Text For Citation: 01 Item/Group: 004B Hazard:

29 CFR 1910.1025(e)(1)(i): For any employees exposed to lead above the permissible exposure limit for more than 30 days per year the employer did not implement engineering and work practice controls (including administrative controls) to reduce and maintain employee exposure to lead : a) Higher Ground Tactical, LLC ? employees, Range Safety Officers, while working in the firing range observing and instructing clients, were exposed to inorganic lead at an eight hour time weighted average exposure of 0.69 milligrams per cubic meter of air. This exposure is 13.8 times the OSHA permissible exposure limit of 0.05 milligrams per cubic meter of air. This exposure was observed occurring over a 460 minute sampling period on November 15, 2015. A zero exposure was assumed for the 20 minutes not sampled. The employer did not implement feasible engineering and work practice controls to reduce employee exposure to lead. b) Higher Ground Tactical, LLC - employees, Range Safety Officers, while performing gun range clean-up activities such as dry sweeping the shooting range lanes and vacuuming carpets were exposed to inorganic lead at an eight hour time weighted average exposure of 0.22 milligrams per cubic meter of air. This exposure is 4.47 times the OSHA permissible exposure limit of 0.05 milligrams per cubic meter of air. This exposure was observed occurring over a 23 minute sampling period on November 13, 2015. A zero exposure was assumed for the 457 minutes not sampled. The employer did not implement feasible engineering and work practice controls to reduce employee exposure to lead. Feasible engineering and administrative controls include but are not limited to: 1. Install and maintain a supply air and exhaust ventilation system that effectively captures the dust in the shooting range area and exhausts clean air to an outside location. 2. Substitute current ammunition for those with non-lead primer cartridges and non-lead or jacketed bullets designed specifically for firing ranges. 3. Establish a regular maintenance and replacement schedule for the ACSI Air Scrubbers filters. 4. Clean the gun range and adjacent areas using proper cleaning procedures such as HEPA vacuuming and wet sweeping. 5. Eliminate all dry sweeping. ABATEMENT NOTE: ABATEMENT NORMALLY WILL BE MULTISTEP AS FOLLOWS: Step 1: EFFECTIVE RESPIRATORY PROTECTION SHALL BE PROVIDED AND USED BY EXPOSED EMPLOYEES AS AN INTERIM PROTECTIVE MEASURE UNTIL FEASIBLE ENGINEERING AND/OR ADMINISTRATIVE CONTROLS CAN BE IMPLEMENTED, OR WHENEVER SUCH CONTROLS FAIL TO REDUCE EMPLOYEE EXPOSURE TO WITHIN PERMISSIBLE EXPOSURE LIMITS. Step 2: SUBMIT TO THE AREA DIRECTOR A WRITTEN, DETAILED PLAN OF ABATEMENR OUTLINING A SCHEDULE FOR THE IMPLEMENTATION OF ENGINEERING AND/OR ADMINISTRATIVE MEASURES TO CONTROL EMPLOYEE EXPOSURE TO HAZARDOUS SUBSTANCES AS REFERENCED IN THIS CITATION. THIS PLAN SHALL INCLUDE, AT A MINIMUM, TARGET DATES FOR THE FOLLOWING ACTIONS WHICH MUST BE CONSISTANT WITH THE ABATEMENT DATES REQUIRED BY THIS CITATION: (1) EVALUATION OF ENGINEERING/ADMINISTRATIVE CONTROL OPTIONS; (2) SELECTION OF OPTIUM CONTROL METHODS AND COMPLETION OF DESIGN; (3) PROCUREMENT, INSTALLATION AND OPERATION OF SELECTED CONTROL MEASURES; AND (4) TESTING AND ACCEPTANCE OR MODIFICATION/REDESIGN OF CONTROLS. NOTE: ALL PROPOSED CONTROL MEASURES SHALL BE APPROVED FOR EACH PARTICULAR USE BY A COMPETENT INDUSTRIAL HYGIENIST OR OTHER TECHNICALLY QUALIFIED PERSON. THIRTY - (30) DAY PROGRESS REPORTS ARE REQUIRED DURING THE ABATEMENT PERIOD. (THE 30 DAY REQUIREMENT CAN BE SHORTENED OR LENGTHENED BY THE AREA DIRECTOR DEPENDING ON THE SPECIFIC CIRCUMSTANCES.) Step3: ABATEMENT SHALL HAVE BEEN COMPLETED BY THE IMPLEMENTATION OF FEASIBLE ENGINEERING AND/OR ADMINISTRATIVE CONTROLS UPON THE VERIFICATION OF THEIR EFFECTIVENESS IN ACHIEVING COMPLIANCE. Abatement certification and documentation required within 10 days after abatement date. The certification shall include a statement that abatement is complete, the date and method of abatement, and state that employees and their representatives were informed of this abatement. Abatement documentation shall include documents demonstrating that abatement is complete, such as evidence of the purchase or repair of equipment, photograph or video evidence of abatement or other written records.