Testimony in Support of MD HB 523 Use of Lead Ammunition in School Programs – Prohibition
A high school student handles lead pellets while participating in the school's Junior Reserve Officers' Training Corps (JROTC) Marksmanship Program
Testimony in Support of HB 523 - Use of Lead Ammunition in School Programs – Prohibition
Many schools in Maryland and across the country allow rifle practice to occur during school hours in classrooms, cafeterias, and gyms that are contaminated by lead fragments that become airborne and are deposited on the floor at the muzzle-end of the rifle and at the target backstop. Loose enforcement of regulations creates a health hazard for students and custodial staff. Students walk through lead-contaminated areas and routinely track poisonous lead particulates throughout their schools.
The congressionally chartered Civilian Marksmanship Program (CMP) lists 26 schools in Maryland with marksmanship programs. The shooting classes are part of the Junior Reserve Officer’s Training Corps program (JROTC). Maryland has 76 high schools with JROTC programs according to the four military branches which host the programs. Across the country, 1,871 high schools have shooting programs, about half the total of all JROTC programs.
Children as young as 13 handle the lead ammunition and are taught to shoot air rifles. The U.S. is the only developed nation to teach marksmanship in its public schools.
The JROTC shooting programs are run by the four military branches and are regulated by the CMP which publishes The Guide to Lead Management for Air Gun Shooting, a widely distributed document that rules out the use of non-lead ammunition and minimizes the potential for exposure to toxic lead.
When confronted by parents concerned about lead contamination in a school with a JROTC shooting range, officials in Montgomery County, Maryland, cited the CMP’s lead guide while telling parents there was no threat from the lead. Officials said they were satisfied that students were only being exposed to small amounts of lead.
The air gun rifles may discharge visual quantities of lead on the floor at the muzzle end of the firing line. The manual on standard operating procedures published by the JROTC Cadet Command says it’s recommended to clean rifles every 1,000 to 2,000 shots. The rifles don’t need to be cleaned often because every pellet being fired down the barrel scrapes out the deposits from the pellets that went before.
The pellets smash into the target backstops creating a shower of poisonous, minute lead particulate matter that permeates the air and covers the floor. School children come into contact with lead the moment they handle the pellet.
The CMP lays out stringent guidelines to minimize the risk of lead exposure from lead residues. The guide also details exhaustive measures to follow while cleaning up the lead, however, the procedures are often ignored in the schools. Hundreds of photos, articles, and videos document violations. Children are not allowed to cross the firing line, but they frequently do. Specific lanes are to be established between the firing line and the targets and shoe covers are to be worn, but that is often ignored. Children shouldn’t be cleaning lead residue, but they often do. Vulnerable school staff do not always follow the rigid protocol for cleaning the lead.
The Army’s guide for JROTC firing ranges contradicts the CMP on the necessity of allowing cadets to walk downrange. “On most ranges, it is necessary for cadets to go downrange to hang, change or retrieve targets.”
The CMP advises that a wet mopping with a solution of water and tri-sodium phosphate should be used to clean up the lead, although the US Department of Housing and Urban Development advises that tri-sodium phosphate should be avoided because it is deadly to the environment. The CMP directs students to wash their hands with soap and water after shooting, but the National Institute for Occupational Safety and Health warns the public that washing hands with soap and water is not completely effective in removing lead from the surface of the skin.
The CMP’s lead guide makes the claim that air guns do not produce airborne lead particulates. This is a big deal because it means schools aren’t required to install special air ventilation systems to protect public health. To substantiate the claim, the CMP relies on the work of a discredited Colorado firm to maintain that firing air guns does not create airborne lead. The CMP 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. HET came under scrutiny in Colorado in 2012 for “gross technical incompetence in technical compliance.” HET’s work is cited by high school officials in Montgomery County, MD and across the country to defend the presence of indoor firing ranges in their schools. There’s plenty of science to refute the CMP’s stance.
A Swedish study 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). (micrograms per cubic meter) The study calls for special ventilation system that are able to filter out the tiniest lead particles.
For comparison’s sake, in 2013, the California Department of Public Health recommended that the California Division of Occupational Safety and Health lower the permissible exposure limit for lead in air to 0.5 - 2.1 μg/m3 to keep BLLs below the range of 5–10 μg/dL.
Studies of shooters who only fired airguns report blood lead levels of 1.8 - 12.7 ug/dl. (Demmeler, et.al. International Archives of Occupational and Environmental Health; Heidelberg Vol. 82, Iss. 4, (Mar 2009): 539-42.)
Lead is deadly. The Center for Disease Control and Prevention (CDC) says there is no safe blood lead level in children. Protecting children from exposure to lead is necessary to insure lifelong good health. Even the tiniest levels of lead in blood have been shown to affect IQ, ability to pay attention and academic achievement.
Maryland’s bill only protects the health of children enrolled in the state’s public school programs. The bill does not address other children’s shooting programs like the Young Marines, 4-H, and Boy Scouts that may bring children as young as 8 to largely unregulated commercial firing ranges that are sometimes loaded with lead from the routine firing of large-caliber weapons.