5 feet). These measurements were averaged and the average was reported for each location.
To test the effectiveness of the filtration system in the firing range we used a TSI
condensation particle counter in the parking garage approximately 20 feet downstream
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from the exhaust grilles. We measured airborne submicron particle levels in the exhaust
while theatrical smoke was generated in the firing range. For comparison, we measured the
particulate in the exhaust air when the firing range was clear of theatrical smoke.

Results and Discussion
Employee Interviews and Symptoms
The average length of employment at the department was 20 years (range: 8 to 36
years). Eight of 12 (67%) employees reported symptoms they felt were related to work.
Approximately one third of interviewed employees reported shortness of breath, sneezing,
sinus congestion, and itchy eyes. Most employees stated their symptoms improved on days
off or when not working on the second floor. Some employees reported seasonal allergies
that were also associated with nonwork exposures. Multiple factors could contribute to these
nonspecific symptoms. These factors include prior mold exposure, poor indoor environmental
quality, and discomfort due to fluctuations in temperature and humidity. Some employees
may have been more sensitive to these factors than others, and thus more likely to report
symptoms. Nonwork exposures and seasonal allergies can also contribute to symptoms.
Five employees previously sought medical care for health effects they thought could be workrelated. Four of these employees were seen for symptoms attributed to recurring allergies, sinus
infections, and chronic back pain. An employee who worked in the basement sought medical
care for fatigue, headache, and leg weakness/pain. This employee’s blood was tested for lead
as part of a medical evaluation. The employee’s blood lead level (BLL) was 38 micrograms per
deciliter (μg/dL). After sharing the test results with the employer, this employee was moved to
the second floor. The employee’s BLL gradually decreased to 5.7 μg/dL over the next 8 months.
An employee’s BLL should be maintained below 40 µg/dL according to OSHA [29 CFR
1910.1025] and below 30 µg/dL according to the American Conference of Governmental
Industrial Hygienists [ACGIH 2013]. These levels are intended to prevent overt symptoms
of lead poisoning; the OSHA recommendations were set almost 30 years ago. Controlling
lead at these levels has not been found to be sufficient to protect employees from more
subtle adverse health effects including high blood pressure, kidney problems, reproductive
concerns such as infertility, and cognitive effects [Schwartz and Hu 2007; Schwartz and
Stewart 2007; Brown-Williams et al. 2009]. Acute lead poisoning is uncommon today due
to current occupational exposure limits (OELs). Acute lead poisoning, with BLLs usually
over 70 µg/dL, can result in clinical symptoms such as abdominal pain, hemolytic anemia,
and neuropathy, and in very rare cases has progressed to encephalopathy and coma [Moline
and Landrigan 2005]. Chronic lead poisoning may not cause any symptoms, or may present
with a variety of symptoms including headache, joint and muscle aches, weakness, fatigue,
irritability, depression, constipation, anorexia, and abdominal discomfort [Moline and
Landrigan 2005]. The non-specific symptoms of headache, fatigue, and leg pain in this
employee have been reported with chronic lead exposure and BLLs of 40–50 µg/dL or lower
in individuals with other medical conditions. We do not know how this employee’s BLL had
been elevated or if it was ever higher than 38 μg/dL. Overexposure to lead may also result in
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kidney damage, anemia, high blood pressure, infertility and reduced sex drive in both sexes,
and impotence in men.
A panel of experts published guidelines to prevent both acute and chronic effects of lead
poisoning in adults [Kosnett et al. 2007]. It recommended removing an employee from
exposure if a single BLL exceeds 30 µg/dL, or if two measurements taken over 4 weeks
exceed 20 µg/dL. Removal should be considered if control measures over an extended
period do not decrease BLLs to < 10 µg/dL. The panel also recommended quarterly
BLL testing if the BLL is between 10 and 19 µg/dL, and semiannual testing if the BLL
is < 10 µg/dL. Pregnant women should avoid BLLs > 5 µg/dL. These guidelines are
endorsed by the California Department of Public Health and the Council of State and
Territorial Epidemiologists [California Department of Public Health 2009; CSTE 2009].
The NIOSH adult blood lead reference value is 10 µg/dL. The NIOSH Adult Blood
Lead Epidemiology and Surveillance program tracks elevated BLLs (i.e., BLLs at or
above the reference values) among adults in the United States. The geometric mean BLL
among adults age 20 and older in the United States is 1.23 µg/dL [CDC 2013]. The CDC
recommends public health actions when the BLL in children is 5 µg/dL or higher. This
“reference level” identifies children ages 1–5 years in the United States whose BLLs are
higher than 97.5% of children based on the National Health and Nutrition Examination
Survey, and is designed to allow early action be taken to reduce further exposure to lead
[CDC 2012].
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. In cases
where careful attention to hygiene (for example, hand washing) is not practiced, smoking
cigarettes or eating may represent another route of exposure among employees who are
exposed to lead and then transfer it to their mouth through hand contamination.
Occupational exposures can also create non-occupational exposures among household
members, including children, from take-home contamination with lead. Take-home
contamination occurs when lead dust is transferred from an employee’s skin, clothing, shoes,
and other personal items to their vehicle.
In addition to their health symptoms, employees told us they did not receive annual
audiograms or blood lead tests; this was confirmed by the employer. OSHA requires
annual audiometric testing if an employee’s full-shift time-weighted average exposure
level is ≥ 85 A-weighted decibels [29 CFR 1910.95]. Although we did not evaluate noise
exposures, evaluations at other indoor firing ranges have found peak sound pressure
levels > 155 decibels [Kardous et al. 2003; NIOSH 2003; Murphy and Tubbs 2007];
exposures to these extreme sound levels for just a few seconds or less will result in fullshift time-weighted average exposures ≥ 85 A-weighted decibels. Studies have shown
that exposure to lead can enhance noise-induced hearing loss [Hwang et al. 2009]. The
U.S. Army recommends annual audiometric testing if employees are exposed to lead at
levels ≥ 50% of the most protective OEL [U.S. Army 2009].

