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Mr. Bill Vannett
Safety Specialist
Risk Management, 4 th Floor
City of Sacramento
915 "I" Street
Sacramento, CA 95814
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Website - www.cityofsacramento.org/personnel/
Key Contacts -
[Hom e > Government > Departme nts > ~a rks and Recreation Home > Office of the Di rector]
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Hi Bill ,
Thank you for sending the air sampling results taken while employees were cleaning the bullet
traps at James Mangan Firing Range . Since these 8-hour TWA sample results represent a three-
hour cleaning period, average exposures during the three hour cleaning were as high as 1666
ug/m3 or 33 times the permissible exposure limit for lead . These results confirm the need for full-
face respirators while cleaning the bullet traps.
Thank you for responding on behalf of the City of Sacramento to each of my recommendations
for its lead safety program and thank you for sending me the records I requested. I do have a
suggestion for your fit test record which is to list each of the elements required by the Cal/OSHA
respirator standard. You will find those elements in section m) recordkeeping here:
http://www.dir.ca.gov/title8/5144.html In addition to the information in your training record sheet,
the fit test record needs to also include the specific make, model, style, and size of the respirator
fit tested and the type of fit testing performed .
I also reviewed the outline of your "Lead Hazard Training" . One item I didn't see listed was how to
care for and clean respirators, protective clothing and shoes. You may have covered this and it's
just not listed . I did want to mention, however, that when I was there I noticed that at least one
employee who worked at the range did not properly clean their respirator and it was quite dirty on
the inside. So, employees may need encouragement or ideas on how to make it easier to clean
their respirators so they don't get unnecessary exposure from their respirator. When I train our
employees here, I bring a bucket and cleaning solution and demonstrate how to clean a
respirator. We practice taking apart a respirator, cleaning it and putting it back together. Other
suggestions on the lead training are to cover the purpose and a description of the medical
surveillance program and to cover the results of the airborne lead exposure measurements and
what tasks result in exposures above the Cal/OSHA action level.
Have you looked into requiring only lead free ammo and primer at the range?
Thank you for your efforts to improve the lead safety program.
Regards,
Hi Bill,
After we talked today on the phone, I thought of some publications of ours that may be helpful to
you . They are available on the internet here:
http://www.dhs.ca.gov/ohb/OLPPP/pubshealthpro.htm .
I also wanted to make sure you knew that the City of Sacramento will need to have a licensed
physician acting as the medical supervisor to order the blood lead level tests and receive the
results . The medical supervisor should be informed of the types and levels of lead exposures that
employees receive and the fact that they will be wearing respiratory protection.
One publication that may be helpful to you is a Model Contract for a Lead Medical Program .
http://www.dhs .ca.gov/ohb/OLPPP/modcon. pdf
The Cal/OSHA Lead standard requires that the blood lead analyses be done by an OSHA-
approved laboratory.
Regards ,
Hi Bill ,
This is a friendly reminder to please send me records of respirator fit testing and training , medical
clearance reports for respirator use, and lead safety training records for maintenance workers
who clean the James Mangan Rifle and Pistol Range. I also need the airborne exposure
monitoring report once the monitoring has been completed .
Thank you.
Company Name:
City of Sacramento
Department of Parks and Recreation
James Mangan Rifle Range
th
2140 34 Avenue
Sacramento, CA 95822
Background Information
Company Contact: Bill Vannett, Safety Specialist (916) 808-8598 and Greg Naramore, Parks and Rec Dept. (916)277-6095
Number Exposed to Lead: maintenance worker. Scope of this assessment does not include range masters.
Union:
BLL Testing : attach copy of stripped BLL report from ELVIS for one year prior to site visit.
City of Sacramento
Department of Parks and Recreation
James Mangan Rifle and Pistol Range
th
2140 34 Avenue
Sacramento, CA 95822
Make sure no dry sweeping is M How is the floor cleaned? Employees clean either with wet mop or power washers. Also
done. Wet mop or use a HEPA- have squeegee. Include walls and sometimes ceilings. Frequency
filtered vacuum. How is the brass collected? is once every two to three months. Range users collect and sort
Do they sort the brass? the brass, not employees. Employees showed use trenching
Observe this process if shovels to shovel bullet collection trays. Employees tell us that
possible. bullet traps were cleaned once per quarter but now are cleaned
Determine range's own guideline NM once per month. Dust mop and two brooms observed on range.
for acceptable surface 1ead How do you decide if the Dust mop used to clean bathrooms.
contamination (case manager eating area is clean? Do
provided a method for this) . you do the same for the No. Employees do visual assessment.
public area? Do you use a
Check the cleanliness in eating NM specific guideline for
and public areas of the range. surface lead (de)-
Surface contamination levels contamination?
should not exceed 40 ug/ft2 or Did wipe sampling in March 2003 but not since that time.
your self-determined guideline. How do you check the
cleanliness of the range?
