Page 6 Mon Jun 2, 2014 Baltimore County Police Department Inspection Nr. 316943984 Walkaround Inspection A walkaround inspection was conducted on February 10. Bill-t ui 12:31.5 pro by his. IWhite. with Corporal isossi. The range was shut down for cleaning by a company contracted to do the cleaning so their: were no employees writhing inside the range. The employer indicated that the range is cleaned once each trident as well as the High Efficiency Patti-enters stir (HEPA) filters changed This IH observed 16 booths where officers restrained stationary while shooting, a neck system allowing the targets to move. and a baf?e system along the wall down rams to strip and cottect that hard been fired. The instrucrot?s stood behind the officers to observe them. Corporal Bossi explained that the ammunition used in the range has a tall meta! jar-Let and a lead free printer and load would only occur once the bullet hit the baf?e system. it was also that tin: department began converting to a new firearm in January 2014 and was expected to last thr0ugh July. Because of t ti.~ as titan-y as l-i police. artisan each day were each required to shoot 300 rounds in order to qualify. for the new lirearnt. instructors at the range also qualified new recruits who were required to shoot more than returning to neutrality for their Retirees theirown ammunition and were also readmitted once each by the instructors. .?1Iil intake units were instant-d in the helitnti the booths which had a brown Substance tii'l?tlih'iitfd on {'tit?pnt'nl Bussi stated the vents lune rusted from moisture in the outside air coming through the vents Exhaust vents were also installed down range above the baf?e system. Some of these vents were open while others were closed. Corporal Bossi indicated that there were plans to renovate the range by replacing the ventilation system and the baf?ing system and removing the floor tile but he was unsure of the timeline. Tile was observed on the floor from inside of the booths back to the wall behind the booths Employees stated that to their knowledge the floor tile did contain asbestos based on the age of the building. Some of the tiles were broken but most of the ?oor tiles were intact. The condition of the ?oor down range was observed, which appeared to have been chipped from bullets striking the floor over the years. The floor down range past the booths did not contain any floor tile and was a concrete floor According to employees interviewed, the range floor was painted by an instructor about 8 years ago with a garage ?oor paint purchased from Home When asked, the employee who painted the ?oor indicated that there was no paint left over. Ms. White was not able to obtain a Safety Data Sheet (SDS) for the paint because there was no identifying information available. Anether employee indicated the range floor was not painted prior to that. The baf?e system was observed and employees caplained that sometimes the baffles move from their position due to improper welding. An employee indicated that any ammunition that does ricochet would not have the velocity to travel the 75 feet from the baf?e back to firing line This IH did not observe the baf?es moving while onsite. There was an outdoor range onsite however, Sergeant Thomas Stetson, Range Master. stated that shooting had been done inside since November or December 2013 because of the weather, On February 11, 2014 Ms. White returned to the site with Mr. Mike Penn, MOSH Chief of Compliance, and Ms. Dawn Windham, Region 1.1 Industrial hygiene Supmtisor. {tinting this visit. MOSH personnel observed the set up of tie range. obtained air velocity measurements at different booths and down range. and incited at; the air haadier on the root? of the range. Ms. White returned to the range for air and noise monitoring on February 19, 2014 and repeated air monitoring on March 6, 2014 and April it 2014. Refer to the sampling section for results Air velocity measurements were repeated inside the range On February 19, average air velocity down range was 33 feet per minute {fpm}. Readings were also taken at booth numbers 5, 10, and 15. The respecrive average air velocities were 42 fpm, 83 t'pm. and 107 fpm. On March 6, the average air velocity down range was 37 The National Institute of Occupational Safety and Health (NIOSH) recommends airflow along the firing line be between 50 and 75 fpm. On March 12. 2014 Ms White and Mr. Penn met with Mr John Schatz, Balthnore County Property Management Maintenance Supervisor; Officer Jessica Ables, Baltimore County Police Safety Officer; Captain John Campbell, Commander of Baltimore County Police Training Academy; Sergeant Thomas Stetson, Range Master; and Corporal Bossi to discuss the results of the air monitoring from February 19 and ti- Ms. White and Ms. Penn explaimd that earning-3e exposures or: February to were over the OSHA action Limit this: for lean. ugt?mftt with the exception of one. being altsf?lir we? the Permissible Exposure Limit it} safari. it was slow explained that the employee exposures on March Ci were all signi?camiy ??ii?t Mr. Perm discussed the requirements in the OSHA lead standard (29 CFR lolt?ldtl?z?