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Many employees expressed concern about the cleaning, maintenance, and operation of
the HVAC system, as well as previous roof leaks and mold growth on the second floor
that they felt contributed to their symptoms. Several employees stated that desk surfaces,
supply air vents in offices, and the maintenance room had been cleaned prior to our first
visit. Employees also mentioned that areas of the range had recently been painted and the
employer had recently purchased a HEPA vacuum for cleaning the range. The employer
stated that part-time cleaning services were provided by the city under contract, and these
services were typically only available from 9:00 a.m. to 5:00 p.m. According to the employer,
general maintenance and repair of the building was the responsibility of the city.

Second Floor Offices: Mold Inspection
We found no evidence of current water intrusion or visible mold contamination on the ceiling
tiles or the plenum area of the second floor offices. Because we had only a limited view of
the plenum area above the juvenile office, we cannot be certain that no mold was present.
Past water intrusion, however, was evident from water-stained ceiling tiles. According to an
HVAC contractor’s report, no microbial contamination or mechanical problems were found
in the HVAC system inspection. Using ventilation smoke tubes, we found that the second
floor office area was under negative pressure relative to the hallway and plenum (meaning
that air was flowing from the hallway and plenum and into the office area). The large
volume of air coming from the plenum and hallway suggested that the HVAC system needed
balancing. The relative humidity was 50% in the second floor offices during our March 2012
visit. However, we only sampled during 1 day in the early spring. Humidity levels are likely
to vary over time. The American Industrial Hygiene Association recommends maintaining
relative humidity below 60% to minimize microbial growth [AIHA 2010].

Firing Range: Ventilation Assessment and Noise Considerations
A summary of the ventilation flow rate measurements is provided in Table 2. The firing
range did not meet the NIOSH recommendations for supply air ventilation design [NIOSH
2009]. Most notably, some airflow rates along the firing line exceeded the NIOSH maximum
recommended airflow of 75 feet per minute. Excessive air velocities can cause eddies (air
currents that run contrary to the main current). A few of our ventilation measurements 17 feet
downrange and all of our ventilation measurements at the bullet trap were below the NIOSH
minimum recommended airflow of 30 feet per minute that is intended to minimize the fallout
of gun emissions downrange. Overall, the airflow was not evenly distributed across the firing
range. This can result in a reversal of airflow. We visualized this reverse airflow in the firing
range using theatrical smoke and found the following:
●● Smoke generated at the firing line traveled downrange, reversed direction, and then
traveled back towards the firing line.
●● Smoke generated 17 feet downrange of the firing line traveled downrange toward the
exhaust fan.
●● Smoke generated 32 feet downrange traveled downrange, reversed direction back

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toward the smoke generation point, and then exhausted from the range.
●● Smoke generated at the bullet trap traveled uprange toward the exhaust fan and was
exhausted from the range.
The firing range did not meet many of the NIOSH recommendations for exhaust ventilation
Table 2. Firing range ventilation flow rates (feet per minute) measured during the second visit
Firing
lane

Firing line

Downrange
(17 feet)