How often do you do that?
Hygiene:
* Remember to ask employer whether it was difficult to implement a specific recommendation or ifa recommendation wasn 't implemented, "why not?"
2
City of Sacramento
Department of Parks and Recreation
James Mangan Rifle and Pistol Range
2140 34 th Avenue
Sacramento, CA 95822
bullet trap. After cleaning the range
and before leaving the worksite:
Employees should remove tyvek M What is your policy Wear tyvek disposable suits. Remove suits and dispose of them .
suits , then walk to other building regarding changing out of
where shower is located . work clothes and shoes? (if
possible, observe
Ensure workers shower after NM lunchtime)
cleaning the range and before Jim Vannett is will ing to require them to shower from today
leaving the worksite. What is your policy onward . To this point, they have not had a policy to shower. Only
regarding showering? recently fixed water heater so can shower.
Employees should put on clean NM
work clothes. How do you ensure that I .Not applicable~ ot a policy to shower. Wash face and hands.
employees shower? I, w\\~ Y\OJ; "7L
Continue providing workers with M What protective clothing is Tyvek suits, rubber boots, disposable nitrile gloves (observed).
disposable Tyvek suits. required for cleaning the Plan to get tyveks with hoods because they are more protective.
range? For cleaning the
Ensure workers wear tyvek suits M bullet trap? Can I see it?
and gloves while cleaning bullet
traps. How do you ensure Honor system . Employer believes that
maintenance workers wear is conscientious. While employees do not change their
appropriate protective clothes, this evaluation team believes that wearing tyvek suits
Provide workers with separate M clothing? meets the intent of the recommendation .
shoes for cleaning the range or
disposable shoe covers. Does the City provide
shoes? Or shoe covers? City provides rubber boots.
Make sure shoes do not leave the M Can you show me?
range .
How do you ensure shoes Kept at range .
do not leave the range?
Can I see where they are
3
City of Sacramento
Department of Parks and Recreation
James Mangan Rifle and Pistol Range
th
2140 34 Avenue
Sacramento, CA 95822
kept?
Provide lead safety training for the Need How often is lead safety Bill Vannett provided once in 2003. No refresher.
poisoned worker and the to see training provided? Who
maintenance workers. docum does the training?
entatio 2003
n When was the last time that
(Met training was provided?
the
initial Ask for training records
recom after site visit.
mendat
ion ;
howev
er, do
not
meet
the
annual
require
ment)
Ni"\
4
City of Sacramento
Department of Parks and Recreation
James Mangan Rifle and Pistol Range
th
2140 34 Avenue
Sacramento, CA 95822
Test maintenance workers every NM Are all workers being tested Last time was in 2003 and was "optional ". From now on, plans to
six months. and how frequently? do annually. Due now. Also have new workers who clean the
5
City of Sacramento
Department of Parks and Recreation
James Mangan Rifle and Pistol Range
th
2140 34 Avenue
Sacramento, CA 95822
range and bullet traps. They need initial BLLs. Bill says they will do
within next month .
May I have a roster of all
workers (being tested) after Asked Bill Van nett for roster of employees. Probably need to
site visit. request from Mr. Naramore.
6
City of Sacramento
Department of Parks and Recreation
James Mangan Rifle and Pistol Range
th
2140 34 Avenue
Sacramento, CA 95822
Conduct lead exposure monitoring M Airborne exposure Bill Vannett agreed to do additional exposure monitoring since
for maintenance workers. monitoring done and workers are clean ing bullet trap on a regular basis. Need to
documentation received by establish what level of respiratory protection is required . Employee
OLPPP in 6/03. No further remembered that air monitoring results were provided to
confirmation needed unless employees.
conditions or 12ractices have
changed since that time.
