Pat Elder | Counter-Recruit Press | January 2019
While Endangering the Health of the American Public Through Lead Exposure
When I hold you in my arms And I feel my finger on your trigger I know nobody can do me no harm Happiness is a warm gun Bang bang shoot shoot - Lennon-McCartney
The public knows it as the Civilian Marksmanship Program (CMP), but since 1996 its legal name has been the Corporation for the Promotion of Rifle Practice and Firearm Safety, Inc. A Congressionally-chartered program, the CMP is a prolific small arms and ammunition dealer. Although more responsible nations prudently destroy their aging, warehoused military rifles, pistols, and ammunition, the U.S. government gives it to this private, non-profit corporation based in Anniston, Alabama, home of the Army weapons depot. In turn, the CMP sells the weaponry and ammo to U.S. citizens at discounted prices. This is irrational public policy.
The CMP, according to its annual report, “promotes firearms safety training and rifle practice for all qualified U.S. citizens with special emphasis on youth.” There are 4,664 clubs, teams, and other shooting sports organizations currently affiliated with the CMP, many in the high schools that are associated with Junior Reserve Officer Training Corps (JROTC) programs. The CMP is responsible for training JROTC instructors and certifying JROTC ranges in the nation’s high schools. It has trained more than 4,000 JROTC instructors since 2005.1
The CMP creates and disseminates curriculum for marksmanship and safety instruction. It also publishes “The Guide to Lead Management for Air Gun Shooting,” a widely distributed document that rules out the use of non-lead ammunition and is based on questionable science that purports to minimize exposure to toxic lead. The CMP is best known to the public for organizing the National Air Rifle Championships at Camp Perry in Port Clinton, Ohio.
The Corporation for the Promotion of Rifle Practice and Firearms Safety, Inc. has total net assets of $220.8 million and holds $184.7 million in publicly traded securities. It received more than $17 million from the federal government for 2013. The corporation’s 2013 990 states,
JROTC and active Army programs — at no cost to the government, develops curriculum for marksmanship and safety instruction, trains and certifies JROTC coaches, inspects high school range facilities, organizes, administers, and conducts JROTC Air Rifle competitions for all military services, subsidizes JROTC travel to CMP events, awards significant scholarships to deserving JROTC and other high school marksmanship competitors, provides annual grants to state 4-H shooting programs. At no cost to the government CMP produces and provides marksmanship safety videos and literature, administers Army and USMC rifle competitions.2
At no cost to the government? Their 2013 Form 990 reported $17 million in government grants. The corporation spent just $410,000 on the above items, slightly more than the compensation received by its Chairman and CEO, Judith A Legerski.
Air Guns are dangerous weapons
Ralphie: “I want a Red Ryder carbine action two-hundred shot range model air rifle. Oooooooh!”
Mother: “No, you’ll shoot your eye out!”
- A Christmas Story
We laughed, but air guns are no laughing matter. Some air rifles today are capable of routinely hitting a dime at 50 yards and killing rabbits at 100 yards and beyond. Some of the new breeds of air guns shoot pellets at supersonic speeds of 1,500 feet per second (FPS) and are capable of taking coyotes, wild boar, and even bigger game.3
The rifle Ralphie got for Christmas, the Daisy Red Ryder air gun, shoots a BB, typically made of steel, at 350 FPS and is available online today for $39.
The Daisy Avanti 887 CO2 air rifle, a powerful cousin of Ralphie’s Red Ryder, is classified as an Army weapon and is used by Army JROTC Marksmanship programs in high schools across the country. It shoots a .177 caliber flat-nose (wadcutter) air gun pellet at speeds up to 500 feet per second. A .177 caliber pellet has a diameter of .177 inches, just like a “22 rifle” shoots a bullet with a diameter of .22 inches. A .22 pistol, the kind that was used in the attempted assassination of President Reagan, fires at about 900 feet per second. They are both lethal weapons.
The Daisy Avanti 887 Operation Manual carries the following warning:
NOT A TOY. THIS AIRGUN IS DESIGNED FOR USE BY EXPERIENCED SHOOTERS AND IS INTENDED FOR MATCH COMPETITION OR TARGET RANGE USE. MISUSE OR CARELESS USE MAY CAUSE SERIOUS INJURY OR DEATH. MAY BE DANGEROUS UP TO 257 YARDS (235 METERS). THIS IS A SPECIAL CLASS OF NON-POWDERED GUNS AND NOT FOR GENERAL USE. IT IS TO BE USED FOR TRAINING AND TARGET SHOOTING UNDER SUPERVISION. RECOMMENDED FOR USE BY THOSE 16 YEARS OF AGE OR OLDER. THIS GUN SHOOTS PELLETS ONLY. THE PURCHASER AND USER SHOULD CONFORM TO ALL LAWS GOVERNING THE USE AND OWNERSHIP OF AIRGUNS.4 The Daisy Avanti 887 is available online for $450. Although the warning above recommends the use of these rifles for those 16 years of age and older, JROTC Marksmanship Programs include high school freshmen who are usually 13 or 14 years of age.