Downrange
(32 feet)

Bullet trap

3 feet
height

5 feet
height

3 feet
height

5 feet
height

3 feet
height

5 feet
height

3 feet
height

5 feet
height

2

51

95

46

21

32

35

4

13

3

162

70

30

31

35

48

4

7

4

281

205

68

15

39

42

3

3

Mean

165

123

48

22

35

42

4

8

Overall
mean

144

35

39

6

design [NIOSH 2009]. Most notably, the air should be exhausted at or behind the bullet trap,
not from the sidewall halfway down the range. The air should also be exhausted outdoors
after being filtered with a HEPA or MERV-18/19 primary filter. These filters capture a
minimum of 99.97% of 0.3-micron diameter particles, which is the most difficult particle
size to capture [EPA 2009]. The air at this firing range was exhausted indoors (in the garage)
and was filtered with a MERV-14 primary filter that only captures 75%–85% of 0.3-micron
diameter particles [EPA 2009]. This explains why we were able to detect submicron particles
in the firing range exhaust when the range was in use or filled with theatrical smoke. Figure
3 shows elevated submicron particle concentrations (compared to background levels) in the
exhaust air during and shortly after an officer fired several shots from a 9-mm handgun in
the firing range during our first visit. The ammunition used in this gun contained non-lead
primer and a total metal jacket bullet. However, even when lead-free ammunition is used,
other potentially harmful metal particulate can be produced (depending on the makeup of the
bullet). Figure 4 shows elevated submicron particle concentrations (compared to background
levels) in the exhaust air when we generated theatrical smoke in the firing range during our
second visit.

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Figure 3. Submicron particle number concentrations measured in the exhaust air of the firing range while an
officer fired his weapon inside the firing range during the first visit.

Figure 4. Submicron particle number concentrations measured in the exhaust air of the firing range while
theatrical smoke was generated inside the firing range during the second visit.

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Noise-induced hearing loss is one of the most common occupational diseases [NIOSH 2001].
Although we did not monitor noise exposures during the evaluation, employees were exposed
to impulse noise when firing weapons. While their exposures were typically of short duration,
prolonged exposures to impulse noise may lead to noise-induced hearing loss [Chan et al.
2001]. According to the police department, officers were required to wear earmuffs during
shooting. However, none of the officers were included in a hearing conservation program.
NIOSH has made recommendations for preventing occupational exposures to noise at indoor
firing ranges [NIOSH 2009]. NIOSH recommends engineering, administrative, and personal
protective equipment measures to limit noise exposure. These recommendations include
requiring employees who use the firing range to wear dual hearing protection (ear plugs and
earmuffs) and enrolling these employees in a hearing conservation program that adheres to
the OSHA noise standard [29 CFR 1910.95].

Parking Garage: Lead Contamination
In the past, lead bullets and primers had been used for practice and qualifying rounds. The
new policy required clean-fire ammunition (non-lead primer and total metal jacket bullet)
for all practice rounds. Duty ammunition was still required for qualifying rounds. Some
of the lead particles produced by firearms during past practices (or during more recent
qualifying rounds) likely passed through the exhaust filtration system and were deposited
into the parking garage. During our first visit we found qualitative evidence (i.e., color
change indications) of lead contamination on the exhaust grilles inside the garage and
on the door handle and computer mouse inside the automotive maintenance office. The
approximate level that can be detected by color change is 18 micrograms per 100 square
centimeters (µg/100 cm2). We sampled more surfaces during our second visit; the qualitative
and quantitative results are provided in Table 3. Our measurements (ranging from 1.8
µg/100 cm2 to 3,100 µg/100 cm2) were generally lower than the consultant’s measurements
made approximately 1 year prior to our second visit (ranging from 1,200 µg/100 cm2 to
210,000 µg/100 cm2). Officers informed us that some surfaces had been cleaned before our
evaluation. The highest levels the consultant measured were in the firing range and in the
garage at or near the exhaust ventilation grilles. The highest levels we measured were also
in these areas. This indicates that the firing range was the main source of lead contamination
in the garage. Occupational health and safety government agencies or national organizations
have not established surface contamination limits for lead. However, OSHA specifies 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)].
In a letter of interpretation from January 2003 related to surface lead contamination in the
OSHA lead-in-construction standard [29 CFR 1926.62], “free as practicable of accumulations
of lead” is described as a performance-oriented requirement. According to OSHA, “The
requirement is met when the employer is vigilant in his efforts to ensure that surfaces are
kept free of accumulations of lead-containing dust. The intent of this provision is to ensure
that employers regularly clean and conduct housekeeping activities to prevent avoidable
lead exposure” [29 CFR 1926.62]. To evaluate the effectiveness of cleaning in change areas,

