Eddie B wrote: »

Has the duck gizzard project something to do with the lead ban? Our club has asked members to hand in gizzard's to help fight against the ban

Following from last years survey it will run again hopefully to give further evidence against the ban

Some updates and it is not looking good for any shooter irrespective of what you shoot in the EU.Please make sure this info falls into the right hands of your clubs,range and organisations.

https://firearms-united.com/eu-ammo-ban-impacts/?fbclid=IwAR3ggxEVCuxfKst1QowziT39nkQ670fONaIThlrEtao1vyLY0tIseAgzHCg

Also a study from the shooting side of things.
Again pass it on. Sorry it is in PDF.So I've just copied it here.Cut&paste and use as a document. Analysis of the:
„ECHA report – recommendation of total ban on lead ammunition“
by LEX – Czech association for protection of firearms rights – www.gunlex.cz
Source: ECHA report - identifies risks to terrestrial environment from lead ammunition
https://echa.europa.eu/cs/-/echa-identifies-risks-to-terrestrial-environment-from-lead-ammunition
ECHA/PR/18/14

1 INTRODUCTION
The ECHA report is relatively well sourced. By checking the sources, however, we found that
ECHA often omitted important claims of source studies and misinterpreted many others. In
addition, around half of the sources mentioned in the text of ECHA report are missing in the
bibliography list. As a result, we had to find them through our own research, which was not always
successful. The ECHA report therefore does not fulfill standards of scientific research.
We also doubt the objectivity of the report, as it openly prefers total ban on grounds of simple and
easy enforcement, at the expense of firearms owners.
When checking the sources, we always attempted to track the chain of information back to primary
data (i. e. results of actual research), and where we found it, we point to that research (with
eventual comments to its faults or misinterpretation.)

2 HEALTH RISKS

2.1 Direct emissions into environment
ECHA reports the risk of pollution by deposit of lead ammunition into soil through shooting.
Reported amount (21 000 tons per year) was computed from number of manufactured rounds and
average lead content per round1.
As proof of risk, ECHA report refers to Finnish study2, which claims around one-third of Finnish
shooting ranges to be risk of pollution of groundwater. However, upon more detailed review of that

1] As a source of amount of manufactured ammunition, ECHA report refers to AFEMS (Association of European
Manufacturers of Sporting Ammunition) report for 2010. We could not find that report, so we could not verify it.

2 Sorvari, J., Antikainen, R., Pyy, O. (2006). Environmental contamination at Finnish shooting ranges - The scope of the
problem and management options. Science of the Total Environment, 366, 21–31.
https://www.sciencedirect.com/science/article/pii/S004896970500923X#bib30
study, we learned that the study simply assumes as risk any shooting range placed closer than 100
m to source of groundwater; no actual measurement of lead content in water was performed during
this study. The study claims (without stating any sources) that three Finnish shooting ranges were
actually detected (by measurement) as a source of lead pollution exceeding health limits, while the
number of shooting ranges in Finland is estimated by the study to be between 2000 and 2500.
In relation to that, we point to a study performed on an outdoor range in Czech Republic3, where
actual measurement of lead in soil was carried out. The study found that even before the backstop
where most bullets fall, lead did not penetrate deeper than 30 cm into soil.
Since we were not able to find any study, which would actually perform measurement of lead
content in groundwater near shooting ranges in larger scale, we recommend performing such a
study.

2.2 Health risks of lead ammunition for birds and mammals
Primary poisoning – ingesting lead projectile from environment: This phenomenon is well proven in
waterfowl on wetlands, where birds often swallow lead shot with food or grit (however, use of lead
shot on wetlands is already banned). ECHA report claims that terrestrial birds, especially mourning
doves and gallinaceous birds (pheasants, partridges) are at the same risk as waterfowl. In case of
mourning doves, we found studies which prove that claim4 5 6 (around 2,5% of examined birds had
one or more lead shot in its intestines). With gallinaceous birds, we found study of pheasants
performed in the pheasantry7, which has showed 3% of such occurrence.
Secondary poisoning – ingesting lead shot with prey or carcass, of ingesting lead-contaminated