There are no federal laws regarding air guns, although they are regulated by the Consumer Product Safety Commission (CPSC). Federal law prevents states from prohibiting the sale of traditional BB or pellet guns but allows states to prohibit the sale of these weapons to minors.5
The CPSC specifically required Daisy Outdoor Products, Inc. to label its air guns as potentially dangerous to children. Like cigarette manufacturers who fought to keep cancer warnings off their cigarette packages, Daisy opposed the measure, not wanting to give Ralphie’s dad and others a reason to think twice before buying the gun.6
Twelve states and the District of Columbia impose age restrictions on the possession, use, or transfer of air guns like the Red Ryder, the Daisy Avanti 887, or the Boar-killing weapon described above: California, Delaware, Florida, Illinois, Maine, Massachusetts, Michigan, Minnesota, New York, North Carolina, Pennsylvania, and Virginia. Most of these states and a few others specifically prohibit carrying air guns into schools. Incredibly, almost half of the states have no laws regulating air guns.7
It is instructive to frame the general issue of air guns before exploring the intransigent mindset of Junior Reserve Officer Training Corps (JROTC) Marksmanship Program officials, some school administrators, and parents of many of the children enrolled in shooting programs in the high schools. For many of these enthusiasts the suggestion that the presence of firing ranges in high school classrooms may be inappropriate or dangerous amounts to a preposterous infringement of 2nd Amendment rights. There’s no poll data regarding public opinion over the use of classroom space for firing ranges.
The concern that shooting guns in classrooms send the wrong message to high school children may not be enough to sway public opinion to the point where high school officials feel compelled to rein in the practice, although there have been some notable exceptions. In 2009, the San Diego Unified School District’s School Board voted to eliminate the JROTC Marksmanship Program in the city’s high schools after a community-led movement called for the shut-down. Rick Jahnkow, a coordinator for the Project on Youth and Non-Military Opportunities (YANO), said having air rifles on campus sent the wrong message to students. “Students and parents felt it was inconsistent with the philosophy of the district to try to encourage students to not think about using violence to solve problems,” Jahnkow said. “So they felt that these ranges did not belong.” 8
These outcomes are extraordinarily rare as the public is either unaware of the practice or has come to accept the increasing number of firing ranges in the nation’s high schools with a shrug of the shoulders. It is the potential for the exposure to lead that will ultimately require these JROTC programs to either shut down or switch to non-lead pellets. The Civilian Marksmanship Program, through its Guide to Lead Management for Air Gun Shooting and other publications, seriously understates the health hazards associated with the use of air guns that shoot lead pellets in indoor firing ranges in the nation’s high schools.
The guide is used by Junior Reserve Officer Training Corps (JROTC) instructors and high school officials to manage firing ranges that are typically located in high school classrooms and gyms.9
Hundreds of thousands of high school children and school staff across the nation come into contact with highly toxic lead particulate matter as a result of inadequate supervision and maintenance of indoor firing ranges. The CMP, along with the various JROTC programs run by the Army, Navy, and Marines, and high school officials in every state, together with private gun club owners, where target practices are also held, share the responsibility for safeguarding the health of the public regarding high school marksmanship programs. School districts typically don’t monitor lead contamination caused by JROTC marksmanship programs. Instead, inspections are performed either by the Brigades/Area Commands, the CMP, or private firms.10
According to the CMP, there are over 2,400 Army, Navy, and Marine Corps JROTC units in the USA. Statistics kept by JROTC commands and the CMP indicate that at least two-thirds or approximately1,600 JROTC units offer rifle marksmanship programs to their cadets.11 Interestingly, the CMP does not count the 800 Air Force JROTC programs across the country, so the total tops 3,200 units.12
Approximately half or 1,600 of these units offer rifle marksmanship programs to their high school cadets. Most of these JROTC units have rifle teams, and many provide basic safety and marksmanship training to all of the cadets in their programs.13
The ARMY JROTC Marksmanship Program was first established in 1916 using small-bore rifles. It was not until 1964 that the US Navy and the US Marine Corps established marksmanship programs using the .22 caliber small-bore rifles. The Air Force did not commence a shooting program until 2006. In 2009 Army JROTC units were issued the Daisy M887 CO2 air rifles.14
Today all JROTC units use air guns that shoot lead pellets, except for the Air Force, which has largely eliminated the use of lead ammunition in both its school-based JROTC Program and on its small arms training facilities. Rather than banning the use of lead pellets, the Air Force JROTC command “strongly recommends” using non-lead pellets due to health concerns.15
Incredibly, there are still many high school shooting programs affiliated with the CMP that continue to use small-bore .22 caliber rifles and hold practices at indoor firing ranges. The .22 small bore rifles fire standard bullets and deposit substantially more lead into the air and on the floor than the lead pellets fired from air guns. That is not to say that the lead exposure associated with air guns shooting lead pellets is not a problem—a view held by many shooters, thanks in large part to the misinformation spread by the CMP.
Too often, youth groups affiliated with high school JROTC programs are forced to use commercial firing ranges where .22 caliber rifles and larger guns are regularly fired. The nation has an estimated 6,000 commercial indoor and outdoor gun ranges, but only 201 have been inspected in the past decade, according to a Seattle Times analysis of Occupational Safety and Health Administration (OSHA) records. Of those inspected, 86% violated at least one lead-related standard, the analysis found. In 14 states, federal and state agencies did not inspect a single commercial gun range from 2004 to 2013, an analysis of OSHA records found.16
Although the Civilian Marksmanship Program claims inspections of JROTC firing ranges are performed either by the Brigades/Area Commands or by the CMP, someone dropped the ball at the Vancouver (Wash.) Rifle and Pistol Club, an organization affiliated with the CMP.17
In 2010, blood tests revealed that 20 youths had been overexposed to lead after shooting in the club’s dirty, poorly ventilated range.
