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Founded by Theodore Roosevelt in 1887, the Boone and Crockett Club promotes guardianship and visionary management of big game and associated wildlife in North America. The Club maintains the highest standards of fair-chase sportsmanship and habitat stewardship. Member accomplishments include enlarging and protecting Yellowstone and establishing Glacier and Denali national parks, founding the U.S. Forest Service, National Park Service and National Wildlife Refuge System, fostering the Pittman-Roberson and Lacey Acts, creating the Federal Duck Stamp program, and developing the cornerstones of modern game laws. The Boone and Crockett Club is headquartered in Missoula, Montana.
A threat by outside lobbyists in an ATTEMPT TO BAN ALL LEAD IN HUNTING AND FISHING:
Anti-hunting and anti-fishing interests are currently litigating against the Environmental Protection Agency (“EPA”) to force the EPA to expand its Toxic Substance Control Act (TSCA) authority in order to regulate traditional ammunition and recreational fishing tackle.
When the Act was established in 1976 Congress explicitly excluded from regulation any article subject to excise taxes -- including pistols, revolvers, firearms, shells and cartridges.
The EPA has already once declined a petition that asked the agency to prohibit the manufacture, processing, and distribution in commerce of lead for shot, bullets, and fishing sinkers because it did not have the authority to do so under the TSCA.
Anti-hunting and anti-fishing interests assert the EPA does have the authority and that a lead ban is necessary to address the significant impacts to wildlife populations that are resulting from traditional tackle and ammunition.
The assertions made by the petitioning groups lack credible scientific foundation, especially when seeking a blanket ban on all lead use. Outside of the California condor, where every death is significant, there is no evidence of a lead crisis at the population level – an entire group of one species living in a specific area.
The biggest threat of lead in wildlife is with birds that have gizzards, which hold on to and grind up food, rather than pass it quickly through their systems.
Proponents of the ban cite the impacts on individual raptors, such as Bald Eagles even though raptor populations are increasing across North America and the Bald Eagle was removed from the Endangered Species list as recently as 2007.
If a complete ban on lead in ammunition where achieved it would have a dramatic negative impact, because of the increased cost of alternative metals, on the cost of ammunition, and therefore participation in hunting and recreational shooting, which in turn is the engine that drives most of the funding for conservation and wildlife management through the excise taxes paid on the purchases of ammunition.
Sportsmen groups have rallied to push forward the introduction of the Hunting, Fishing and Recreational Shooting Protection Act (S.838 & H.R. 1558), which will amend TSCA in a manner that serves to protect and enhance our hunting, recreational shooting and recreational fishing heritage while concurrently facilitating the important benefits that the hunting, shooting and recreational fishing industries contribute to the betterment of our nation’s economy and treasured natural resources.
The Act is now being discussed and considered in committees. To learn more:
Lead in all its forms has become a four-letter word in our society. Of late it has become a tool for environmentalist, animal activist and anti-hunting and fishing groups – a tool with dangerous consequences, in some ways maybe more so than the metal itself. If there ever was an elephant in the room that could affect how we hunt, shoot, and fish from here on out, this is it.
Environmental groups are now claiming that wildlife on a large scale are being impacted by lead poisoning, either by ingesting spent lead, or in the case of large raptors and scavengers, ingesting lead fragments from consuming gut piles or unrecovered game. They further claim a human heath risk from eating wild game. They make no secret; they are pushing for a complete ban on the use of lead in all ammunition and fishing tackle.
The facts surrounding this issue are complex and the ramifications of a complete ban far reaching.
Lead is the easiest and least expensive metal to form into bullets, birdshot, and sinkers. As such lead is at the foundation of the traditional outdoor actives of hunting and fishing. All forms of hunting with a firearm, plus recreational, law enforcement, and military shooting involve lead ammunition. In fishing lead is used in weights, sinkers, and jig heads, and in flyfishing, in split shot and twist-ons.
Because lead is so widely used in the products that support these activities, two issues emerge – funding for wildlife conservation and management, and the low cost participation in these activities by young hunters, shooters, and anglers.
It’s no secret that sportsmen and women, shooters and anglers pay for the majority of wildlife conservation and management through the excise taxes on equipment purchases, including ammunition. It is also no secret that if equipment manufactures are forced to use alternative metals that cost more to source and produce into product, the cost of these products has to go up, and in some cases go up substantially. Ramification #1 is future conservation funding – as costs go up participation goes down, purchases go down and excise taxes go down. Ramification #2 is the loss of inexpensive ammunition for young shooters getting into shooting or hunting. The last thing conservation, our wildlife, and hunting and fishing needs is another obstacle keeping young people for getting active outdoors.