3 ASH, C. – TEJNECKÝ, V. – ŠEBEK, O. – NĚMEČEK, K. – ŽAHOUROVÁ - DUBOVÁ, L. – BAKARDJIEVA, S. –
DRAHOTA, P. – DRÁBEK, O. Fractionation and distribution of risk elements in soil profiles at a Czech shooting
range. Plant, Soil and Environment, 2013, roč. 59, č. 3, s. 121-129. ISSN: 1214-1178.
https://www.researchgate.net/publication/235217492_Fractionation_and_distribution_of_risk_elements_in_soil_profile
s_at_a_Czech_shooting_range

4 CASTRALE, J.S. 1991. Spent shot ingestion by Mourning Doves in Indiana. Proceedings of the Indiana Academy of
Science 100:197–202. http://journals.iupui.edu/index.php/ias/article/view/7223/7223

5 FRANSON et al. Ingested shot and tissue lead concentrations in mourning doves. 2009.
https://www.peregrinefund.org/subsites/conference-lead/PDF/0202%20Franson.pdf

6 KENDALL, R. & SCANLON, P. Lead concentrations in mourning doves collected from Middle Atlantic Game
Management Areas. 1979.
https://www.researchgate.net/publication/266330176_Lead_concentrations_in_mourning_doves_collected_from_Mid
dle_Atlantic_Game_Management_Areas

7 Butler DA, Sage RB, Draycott RAH, Carroll JP. Potts D, (2005). Lead exposure in ring-necked pheasants on shooting
estates in Great Britain. Wildlife Society Bulletin 33(2), 583-589.
https://www.researchgate.net/publication/261826356_Lead_Exposure_in_Ring-
Necked_Pheasants_on_Shooting_Estates_in_Great_Britain
meat: this phenomenon is allegedly8 proven in raptors hunting waterfowl (affected by primary
poisoning). However, this problem should be solved by already existing ban on use of lead
ammunition on wetlands. This phenomenon is further well proven (by finding of projectiles in
stomachs or pellets regurgitated by birds) in scavenger birds feeding on carrions, for example
condors9 or red kites10. We were unable to find a study with such certain proof concerning common
birds of prey; lead poisoning from ammunition is usually only assumed on grounds of high blood
lead level11, which can have other sources. We recommend further research in this matter.
Risk for mammals: ECHA reports cases of lead poisoning of cattle by eating silage harvested from
lead ammunition contaminated fields. We could not find any of the reported sources except for
one12, which we could not evaluate, as only an abstract of the source is available online.
2.3 Health risks of eating lead-harvested game by humans
Transfer of lead from ammunition to game meat: According to the ECHA report, this happens by
embedding of lead projectile either in animal body or by fragmentation of projectile (especially
when hitting a bone) and contamination of meat by microscopic fragments of lead. This is well
proven by a study13 examining content of lead in bird game meat: 65% of examined birds
contained 1-18 (2,17 on average) shots. 76% of birds contained fragments of shots visible on X-ray
picture.
After removal of shots from samples, lead level in game meat was measured. Maximum level

8 The only source we found on the web is printed book unavailable to us: Pattee OH, Hennes SK (1983) Bald eagles
and waterfowl: the lead shot connection. Trans 48th N Am Wildl Nat Resour Conf 48:230–237
https://pubs.er.usgs.gov/publication/5221827

9 CADE,T. J. 2007. Exposure of California Condors to lead from spent ammunition. Journal of Wildlife Management
71:2125–2133. http://www.bioone.org/doi/abs/10.2193/2007-084

10 PAIN,D.J.,I.CARTER,A. W.SAINSBURY,R. F.SHORE,P.EDEN,M.A.TAGGART,S.KONSTANTINOS,L. A.WALKER,A.
A.MEHARG,AND A.RAAB. 2007. Lead contamination and associated disease in captive and reintroduced Red Kites
(Milvus milvus) in England. Science of the Total Environment 376:116–127.
https://www.sciencedirect.com/science/article/pii/S0048969707001003

11 Fisher IJ, Pain DJ, Thomas VG. A review of lead poisoning from ammunition sources in terrestrial birds. Biol Conser.
2006;131(3):421–432. https://www.sciencedirect.com/science/article/pii/S0006320706000802

12 RICE, D., McLOUGHLIN, M.F., BLANCHFLOWER, W.J., THOMPSON, T.R. Chronic lead poisoning in steers eating
silage contaminated with lead shot-Diagnostic criteria. 1987.
https://www.researchgate.net/publication/19471926_Chronic_lead_poisoning_in_steers_eating_silage_contaminated
_with_lead_shot-Diagnostic_criteria