According to the Seattle Times, “The club allows the JROTC, the Young Marines and Boy Scouts of America to shoot there. While none of the shooters showed signs of being affected by the lead, the county’s public health director said damage might not be noticed for many years. An examination of the range revealed lead nestled in the carpet, chairs and a couch. Surface tests showed dangerous amounts of lead stuck to counters, a soda machine, and the refrigerator. The floor was 993 times higher than a federal housing guideline for allowable lead on surfaces.”18
The Center for Disease Control and Prevention says there is no safe blood lead level in children. Protecting children from exposure to lead is necessary to insure lifelong good health. Even minute levels of lead in blood have been shown to affect IQ, ability to pay attention and academic achievement. Effects of lead exposure cannot be corrected. The most important step parents, doctors, and others can take to prevent lead exposure before it occurs.19
In 2014 another CMP-affiliated firing range, Hopedale (MA) Pistol and Rifle Club, had three teenagers test for high lead blood levels.20 An inspection conducted by the Massachusetts Workplace Safety and Health Program documented contaminated surface areas but also directed the shooting range owners to improve the pattern of air flow by improving the ventilation system. Air should flow from behind the shooter’s back towards the target backstop, the report said.21
Hopedale’s website says it is affiliated with the CMP and prominently displays the CMP logo along with a link to the CMP.
These dangerous indoor firing ranges for small bore .22 caliber rifles are still being formed in high schools. In 2014 Walla Walla High School officials announced the formation of the Blue Devil Smallbore Precision Rifle Club, which plans to practice at the Walla Walla High School Range.22 Walla Walla is affiliated with the CMP.
The CMP holds regular youth competitions using standard firearms. Competitors for rim fire rifle matches are open to anyone 12 years of age or older, whereas competitors for “As-Issued Military Rifle and Pistol Matches” must be at least 14. The CMP may waive age requirements if they determine that the young shooters be competent.
All the while, the CMP’s Guide to Lead Management asserts, “Target shooting with air rifles and small bore (rim fire) rifles does not create real health risks for shooting sports participants.”23
There is substantial scientific evidence to refute the CMP’s stance. Lead is a deadly toxin. Notice the use of the word “real” in the CMP statement. Throughout the world of shooting sports, there exists a kind of denial among gun enthusiasts of the truly harmful effects of lead ammunition. There is a sense, often expressed in online chat rooms, that the issue has no merit and is being employed as a ruse by anti-gun forces to mandate additional gun control measures.
The CMP advises against the use of non-lead pellets in its Guide to Lead Management, arguing they do not perform as well as their lead counterparts. “Non-lead or so-called “green” pellets have yet proven capable of producing ten-ring accuracy on air rifle targets. Most nonlead pellets are, in fact, so inherently inaccurate that they cannot even be satisfactorily used in the earliest stages of youth target shooting.” It is a childish rant.
Notice again, this time - the depreciatory reference to “so-called green pellets.” The technology of producing alternatives to lead pellets has come a long way in recent years. The Air Force’s switch to non-lead pellets and the move by many high school districts across the country to do the same, along with laws like those in California that prohibit the use of lead pellets in hunting, (but not in the classroom) have conspired to create a hot market for non-lead substitutes. In 2011, teams from the Battle Ground High School and Prairie High School AFJROTC marksmanship programs in Washington State became the first teams to use non-lead pellets in a national JROTC match. The shooting programs in those schools were shut down for nearly a year because of fears of possible contamination caused by the use of air guns that shot lead pellets in the indoor shooting ranges. The schools switched to a non-lead pellet from the Czech Republic made of tin and bismuth.24
According to the JROTC coach, “Once the other coaches started seeing our scores, they knew these pellets were for real.” Battle Ground went on to win the precision class during the 2011 national championships, where Prairie High’s riflemen also excelled.25 The two schools shoot non-lead Predator brand international pellets.26
A second CMP publication rules out the use of non-lead pellets. In its Power Point Presentation, “Starting a JROTC Marksmanship Program”, a required course for all JROTC Marksmanship instructors, the CMP requires JROTC programs in high schools to “use 4.5 mm (.177 cal.) lead flat nosed pellets only.” There is no mention of the potentially harmful effects of lead or the existence of non-lead alternatives.27 While the CMP calls for the use of lead pellets, its other publications downplay the potential for lead exposure. JROTC Standard Operating Procedures for Air Rifle Safety and Air Rifle Range Management only mentions the possibility of lead contamination while discussing food. The procedures state, “No food items are permitted on an air rifle range. Eating food while handling lead pellets could cause lead ingestion.”28
Likewise, the CMP’s Guide to Rifle Safety downplays the health risks of lead exposure,
The rules are simple: Do not bring food into the range or consume food on the range. Do not bring any drinks into the range unless they are bottled and can be closed. Wash your hands after handling air rifle pellets (preferably in cold water). Cleaning the target backstops of spent lead pellets must be done by the instructor or another adult.
Interestingly, the guide encourages participants to wear protective eye glasses “because it is possible for pellet fragments to bounce back to the firing line.”
Lead particulate matter is flying all over the place, settling on skin and clothing. Air gun rifles, like those used in high schools across the country, discharge lead at the muzzle end of the firing line. Many air gunners do not bother to clean their guns because every pellet being fired down the barrel scrapes out the deposits from the pellets that went before.29
The Individual Junior Shooter Safety Pledge that appears at the back of the CMP’s Guide to Rifle Safety, and often hung in JROTC classrooms, contains 15 provisions that shooters must follow, but none address lead as a potential safety issue. The guide fails to mention the lead sprayed on the floor and in the air by the gun. These lax rules are contributing to lead exposure.30
The CMP’s 2013 Guide to Lead Management relies on the findings of Health & Environmental Technology LLC (HET), an environmental testing firm in Colorado Springs, Colorado to dispel the notion that air guns shooting lead pellets create airborne particles. The sole employee of HET is Mr. Robert Rodosevich.