7
City of Sacramento
Department of Parks and Recreation
James Mangan Rifle and Pistol Range
th
2140 34 Avenue
Sacramento, CA 95822
Make sure no dry sweeping is done. How do you clean the floor of the Employee reports misting the walls and ceiling of range
Wet mop or use a HEPA-filtered range? How do you pick up the and cleaning the range every two months. Traps are
vacuum . casings? What is done with the cleaned three times per year.
casings? Can you show me what you
use to clean?
Determine range's own guideline for Can you describe how you clean the
acceptable surface lead bullet trap? After we finish , can you
contamination . show me your tools?
Check the cleanliness in eating and How do you decide if the eating and
public areas of the range. Surface public area is clean enough?
contamination levels should not
exceed 40 ug/ft2 or your self- Does someone check the cleanliness of
determined guideline (case manager surfaces in the public and eating areas
provided a method for this) . in the range? How?
Continue providing workers with Do you use protective clothing when you What protection is worn for cleaning the range?
disposable Tyvek suits. clean the range? Will you show it to me? D Tyvek suit D Gloves
D Goggles D Hoods/hats
D Uniforms D Work shoes
Ensure workers wear tyvek suits and Do you use protective clothing when D Shoe covers
gloves while cleaning bullet traps . cleaning the bullet trap? Will you show it
to me? What protection is worn for bullet trap?
Provide workers with separate shoes D Tyvek suit D Gloves
for cleaning the range or disposable Does the range provide shoes or shoe D Goggles D Hoods/hats
shoe covers. covers? Do you use them? D Uniforms D Work shoes
D Shoe covers
8
City of Sacramento
Department of Parks and Recreation
James Mangan Rifle and Pistol Range
th
2140 34 Avenue
Sacramento, CA 95822
RECOMMENDATION CONFIRMATION COMMENTS/OTHER OBSERVATIONS
Hygiene:
Employees should put on clean work No. Use tyvek and dispose.
Do you put on a complete change of
clothes. clothes after showering?
No.
After cleaning the bullet trap, do you
change out of your work clothes and
leave all clothing worn during the shift at
work?
Yes. Observed in back area. Are bagged.
Do you leave your shoes at the range
Make sure shoes do not leave the when you leave? Where do you keep
range. them?
Yes.
Do you wash up before breaks, lunch ,
and before leaving work? Observe if
possible
9
City of Sacramento
Department of Parks and Recreation
James Mangan Rifle and Pistol Range
th
2140 34 Avenue
Sacramento, CA 95822
Provide lead safety training for the Did your employer train you about steps Yes.
poisoned worker and the maintenance to take to prevent lead poisoning?
workers
When were you trained? Lead safety training 2003 .
What do you remember from the One employee remembers airborne results. Other
training? employee remembers respirators , work clothes, and
cleaning methods.
Conduct lead exposure monitoring for Your employer measured lead in air in One employee remembers receiving . Other employee
maintenance workers. 2003. Did they provide you with the doesn't remember getting results.
results of lead in air measurements?
Respirators:
Maintenance workers should wear a When do you wear a respirator? Will Yes, always.
mask respirator for routine cleaning of you please show it to me?
the range.
Do you wear a respirator for cleaning Yes for one employee: mask w HEPA filters.
the range? What kind? Observed. Note: was quite dirty and needed to be
cleaned . Other employee said does not always wear;
Continue using the full-face respirators Do you wear a respirator for cleaning usually not.
with P-100 filters for maintenance the bullet trap? What kind?
workers when cleaning the bullet trap. Yes. Same as above.
Provide respirator training for the Have you received respirator training? 1)Yes. Two years ago. 2)Yes for chlorine gas in 2003.
maintenance workers. When was the last training?
10
City of Sacramento
Department of Parks and Recreation
Jar,nes Mangan Rifle and Pistol Range
th
2140 34 Avenue
Sacramento, CA 95822
Provide respirator fit testing for Have you had fit-testing for your 1)Never for mask. 2) No.
maintenance workers. respirator to make sure it fits? When
was the last respirator fit test done?
Test all workers twice a year. When was your last blood lead test? 1)2003 2) 2003
Did your employer provide you with the 1) Yes. Were really low. 2) yes
results of your last test?
