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Main
question
about
gun
range
referral
policy
to
CDPH
and
response
QUESTION:
Unless
it
has
recently
done
so,
CDPH
has
never
referred
the
Target
Masters
gun
range
to
either
Cal/OSHA
or
to
the
DTSC.
Given
the
background
facts
of
this
case,
does
CDPH
Director
Smith
believe
that
the
decision
to
not
refer
this
gun
range
to
enforcement
officials
was
proper?
CDPH
RESPONSE
to
QUESTIONS
1
and
6:
OLPPP
does
not
currently
refer
employers
to
Cal/OSHA
for
enforcement
action
based
solely
on
an
employee
blood
lead
level
(BLL).
When
determining
whether
to
refer
an
employer
to
Cal/OSHA,
multiple
factors
are
taken
into
consideration
and
each
referral
is
examined
on
a
case-‐by-‐case
basis.
The
program’s
case
management
team
provides
in-‐depth
case
management
services
when
an
employee
BLL
meets
the
Cal/OSHA
trigger
for
Medical
Removal
Protection
(50
µg/dL).
This
process
includes
interviewing
and
providing
information
to
the
worker,
physician,
and
employer;
making
sure
the
worker
has
been
removed
from
significant
lead
exposure
per
the
Cal/OSHA
standard;
determining
gaps
in
the
lead
safety
program;
providing
recommendations
and
technical
assistance
to
the
employer;
and
following
the
case
to
see
that
program
recommendations
are
carried
out.
Factors
that
are
considered
when
referring
a
case
to
Cal/OSHA
include
whether
an
employer
does
not
follow
through
to
address
Occupational
Lead
Poisoning
Prevention
Program
(OLPPP)
recommendations
and
whether
the
employer
has
received
case
management
services
in
the
past
and
has
a
new
MRP
case.
OLPPP
has
a
mandate
to
provide
information
and
technical
assistance
to
employers
in
order
to
reduce
lead
poisoning,
which
is
a
public
health
approach
rather
than
a
regulatory
approach.