Rodosevich came under scrutiny in Colorado in 2012 for “gross technical incompetence in technical compliance.” Meanwhile, HET’s work performed for the CMP is cited by high school officials who are forced to defend the presence of indoor firing ranges in their schools by parents concerned about the potentially harmful effects of lead contamination.
HET came under official scrutiny when it was contracted by a listing realtor (selling agent) to prepare a “Preliminary Assessment” of the degree of contamination of a house used as a methamphetamine lab. HET came very close to giving the house a clean bill of health before
properly licensed professionals were called in to conduct a thorough and legal evaluation of the highly contaminated residence.
“The Industrial Hygiene Review and Regulatory Audit Resulting in Findings of Noncompliance and Regulatory Misconduct at an Identified and Illegal Drug Laboratory,” dated May 29, 2012, and performed by Forensics Applications Consulting Technologies found HET’s work to be “fatally flawed.”31
The state audit reported, “The HET document was not prepared by an individual documented as being capable or authorized under regulation to perform such work. The document prepared by HET exhibited gross technical incompetence in technical compliance.” The state auditor continued, “Mr. Robert Rodosevich has violated state regulations by entirely failing to demonstrate that he has any kind of knowledge in performing the work at all.” The auditor’s report documented 35 violations of state regulations.
At one point, the auditor reported, “Mr. Rodosevich states that he sent the samples to Analytical Chemistry in Tukwila, Washington, but the laboratory reports are actually from ALS Laboratories in Salt Lake City, Utah.”
From the state audit,
Pursuant to state statute, if the seller of the property presents the work by Mr. Rodosevich as a genuine Preliminary Assessment, then this to would appear to meet the definition of “Offering a false statement for recording. Similarly, HET explicitly states they possess knowledge of the regulations, and therefore, establish the fact that they are aware of such recording.
We recommend that the situation be forwarded to the District Attorney for proper evaluation, and to determine if the case rises to the level of criminal account. A legitimate preliminary assessment must be performed for the property.
The Civilian Marksmanship Program relies on the findings of HET to claim there is no airborne dust created by firing air guns that shoot lead pellets in America’s high schools. Based on this finding, the CMP says normal ventilation systems are fine for shooting ranges in America’s high schools and in private gun clubs where CMP affiliated clubs practice.
From The Guide to Lead Management for Air Gun Shooting (page 7):
The issue of whether air gun firing creates airborne lead was re-examined in 2007 tests conducted by Health & Environmental Technology (HET), a professional environmental testing firm from Colorado Springs, Colorado. These tests were conducted on an air gun range at the U. S. Olympic Shooting Center. For these tests, air samplers were placed in the breathing space of the air gun shooters while they fired and next to the target backstops. No measurable airborne lead was detected by any of these monitors during air gun firing.
Firing air rifles or air pistols at muzzle velocities prescribed for target shooting (<600 fps) does not generate any detectable air- borne lead. There is therefore no need for special ventilation systems on air gun ranges since there is no airborne lead to exhaust from the range.
Normal ventilation achieved by modern HVAC systems provides more than adequate ventilation for air gun ranges. HET found that “minute deposits of detectable lead fragments and residue are deposited on the range floor in front of the gun muzzles, lead residues are also deposited on the floor in the area around the backstops.”
HET reported that the lead fragments “are of sufficient density that they do not become suspended in the air, but rather fall to the floor.”
A Swedish study in 1992 analyzed the air in an indoor firing range that was used exclusively for air guns and found the air had lead levels an average of 4.6 μg/m3 (range 1.8 - 7.2 μg/m3). The study documents the presence of airborne lead as a result of air rifle shooting and cast doubt on HET’s findings, as well as the CMP’s claim that there’s no need for special ventilation systems.32
A 2009 German study examined the blood lead levels of 129 individuals from 11 different indoor shooting ranges who shot a variety of weapons.
- 20 individuals who shot only air guns showed a median BLL of 33 μg/l with a (range 18–127 μg/l). (Translated into standard American usage per deciliter – 3.3ug/dl or 3.3 micrograms per deciliter)
- 15 shooters who were users of air guns and .22 long rifles had a median of 87 μg/l with a range of14–172 μg/l.
- 51 shooters of the .22 caliber rifles and large caliber handguns (9 mm or larger) had a median of 107 μg/l (range 27–375 μg/l)
- 32 who only used large caliber handguns had a median of 100 μg/l with a range 28–326 μg/l.
- Finally, the study tracked an 11-member IPSC group (International Practical Shooting Confederation members employ all shooting disciplines - handgun, rifle, shotgun, and air gun.) he IPSC-group had the highest median of 192 μg/l with a range of 32–521 μg/l.
