If you are a loyal reader of all4shooter.com, you should be well-informed about the EU “lead ban” and the European Chemicals Agency (ECHA) restriction proposal currently in the public consultation phase. And you should also know that this is just an ideological crusade in disguise against hunters and shooters – and more generally, against legal gun owners. In case you have still have doubts, on behalf of the European Shooting Sports Forum (ESSF) Euractiv published an article that highlights the main methodological flaws of the ECHA’s Environment and Human Health risk assessments included in its restriction proposal.
Euractiv is an independent pan-European media network specialised in EU affairs, established in 1999, and the article is part of an awareness campaign launched by the ESSF. We have summarized the key facts of the article for you.
ECHA's risk assessments “scientifically unsound”
“The new ban proposal is off on the wrong foot and history seems doomed to repeat itself. On closer inspection, the ECHA Restriction Report contains different flaws,” ESSF writes in the introduction. The article then proceeds to examine the ECHA´s human health and environmental risk assessments.
As for the first, ESSF notes that “The ECHA´s human health risk assessment is flawed because it is based on arbitrarily-selected parameter values that do not reflect reality and disregard existing scientific literature.” The ECHA in fact estimates that the average adult (weighing 70 kg) consumes 80.89 kg of game meat per year, a number that is four to eight times higher than even the most extreme consumption rates of any publicly available report published by the European Food Safety Agency (EFSA) or any other national food agency. “As a result, it presents unprecedented lead exposure levels as if they were the norm.”
Moreover, the parameter related to average lead concentration in game meat seems not to be backed by the available scientific evidence: “To start, the ECHA states that lead concentration in game killed by rifle bullets is almost 7 times higher than that in game hunted by gunshot. This is counterintuitive, as the concentrations of lead in small game, like pheasants and partridges, hunted by shotguns should be higher than in large game, like moose.” ECHA also estimated lead concentrations on meat samples taken around the wound channel only, ignoring most of the meat far away from the bullet and uncontaminated. And even the average lead concentration figures used by the ECHA (0.366 mg/kg for game hunted with lead shots and 2.515 mg/kg for game hunted with lead bullets) “are not in line with any of the available scientific evidence provided by the national food agencies in the EU.”
As for the environmental risk assessment, the estimates of the annual release of lead gunshot into the environment seem extremely excessive for both hunting and sport shooting. “The release of 14,000 tonnes of lead per annum (tpa) resulting from hunting with shotguns, whose cartridges contain 34g of lead pellets, would mean that every hunter in the EU shoots an average of 67 gunshots per year (404.6 million cartridges / 6 million hunters in the EU), which is frankly a high average proxy.” The same goes for the emission of lead into the environment resulting from clay target shooting: “The ECHA assumption of 10,000 kg/year of lead used 'on a typical outdoor clay target range’ refers to one worst-case scenario based on one sample site that should not be considered as 'typical’, as the values were not meant to be ‘representative’.” The resulting value of lead released in the environment, 35,000 tpa, “does not correspond to reality, as more accurate estimates are less than half that amount.”
The article also stresses how the study of the primary poisoning of terrestrial birds overlooks the fact that many bird species have either not been specifically studied or are assumed to have similar feeding ecologies and exposure probabilities, even if living in completely different ecosystems. Add to this that the assessment “completely ignores other routes of lead ingestion from environmental sources, such as food or poisoning that occur because of exposure to elevated lead concentrations in the vicinity of mines, waste disposal sites and industrial premises. Simply put, mortality from lead poisoning is a fraction of total mortality.”
No scientific evidence or reliable data on the effect of lead in ammo
Not even a grotesque note is missing: “The ECHA estimates that 135,429,204 birds (not a single bird more, and not one less) are at risk of poisoning from lead ammunition and 1,354,292 birds actually die from lead poisoning every year (taking into consideration a mortality rate of 1%): very precise figures, considering it’s anyone’s guess how they were calculated.”
As all4shooters.com already noted many times, the ECHA Report is simply based on arbitrarily selected parameter values, a disregard for existing scientific literature on specific subjects, a lack of suitable scientific evidence in some contexts, and the use of statistically-unreliable data. “If this is indeed the document upon which the Commission will draft a proposal that will impact the lives of millions of European citizens, we are afraid the outlook for future decisions is rather grim,” ESSF concludes. We fully agree with this assessment.
Here is another interesting article about the effects of lead in ammunition: The myth of "poisonous" lead in ammo. It's worth reading.