} that the wootd need to inflow it? emptayees were or continue to rinse exposure to lead at levels at or above the PEL. Sergeant Stetson stated that with the warmer weather. watering woman, he (tn-tie at the outdoor range primarily with the exception of low light qualifications consisting of 30 cements recruiting about one hour inside the range. Representatives of the Baltimore County Police Department indicated that the plans to renovate the indoor range were still ongoing and that decisions were pending on the results of the air monitoring performed by MOSH. Health Hazards Oracle - 114?99} Page 7 Mon Jun 2, 2014 Baltimore County Police Department Inspection Nr. 316943934 Noise Exposure to high levels of noise can cause permanent hearing loss Neither surgery nor a hearing aid can help correct this type of hearing loss. Short term exposure to loud noise can also cause a temporary change in hearing (ears may feel stuffed up) or a ringing in the cars {tinnitus}. These pmblems may go away Within a few ntinures or hours after leaving 53W limit Ere-?21- repeated exposures- so iouti noise can lead to pennanem tinnitus andior hearing loss. Loud noise can also create physical and stress, reduce productivity interim: with and concentration; arid contribute to workplace accidents and injuries by making it difficult in bear warning signals. Noise-indirect hearing loan limits the ability to hear high frequency sounds, understand speech, and seriously impairs a person's ability to cottintunicste. OSHA has an Action Level (AL) of 85 decibels (dB) for noise and a. Permissible Exposure i..hnit tl?l?ls ct {90 d. In?im?'?f? ?mung ill UN magi? ?uviecwd 3:0 high invcis of misc from firearms discharging and subsequently striking objects inside ranger Empioyecs indicated that they did receive annual audiograms but did not receive treating conservation training annually. This petitioned noise monitoring on Feburary 19, 2014 by fitting two instructors with Quest NoisePto DL dosimeters. The instructors wore the dosimeters during their duration inside of the indoor range. After the lunch break. one employee did not return to the range and that employee?s exposure was 91 dB after 109 minutes. The other employee?s exposure was 95 dB after 220 minutes, The dosimeters have a 2 dB error rate which suggests that the first employee was exposed to noise levels above the AL and the second employee was exposed to noise levels above both the AL and the PEL. According to employees, they received audiograms annually. Ms. White requested to see these records multiple times but never received them. Ear plugs and ear muffs were required to be worn in the indoor and outdoor firing range Instructors wore 3M E-A?Rsofi yellow menus with 3 Noise Reduction Rating (NRR) of 33 and 3M Peltor Powercom Plus Headband ear muffs with a NRR of 25 These two hearing protectors, when worn together properly, adequately reduce the noise levels employees are exposed to below the OSHA AL. Range staff also indicated some employees had received training on noise but not on an annual basis The training program must consist of the effects of noise on hearing; the purpose of hearing protectors, the advantages, disadvantages, and attenuation of various types, and instructions on selection, fitting. use, and care; and the purpose of audiometric testing, and an explanation of the test procedures. Lead Lead overexposure is one of the most common overexposures found in industry and is a leading cause of workplace illness. Therefore, OSHA has established the reduction of lead exposure to be a high strategic priority. Lead is also a major porential public health risk. in general populations. lead may be present in hazardous Concentrations in food, water, and air. Sources include paint, urban dust, and folk remedies. Lead poisoning is the leading environmentally induced illness in children At greatest risk are children under the age of six because they are undergoing neurological and physical development Instructors had exposure to lead dust when observing police of?cers firing handguns in the indoor and outdoor gun range The OSHA Action Limit (AL) f0r lead is 30 lug/mil and the Permissible Exposure Limit (PEL) is 50 ug/m3, The OSHA lead standard requires employers to monitor their workplace for airborne lead to determine if employees are exposed at or above the AL. This had not been done previously so the employer utilized the monitoring done on February 19 by Ms White as the initial determination. Ms White requested to view blood lead level records for the range staff but, did not receive them. According to Corporal Bessi. annual training on lead had not been provided to employees. If an employer has employees exposed to lead above the PEL the employer must reduce their exposure below that or: implement engineering controls to reduce exposures below the develop and implement a written compliance program that includes a description of the Operation where lead is emitted. a description of the speci?c means that will be used to comply with the standard, a report of technology considered in meeting the PEL, air monitoring data, a detailed schedule for implementation of the program (e.g purchase orders, construction contracts, etc), and a work practice program including PPE, housekeeping, and hygiene; take air velocity measurements of any mechanical ventilation to demonsrrate effectiveness; provide respirators and implement a respiratOry protecnon program that meets the requirements of OSHA respiratory protection Standard (1910.134); provide clean, dry prorective work clothing and equipment at least weekly; provide change rooms with separate Storage for street clothes and clothes worn during the work shift. require employees shower at the end of their work shift: provide annual training on the content of the OSHA lead standard (1910 1025), the specific nature of the Operations which could result in exposme to lead above the AL, the purpose. proper selection, fitting, use. and limitations of respirators. the purpose and a description of the medical surveillance program and medical removal program, the engineering controls and work practices associated with the employee?s job assignment, the contents of any compliance plan in effect and instructions to employees that chelating agents should not routinely be used to remove lead from their bodies Oracle - A(Rev 11!.99) Page 8 Mon Jun 2. 