13 Pain, D.J., Cromie, R.L., Newth, J., Brown, M.J., Crutcher, E., Hardman, P., Hurst, L., Mateo, R., Meharg, A.A.,
Moran, A.C. (2010). Potential hazard to human health from exposure to fragments of lead bullets and shot in the
tissues of game animals. PLoS One, 5(4), e10315.
https://journals.plos.org/plosone/article?id=10.1371/journal.pone.0010315
allowed by EU regulation14 for chicken, beef, lamb and pork meat was exceed in 20 – 87,5 % of
samples (depending on type of game). Of that, 0 – 25 % samples exceeded the limit ten times, in 0
– 12,5 % samples the limit was exceed hundred times.
Toxicity of lead in human organism: ECHA report claims (without presenting any sources to that
effect) that lead is considered to be ―non-threshold substance‖, i.e. harmful in any amount,
therefore any limitation is desirable and justified by itself.
However, ECHA-referred sources state only one condition where lead is actually harmful in any
amount – toxicity for developing nervous system of children. In this case, even micrograms per
deciliter of blood is associated with slight decrease of intellect (in children up to 10 years, raise of
blood lead level from 2,4 μg/dl to 10 μg/dl correlates with decrease of IQ by 3,9 point15). We found
no study, which would prove health issues in adults with blood lead levels of micrograms/dl. By
U.S. standards, acceptable blood lead level is set at 5μg/dl16, for adults 10 μg/dl17. Average blood
lead level for Americans is 2,58 μg/dl18 (therefore, this is amount of lead collected by human
through normal life in developed country).
Transfer of lead from game meat to human organism: this issue is not addressed by ECHA at all.
The report only inquires into amount of game meat consumed in certain EU member states. ECHA
explicitly writes that actual research of influence of game meat harvested by lead ammunition on
human health was not performed at all, because lead is a known non-threshold substance. ECHA
reports to decision of CONTAM panel (EFSA) as a source. We find quite unusual to establish such
factor by agency decision, instead of scientific research.
We have very serious issues with this claim. A study performed on Italian hunters19 found that
game eating hunters actually have a blood lead level higher (0,9 – 6,1 μg/dl) than people who do

14 COMMISSION REGULATION (ES) No. 1881/2006 of Dec.19 2006, which establishes maximum limits of certain
contaminants in food, https://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=OJ:L:2006:364:0005:0024:CS:PDF
1
5 Lanphear, B. P., Hornung, R., Khoury, J., Yolton, K., Baghurst, P., Bellinger, D. C., Canfield, R. L., Dietrich, K. N.,
Bornschein, R., Greene, T., Rothenberg, S. J., Needleman, H. L., Schnaas, L., Wasserman, G., Graziano, J., Roberts,
R. (2005). Low-level environmental lead exposure and children's intellectual function: an international pooled
analysis. Environmental Health Perspectives, 113(7), 894-899.
https://www.ncbi.nlm.nih.gov/pmc/articles/PMC1257652/

16 Center for Disease Control and Prevention, https://www.cdc.gov/nceh/lead/acclpp/blood_lead_levels.htm

17 Center for Disease Control and Prevention, https://www.cdc.gov/niosh/topics/ables/description.html

18 HITTI, M. Lead in Blood: 'Safe' Levels Too High? 2006 https://www.webmd.com/a-to-z-guides/news/20060918/leadin-
blood-safe-levels-too-high#1