The survey size of the air gun-only shooters in the German study was small at 20, and it’s possible the subjects developed elevated BLLs from a variety of sources, but it seems to be clear from both the Swedish and the German studies that air gun shooters using lead pellets may be exposed to harmful lead particulate matter. The authors of the German study call for the use of either lead-free ammunition or vastly improved ventilation systems.33
The Centers for Disease Control and Prevention is adamant that the smallest exposure to lead may be dangerous to children. In 2012, its Advisory Committee on Childhood Lead Poisoning Prevention released a report entitled “Low-Level Lead Exposure Harms Children: A Renewed Call for Primary Prevention.” In this report, the committee recommended lowering the Blood Lead Levels (BLL’s) considered to be poisoned from a minimum of 10 ug/dl to a minimum level of 5 ug/ Military Recruiting In The United States 143 dl. They cited that BLLs lower than 10 ug/dl still result in “IQ deficits,” “behavioral problems, particularly attention-related behaviors and academic achievement,” and “adverse health effects [such as] cardiovascular, immunological, and endocrine effects.”34
Adverse developmental effects were also found by the National Research Council of the National Academies in infants and children at maternal blood lead levels under 10 μg/dL, and reduced fetal growth and low birth weight were observed at maternal blood lead levels under 5 μg/dL.35
The German study (Demmeler, Matthias, et.al.) showed blood lead levels of air gun shooters up to 12.7 μg/dL, more than twice the 5 ug/ dL the Centers for Disease Control considers to be the threshold for poisoned blood in a child.
Only a few in this country have connected the dots. Regularly firing lead projectiles at 500 feet per second in programs involving 1,600 high schools is terrible public policy.
In 2013 parents (including the author) in Montgomery County, Maryland approached district officials regarding their concerns about the potential for lead exposure in regular classrooms used for both firing ranges and academic subjects. Montgomery County Public Schools Deputy Superintendent Dr. Erik J. Lang acknowledged that Gaithersburg, Kennedy, Paint Branch, and Seneca Valley high schools all had indoor firing ranges that operate in classrooms during the school day.
In a detailed response, parents received correspondence dated March 13, 2013, from Sean Yarup, Environmental Team Leader, Division of Maintenance, Indoor Air Quality Office of the Montgomery County, Maryland Public Schools. In the letter, Mr. Yarup cited the CMP’s Guide to Lead Management and advised parents:
There is no scientific evidence that firing lead projectiles in target air guns with velocities of less than 600 fps. generates any detectable airborne lead. All available medical testing shows that air rifle target shooting participants do not develop elevated lead levels as a result of this activity. Anyone who handles lead pellets during air rifle or air pistol shooting can effectively minimize their lead exposure by washing their hands after firing and by not consuming food or beverages on the range.
Apparently, Montgomery officials were satisfied that their students were only exposed to “minimal” amounts of lead.
In contrast, a neighboring jurisdiction, Fairfax County, Virginia was confronted by another group of parents with the same concerns back in 2007. They worried that JROTC air gun shooting ranges in classrooms and gyms at Mount Vernon, Hayfield, Herndon, Edison and South Lakes high schools posed a potential risk of lead exposure to the general school population. Unlike Montgomery County, Doug O’Neill, from the Fairfax County Office of Safety and Environmental Health, immediately took action - once he became aware of the firing ranges!
According to a story in the local Connection newspaper, O’Neill said, “Nobody really knew the ranges existed,” but when he discovered them, his office began “asking hard questions.”36
The spokesman from the Office of Safety and Environmental Health of the Fairfax County Public Schools, with 180,000 students and a $1.8 Billion budget, ranked as one of the nation’s top school districts, didn’t know the military used the school system’s classrooms as rifle ranges? From the article:
I don’t think it ever crossed anybody’s radar screen. I knew we had lots of programs; I’ve been in the schools 14 years,” said O’Neill. “We went out to review what they were, and asked for wipe samples.”
The samples resulted in the discovery of lead dust, but there weren’t any county standards in place to gauge whether the levels detected were dangerous, which O’Neill said concerned him. “I wrestled with that. We used the most conservative standard we could find.”
In the meantime, the county shut the ranges down until hired contractors could clean the lead out of the rooms.
Letters were sent to parents of students whom school officials determined might have also been exposed to the dust. Art students at South Lakes also used the JROTC room for art class, and wrestlers at Mount Vernon used the JROTC room there for wrestling practice, said Doug O’Neill, school spokesperson from the office of safety and environmental health. Everyone who was in those rooms was sent a letter,” said O’Neill. “Contamination was confined to the five rooms, one in each school, and did not affect other areas of the schools,” O’Neill said. “We found lead that exceeded a very low standard, and we cleaned it up,” said O’Neill.
Immediately after the incident Fairfax schools adopted a policy that mandated the use of non-lead projectiles in all of the firing ranges located in the county’s schools. The policy states,
Effective January 11, 2007, FCPS determined that the usage of leadbased air rifle pellets is inconsistent with the design of the JROTC classrooms. No lead projectiles are allowed on FCPS premises. Only non-lead projectiles will be used for air rifle activities within FCPS facilities. Lead projectiles may be used by participating air rifle programs at non-FCPS ranges that are properly ventilated and designed for air rifle activities. Air rifles must be thoroughly cleaned to remove all lead residues prior to being brought onto FCPS property! It is the responsibility of the JROTC instructor to effectively clean all air rifles prior to being transported onto FCPS property.37
Fairfax officials only allow their students to participate in air rifle programs at non-Fairfax facilities if the ranges are “properly ventilated and designed.”
The unsettling notion that the Fairfax school administration did not realize that classrooms were being used for firing ranges may be understood in the way high schools across the country often grant the military autonomy in running the JROTC program, along with several dozen other military programs. School officials have little sense of the content of the curriculum and exercise no oversight regarding the professional credentials of “teachers”. Instructors associated with the JROTC Marksmanship program are frequently the only non-degreed, non-certified individuals allowed to manage classrooms in the absence of professional supervision in most states.