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storage facilities, and lunchrooms/eating areas, OSHA recommends using the Department
of Housing and Urban Development (HUD) acceptable decontamination level for lead of
200 micrograms per square foot (µg/ft2) for floors [OSHA 2003].
Since the time that OSHA issued this letter of interpretation, HUD lowered the acceptable
decontamination level for lead to 40 µg/ft2 for carpeted and noncarpeted horizontal surfaces
[HUD 2012]. To our knowledge, OSHA has not determined whether the lower HUD
decontamination level should be considered a concentration of lead in workplaces that is
“free as practicable of accumulations of lead.” Because we measured lead contamination
on an area of 100 cm2, our results are not directly comparable to the HUD decontamination
levels (measured on an area of 1 square foot or about 930 cm2). Assuming that the lead was
equally distributed on the surfaces we sampled, then some of our surface measurements may
exceed the HUD decontamination level of 200 µg/ft2 (22 µg/100 cm2), including surfaces
inside the parking garage. Ultimately, the police department will need to determine what it
believes represents “free as practicable of accumulations of lead.”
Table 3. Qualitative and quantitative sampling results for surface contamination of lead during the
second visit
General location
Evidence room

Firing range
Parking garage

Mechanic room
Second floor

Specific location

Qualitative result

Quantitative result
(µg/100 cm2)†

Door vent inside room

+

88

Computer desk

+

(4.5)

Table next to computer

+

(1.8)

Metal cart

+

34

Floor

+

3,100

Table

+

490

Desk next to elevator

−

(1.9)

Upper corner of the firing range
exhaust vent

+

2,200

Floor by range exit

+

2,600

Steering wheel of patrol car
(window open)

−

(4.9)

Floor outside the elevator

+

32

Floor by bicycles

+

170

Bicycle handles

+

28

Door knob to mechanic room

+

23

Middle table

+

14

Desk

+

16

Outside elevator

+

44

Computer mouse in the range officer’s
office

−

(5.4)

Detection limit

0.3

Quantitation limit

8.0

*Color change = “+” or positive for lead. No color change = “−” or negative for lead.
†Values between the detection limit and quantitation limit are shown in parentheses to point out that
there is more uncertainty associated with these values than with levels above the quantitation limit.

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Local government agencies like police departments are not regulated by OSHA.
Nevertheless, OSHA regulations or more protective guidelines should be followed to protect
the health and safety of employees. The OSHA lead standard [29 CFR 1910.1025] requires
each employer who operates a firing range to determine if any employees may be exposed
to lead at or above the action level (30 micrograms per cubic meter of air as an 8-hour
time-weighted average). The employer is also required to institute a medical surveillance
program, including biological monitoring, for employees who are exposed to lead at or
above the action level for > 30 days per year. We did not do air sampling for lead because the
firing range was used infrequently during our visit. Because we observed reverse air flow in
the range and because air from the firing range was exhausted into the parking garage, the
range officer and automotive maintenance employee (who works in the garage) may have
the greatest potential for exposure to lead at or above the action level. After the second site
visit in June 2012, we recommended that the police department stop using the firing range
because (1) it did not meet NIOSH design recommendations [NIOSH 2009] and (2) it was
contaminating the garage with lead and possibly exposing employees. As of June 2013, the
police department was still using the firing range.

Property Room: Illicit Drug and Mold Contamination
Table 4 presents the levels of illicit drugs measured on surfaces in the property room. Other
than for cocaine, the levels were mostly not detected (ND) or below the quantitation limit.
The cocaine levels measured on work surfaces, such as the computer desk or front table,
were lower than the levels measured on undisturbed areas such as the corner of table 2 or
the shelf above the computer desk. Occupational health and safety government agencies
or national organizations have not established surface contamination limits for illicit
drugs. However, several states have established feasibility-based surface contamination
limits when remediating clandestine laboratories for methamphetamine ranging from 100
nanograms per 100 square centimeters (ng/100 cm2) to 500 ng/100 cm2 [NAMSDL 2008].
The methamphetamine levels we measured were below the detection limit of 10 ng/100
cm2. In the past, we sampled surfaces for illicit drugs during an evaluation of a drug vault at
another police department and found on average higher levels of THC, methamphetamine,
and cocaine (heroin was not sampled) than what we measured in this evaluation [NIOSH
2011]. Although acute and chronic health effects from the low levels of drugs found in the
property room appear unlikely, we cannot definitively state that they did not contribute
in part to reported symptoms. Additionally, potential exposure to illicit drugs stored as
evidence will likely vary over time and may be higher during periods of increased work
load .and evidence processing.