19 FUSTISTONI, S., SUCATO, S., CONSONNI, D., MANNUCCI, P.M., MORETTO, A.: Blood lead levels following
consumption of game meat in Italy. 2017. https://www.ncbi.nlm.nih.gov/pubmed/28189071
not eat game meat (1,0 – 5,3 μg/dl); however, this is still safely under limit of 10 μg/dl for adult. On
top of that, study found that hunters themselves had higher blood lead levels, but their friends and
family members who also eat game meat had not. The study speculates that higher lead levels in
hunters' blood could have other sources than game meat, possibly handling ammunition or inhaling
fumes produced by shooting.
Since ECHA lists Italy as one of countries with high consumption of game meat, we consider these
findings very important.20.
Another such a study was performed on American hunters21. It also found blood lead level
increased by 0,30 μg/dl – to total average of 1,27 μg/dl, which is still almost four times less than
maximum level allowed for children.
Similar study performed in Switzerland22 did not find significant difference in blood lead level
between hunters consuming game meat and control group of blood donors, nor any significant
correlation between blood lead level and frequency of game meat intake.
Another study performed in Sweden23 found (by X-ray and computer tomography examination of
wild boars killed by lead bullet) that fragments of lead are concentrated in distance to 4,5 cm from
wound channel, with smaller concentrations up to 10 cm of distance. This meat is removed with
common meat processing methods. The study also performed experiment with simulated digestion
process and found that bioavailability of metallic lead is under 1%, i.e. less than 1% of metallic lead
is absorbed into human body in digestive system.
At this particular point, we must note omission in ECHA report that almost looks like an intentional
misleading. One part of often-cited study Pain et al. 201024, looks into bioavailability, i.e. computes
how much lead would be transferred into human organism from lead-contaminated meat, and

20 FERRI, M., BALDI, L., CAVALLO, S., PELLICANO, R., BRAMBILLA, G.: Wild game consumption habits among Italian
shooters: relevance for intakes of cadmium, perfluorooctanesulphonic acid, and 137cesium as priority contaminants.
2017. https://www.ncbi.nlm.nih.gov/pubmed/28271815

21 Iqbal S., Blumenthal W., Kennedy C., Yip F.Y., Pickard S., Flanders WD., Loringer K., Kruger K., Caldwell K.L., Jean
Brown M.: Hunting with lead: association between blood lead levels and wild game consumption. 2009.
https://www.ncbi.nlm.nih.gov/pubmed/19747676

22 Intake of lead from game meat – a risk to consumers’ health? HALDIMANN, M., BAUMGARTNER, A.,
ZIMMERLI, B. 2002. https://link.springer.com/article/10.1007/s00217-002-0581-3

23 LEAD IN GAME MEAT - Bio accessibility of fragments of metallic lead. QUARFORT, U., HOLMGREN, CH. 2012.
https://www.leadinammunition.com/independent-studies-011/

24 See 13.
whether such amount would exceed the maximum allowed daily dose for children, set by WHO25 at

25 μg per kg of body weight. The study claims that this limit would be exceeded only in two of eight
types of game meat, through daily consumption. If consumed once per week, no type of game
meat would exceed allowed dose. ECHA ignored and omitted these findings, substituting them by
claims about absolute harmfulness of lead. Note that precisely these claims about ―non-threshold
substance‖ and research-unsupported claims of harmfulness of game meat for human health is
what ECHA declares as legal basis for EU action and total ban on lead ammunition.
Findings of the above-mentioned studies show that while contamination of game by lead
ammunition is indeed high, this effect is largely negated by very low bioavailability of metallic lead
in human organism and amount of lead actually absorbed through human digestive system is
safely under daily dose for adult human. The only point where we can agree with ECHA claims is a
recommendation for children and pregnant women to avoid game meat (or eat only game
harvested with lead-free ammunition) due to high toxicity of lead for developing neural system.
The ECHA study points to fact that, unlike chicken, pork etc., game meat does not have any limit of
lead contamination set; we must however point to the fact that these limits were set in regard to
water-soluble compounds of lead, where bioavailability is much higher.
We definitely recommend performing an actual study on blood lead level among hunters, in order
to base further decision-making on facts and not on mere assumptions.
2.4 Health risks accompanying sport shooting
A complex study26 referred to by the ECHA report found a serious air pollution by lead on shooting
ranges, with corresponding high blood lead levels in present persons, up to 125 μg/dl for firearms
instructors. On the other hand, another cited study27 found that this pollution can be lowered by 95
– 97% through use of lead-free primers and jacketed bullets. Considering that mentioned
technology went into widespread use since execution of study (1989), we recommend performing a
study that would test a current situation in this field.

