Piqua, Ohio ­— Because of its high level of toxicity, lead is considered one of the most hazardous contaminants that we can come into contact with in the workplace. In adults, the toxic heavy metal can cause high blood pressure, muscle & joint pain, memory & concentration difficulties, mood disorders, heart disease, stroke, chronic headaches, abdominal/gastrointestinal issues, weight gain, reduced sperm count in men, and miscarriage or stillbirth in pregnant women. Lead is substantially more dangerous to children, causing delay in development, learning difficulties, fatigue, hearing loss, and seizures. Although there is no level of exposure to lead that is known to be without harmful effects, the Federal government (via NG Pam 420-15, 40 CFR 745, and 24 CFR 35) lists “acceptable” exposure levels to be 200 µg/ft² for adults; 40 µg/ft² for children. This is a measurement of micrograms of lead dust per square foot of a tested surface. Remember these numbers as you read on.

The Kettering Armory is located near Dayton, Ohio. It is currently home to HHD, 155^th Chemical Battalion, 637^th Chemical Company, an Army National Guard Recruiting team, a Field Maintenance Shop, and a Recruit Sustainment Program unit. Decades ago, the facility housed an indoor firing range as well. That range was removed in 1991, but the building has since been haunted by a dangerous invisible remnant of its existence: The facility’s interior, to include its ventilation ducts, still contains disturbing amounts of lead.

The data below was obtained through a Freedom of Information Act (FOIA) request submitted to National Guard Bureau and provided to us by a contributor who wishes to remain anonymous. It displays an overtly negligent lack of concern for the health of our Soldiers, families, guests, employees, and members of the public who rent the facility. It also shows the willful nonoccurrence with State and Federal regulations in regards to employee notification, employee health monitoring, and safe working conditions.

December 2012: A lead sampling report contained the following concerning measurements and their locations:

Classroom 1 top of refrigerator = 91 µg/ft²

S4 Office (SFC Berio) = 95 µg/ft²

Table on Drill Floor = 91 µg/ft²

Exercise Room = 91 µg/ft²

MRE box in cage = 91 µg/ft²

Classroom 106 window sill = 91 µg/ft²

CERF-P Emergency Response bags = 315 µg/ft²

Commo cage in storage area = 559 µg/ft²

Ventilation duct (to drill floor) = 17,626 µg/ft²

Yes, you read that correctly. The vent supplying air to the drill floor tested at more than 88x the “safe” level. This is the same drill floor where Soldiers work, eat, and even sleep during training. This is the drill floor where Soldiers’ children sit on Santa’s lap during the holiday party. This is where dozens of high school age band members practice, and sleep, for a week straight when they rent the armory every summer. And it’s the drill floor where full-time employees exercise throughout the week.

October 2014: LtCol Stephanie Steve (State Surgeon) sends an email to Mr. James Penn, MAJ Chris Bricker, COL Chip Tansill, BG(Ret)Jack Lee, LTC Anthony Lam, LTC Dan Shank, CPT Elena Gonzalez, James Brewster (and others) regarding the armory. LtCol Steve states, “Kettering old firing range is still full of lead after an alleged cleaning…”. She states that the results were between 506 µg/ft² and 46,818 µg/ft² and continues, “standard is 200 [µg/ft²] for adults and 40 [µg/ft²] for children.”

January 2015: A lead sampling report contained the following concerning measurements and their locations:

Drink machine on drill floor = 90 µg/ft²

Drill floor ventilation grille = 286 µg/ft²

Ceiling beam in FMS = 63,250 µg/ft²

March 2015: A lead sampling report contained the following concerning measurements and their locations:

HHD Supply SGT Office (SSG Posey) Air vent = 91 µg/ft²

HHD Supply SGT Office (SSG Posey’s desk) = 2,411 µg/ft² (over 12x the “safe” level)

March 2016: A lead sampling report contained the following concerning measurement:

HHD Supply SGT Office (SSG Posey) Ventilation duct: 3,043 µg/ft² (over 15x the “safe” level)

March 2017: A lead sampling report contained the following concerning measurements and their locations:

