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Water isn't the only source of lead contamination in Flint

By Pat Elder,

Thailynn Smith, 15, a freshman at Flint Northwestern, shoots an air rifle at the school's ROTC indoor shooting range on Monday, Feb. 3, 2014. Samuel Wilson |

The firing range at Flint Northwestern High School is run by the Navy and affiliated with the Civilian Marksmanship Program which provides regulations for the shooting activity. According to the Civilian Marksmanship Program's Guide to Lead Management of Air Gun Shooting, a key to minimizing the risks of lead exposures from any residues that are deposited between the firing line and the targets is to minimize requirements for coaches or shooters to go downrange in order to prevent lead residues from migrating behind the firing line.

It doesn't seem like officials are minimizing these risks in Flint, Michigan. Apparently, the city's drinking water is not the only source of potential lead contamination.

The CMP's guide also suggests high schools control the paths used to go down-range so that no one walks in the area immediately in front of the firing line. It doesn't appear from the numerous photos on the website the high school, the Navy, or CMP officials are enforcing this. The guide also calls for the use of disposable plastic shoe covers when going downrange which also does not appear to be happening. The shoe covers are meant to minimize the likelihood of lead fragments being tracked throughout the school.

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, along 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 supposed to be performed either by the Brigades/Area Commands, the CMP, or private firms.

Zackir Metcalk, 17, a sophomore at Flint Northwestern, proudly points out his accuracy on a target after a session in the school's indoor shooting range during ROTC training on Monday, Feb. 3, 2014. Samuel Wilson |

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 approximately 1,600 JROTC units offer rifle marksmanship programs to their cadets. Interestingly, the CMP doesn't count the 800 Air Force JROTC programs across the country, so the total tops 3,200 units. Approximately half, or 1,600 of these units offer rifle marksmanship programs to their high school cadets.

The cleanup of toxic lead materials is a major concern.

Here's a list of the necessary procedures in the CMP Guide designed to protect the health of children in high schools with shooting ranges. Are we certain school officials in Flint are taking these precautions? Are we certain these precautions are taking place in the 1,600 sites across the country?

  • Only authorized adult personnel who follow proper procedures should remove lead from pellet traps or target holders.
  • You must 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:
    • Shop or industrial vacuum cleaner and mops and disposable mop heads,
    • Container (bucket) with secure closure for spent pellets
    • 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 may require mopping with tri-sodium phosphate, a buffering solution that suspends particulates long enough to be picked up by the mop.

ROTC students at Flint Northwestern remove their targets after a session at the school's indoor shooting range on Monday, Feb. 3, 2014. Samuel Wilson |

Parents of children participating in Flint's Northwestern High School's NJROTC Marksmanship Program 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."

Officials say lead pellets are not airborne and pose no health risk. In 2013 parents in Montgomery County, Maryland approached district officials regarding their concerns about the potential for lead exposure in regular classrooms that were used for both firing ranges and academic subjects. Firing ranges in the nation's high schools are managed by JROTC programs affiliated with the Army, Navy, Air Force, and Marines. They are all "regulated" by the CMP.

Montgomery County Public Schools Deputy Superintendent Dr. Erik J. Lang acknowledged that Gaithersburg, Kennedy, Paint Branch, and Seneca Valley high schools all have indoor firing ranges that operate in classrooms during the school day.

In a response dated March 13, 2013 Sean Yarup, Indoor Air Quality Office, MCPS 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.

All three statements are untrue.

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 ìg/m3 (range 1.8 - 7.2 ìg/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.

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 ìg/l with a (range 18-127 ìg/l). (Translated into standard American usage per deciliter - 3.3ug/dl or 3.3 micrograms per deciliter)

The National Institute for Occupational Safety and Health (NIOSH) said in 2011 that washing hands with soap and water is not effective in removing lead from the surface of the skin.

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, who has come under scrutiny in Colorado in 2012 for "gross technical incompetence in technical compliance."

The CMP says normal ventilation systems are fine for shooting ranges in America's high schools.

More unbelievable stuff:

Lead from airguns is deposited at the muzzle end of the gun at the firing line. Every pellet being fired down the barrel scrapes out the deposits from the pellets that went before. Kids pick it up on their shoes and clothing and track it throughout the building. High concentrations of lead residues are also deposited on the floor in the area around the backstops. And all of this is happening in some classrooms in Montgomery County, MD, just a few minutes before kids in the next class file in.

Once the director of environmental health at Fairfax County schools became aware that classrooms were being used for firing ranges he sprang into action and ordered lead testing on surfaces. The tests came back showing a severe threat to public health. Fairfax authorities shut down the programs, cleaned and re-cleaned, and sent letters home. They re-opened the ranges but required the switch to non-lead ammunition. That was in 2007. All Air Force JROTC units use non-lead pellets. Montgomery County's Police firing range only uses non-lead ammunition.

The Menehune High School Junior ROTC Marksmanship Program in Waimea, Hawaii has operating procedures that direct custodial staff to "sweep up lead pellets."

Will it play in Peoria? Apparently so. The Richwoods High School Marine Corps JROTC Rifle team's range supports six full time firing points. For air rifle matches for up to 20 shooters the team uses the local roller skating rink.

Congress failed to include a mandatory annual financial audit to examine the CMP's internal controls regarding compliance with the 1996 act.

The private CMP has $164.5 million in publicly traded securities. The 990 states, "at no cost to the government," the CMP "develops curriculum for marksmanship instruction in the high schools, trains and certifies JROTC coaches and inspects high school range facilities." The corporation spent just $346,000 on these items.

Rep. Mike Rogers (R-AL 3) represents Anniston, Alabama in Congress. Anniston is the home of the CMP. Rogers inserted an amendment into the 2015 NDAA that allows 100,000 Army M1911A1 pistols to be transferred to the CMP for eventual sale to the public.

Incredibly, there are still many high school shooting programs affiliated with the CMP that continue to use small-bore .22 caliber rifles inside schools. The .22 small bore rifles that fire standard bullets deposit substantially more lead into the air and on the ground than the lead pellets in use in the classrooms.

The CMP advises, "a periodic wet mopping with a solution of water and tri-sodium phosphate" (TSP) should be used to clean classroom floors. In 2012 the US Department of Housing and Urban Development advised that tri-sodium phosphate should be avoided when cleaning up lead because it's deadly to the environment and no better than many other less harmful cleaning agents.

The CMP advises against the use of non-lead pellets in its Guide to Lead Management, arguing they don't perform as well as their lead counterparts.

The CMP's lead guide states 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. According to a study by NIOSH in 2011, washing hands with soap and water is not completely effective in removing lead from the surface of the skin.


Pat Elder is the Director of the National Coalition to Protect Student Privacy.  He is the author of  “Military Recruiting in America” set to be published in the summer of 2016.







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