Lead Contamination of State Armories (Follow-Up)

Issued Date
December 16, 2021
Military and Naval Affairs, Division of


To determine the extent of implementation of the five recommendations included in our initial audit report, Lead Contamination of State Armories (Report 2019-S-50).

About the Program

The Division of Military and Naval Affairs (Division) is the State’s executive agency responsible for managing New York’s military forces, including the New York National Guard. The Department of Defense National Guard Bureau 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 National Guard Bureau’s Army National Guard (ARNG) issued guidance to all states regarding a possible lead dust hazard in ARNG armories, with personal exposure possibly resulting in growth disorders as well as damage to the nervous system, kidneys, and reproductive system. The 2015 guidance issued a new acceptable level for surface lead dust. It required that all facilities be tested, and if lead surface contamination above the acceptable level was 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 was remediated and lead testing confirmed compliance, public access could resume. The guidance also required the implementation of safety measures such as posting warning signs and training all armory employees in lead hazard awareness.

Our initial audit report, covering the period January 1, 2015 through March 12, 2020, was issued on September 3, 2020. The audit sought to determine whether the Division had implemented adequate controls to ensure all armories were tested for lead and were remediated where excessive levels were detected. The audit found that the Division had generally established adequate controls to ensure that the federally funded areas of all armories were tested for lead and that necessary steps were taken to address remediation when high levels were detected. Based on our site visits to a sample of 12 armories undergoing lead remediation, we found the Division was generally abiding by ARNG requirements to protect the health and safety of Soldiers and armory employees in these areas. While the Division’s controls provided reasonable assurance that the public was not being unnecessarily exposed to lead at most armories, in certain instances, more could be done.

Key Finding

The Division has made progress in addressing the issues we identified in the initial audit report. Of the initial audit report’s five recommendations, four have been implemented and one has been partially implemented.

Key Recommendation

Officials are given 30 days after the issuance of this follow-up to provide information on any actions that are planned to address the unresolved issues discussed in the report.

Nadine Morrell

State Government Accountability Contact Information:
Audit Director
: Nadine Morrell
Phone: (518) 474-3271; Email: [email protected]
Address: Office of the State Comptroller; Division of State Government Accountability; 110 State Street, 11th Floor; Albany, NY 12236