11
03/30 / 2007 12:52 915-808-5150 CITY OF SAC RISK MGT PAGE 01 / 01
c,;,!.-.,._l v rl
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Thank You,
Bill V annett
EH&S Specialist
City of Sacramento
Where is the lead in the work place
In the air
On all surfaces
On your clothes and skin after cleaning the
range
Routes of Entry
Small amount can be absorbed through the
skin
Inhalation:
Breathing air/dusUfumes
Ingestion :
Eating lead -contaminated food (not washing
hands after working with lead)
1
Symptoms of Acute Lead Poisoning
Cramping, abdominal pain
Nausea and Vomiting
Headache
Confusion
Jaundice-Yellowing of skin and eyes
2
,I
,I
3
Preventing Lead Poisoning (cont.)
Protective Clothing
Disposable "Tyvek" suits
Disposable Gloves
Respirators
Respirators
Must be fit tested
Use only HEPA filters (magenta)
4
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RESPIRATORY PROTECTION
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AIRBORNE CONTAMINANTS
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air In the area Is contaminated with gases,
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concentration of Yhe !o/rlome substance
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Reuulatorv Issues
9 PHCP Evaluation
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Phvslcal
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Annual
Change In face
3
04/20/2007 01:51 N0.422 Gl01
a member of CHW
Respirator Clearance
City of Sacramento
ployee:
ate : 04.04.07
Occupatior,al Health
Services
Downtown
3160 Folsom Bovle\/ard
Sacramento, CA 95816
916.733.3390
Folsom
1580 Creekside Drive,
Suite 150
Folsom, CA 95630
916.817.8690
timberlake
8120 Timberlake Way
S;,cr;,mento, CA 95B23
916.681.6088
a member of CI-I\V
Respirator Clearance
City of Sacramento
Et ployee:
Rlliewer: J fl l.,.,...
Da; e: 04.04.07
I
Occupational Health
Services
Downtown
3160 Folsom B01.1levard
Sacramento, CA 95816
916.733.3390
Folsom
1580 Creekside Drive,
Suite 150
Folsom, CA 95630
916.817.B690
Timberlake
8120 Timbi;:dake Way
Sacramento, CA 95823
916,681,6088
04/20/2007 01:51 N0.422 [;103
a member of CHW
Respirator Clearance
ECljlployee:
I
Dlte: 04.04.07
Rriewer;. _ _:J_._~_~_JA.__A_-._~->,-LV\.:_V\.r""
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Date: 04.04.07
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Occup~tioniall Health
Services
Downtown
3160 Folsom So1,1lev~rd
S.icramento, CA 95816
916.733.3390
Folsom
1580 Creekside Drive,
Suite 150
Folsom, CA 95630
916,817.8690
Timberlake
8120 Timberlake Way
S.icramMto, CA 95823
916.681.6088
As you know , Mary and I visited this range in January of 2007 for our case management
evaluation project and I subsequently made recommendations for improving the City of
Sacramento's lead safety program. Bill Vannett called me this week to update me on exposure
monitoring they did. Bill told me that a consultant from ASES, Inc. conducted personal airborne
th
exposure monitoring at the James Mangan Firing Range on May 24 while three employees
cleaned the bullet traps at the range . Employees clean the bullet traps approximately six times
per year. The 8-hour TWA results ranged from 130 ug/m3 to 625 ug/m3; however, the cleaning
lasted only three hours. These were worst case exposures because the traps hadn't been
cleaned in a few months . Normally, bullet trap cleaning takes 1 to 1 hours. Since lead
exposures were assumed to be zero during the time that the workers were not cleaning the bullet
traps, these results mean that exposures during the three hours of cleaning were as high as 1666
ug/m3 or 33 times the PEL for lead.
These results confirm the need for workers to wear full face respirators while doing the bullet trap
cleaning. I propose that I reiterate that recommendation in a close-out letter to Bill. Or do you
think a close out letter is a good idea? I'm wondering whether to recommend additional blood
lead testing . With exposures above the PEL, they are required to do BLL testing every six
th
months. The last BLLs were low. Since they were tested on April 6 , they are not due for BLL
testing until October.
Other items:
Bill Vannett will do additional air monitoring when workers clean the range They did not clean the
range floor and walls during this last monitoring session .
Bill says that fit testing of the full face respirators was done. I have asked for the fit-testing
records but have not received them. I'll ask him for the records again .