2014 Baltimore County Police Department InSpectlon Nr. 316943984 and should not be used at all except under the direction of a licensed physician; and recordkeeping of all monitoring and medical surveillance. Sampling Air monitoring for asbestos was perfumed on February t9. 20rd. Area samplhig tor asbestos mess performed by setting up two SEC r?tirChecl-t 200$ high-?ow pumps with Mixed Cellulose Ester in two of the lamina in the range. The lab retained on asbestos detected on the santpies. Lead was nannitored for on February 1?3. March (it and April 1 by MS- Whiiea i??'mn?i Silml?i?tl fill? [and was madame} by ?tting with SEC hirCheL-it ?31:th high-flow pumps and The highest extensors on February is has 59.69 ng?m'J. The highest exposure on March 6 was 154 ug/m3. Monitoring on April 1 was conducted to determine the instructors? exposure at the outdoor gun range and while inside the indoor gun range For ant-int one hour to cornice; low light modifications. The lab reported no lead detmretl on the samptes collected at the outdoor range. The highest exposure inside the indoor range was 2.65 ngr?rrsil, The remaining resorts can he found on the attached sampling sheets and subsequent results. Note that the results on the sampling sheets are reported in milligrams per cubic meter, All of the samples were sent to the OSHA Salt Lake Technical Center (SLTC) for analysis and all results were calculated as an 8-hour Time Weighted Average (TWA). While Baltimore County goes through the various stages of renovating the indoOr range, shooting will be done primarily at the outdoor range and for less than one hour inside the indoor range as an interim protection measure. It was suggested that Baltimore County ask for references as they begin the renovation process and look for bidders. The importance of ?nding someone with experience building firing ranges and providing documentation of how they helped their clients whieve compliance with the OSHA standard was explained during the closing conference. Records Review Hazard Communication Range instructors were exposed to lead dust from ammunition fired by police officers in the gun range. Lead is a systemic poison and employee commute to it requires the development, implementation, and maintenance of a hazard communication program. A written program containing the elements of Safety Data Sheets (SDS), labeling. and employee information and training had nor been maintained Ms. White provided the employer with a copy of the Right~to-Know booklet which includes an outline and ?ll-in-the-blank program that can be used to establish a site-specific program. SDS were not maintained onslte. Corporal Bossi did provide Ms. White with copies of SDS later during the course of the inspection. Labeling was compliant with the OSHA hazard communication standard. This 1H discussed the new labeling requirements of the Global Harmonization System (GI-IS) with the employer. According to Corporal Bossi, employees at the range had not received hazard training which requires an explanation of what the law is about. an explanation of how the chemicals in the workplace can be a hazard, a discussion of how exposure to hazardous chemicals can be controlled, an explanation of how employees can obtain information on hazardous substances. an explanation of labels and SDS. and an explanation of employee rights. A list of hazardous chemicals had not been compiled and maintained. Ms. White explained the requirements of the list to the employer. OSHA Injury and Illness (300) Logs ids. White requested semantics and logs mnlripie times for loll-1t] 14. {Jf?cer Jessica doles provide-rt Ms. White with rags for 2m 1. ?lm. and 'Zl?lld. Baltimore Conroy man-trains injnries and llinessea for all employees on. one log. so due to the large number of pages per year, Ms, White requested that Officer Ables supply only the pages that include injuries suffered by the range staff, There was one injury in 2011, one in 2012, and one in 2014. There were no injuries in 2013. Employee Interviews Employees were interviewed regarding their experiences concerning the complaint items. Employees indicated that the ventilation system was dated and at times black dust could be seen 0n surfaces inside of the indoor range It was indicated that the ventilation has been a concern for years. Employees stated that their blood lead levels had increased since the police department started converting over to a new weapon requiring all of the County's of?cers to qualify for the new weapon. Employees also indicated they were having blood lead testing done every six months through Mercy Hospital but as their blood lead levels began to rise. the dector wanted them to have their blood tested Mosr employees stated they thought the floor tiles in the range were asbestos based on the age of the building, An employee indicated that the floor tile is asbestos floor tile and some of it had been removed in the past because it was farther dowo the range floor and was being Oracle ll199) Page 9 Mon Jun 2, 2014 Baltimore County Police Department Inspection Nr. 316943984 shot at, potentially releasing asbestos fibers. Most employees were nut sure if the floor down the range was coated with lead paint. An employee Stated that the floor was never painted until about 10 years ago and lead paint was not used to paint the ?oor. Employees were not sure what the substance on the ventilation in the range was or where it was coming from. Many of the employees interviewed indicated that the welds holding the baffle system up are weak and some of the baf?es on the bottom of the system fall when hit by a bullet. None of the employees indicated bullets ricochet occurring once a baf?e had fallen. Closing Conference A closing conference was conducted on May 7. 