Nine years later, in 2016, the Washington Post reported on firing ranges in Fairfax County High Schools, emphasizing the safety of the sport. The article stated that “air rifles can be shot anywhere, even in a garage, where ventilation systems and backstops aren’t needed.”38 This may be the case with non-lead projectiles, but the Post did not make an important distinction between lead and non-lead pellets.
The CMP cautions that if shooters or coaches move forward of the firing line “they can potentially pick up lead fragments on their shoes and track them back to the firing points or areas behind the firing line. For this reason, personnel movements forward of the firing line should be reduced and restricted to marked lanes on either side of the firing points.”39
It is difficult to see how these standards are rigorously and universally maintained, especially when the CMP calls for the meticulous use of shop or industrial vacuum cleaners and mops and disposable mop heads, along with a variety of other measures after each shooting session. (See the complete list of cleaning measures below). In Fairfax, VA, rooms used for shooting are also used for art classes and wrestling matches when students roll around on the floor. In Montgomery, Maryland, rooms are also used for other classes. Fairfax and Montgomery are among the nation’s wealthiest jurisdictions, in a better financial position than most school districts across the country to provide separate housing for firing ranges.
To clean up the deposits of lead at the firing line and target area the CMP suggests using “relatively simple cleaning procedures” to remove lead from the classroom floor to the point where no detectable lead remains. To do so, the CMP advises, “a periodic wet mopping with a solution of water and tri-sodium phosphate” (TSP) should do the trick.40
In 2012, the US Department of Housing and Urban Development advised that tri-sodium phosphate should be avoided when cleaning up the lead because it is deadly to the environment and no better than many other less harmful cleaning agents. HUD does not recommend trisodium phosphate (TSP). Not only has TSP been banned in some areas because of destructive effects on the environment, but research indicates that phosphate content is not associated with effectiveness in removing lead-contaminated dust from residential surfaces.41
A 2006 study in the journal, Environmental Science & Technology found no evidence to support the use of TSP over all-purpose cleaning detergents for the removal of lead-contaminated dust. The authors concluded that childhood lead prevention programs should consider recommending all-purpose household detergents for removal of lead-contaminated dust after appropriate vacuuming.42
Back in 2002, (eleven years before the CMP lead guide) the Navy recognized that non-TSP phosphate cleaners may be more effective than TSP. The Navy’s Indoor Firing Ranges Industrial Hygiene Technical Guide warned that diluted, TSP is a skin irritant and users should wear waterproof gloves. The Navy guide also warned that if TSP is used, eye protection should be worn, and portable eyewash facilities should be located in or very near the work area.43
Lead-based ammunition is likely the greatest unregulated source of lead knowingly discharged into the environment in the United States. In contrast, other significant sources of lead in the environment, such as leaded gasoline, lead-based paint, and lead-based solder, are recognized as harmful and have been significantly reduced or eliminated over the past 50 years.
More to the point, there is a large body of work to demonstrate the harmful effects of lead exposure associated with indoor firing ranges. No one disputes the fact that lead accumulates on the floor at the muzzle of an air gun, and the floor around the target area. Meanwhile, the CMP’s lead guide says that high school children who fire lead pellet rifles in classrooms are safe from lead contamination if they wash their hands and keep open food and drink away from shooting activity.
In 1988, William L. Marcus, PhD., a researcher at the National Institute of Health, examined the issue of lead exposure for air gun shooters. He concluded that if young target shooters follow a few simple precautions, their use of lead pellets during target shooting does not constitute a health hazard. Dr. Marcus worked with shooting sports leaders to develop two simple rules that are still the basis for health guidelines that are taught to shooting coaches and shooting sports participants. Those rules are:
1) Anyone who handles air gun pellets during shooting must wash their hands, with soap and water, after they finish shooting.
2) No food or open beverage containers may be taken into the range and no food may be consumed on air gun ranges. It also should go without saying that pellets should never be placed in a shooter’s mouth.44
The research by Dr. Marcus was conducted in 1988, a Neanderthal age in the world of monitoring the effects of lead on the public. According to a study by the National Institute for Occupational Safety and Health (NIOSH) in 2011, washing hands with soap and water is not completely effective in removing lead from the surface of the skin.
NIOSH researchers developed and patented a novel and highly effective skin decontamination/cleansing technology. NIOSH recommends use of this technology to reduce the risks of lead exposures after firing weapons.45
Lead enters the body when we breathe in tiny lead particulates or ingest them mostly by hand to mouth contact. It is also possible to enter our bodies through the skin. In Fairfax County, Virginia wrestling rooms and art studios were used as firing ranges. Unless the stringent procedures to protect the health of children outlined by the CMP (below) are meticulously followed by JROTC and school officials by each of the 1600 high schools with marksmanship programs, children and staff are at risk. Anecdotal evidence in Maryland and Virginia suggests that high school students in the JROTC marksmanship program sometimes cross the firing line on the floor with their hands, arms legs, and feet. When the class period is over, floors may remain untouched, and the firing line disappears, and furniture is rearranged while the next group of students file in for an unrelated academic subject. Meanwhile, the lead dust is stirred into the air and picked up by students on their shoes, hair, clothing, and backpacks to be transported throughout the school. Kids become like dust mops, spreading the deadly material throughout the building.
