Objectives

To determine whether the Division of Military and Naval Affairs (DMNA) has implemented adequate controls to ensure all armories are tested for lead and are remediated where excessive levels are detected. The audit covers the period January 1, 2015 through March 12, 2020.

About the Program

Historically, armories were built with an indoor firing range (IFR), used for training purposes. The firing of weapons inside the IFR resulted in lead dust accumulation throughout. Although IFRs in New York have not been used in more than 20 years, over time, the accumulation of lead dust has been transported to other areas of the armory on Soldiers’ shoes; through the heating, ventilation, and air conditioning system; and as a result of weapons cleaning, maintenance, movement, or storage. Personal exposures to lead can occur through ingestion, inhalation, and dermal contact and can result in growth disorders as well as damage to the nervous system, kidneys, and reproductive system. Lead is considered a cumulative poison, as it is transported by the bloodstream and accumulates in the bones and organs. Exposure to lead is especially dangerous for young and unborn children.

DMNA is the State’s executive agency responsible for managing New York’s military forces, including the New York National Guard. The Department of Defense (DOD) National Guard Bureau (NGB) acts as a federal authority over the New York National Guard, and provides them with federal resources, including funding, regulatory guidance, and equipment. In September 2015, the NGB’s Army National Guard (ARNG) issued guidance to all states regarding a possible lead dust hazard in ARNG armories. The guidance issued a new acceptable level for surface lead dust of 40 micrograms per square foot (μg/ft²). It required that all facilities be tested, and if lead surface contamination above the 40 μg/ft² threshold is confirmed, public rental of the armory must be immediately suspended and access to family members, the general public, and pregnant women no longer permitted. Once the armory is remediated and lead testing confirms compliance below 40 μg/ft², public access may resume. The guidance also requires the implementation of safety measures such as posting warning signs and training all armory employees in lead hazard awareness. ARNG guidance issued in December 2016 stipulates the cost of lead remediation efforts will be 100 percent federally funded.

Key Findings

• Public access has continued at four armories that contain lead levels exceeding the acceptable threshold. None of these four armories disclosed the excess lead levels to the public. Three are allowing public access through a non-military use agreement and one is a military museum in a former armory building.
• Lead hazard awareness training was not provided to employees at three armories.

Key Recommendations

• Update non-military use agreements to disclose lead issues to armory occupants.
• Post signs warning of potential lead hazards in public areas.
• Ensure that new staff receive lead hazard awareness training upon hire and that this training is provided to all staff annually.