25 http://www.euro.who.int/__data/assets/pdf_file/0004/97042/4.4.-Exposure-of-children-to-chemicalhazards-
in-food-EDITED_layouted.pdf

26 Laidlaw, M.A., Filippelli, G., Mielke, H., Gulson, B. and Ball, A.S., 2017. Lead exposure at firing ranges—a review.
Environmental Health, 16(1), p.34. https://ehjournal.biomedcentral.com/articles/10.1186/s12940-017-0246-0

27 SARAH E. VALWAY, JOHN W. MARTYNY, JEFFREY R. MILLER, MAGDALENA COOK, ELLEN. J. MANGIONE:
Lead Absorption in Indoor Firing Range Users. 1989. https://www.ncbi.nlm.nih.gov/pmc/articles/PMC1349901/


3 ALTERNATIVE AMMUNITION
For the proposed ban on lead shot and its replacement with lead-free shot, no impact assessment
study was carried out by ECHA. In place of it, the ECHA report refers to an AMEC study28
considering such replacement, performed in 2012. This study expects costs of 190 mil. € per year.
In 25 years, it expects one-time and yearly costs together as 2,7 billion €.
Another study, which ECHA substitutes for impact assessment, is a COWI study29 from 2004. This
study expects costs of 220 – 370 mil. € per year while explicitly declaring that in the end, firearms
owners shall pay it all through higher ammunition prices. The study also notes that with some
considered alternatives to lead, like tin, bismuth and tungsten, no studies were performed in regard
of their toxicity in water and soil.
The ECHA report further contains some more interesting thoughts:
 There is a problem that steel shot loses energy quickly at longer distances and may not
have enough power to ensure quick and humane killing of bird. ECHA report ―solves‖ this
problem by recommendation not to shoot at longer distances.
 One of ECHA presented reasons for total ban on lead ammunition is that hunters prefer it if
it is available.
 ECHA report considers that in place of total ban on lead ammunition, lack of alternatives
shall be solved by ―market mechanism‖, i.e. that hunters shall be forced to buy unwanted
lead-free ammunition because better lead ammunition shall not be available, and
manufacturers shall be forced to make lead-free ammunition, because they shall be
forbidden to make anything else.
3.1 Soft steel
Shotgun ammunition with steel shot is quite widely available on market now, and its cost is
comparable to lead shot.30. However, a lesser efficiency is expected both at longer ranges (as
ECHA report admits, see above) and shorter ranges (steel is lighter than lead, therefore
manufacturers recommend using a larger steel shot rather than a lead one. Consequently there is
28 AMEC Environment & Infrastructure UK Limited, Abatement Costs of Certain Hazardous Chemicals, Lead in shot –
Final Report, 2013 https://echa.europa.eu/documents/10162/13580/abatement+costs_report_2013_en.pdf/6e85760eec6d-
4c8a-8fcf-e86a7ffd037d
29 REACH studies - Lead - Advantages and drawbacks of possible market restrictions in the EU - Final report
http://ec.europa.eu/DocsRoom/documents/13043/attachments/1/translations
30 See price list of Czech firearms retailer: http://www.9mm.cz/naboje.html
a smaller amount of shots in a single round, and at certain range the quarry may not be hit with
enough shot to ensure quick killing – five hits are considered to be a reliable minimum.)
The AMEC study estimates that 95% of shotguns shall need reproofing to steel shot. Further it
estimates that about 15% of shotguns shall not pass such reproofing (and very probably shall be
damaged in the process, we add). ECHA report omits this and simply states that “some firearms
might need reproofing”. That is possible – ECHA report claims that according to statement of
(unnamed) large shotgun manufacturers, shotguns manufactured after 1970 are able to shoot steel
shot without reproofing. We recommend asking national proofhouses for opinion.
The COWI study mentions another disadvantage – in the woods, steel shot penetrates deep into
trunks of trees, damage wood by soaking rust and damage woodcutting tools. Many forest owners
therefore prohibit use of steel shot on their lands. ECHA report omits this disadvantage entirely.
Further possible disadvantage of steel shot, also entirely omitted by ECHA report, is higher
potential of steel shot for ricochet. According to COWI study, this may mean more injuries for
hunters and a necessity to rebuild some shooting ranges.

3.2 Bismuth
Bismuth shot has density of 9,7g/cm3, therefore it is a bit lighter that lead (11,3 g/cm3 ) but heavier
than steel (7,9 g/cm3). Hardness of bismuth is comparable to lead, therefore bismuth shot does not
cause problems with wear and tear of barrels and with ricochets, like steel shot has. Main
disadvantage is 3 – 5 higher cost.

3.3 Tungsten
Tungsten shot is manufactured from plastic filled with tungsten dust. From both weight and
hardness criteria, it can be equivalent replacement for lead shot. However, the price can be up to
ten times higher.