Hallway air intake = 180 µg/ft²

Hallway = 1,200 µg/ft²

Room 130 = 110 µg/ft²

Room 130C = 100 µg/ft²

Room 126(1) = 190 µg/ft²

Room 126(2) = 250 µg/ft²

Room 126(3) = 1,700 µg/ft²

Room 126(4) = 3,300 µg/ft²

Room 124(1) = 1,500 µg/ft²

Room 124(2) = 2,800 µg/ft²

Room 124(3) = 7,100 µg/ft² (over 35x the “safe” level)

So, what has the Ohio National Guard done with these outrageous test results? Department of Defense (DoD) Instruction 6055.05-M dictates “Ensure personnel are informed of potential health risks. Consider reduction or avoidance of lead exposure for all workers. Ensure personnel exposed to lead above the 30 µg/m³ (note: “cubed”) AL are enrolled in medical surveillance.” But the OHARNG has taken none of these measures. In fact, they haven’t performed any air tests whatsoever to identify who may be at risk. And while they continue to test surfaces for lead, units are instructed to clean all horizontal surfaces immediately prior to the testing. I suppose that’s one way to have lower test results.

Countless employees, day-in and day-out, unknowingly collect unhealthy amounts of lead on their clothing, boots, and other belongings to bring home to their families. Some have already experienced many of the symptoms of lead toxicity without ever knowing that their workplace may be the cause. Others won’t experience symptoms until years later. While it’s not unusual for an organization to encounter hazards in the workplace, it’s apparent that there is a culture of secrecy and cost-cutting in the Ohio Army National Guard when it comes to notifying and safeguarding their employees. Check back for our upcoming parts of this ongoing series about hidden hazards in Ohio National Guard workplaces. If you are an employee (military or civilian) or renter of this facility, contact your local OSHA branch for further actions you can take.

Further reading:

· AR 40-5 (The Army Public Health Program), paragraph 2-23: Commanders at all levels will

o Ensure that the health of all personnel in their command is promoted, sustained, and protected in all military activities through aggressive implementation of Public Health services.

o Provide hazard control and hazard communication.

o Ensure proper use of personal protective measures and protective clothing and equipment.

o Ensure Public Health communication.

o Implement worksite, occupational health, and environmental health surveillance.

o Implement occupational health, including ensuring that Soldiers and employees under their command who are enrolled in an occupational health medical surveillance program comply with the medical surveillance.

o Ensure Soldiers who were exposed to known or suspected occupational or environmental threats, report their exposure to medical personnel.

o Ensure that assigned PH personnel receive, enter, manage, report, and maintain all PH information in the appropriate systems of records.

· AR 40-5 paragraph 2-23: Army managers and supervisors at all levels will—

o Ensure that the health of all personnel under their supervision is sustained and protected in all Army activities through aggressive implementation of Public Health activities, to include:

§ Training.

§ Hazard control.

§ Communication of hazards and health risks.

§ Worksite OEH surveillance.

o Adhere to federal, state, and host nation statutory and regulatory laws, directives, licenses, and guidance governing OEH in garrison and during training exercises.

· DoDI 6055.01 DoD Safety and Occupational Health (SOH) Program excerpts:

o The DoD Components must comply with the federal regulatory standards distributed by OSHA at all nonmilitary-unique DoD operations and workplaces, and with regulatory requirements of part 20 of Title 10, CFR part 1040 and sections 1040.10 and 1040.11 of Title 21, CFR.

o While military personnel are excluded from the definition of “employee” in federal regulatory standards distributed by OSHA, the DoD Components must apply these OSHA standards to military personnel in nonmilitary-unique workplaces.

o Local-area Hazard Safety Briefing. Develop and keep current pertinent safety and health hazard briefings for unique local-area and workplace conditions and practices to include overseas locations. Provide this briefing to all DoD personnel before being exposed to the hazards. Provide applicable installation-related information to non-DoD visitors in conjunction with obtaining an installation visitor pass.

o Personnel Notification. Notify affected personnel of risks, risk mitigation actions planned and completed, their role in risk mitigation actions, and actions they can take to further reduce risks.

· DoD 6055.05-M

o Facilities with employees exposed to stressors at or above the action level (AL) are required to perform appropriate medical surveillance examinations if a suitable examination exists. The scope of these medical screening examinations shall be determined at the Service, command, or activity level based on the nature and extent of personnel exposed at or above the AL.