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Table 4. Surface contamination levels of illicit drugs in the property room (ng/100 cm2)
Location

Heroin*

THC*

Cocaine*

Methamphetamine

Front table

(1.7)

ND

49

ND

Table 2 in the rear of the room

(1.5)

ND

150

ND

Corner of table 2

(1.4)

(2.7)

270

ND

Top of ladder

(1.1)

ND

170

ND

Cart, second shelf from top

(1.0)

ND

51

ND

Inside secure narcotics cabinet

ND

ND

71

ND

Floor in front of narcotics cabinet

ND

ND

140

ND

Computer mouse

(1.4)

ND

ND

ND

Computer desk

(1.4)

ND

(35)

ND

11

ND

290

ND

Shelf above computer desk
Ear piece of phone

(1.1)

ND

ND

ND

Floor under marijuana cage

ND

4.4

170

ND

Limit of detection per sample

0.9

2

20

10

Limit of quantitation per sample

1.9

3.2

38

21

*Values between the detection limit and quantitation limit are shown in parentheses to point out that
there is more uncertainty associated with these values than with levels above the quantitation limit.

The property room was under slight positive pressure relative to the adjacent garage during the
first visit. The American Society of Heating, Refrigerating, and Air-Conditioning Engineers
does not provide specific exhaust ventilation flow rate recommendations for drug vaults or
property rooms other than that they should be kept under negative pressure [ASHRAE 2007].
This recommendation is mainly intended to keep odors (e.g., marijuana odors) or volatile
contaminants from migrating to adjacent occupied spaces. However, engine exhaust in the
garage likely presented a greater health hazard than the marijuana odors, which are mostly
terpenes [Lai et al. 2008; NIOSH 2011]. Few terpenes have occupational exposure limits.
Therefore, it may be better to keep the property room under positive pressure. The relative
humidity inside the property room during our March 2012 visit was 55%. The American
Industrial Hygiene Association recommends maintaining relative humidity below 60% to
minimize microbial growth [AIHA 2010]. We did not see any visual evidence of mold growing
on the paper bags and cardboard boxes that held marijuana or other plant-based drugs.

Criminology Procedures: Potential Chemical Exposures
The minimum detectable concentrations for the compounds we sampled in air were
calculated by dividing the detection limit for each compound by the average volume of air
sampled. The minimum detectable concentrations represent the smallest air concentrations
that could have been detected on the basis of volume of air sampled.
All the personal and area air concentrations of ethyl cyanoacrylate measured during
cyanoacrylate fuming were ND (below the minimum detectable concentration of 0.024 parts
per million). This procedure lasted and was sampled for about 40 minutes. One area air
sample collected between the two exhaust fans was excluded because the sampling pump
malfunctioned. The American Conference of Governmental Industrial Hygienists threshold
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limit value for ethyl cyanoacrylate is 0.2 parts per million (as an 8-hour time-weighted
average) [ACGIH 2013] and is based upon the potential for eye, skin, and upper respiratory
tract irritation; dermatitis; and possible respiratory sensitization or asthma [ACGIH 2001].
Although the threshold limit value does not have a skin notation, skin contact has been
shown to cause adhesions that result in tissue damage [ACGIH 2001]. Our sampling results
suggest that if cyanoacrylate fuming was performed for an entire 8-hour work shift, the air
concentrations would not exceed the threshold limit value. This assumes, however, that
the cyanoacrylate filtration system would perform optimally over the entire shift. If the
carbon-bed filter were to become saturated, then higher airborne concentrations of ethyl
cyanoacrylate concentrations would be expected.
The personal air concentrations of respirable and inhalable carbon black measured during the
dusting of a car were ND (below the minimum detectable concentration of 2.0 milligrams
per cubic meter). This procedure lasted and was sampled for about 25 minutes. The OSHA
permissible exposure limit and NIOSH recommended exposure limit for carbon black are
3.5 milligrams per cubic meter as an (8 to 10-hour time-weighted average) [NIOSH 2010].
The threshold limit value for carbon black is 3 milligrams per cubic meter (as an 8-hour
time-weighted average) [ACGIH 2013]. These OELs are primarily intended to minimize the
irritation and inflammation of the respiratory system [NIOSH 2010; ACGIH 2011]. NIOSH
set a lower recommended exposure limit for carbon black containing polycyclic aromatic
hydrocarbons [NIOSH 2010]. However, fingerprint powder generally contains commercialgrade carbon black that should not contain polycyclic aromatic hydrocarbons. In a previous
evaluation of another crime lab, the same type of powder used by this department (Sirchie
HI-FI silk black) was found not to contain polycyclic aromatic hydrocarbons [NIOSH 2011].
Our sampling results suggest that if fingerprint dusting of a car were performed for an entire
8-hour work shift, the air concentrations would not exceed the applicable OELs. However,
the officer who did the dusting was tall (> 6 feet in height). A shorter officer’s breathing
zone would be closer to the dusting area, and therefore higher personal air concentrations
of carbon black would be expected. Fingerprint dusting of other objects or at a crime scene
could result in different concentrations of carbon black than what we measured.
During a survey at another police department, we analyzed four commonly used powders,
including Sirchie HI-FI silk black, and found that these powders were primarily composed of
submicron particles [unpublished data]. Recent research suggests that inhalation of smaller
carbon black particles may be more likely to cause pulmonary inflammation than large
carbon black particles [Ward et al. 2010]. This is why we measured inhalable and respirable
carbon black. Inhalable particles are large (up to 100-micron diameter or larger) and can
be deposited anywhere in the respiratory system including the nose and mouth. Respirable
particles are smaller (10-micron diameter or smaller) and can penetrate deeper into the
respiratory system. However, more research is needed to determine the specific properties
and particle sizes of carbon black that relate to toxicity. In addition, pulmonary inflammation
is an acute effect; more research is needed to determine whether repeated exposures to