Meanwhile, the number of children considered at risk of lead poisoning jumped more than five-fold after the U.S. Centers for Disease Control and Prevention lowered its threshold for the diagnosis in 2012. Like the CDC, the American Academy of Pediatrics has stated there is no safe level of lead exposure.46
While the CMP says target shooting with lead pellet rifles does not create “real” health risks, the organization publishes a very stringent list of the necessary procedures to protect the health of children in high schools with shooting ranges. The CMP’s guidelines are extraordinarily tedious and there is evidence these guidelines are not being meticulously followed by all 4,664 CMP-affiliated clubs across the country. We should also bear in mind that children are not the only potential victims of lead exposure. Custodial staff may suffer the highest levels of exposure.
According to the CMP’s Guide to Lead Management, the following is a list of the necessary procedures to protect the health of children in high schools with shooting ranges:
- Pellet traps designed to effectively contain the pellets and pellet fragments must be used.
- Only authorized adult personnel who follow proper procedures should remove lead from pellet traps or target holders.
- With this type of pellet trap, you must still ensure all residues fall behind the target line by carefully inspecting the areas behind and in front of the target line before establishing the range map.
- Lead consisting of spent pellets or pellet fragments that is removed from the pellet traps is regarded as a recyclable material. After a quantity of this lead is accumulated, take it to a recycling center.
- If you are working with an older range that does not have a smooth floor, consider replacing or covering the floor to achieve a smooth surface that is easier to clean.
- In order to carry out recommended air gun range management procedures, range managers should have these supplies and materials available to them: (1) Shop or industrial vacuum cleaner; (2) mops and disposable mop heads; (3) Container (bucket) with secure closure for spent pellets; (4) Container (bucket) with secure closure for vacuum filters and mop heads.
- On ranges where the target system allows lead pellet residues to deposit on the floor forward of the targets, it is recommended that the range staff establish a lane (paint or tape a line) to provide a designated walking path for the coach or authorized athlete to follow while moving to the target line.
- At the target line, it is recommended that the designated target changer put on disposable shoe covers before walking over any residues that may be in front of the targets.
- Once targets are changed, the designated target changer should remove the disposable shoe covers before stepping onto the walking path and returning to the firing line. Shoe covers are disposable, elasticized paper.
- If the air gun range is in a multi-use facility where other activities will take place in the downrange area after air gun firing concludes, that area must be cleaned after every training or competition session.
- After firing activities have ended, have the athletes remove shooting equipment from the firing line, ensuring that they do not step over the firing line. Using a shop vacuum, start from behind the firing line and move parallel to the firing line, carefully vacuuming from the firing line downrange for ten feet. Start again from ten feet in front of the target line and move parallel to the target line, vacuuming to the tar- get line (or beyond if there is lead pellet residue behind the target line.
- Ensure that the shop vacuum’s cord, wheels and hoses do NOT drag through un-vacuumed area. Always keep the vacuum and the vacuum operator in the clean area of the range. The operator should not step on or stand in a potentially contaminated area.
- Range floors that are roughly textured or porous and may require mopping with tri-sodium phosphate, a buffering solution that suspends particulates long enough to be picked up by the mop.
Around the Nation
Flint, MI - Flint has come under the national spotlight because of its lead-contaminated drinking water, although this is not the only source of lead contamination. Northwestern High School in Flint boasts an indoor firing range that is run by the Navy and affiliated with the Civilian Marksmanship Program. As we’ve seen from the CMP’s Guide to Lead Management, the CMP cautions that if shooters or coaches move forward of the firing line “they can potentially pick up lead fragments on their shoes and track them back to the firing points or areas behind the firing line. For this reason, personnel movements forward of the firing line should be reduced and restricted to marked lanes on either side of the firing points.”
Published photos show ROTC students at Northwestern High School remove their targets after a session at the school’s indoor shooting range on Monday, Feb. 3, 2014.47 The photo suggests officials in Flint are failing to minimize these risks. Apparently, the city’s drinking water is not the only source of potential lead contamination. Other photos of the shooting range at Northwestern suggest there are no marked lanes. The CMP also calls for the use of disposable plastic shoe covers when going downrange which also does not appear to be happening in Flint. Kids at Northwestern are likely to be tracking lead throughout the school.
Meanwhile, parents of children participating in Flint’s Northwestern High School are required to sign a form that releases NJROTC “from any and all claims, demands, actions or causes of actions due to death, injury or illness, the government of the United States and all of its officers, representative and agents acting officially and also the local, regional, and national Navy officials of the United States.”48
Waimea, Hawaii - The Menehune High School Junior ROTC Marksmanship Program in Waimea, Hawaii has operating procedures that direct custodial staff to “sweep up lead pellets.”49
Peoria, Illinois - Will it play in Peoria? Apparently so. The Richwoods High School Marine Corps JROTC Rifle team’s range supports six fulltime firing points. For air rifle matches for up to 20 shooters, the team uses the local roller skating rink.50
Sanger, California - The Sanger High School NJROTC Marksmanship team did not have the kind of equipment or practice facility it needed so the school district manager of maintenance services found ways to convert an old, leaky stained shed into “a like-new, almost state of the art squad room and air rifle range.” One of the parents applied for a grant to the NRA which came up with “almost $7,000 for precision marksmanship air rifles, pellets, safety shooting glasses, air cylinders, targets and lots more.”
