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Inspection Number! Program CActivity I Bus Loe iAccount Number
311117162 I Health I202505715 I174000002 I 525 i01361000 
IAssignment Type I Site ID I CSHO
Establishment DBAI Legal Name :Region iRegion
CITY OF KIRKLAND I CITY OF KIRKLAND lReferral I 1055320 id0483 I 1055320

CSHO: Katie Keefe  1  7  

DOSH compliance received a referral indicating a cluster of elevated blood lead levels among Kirkland Police Dept
employees. The referral indicated that the exposure occurred while shooting at an indoor ?ring range. I made
initial contact with Kathy Joyner, Safety/Risk Management Analyst for the City of Kirkland, on 7/ 3/ 07',
explained the purpose of my visit, requested the Police Guild union representative be contacted, and then continued
with the opening conference.- Ms. Joyner explained that the incident involved Kirkland Police Department (KPD)
employees and that she had minimal information on the circumstances surrounding the exposure incident and on
the incident investigation ?ndings. Ms. Joyner stated that the Police Dept. creates and manages their health and
safety programs. She provided Lt. Bill Hamilton?s name and number as the contact person for the police
department. Ms. Joyner was unable to provide any written information pertaining to the exposure incidents. I met
with (previously Lt) Hamilton on 7/16/07.

Inspection Findings
The exposure incident occurred on 3/ 13/07 at Issaquah Police Department?s indoor ?ring range and involved City

of Kirkland employees. Two Kirkland Police Dept (KPD) ?rearms instructors were conducting a S-day ?rearms
training and quali?cations course for three Corrections Of?cers at an indoor ?ring range. Of?cers practiced ?ring
weapons inside the range on three days during the training. On 3/13/07, of?cers practiced shooting in the range for
approximately 5-6 hours. The mechanical ventilation system for the range was not turned on during the practice
shoot on 3/13/07. When all three corrections of?cers reported associated with lead exposure, 
Hamilton sent all ?ve of?cers to the dept physician who collected tested for blood lead levels. The 5 of?cers?
blood lead levels ranged from 25-33 ug/dL.

KPD rents the facility from IPD for use in training courses, open shoots and quarterly quali?cations. The indoor
?ring range is equipped with a mechanical ventilation system that is inspected and maintained by the City of
Issaquah. The on/off switch for the ventilation system is located in the staging area adjacent to the door to the
?ring range. According to the KPD ?rearms instructors, the on/off switch fer the ventilation system was not
working on 3/13/07 and they couldn?t ?gure out how to get the system to turn on. KPD Of?cer Rich was the lead
instructor on 3/ 13/07. In a typed memo from Of?cer Rich to Cpt. Hamilton dated 3/18/07, he states he attempted to
turn on the ventilation system for the ?ring range when he arrived at the facility but was unsuccessful. According
to this memo and statements from both instructors, Rich left a voice message about this problem on the facility
Range Master?s phone and then proceeded with the scheduled target practice despite the fact that the ventilation
system was not operating. Of?cer Rich stated the 3 corrections of?cers and both instructors operated ?rearms 
within the range for 5 hours without the ventilation system operating. Of?cer Rich noted that although he observed
a slight haze inside the range, he proceeded with training to avoid scheduling con?icts. Correctidns of?cers?
statements indicate that the ?smoke? within the range was very visible after the ?rst hour of shooting and that one
could see a laser sight through the haze.

Firearms Instruction Unit has protocols in place for range use that they must follow to ensure safety.
Firearms instructors are trained in procedures for range use, which include activating the ventilation system
before and while using the range. The senior ?rearms instructor stated that it is policy to follow all range
rules, which lists using the ventilation system at all times when shooting in the range. Hamiltdn stated that
under progresSive disciplinary program, both ?rearms instructors received verbal reprimands for not
following operating procedure for the range and continuing to shoot without the ventilation system operating. 
Hamilton stated that the of?cers were reprimanded shortly after the incident; he stated that neither instructor had
violated range use policies or procedures in the past. According to the Senior Firearms Instructor, Wilson, all
instructors will be re?trained on range use procedures and ventilation system operation.

I 

PRR101910 Page 21

 

Enforcement Case Summary  1 1 7  

information on the health effects of lead, of exposure. and routes of exposure was not provided to them
before they began target practice in the firing range. According to the COS, they were instructed to "not eat on the
range", to wash their hands when leaving the range and to change clothes before entering their homes to prevent
lead exposure. Corrections of?cers stated that they did not receive speci?c training on how lead could enter their
body while shooting at an indoor range. None knew that they could be exposed to lead by breathing in fume and
dust generated during shooting. None of the 005 I interviewed knew the health of lead eXposure. Two
of the three 005 asked for more information on lead during their interviews with me. Each of the corrections
officers stated they experienced flu-like following the shooting practice; none knew that those 
could be associated with an acute, high level exposure to lead. The 005 were previously prohibited from carrying
firearms and, therefore, had not received any safety training pertaining to firearms or firing ranges (including lead
awareness) before this particular training in March 2007. KPD did' not provide corrections of?cers with adequate
training on the hazards, all potential routes of exposure, or health effects of lead before they worked in an area with
airborne lead exposure.

Since it appeared that the exposure incident resulted from employee misconduct that was properly dealt with
internally, no citations are proposed in regard to exposure monitoring. One serious violation citation is proposed for
not' providing lead training that meets the requirements of the lead standard 'to officers working in an area with
potential exposure to lead above the action level.

Closing Conference

The closing was held with Hamilton, Wilson, Lt and police guild representative, Don Carroll on 1019107 at
the Kirkland Police Dept.

gig/7.x: 

sigrfatur?/ date Supervisor signature approved date

Reviewer?sinitials/date: (AD lDqul 07
lDlLailo'j   

FR 101910 Page 22