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carbon black could lead to chronic health effects. This new research could lead to revised
occupational exposure limits. More information on OELs is provided in the Appendix.

Conclusions
One employee had an elevated BLL and clinical signs consistent with lead toxicity which
were likely caused by exposure to lead at work. BLLs in other employees had not been
evaluated. We did not see evidence of ongoing water damage or water infiltration. However,
past reports of water intrusion and mold growth could have contributed to upper respiratory
and eye irritation symptoms reported by some employees. The HVAC system on the second
floor was out of balance. The ventilation system for the firing range had deficiencies that
could result in employee exposure to gun emissions (including lead) in the range and
garage area. We found lead contamination in the garage and illicit drug contamination in the
property room. Chemical exposures from criminology techniques were below applicable
OELs, but are likely to vary depending on the type and amount of evidence being processed.
Implementing the recommendations below will help reduce exposures and improve working
conditions at the police department.

Recommendations
On the basis of our findings, we recommend the actions listed below. We encourage the
police department to use a labor-management 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 the police department.
Our recommendations are based on an approach known as the hierarchy of controls (see
Appendix for more information). 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.

Elimination and Substitution
Eliminating or substituting hazardous processes or materials reduces hazards and protects
employees more effectively than other approaches. Prevention through design, considering
elimination or substitution when designing or developing a project, reduces the need for
additional controls in the future.
1. Use jacketed or non-lead bullets and lead-free primer when firing guns in a firing
range [NIOSH 2009].

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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. Redesign the firing range or use another firing range that meets all the recommended
design elements in the NIOSH Alert titled “Preventing Occupational Exposures to
Lead and Noise at Indoor Firing Ranges” [NIOSH 2009]. Do not use the firing range
at the department unless it has been redesigned. Proper ventilation is necessary even
when lead-free ammunition is used because other potentially harmful metal particulate
can be produced when firing such ammunition depending on the makeup of the bullet.
2. Determine change-out schedules for the filters used in the cyanoacrylate fuming chamber,
exhaust hood, fingerprint powder downdraft table, and HEPA vacuum. The manufacturers
of these systems may have recommended change-out schedules. The carbon bed filters,
in particular, should be changed before they become saturated to prevent the release of
organic compounds (including ethyl cyanoacrylate) into the atmosphere.
3. Have the exhaust hood in the crime lab tested and certified annually.
4. Hire a contractor to balance the HVAC system on the second floor and provide
conditioned air to maintain a relative humidity at or below 60% in the offices and the
property room throughout the year. This will help keep occupants comfortable and
help reduce the potential for mold growth in these areas.