2014 at 1:00 pm by Ms. White along with Mr. Penn. Baltimore County representatives present for the closing conference included Sergeant Anthony Russell1 Captain John Campbell. Major Daniel Kalisaak. Colonel Joe Burris, Lieutenant Orlando Lilly. Officer Jessica Ables, Corporal Mandy Biter, and Corporal James Bossi. The complaint items, inspection ?ndings. recommendations for citations, potential methods of abatement. and other reconunendations were discussed. Colonel Burris indicated that Baltimore County plans to begin renovations on the firing range within 3-4 months. Letter to Complainant 1. Possible overexposure to lead dust due to a poorly operating ventilation system Findings: Ms. White perform air monitoring for lead on February 19, March 6, and April 1. Monitoring done on February 19 was shortly after the range had been cleaned and ?lters replaced on February 10. 0f the four samples, the OSHA Salt Lake Technical Center (SLTC) lab reported three samples above the OSHA Action Level (AL) for lead (30 micrograms per cubic meter (ugKmB) and one above the OSHA Permissible Exposure Limit for lead (50 ugr?m3). On March 6, air monitoring was performed while instructors were still working in the indoor range before the weather warmed up. Employees indicated that the doors in the range were blowing open at this time which suggested to them that the filters were probably clogged. SLTC reported all ?ve samples above the OSHA PEL. A meeting was held with Baltmtore County Police representatives to make them aware of the overexposures to lead and the requirements of the OSHA lead standard. including additional personal protective equipment (ppe) and protective measures that would be required if employees were to continue having expo-aura to lead above the PEL. Baltimore County indicated they will be replacmg the ventilation in the range and in the interim will be using the outdoor range primarily and the indoor range for low light quali?cations for less than one hour. Air monitoring was repeated on April 1 to determine employee exposures using these interim protection measures. All five samples taken at the outdoor range were reported as ?none detected? by SLTC. The highest exposure while inside the indoor range was 2.65 uglm3. Recommendations: Based on the documented over-exposures to airborne concentrations of lead, numerous citations of the lead Standard were reconunended . 2. Possible poor housekeeping as evidenced by an accumulation of a thick substance on duct work. Findings: The ventilation in the indoor range was observed including duct work along the back wall above where the instructors Stood. A brown substance was seen on the duct work which the employer indicated was rust. Employees did not express any concerns of related to the substance on the duct work. Recommendations: No citations were recommended. The employer indicated there are plans to renovate and redesign the indoor range which will include replacement of the ventilation system. 3. Possible ricochet from steel baf?es falling from their position. Findings: The instructors were observed as police officers shot handguns in the indoor range and observed the condition of the baf?e system as this occurred. No parts of the baf?e system were seen moving out of position on any of the three days while on site sampling; Recommendations: No citations were recommended. The employer indicated there are plans to renovate the indoor range which will include replacement of the baf?e system. 4. Possible exposure to lead paint due to bullets striking the range floor down range. Oracle - 11,199) Page 10 Mon Jun 2,2014 Baltimore County Police Department Inspection Nr. 316943984 Findings: The condition of the floor in the range was observed, which appeared to have been chipped from bullets striking the ?oor over the years- According to employees interviewed. the range floor was painted about 10 years ago with a paint purchased from Home Depot. Another employee indicated the range floor was not painted prior to that. Recommendations: 0 citations were recommended- 5. Possible exposure to asbestos contained in ?oor tile. Findings: The condition of the floor tile in the range was observed, There were some broken tiles but most of the ?oor tiles were intact Air monitoring for asbestos was perfonned on February 19, 2014 and the lab reported no asbestos detected on the samples. Recommendations: his citations were rmammentted rotated to asbestos exposure citation was recommended for mt staring commuted survey It} identify the Meaii?? and quantity (if eshestos tt?t?lt??i?il?lg materiei armor potential asbestos containing [material Tm mmlm-er indicated there are plans 1-) renovate the indoor runes- whiun w?l in?atic removal of lhr.? ?ow CSHID Date I 4 a L- E. ff?! . Accompanied ?y Oracle - 11/99)