3.4 Tin
Tin is even lighter than steel (7,3 g/cm3). It is considered as substitute only in 22 cal. rimfire
cartridges and airgun pellets (COWI). In both cases, lighter projectile would mean significantly
shorter range and lesser accuracy. Cost of tin projectiles would be 1,5 – 6 times higher than lead.

3.5 Copper and copper alloys
Copper and copper alloys have already been used as material for monolithic hunting bullets for
some time. This technology is already quite developed and some hunters prefer these bullets to
leaden ones. There are disadvantages, however – lesser accuracy at longer ranges, lower energy
especially with smaller calibers, and higher penetrative power caused by harder core material.
COWI report also claims that toxicity of copper in water is comparable to lead, and toxicity in soil is
even higher that lead.


4 FISHING WEIGHTS
Health risks for waterfowl: ECHA report sufficiently documents poisoning of waterfowl, especially
loons31 and swans32 by fishing lead. Report states that swallowing of even one lead may cause
acute poisoning and death, due to larger size of fishing lead compared to shot.
Health risks for humans: ECHA report claims (without reporting any sources) possible risk for
humans by inhaling lead vapors during homemade casting of fishing lead.
Reason for EU intervention: ECHA states necessity to complete protection of waterfowl by ban on
fishing lead along with (already existing) ban on lead shot on wetlands as reason for EU
intervention.
Alternative materials: COWI study refers to tin, tungsten, steel, zinc and bismuth as possible
alternatives. Unfortunately, zinc was also already proven to be toxic33, while toxicity of bismuth,
tungsten and tin is not sufficiently scrutinized, as was mentioned above. ECHA report also claims
that according to EFTTA (European Fishing Tackle Trade Association), there is no acceptable
replacement for smallest types of fishing leads.
Costs: Costs of fishing weights from alternative materials would be comparable to projectiles costs.



5 SOCIO-POLITICAL ASPECTS
ECHA report dismisses any alternatives to total ban on lead ammunition (for example, limited
restrictions or support of voluntary use of lead-free ammunition) and explicitly prefers total ban as
most simple and easy solution. In contrast, COWI study even claims explicitly that there is no legal

31 Grade, T. J., Pokras, M. A., Laflamme, E. M. and Vogel, H. S. (2018), Population‐level effects of lead fishing tackle on
common loons. Jour. Wild. Mgmt., 82: 155-164. doi:10.1002/jwmg.21348
https://wildlife.onlinelibrary.wiley.com/doi/full/10.1002/jwmg.21348

32
Kirby, J., Delany, S. and Quinn, J., 1994. Mute Swans in Great Britain: a review, current status and long-term trends.
Hydrobiologia, 279(1), pp.467-482. https://link.springer.com/article/10.1007/BF00027878

33
Steel Shot, Proposed Use for Hunting Waterfowl: Environmental Impact Statement,
https://books.google.cz/books?id=bjA3AQAAMAAJ&pg=SL36-PA46&lpg=SL36-
PA46&dq=zinc+shot+toxicity&source=bl&ots=viCyBMKzGY&sig=kTLIxRSPy5gcrbz6Wn_sdacnbhw&hl=c
s&sa=X&ved=2ahUKEwi76p6Yn63eAhXEiiwKHd3QAqwQ6AEwCXoECAIQAQ#v=onepage&q=zinc%20s
hot%20toxicity&f=false
the basis for EU intervention in case of shooting ranges, because lead pollution in this case stays
limited locally and can be solved at national level. ECHA report basically denies this with
explanation that EU-wide ban would be simplest and most easily enforceable.
Quite interestingly, the ECHA report recommends leaving the enforcement of the ban on fishing
lead to the member states.
One of the main arguments for restrictions presented by the ECHA report is the protection of health
of shooters themselves – i.e. protection of people from themselves, whether they like it or not.
ECHA report goes so far in this aspect that it recommends to consider even ban on home casting
of fishing weights.
ECHA report states that there could be possibility for exemption from lead ammunition ban for
professional shooters of Olympic sport disciplines, for muzzleloaders and antique firearms, as well
as maybe for someone else who can justify his exemption.