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. Administrative controls are
organized below by the work area where the controls primarily apply.
Firing Range
1. Conduct full-shift personal air sampling for lead and other metals (depending on the
makeup of the bullets) in the redesigned firing range or another firing range being
used and adjacent work areas on days during which multiple firearm shootings
are performed consistently throughout the shift. The sampling results for lead will
determine which specific elements of the OSHA lead standard [29 CFR 1910.1025] to
follow, such as the need for BLL surveillance. The sampling results for other metals
should be compared to applicable OELs.
2. Follow the guidance described in the OSHA lead standard [29 CFR 1910.1025]. This
standard provides requirements for exposure monitoring, work practices, engineering
controls, personal protective equipment, housekeeping, and medical surveillance
among other requirements to reduce occupational exposures to lead.

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3. Require the bomb team to wear full-body protective clothing (such as the Tyvek® suits
worn in the past), nitrile gloves, and a minimum of a NIOSH-approved N95 half-mask
filtering facepiece respirator when cleaning the bullet trap with the HEPA vacuum.
This team (while wearing the recommended personal protective equipment) should
also replace the HEPA filter in the vacuum according to a schedule. Have this team bag
and seal the HEPA filter (when it is ready to be changed) and other lead-contaminated
materials (including their personal protective equipment) and dispose of these items
according to environmental regulations. Following these procedures should protect the
bomb team from being exposed to lead. The bomb team employees should be included
in a written respiratory protection program that adheres to the OSHA respiratory
protection standard [29 CFR 1910.134].
4. Measure noise exposures on officers when they use the redesigned firing range or
another firing range. Audiograms should be done annually if their full-shift timeweighted average exposure level is ≥ 85 A-weighted decibels [29 CFR 1910.95]. In
addition, we recommend following the U.S. Army guideline of performing annual
audiometric testing when employees are exposed to air concentrations of lead (or
other ototoxicants) ≥ 50% of the most protective OEL [U.S. Army 2009]. The NIOSH,
OSHA, and ACGIH exposure limit for lead is 50 µg/m3 [NIOSH 2010; ACGIH 2013].
If an audiogram indicates a standard threshold shift (compared to baseline levels), the
officer should be referred for a medical evaluation.
Parking Garage
1. Sample surfaces (1 square foot in area) that employees regularly contact (in the garage
and other areas of the police department) using NIOSH Method 9100 [NIOSH 2010]
to ensure that the surfaces are “free as practicable of accumulations of lead” according
to the OSHA lead standard [29 CFR 1910.1025(h)(l)]. The discussion section provides
more information on OSHA’s interpretation of “free as practicable of accumulations of
lead.” Our surface sampling locations and results (Table 3) can be used to guide your
sampling plan. Surfaces that are not “free as practicable of accumulations of lead”
should be cleaned and resampled. A variety of cleaners have been shown to be effective
at removing lead dust on surfaces [EPA 1997; Lewis et al. 2006; Lewis et al. 2012]. A
more aggressive cleaner may be needed for the mixture of lead and grime on the floor
of the garage. Employees who do the cleaning should wear protective full-body clothing
and gloves that are resistant to the cleaners. The clothing, gloves, and consumable
cleaning items should be disposed of according to environmental regulations.
2. Instruct employees to remove work shoes before entering their home and to store them
in an area inaccessible to children. Officers who walk through the parking garage at
the police department could contaminate the bottom of their shoes with lead. Keeping
work shoes out of the home and out of reach of children should reduce the potential
for exposing family members to lead.

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Property Room
1. Clean the surfaces inside the property room routinely. A vacuum equipped with a
HEPA filter can be used to clean porous and nonporous surfaces. Environmentally
friendly cleaners and disposable paper towels can be used for all other nonporous
surfaces. Because there are no regulations regarding what can be labeled
“environmentally friendly,” management will need to become knowledgeable about
what cleaning materials are appropriate. Useful sources of information to help
select the safest products include the National Institutes of Health database at http://
householdproducts.nlm.nih.gov/ and the Greenguard Environmental Institute at http://
www.greenguard.org/. Employees performing the cleaning should wear protective
equipment (gloves, safety glasses) as recommended by the manufacturers of the
chosen cleaners.
2. Dry marijuana and other plant-based drugs prior to storage to reduce odors and the
potential for mold growth. If possible, seal drug evidence in plastic bags to minimize
drug particle or odor releases.
Crime Lab
1. Develop a written crime lab health and safety plan that describes workplace hazards,
standard operating procedures, engineering controls, and personal protective
equipment required for each method officers use to process evidence. For guidance,
refer to the International Association for Identification, Safety Guidelines [IAI 2004]
and the Federal Bureau of Investigation, Handbook of Forensic Services [FBI 2007].
This plan should be updated regularly (e.g., annually) or as needed.
2. Conduct full-shift personal air sampling for carbon black during fingerprint dusting
at a crime scene that requires several hours of processing. These sampling results will
provide greater confidence that exposure under actual field conditions are below the
applicable OELs.
Second Floor Offices
1. Inspect the second floor plenum and department roof periodically for active water
intrusion. Repair any leaks and dry any water damaged porous materials within 24–48
hours to prevent mold growth. If they cannot be dried within this time period they
should be replaced.
All Areas of the Police Department
1. Wash hands thoroughly after performing work in the firing range, garage, property
room, crime lab, or crime scene. This is especially important to do before eating,
drinking, or smoking to prevent potential hand to mouth transmission and ingestion of
chemical contaminants. Hands should be washed with soap and water or cleaned with
lead decontamination wipes after shooting, handling spent cartridge cases, cleaning
weapons, or doing other work that could result in hand contact with lead-contaminated
surfaces (even if gloves are worn).