“The district didn’t have money for the kind of new equipment we needed,” said Naval Lt. Commander Bryan Kinyoun.”51
Omaha, Nebraska – In 2006 Parents began complaining about potential lead exposure due to JROTC marksmanship programs at Benson, Bryan, Burke, Central, North, Northwest and South Bryan High’s firing range located at Bryan Middle School. Reid Steinkraus, Supervisor of the Douglas County Child Lead Poisoning Program, who did not know the ranges existed, said the district had taken the necessary steps to assure that the schools were not contaminated. 52
According to the “Omaha Public Schools Indoor Air Program”, the JROTC programs use “small pellets instead of bullets at all OPS firing ranges.” The manual states:
No lead is discharged at the ignition point from this type of ammunition. The firing ranges use a system of baffles to slow the velocity of the projectile which were eventually deposited in sand filled troughs at the base. All of the sand in these firing ranges was removed, treated as hazardous waste and disposed of properly. In addition, the firing ranges are equipped with high efficiency particulate air (HEPA) filtered vacuum cleaners for cleaning purposes. Air monitoring was conducted during firing periods in the breathing zone of the cadets and at the exhaust port. No airborne lead was detected.”53
Although lead is not discharged at the ignition point, it is deposited at the muzzle end of the gun at the firing line. Even if the delicate air 152 Pat Elder testing was properly conducted and there was absolutely no airborne lead particulate matter, there’s still the issue of contamination through exposure by students from lead deposited directly in front of them and the exposure by staff if they are not meticulously following lead management procedures outlined by the CMP.
Sheyboygan, Wisconsin - The Sheboygan Rifle & Pistol Club, an organization affiliated with the CMP, moved its shooting range out of a Wisconsin middle school after parents raised concerns about exposing students to lead. The club had an October 2011 deadline to either upgrade the range’s ventilation system or move out. Parents raised concerns about how the children were being protected from the range’s lead residue.54
Lathrop High School, Tanana Valley Alaska - In 2002, Youth shooting programs at the Tanana Valley (AK) Sportsmen’s Association, an organization affiliated with the CMP, shooting range were halted after ten members of the Lathrop High School rifle team were found to have high concentrations of lead in their blood.55
As stated, the CMP is opposed to the use of non-lead pellets. Their position is reminiscent of reactionary stances by those who were opposed to federal steps to take the lead out of paint and gasoline. The CMP is joined by the NRA and other pro-gun groups in its adamant defense of lead in ammunition.
The NRA, for instance, fought California’s recent law to ban lead in ammunition used for hunting. Many nationally renowned scientists testified in California that ammunition used for hunting is the number one source of unregulated lead left in our environment.56 The NRA lobbied against the legislation by distorting the facts. NRA board member Don Saba claimed, “the lead that’s in ammunition is fairly non-toxic.” Like those who deny climate change, the NRA, through its proxies, “claims that the science showing lead ammunition harms wildlife is “riddled with false assumptions, faulty methodology, selective presentation of data and outright ignoring of plausible alternative explanations.”57
It would be laughable if millions did not believe it.
The CMP is similarly fanatic. It argues in its Guide for Lead Management that lead is the only material that is “both practical and economically feasible for use in producing competition-quality air gun projectiles.” Shouldn’t the potential for lead exposure render lead pellets utterly impractical? Moreover, shouldn’t the health of America’s school children take precedence over the cost of .177 caliber pellets?
The Guide to Lead Management says there have been several attempts to produce air gun pellets from other materials such as tin, but that none is a satisfactory substitute for lead. However, we’ve seen the success of the Battle Creek Marksmanship team using pellets made of tin and bismuth and the Air Force strongly recommending the use of non-lead pellets for its ASJROTC marksmanship programs.
Congress is beginning to pay attention to the health risks associated with military firing ranges, although not the firing ranges run by the military in the schools. The National Academy of Science reported in December of 2012 that decades-old limits on lead exposure are inadequate to protect the health of workers on military firing ranges. The researchers reported that lead from ammunition fired on military ranges in the last five years has “frequently exceeded” those limits, “in some cases by several orders of magnitude.”58
Sen. Ben Cardin expressed concern about the report’s implications for workers at Maryland installations with firing ranges, such as Aberdeen Proving Ground. “They’re at risk,” he said.
Barbara Boxer, the chairwoman of the Senate Committee on Environment and Public Works, explained, “We want to protect our people from exposure to these dangerous toxins. And we will do everything in our power to ensure that our families are protected from toxins that harm the human body.”59
Hopefully, Senators Boxer and Cardin will also take measures to protect schoolchildren from these dangerous toxins.
In the meantime, it’ll be tough to dislodge cavalier attitudes about lead that pervade in high schools across the country. For instance, in 2013 when five students with the Somerset (PA) High School gun club were found to have elevated blood levels for lead, the school’s athletic director was quoted in the local paper as saying, “Very few schools are getting their teams tested for this. Lead is prevalent in the sport and high levels are going to exist.” The gun club
members routinely practiced at a shooting range owned by Somerset Sportsmen Rifle & Pistol Association, Inc., affiliated with the CMP. The article explained that the rifle team “experienced high lead levels last year as well. This is a temporary side effect of shooting guns.” The school superintendent assured the public that the school is working closely with the coach to implement proper hygiene guidelines for team safety and that the school purchased a new vacuum and had the shooting range at the Somerset Sportsmen’s Club professionally cleaned.60
Pat Elder is the director of the National Coalition to Protect Student Privacy, an organization that works to prohibit the automatic release of student information to military recruiting services from the nation's high schools. He is also creator of the website Counter-Recruit.org, which documents the deceptive practices used by the US military to recruit students into the armed forces.