6 CONCLUSION
ECHA report is strongly biased towards restriction of lead ammunition, with open preference for
total ban. In all its aspects, it selectively omits important information contained in cited sources (for
example, low bioavailability of metallic lead in human organism) and reports only aspects, which
support this goal.
Also, it interprets some of the sources in a misleading way (for example, cites source claiming that
one-third of Finnish shooting ranges were found to be water pollution risk, omitting fact that cited
study based this claim solely on proximity of shooting ranges to water).
In addition, some of sources are seriously outdated (like 1989 study on lead in shooting fumes on
ranges).
On top of that, roughly half of sources mentioned in the text are not listed in bibliography at the
end. A student who would perform such a sloppy job on his thesis would not be even allowed to
take the exam.
For those reasons, we strongly recommend to MEPs not only to demand full impact assessment,
but also to ask for verifying independent study, which would ensure that evaluation would be fair
and complete. Only then, European Parliament can responsibly decide whether proposed total ban
is in accord with the basic rules of lawmaking, especially principles of legal basis, subsidiarity and
proportionality.

Hate to inform you but this ban is for ALL lead based ammo,including rifle,in all types and formats...[Tis in the previous posts that I put up lads]. That means places like your range if built on a bog[IE midlands] are under a clear &present danger of being shut!! Hunting deer?Yup you too,as the ammo is lead based[ and ALL lead is harmful in foodstuffs according to the EU] so you are at risk as well.Black powder shooter?You are in trouble too,as those rounds are pretty much lead. Flapper clay shoots?A thing of the past if this gets thru too...Dont be fooled into thinking this just applies to shotgun shooting over bogs or wetlands people.It applies to us ALL!!!

that's how it starts, "its only this and its only that" says the EU.

you give them an inch and they will take a mile.

joining the EU was a major mistake, hope the new roads and infrastructure upgrades were worth it.
id rather live by candle light and drive on dirt roads than have an outside entity chip away at my freedoms.

maybe Ireland will wise up and follow brexit

Cass wrote: »

And if there are no migratory birds nesting/feeding (as per the AEWA guidelines below) and the range already meets EPA standards then how can any range be in danger of being shut down?

Dont matter!!! It will be up to US to prove that there is no lead pollution going into the bog water ,or that no migatory birds MIGHT not come there if and when it is re wilded. I refer you to the problem German windfarms have with the Red Kites,bird of prey.Red Kites are migatory birds of prey,that like flat open grassland to hunt over.The kind usually found around windfarms.Kites do usually return to their same nesting ground,but can not as well,they might decide anoter area is more suitable on an annual basis too.No one knows why,but thats the way it is. Very annoying if you are going to plan a windfarm.As you have to do a 5 year eco impact study.So if you have kites nesting in the proposed area for 3 years and they dont come back for two years.Your study is invalid!As they might return in year 6! Off you go again with another 5 year study,while your windfarm is on hold.
What does this mean for us here?Imagine planning to build another range or another 1000 yard range out at Midlands?The project could be choked by red tape requiring us to prove or not,that no migatory birds use that part of the bog. As for the EPA...I give you licensing Irish Cement to burn 90 thousand tonnes of domestic waste in their Limerick plant ,in the middle of a surburban sprawl of Mungret,with a record of coverups at the plant.
So I wouldnt be too sure of their unbiased credintials anymore.

Don't forget this is not a case of stopping this as it's a done deal. Ireland signed up this in 2003, but has not yet addressed it. These discussions are important but they will not stop it from happening.

And we are about the worst to be hit because we have ZERO restrictions in place to temper this.As usual,because of can kicking and "Ah shure it wont affect us,be grand"itis from our Govt and organisations over the last decade on this.:mad:

The best outcome is that the EPA/Dept of AHGAE, etc. put some time and effort into carrying out research as to the nesting, feeding and flight areas of the birds listed and that this ban is only in effect there, and NOT just issued as a blanket ban across the entire country due to laziness or incompetence.

Take a WAG,which one will be done due to political expediency, finance,pirority,and "cos hunters are bad M'kay?" attitudes prevelant out there.:(:(

I really dont think they need to make it any clearer of what they want gone on an EU level...

ope of ECHAs proposed #EUAmmoBan:
1. the use of lead in ammunition (shot and bullets) for hunting in terrains outside of wetlands (i.e. in terrestrial environments) and for target shooting 3 outside of wetlands;
2. the use of lead sinkers and jigs for fishing.