Shots Fired
On August 3rd, 2010 environmental groups petitioned the Environmental Protection Agency (EPA) to issue a complete ban under the Toxic Substance Control Act. Congress had specifically excluded ammunition from this legislation and the EPA rejected the petition on the grounds it did not have the authority for such a ban. Subsequently, environmental groups filed suit against the EPA claiming they do have authority to ban lead ammunition. Those behind this petition would have us believe that any amount of lead deposited into the environment is a threat to wildlife and humans.
Real Science
Lead is a naturally occurring element in the environment and has no functional or beneficial role in biological systems. Based on our knowledge of its toxicity, lead has been banned in paint, toys, and gasoline – gasoline being of the biggest concern in transfer to humans. Over concern for waterfowl eating spent lead pellets and the threat of lawsuits by environmental groups, the U.S. Fish & Wildlife Service banned lead in all waterfowl hunting in 1991. The ban followed from research documenting the accumulation of lead shot in wetland habitats that were heavily used by waterfowl hunters, and other studies reporting mortality in bottom-feeding waterfowl following the ingestion of lead pellets while foraging.
Depending on a range of factors lead can be toxic to some wildlife, but it is primarily an issue with birds. This is because birds have gizzards, which hold on to and grind up food, rather than pass it quickly through their systems. The right type of lead can also be a toxic to humans depending on the amount consumed, over certain duration of time, individual body size, and age.
Proponents of the ban cite the impacts on individual raptors, such as Bald Eagles even though raptor populations are increasing across North America and the Bald Eagle was removed from the Endangered Species list as recently as 2007.
Understanding this issue and sorting fact from fiction is difficult because of all the variables. It is being made even more difficult by groups asking for more science. Many studies have already been conducted and a technical review of existing scientific literature on the subject was completed by The Wildlife Society, the premier professional organization for wildlife science and management, in collaboration with the Association of Fish and Wildlife Agencies. These studies show that potential ingestion rates and health impacts vary by species, age, body size, amount consumed, method ingested, and geographic area. Some have measured the amounts and distributions of lead fragments found in carcasses and gut piles. We know that ingestion rates are related to lead concentration in the specific environments where animals may possibly ingest pellets or fragments while feeding. On the extremely low-hazard end are individual bullets fired in the field. On the high side is where shot-shell pellets concentrate where shooters regularly use the same locations, like dove fields and trap and skeet ranges.
Other than condors there is no evidence lead bullets are a serious conservation issue at the population level – meaning an entire group of one species living in a certain area. With the endangered California condor, every death is significant and so banning the use of lead ammunition in condor range made sense and sportsmen have supported this effort.
Considering human health, we have to realize that the lead in gasoline was emitted into the air and settled everywhere in our environment and that is very different from how hunters and anglers are depositing lead. The question is not whether lead fragments or pellets can be found in wild game. The question is can this be a source of lead toxicity for humans? The only reported human health issue from ingested lead ammunition comes from a study of subsistence hunters in Northern Canada that ate lead-harvested wild game in high quantities every day.
The punch line is, if there is more science needed it would on be at the population level for a specific species in a specific area. The real question with lead is should our policy-makers take a sledge-hammer approach to an issue science says is tightly limited to certain populations and situations?
Bottom Line
The tools used for centuries by hunters, shooters, and anglers are in the crosshairs of environmentalists whose agenda appears to be mixed. Some would say theirs is a real concern for wildlife and humans. Others contend the plot to ban all lead is just another attempt to chop the legs out from under sportsmen and the user-pay model of wildlife conservation.
A blanket ban on all lead ammunition and in fishing tackle is clearly overreaching, especially when it includes lead that has no chance of being deposited in the environment, like indoor facilities for shooters, self-defense and law enforcement training. This is not a one-size fits all issue. The science simply isn't there to support a human health issue. As for wildlife, in terms of the health of populations and ecosystem function there may be the need for localized restrictions, but those decisions are best left to local managers, not judges. Our wildlife professionals need to clearly articulate to policy-makers what is a conservation issue requiring drastic regulatory changes and what is a non-issue, or a personal choice based on a desire to not kill or sicken individual birds.
S. 838
After the environmental groups filed suit a Bill was introduced to Congress supported by sportsmen’s organizations that would amend the Toxics Substance Control Act to clarify the jurisdiction of the EPA. The S. 838: Hunting, Fishing, and Recreational Shooting Protection Act is now being discussed and considered in committees. http://www.govtrack.us/congress/bill.xpd?bill=s112-838
Where this issue will land is yet to be seen. What we do know is that sportsmen care about wildlife, all wildlife, and have proven so time and again. If or where real science, not advocacy called science or agenda-based science, but real science that holds up to scrutiny demonstrates a population impact and the use of non-lead products is warranted, sportsmen will do their part. The best thing you can do now is stay informed and let yourself be heard, especially regarding the proposed Hunting, Fishing and Recreational Shooting Protection Act.
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