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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. Wear nitrile gloves when cleaning firearms, handling spent cartridge cases, handling
illicit drug evidence, performing criminology procedures, or when doing work in
the garage or firing range that could result in lead contamination on the hands. If the
automotive maintenance employee works under vehicles (on the floor of the garage),
this employee should be given disposable coveralls or coveralls that are kept at work
and laundered periodically (e.g., weekly) by a professional service.
2. Use double hearing protection (earmuffs and ear plugs) for impulsive noise generated
during weapons firing [NIOSH 2009].
3. Provide employees who voluntarily use N95 filtering facepiece respirators during
fingerprint dusting with a copy of Appendix D, “Information for Employees Using
Respirators When Not Required Under the Standard,” of the OSHA respiratory
protection standard [29 CFR 1910.134].

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Appendix: Occupational Exposure Limits and
Health Effects
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 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 exposure. A time-weighted average
refers to the average exposure during a normal 8- to 10-hour workday. Some chemical
substances and physical agents have recommended short-term exposure limit or ceiling
values. Unless otherwise noted, the short-term exposure limit is a 15-minute time-weighted
average 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 permissible exposure limits (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 recommended exposure limits 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 recommended exposure limits 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.
●● Other OELs commonly used and cited in the United States include the threshold
limit values, which are recommended by the American Conference of Governmental
Industrial Hygienists, a professional organization, and the workplace environmental
exposure levels, which are recommended by the American Industrial Hygiene

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Association, another professional organization. The threshold limit values and
workplace environmental exposure levels are developed by committee members of
these associations from a review of the published, peer-reviewed literature. These OELs
are not consensus standards. Threshold limit values 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 2013]. Workplace environmental exposure
levels have been established for some chemicals “when no other legal or authoritative
limits exist” [AIHA 2011].
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
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/en/gestis/limit_values/index.jsp, contains international
limits for more than 1,500 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.

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References
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and biological exposure indices. Cincinnati, OH: American Conference of Governmental
Industrial Hygienists.
ACGIH [2011]. Carbon black. In: Documentation of the threshold limit values and biological
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ACGIH [2013]. Threshold limit values for chemical substances and physical agents and
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Keywords: North American Industry Classification System 922120 (Police Protection),
lead, firing range, ventilation, noise, property room, evidence, illicit drugs, mold, indoor
environmental quality, criminology procedures, fingerprint dusting, cyanoacrylate
fuming

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The Health Hazard Evaluation Program investigates possible health hazards in the
workplace under the authority of Section 20(a)(6) 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 control
occupational health hazards and to prevent occupational illness and disease. Regulations
guiding the Program can be found in Title 42, Code of Federal Regulations, Part 85;
Requests for Health Hazard Evaluations (42 CFR 85).

Acknowledgments
Analytical Support: Bureau Veritas North America
Desktop Publisher: Mary Winfree
Editor: Ellen Galloway
Health Communicator: Stefanie Brown
Industrial Hygiene Field Assistance: Catherine Beaucham and Jung Ho Choi
Logistics: Donnie Booher and Karl Feldmann

Availability of Report
Copies of this report have been sent to the employer, employees, and union 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.
This report is available at http://www.cdc.gov/niosh/hhe/reports/pdfs/2012-0083-3189.pdf.

Recommended citation for this report:
NIOSH [2013]. Health hazard evaluation report: evaluation of employee
exposure to lead and other chemicals at a police department. By Fent
KW, Gibbins J, Niemeier T. Cincinnati, OH: U.S. Department of Health and
Human Services, Centers for Disease Control and Prevention, National
Institute for Occupational Safety and Health, NIOSH HETA Report No.
2012-0083-3189.

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Delivering on the Nation’s promise:
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