So you can see, its pretty much bye bye lead ammunition – should ECHA have its way…



The main arguments for ECHAs #EUAmmoBan:
– Health risks posed by lead to humans through the consumption of game meat (lead contaminates meat near wound channel).
– Large-scale contamination of wetlands with thousands of tonnes of lead disposed annually from the use of lead gunshot for is clear.
– lead poisoning of waterbirds through the ingestion of spent lead pellets results in the mortality of approximately one million waterbirds per year in the EU.
– The use of lead gunshot in terrestrial/wetland areas can lead to the lead poisoning of various species in terrestrial areas, including predators and scavengers affected through secondary poisoning (predator eats prey that has elevated lead levels or hunters leave intestines with lead shot to nature where other animals consume it)
– Home ‘casting’ of various types of lead-based fishing tackle/bullets for recreational anglers/shooters appears, based on the predominance of online retailers, to be widespread. The risks of this practice could also be addressed by further regulatory action.
– Shooting ranges using lead shot represent a significant risk of soil contamination in terrestrial areas, and risk contaminating nearby (ground) water sources in the EU.
– Alternatives to lead gunshot ammunition are available (mainly steel, bismuth and tungsten as with lead in shot in wetlands). (Note: Funny – nobody is banning cars, even though most people can walk…)
– There are growing concerns in the scientific community on the exposure of target shooters to lead dust used in lead ammunition, primers and propellants.
– There could be an added value in setting minimum risk management measures (RMMs) for lead exposure and emission control at shooting ranges. 1


– Because lead is bad: Lead is a toxic heavy metal – non-threshold substance, having negative effects on general health, reproduction and behavior.


1 On that point alone our ranges would be goosed! How many ranges ask any female dshooters are they pregnant here?Its a MANDATORY question under H&S on ranges on the Continent[Cue.."what happens in other countries doesnt concern us replies....]
Also it is highly recommended,that after shooting or handling lead ammo,or before smoking,eating,or drinking anyone washes both face and hands according to EU H&S on shooting... No comment on some sanitary facilities on our ranges abround the country.:p:)

Cass wrote: »

Until such a time as people stop this lazy method of voting (excuses like they've always voted one party so will continue to do so) things will not change.

I just dipped into the forum to ask question about renewal of firearms cert and started reading this thread out of interest

Now I agree with pretty much all of your post and I'm probably getting in the middle of something here but my only problem with the above is when I go out to vote as much as i don't like voting for the incumbents so to speak I feel even less like voting for any of the alternatives

I don't find any of them credible or believable, I don't see competence there in fact I would be doubtful any of the alternatives would be any better in my area in fact although some of there hearts might be in the right place I don't see them as being competent at all....

its a weak argument perhaps but thats my honest opinion, I think a lot of the right kind of people don't run for public office as they have too much sense ....that leaves the hopeless, the corrupt, the useful eejits, the career climbers and perhaps some genuine competent people sprinkled here and there......the system is set up to acctract the wrong kind of person and its a bit of a feedback loop because thats what a lot of the influential and the easily swayed electorate want...as long as they get to pull the odd stroke here and there or the road gets tarmaced or the elderly get their bathroom done up as they are "entitled" to etc etc

I'll let the late George Carlin say it for me.Applies just as much to Ireland,as to the USA and anywhere else.


https://www.youtube.com/watch?v=xIraCchPDhk

Agreed. Lead is bad.

It is toxic and has been accepted by humanity for a long time. Out of ignorance and habbit. It's what our Fathers used, our military used etc. People don't like change!, and react mostly negatively to something taken away from them. We feel like it's a personal infringement of our rights. Given time and education we soon become acustomised to the new alternatives. Who'd have thought 20 years ago that we'd be driving electric cars. Growing up I had to make a phone call from a yellow box on the street. Alternatives to lead commonly used today are 100% Copper, which is expensive & 95% Copper 5% Zinc. Which studies have shown to be superior to lead. I'm sure there are many more combinations of metals that will have the same effect we are all used to getting. But no matter what is chosen as the alternative, we are still dumping and polluting our environment. I'm as guilty as everybody else. I'd like to be part of positive change as a responsible shooter.

Footnote:
The downside initially to using alternative rounds is the cost. Manufacturers will need to recoup losses changing over from lead. Once everybody has made the change prices will come down as demand rises. Change is inevitable as is our ability to adapt to it.