The Great Debate over Lead Bullets

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On Tuesday, an editorial in The New York Times took on the heated issue of lead ammunition. “What needs protecting,” it stated, “is wildlife that ingests the lead, including migratory waterfowl and birds of prey, notably California condors. Humans need protection, too. According to the Centers for Disease Control and Prevention, people show higher levels of lead in their blood after eating game killed with lead shot or bullets.” What doesn’t need protection, the editorial argued, are lead bullets and sinkers.

In "Bad Shot" in the May-June issue of Audubon, Ted Williams argues a similar point, noting that despite cheap, readily available alternatives, most American sportsmen still use lead ammunition and fishing tackle. To wildlife’s detriment. He writes: 

When lead is ingested the body mistakes it for beneficial metals, incorporating it into the brain, eyes, kidneys, liver, and other vital tissues, which it damages. Most humans survive plumbism (lead poisoning), albeit with diminished mental and motor function, and victims are prone to violence and crime. Children are especially vulnerable because the growth process requires a heavy intake of metals.

In wildlife, plumbism is rarely survivable or diagnosed. To make it in the wild, all animals require full capacity. So plumbism causes mortality wrongly attributed to predation, starvation, roadkill, or collisions. So far 130 species have been known to ingest lead ammunition. There is no such thing as a “safe” or “normal” blood-lead level.

But the gun lobby is strong, Williams writes, and despite studies showing the harm this substance causes to animals—bald and golden eagles, tundra swans, ducks—and humans, we’re fighting the same century-old battle. “Today—after the public has watched for 117 years as waterfowl and other wildlife die from swallowing lead shot and bullet fragments—the mantra from the gun lobby that plumbism publicity is a plot to disarm America remains unchanged.”

Right now, S.838, Hunting, Fishing, and Recreational Shooting Protection Act—the act against which the Times railed—sits in the Committee on Environment and Public Works. Whether it will pass remains to be seen. But there are actions you can take now:
- Tell your legislators to oppose bills (like S. 838) that would strip the EPA of authority to regulate ammunition and fishing tackle.
- If you hunt, switch to nontoxic ammunition.
- If you fish, switch to nontoxic sinkers and jigheads.
- If you know sportsmen, show them this article.

Comments

As a big game hunter, I used

As a big game hunter, I used conventional lead-core ammunition for years until I learned more from a US Park Service video about the extent to which lead-core bullets shatter and leave fragments in both the carcass and the meat. I have obtained lead-free ammunition and now use it exclusively for hunting, which I am able to do because 1) I have enough money; and 2) both of my hunting rifles are in common calibers for which lead-free ammunition is available. I do not currently load my own.

Though I support Williams' concerns about the dangers posed by hunting with lead-core rifle bullets, I think Williams glosses over real issues in a way that is not constructive.

First, ammunition companies must develop new loads using the copper bullets. Doing this is not just a question of slapping a copper bullet into a load developed for lead bullets. The copper bullets, being harder, less flexible, and longer (for a given weight), behave differently in the bore of a rifle. New loads, usually using different powders, have to be developed carefully to stay within the pressure specifications for each cartridge. There are close to a hundred different hunting cartridges, and it will take time for manufacturers to develop copper loads for the less-common calibers. Just to pick one manufacturer, Remington sells cartridges for 64 different rifle chamberings, and of these only 8 of the most commonly used are available with lead-free bullets. Other manufacturers have similar or even scantier offerings. Thus implementation of a ban on hunting with copper will be a matter of several years and will involve real development and distribution costs for the manufacturers.

Second, the copper ammunition is substantially more expensive. Williams notes the rather small difference in price between the bullets themselves (sold separately for those who load their own ammunition). The difference for the factory-loaded ammunition is much greater, reflecting development costs, expensive materials, and lower production volumes. The lowest priced hunting ammunition in 30-06 (the most common hunting caliber in the US) runs about $18.00 for 20 rounds. Lead-free ammunition runs over $40 for 20 rounds. Costs will decline as volumes increase, but copper is very expensive right now, to the point that thieves strip copper from empty buildings to sell on the salvage market. This is unlikely to change given global demand for copper. I find that I need to fire least 20 rounds per year of the specific ammunition I hunt with, to ensure that my rifle sights are correctly adjusted for the specific round used. Williams' glib statement that ten rounds is more than most hunters need to fire in a season is hogwash. If you fire 20 rounds, you need to buy two boxes so as to have ammunition left to actually hunt with. The cost issue is a real one, and no amount of mocking of extremist statements on NRA blogs will make that fact go away.

Third, some rifles do not shoot with acceptable accuracy with copper ammunition. The bullets are harder, and they don't conform well to an imperfect bore. I have had (and sold) two rifles that simply would not shoot copper bullet ammunition with the accuracy needed to hunt safely and responsibly. If lead core ammunition is banned for hunting, many thousands of hunting rifles will become junk. That's a real cost, and needs to be acknowledged.

Fourth, while copper rifle bullets perform well in the field, steel shot for shotguns is not equivalent to lead. Williams compares the negligible cost difference between 20 gauge shells with lead v. steel shot, but these are not equivalent in the field. Steel shot of equal diameter has a significantly shorter effective range, and Williams' comparison is misleading. There are alternatives such as bismuth and tungsten shot, but these shells are extremely expensive.

Finally, the studies on venison harvested by hunters showed that in states were hunters used low-velocity lead ammunition (typically Eastern states were deer hunting is restricted to shotguns firing slugs or buckshot), there were no lead fragments found in meat. Slow-moving, heavy slugs that do not fragment pose little if any danger to wildlife: no bird is going to ingest a 500 grain slug. Only high velocity rifle bullets shatter into fragments. So any restriction on the use of lead for big game hunting could be limited to high velocity rifles, leaving the slug-guns and traditional black powder rifles (which also fire slow moving, heavy projectiles) unaffected.

We are more likely to get the regulation we need (a ban on hunting with lead-core high velocity rifle bullets) if these complexities are acknowledged. Williams' column too often slips into stereotyping and glossing over the real practical and cost issues.

We need to remember that

We need to remember that just because a group like the CBD petitioned for the ban on lead doesn’t mean we shouldn’t have one. Yes, the CBD is extreme and irrational and, as often as not part of the problem rather than the solution. But even a broken clock is right twice a day. Where the CBD was right is by stating that we need to ban lead for hunting ammo and for fishing weights small enough for birds to swallow. Where the CBD was wrong was by ignoring the advice of the American Bird Conservancy and petitioning for a ban on everything--no exceptions for outdoor or indoor target shooting, deep-sea sinkers so big ostriches couldn’t swallow them, or even military ammo. This way the CBD guaranteed that its petition would be DOA and ensured that any federal control of lead would become virtually impossible. Now, predictably, it is suing the EPA.

A few years ago, I began to

A few years ago, I began to notice CBD in the news, mostly associated with various environmental lawsuits. Curious, I went to their website and looked at their staff listing. The bulk were lawyers.

I don't know why I was suprised, but I was. Maybe I thought there should have been a listing of folks with PhD's in Environmental Sciences or something. I'm sure there is, but what I saw was lawyers.

Then came the Delta Smelt fiasco, where CA had shut off a good junk of water to the state to preserve a smelt. I didn't really have a sense of the impact that caused until I drove through the San Joaquin valley last year.

Mile after mile of farms lay fallow, abandoned orchards and signs screaming, give us water and we can feed the nation. Farmers were broke and out of work. Lots of them.

It seems that CBD doesn't really care about the human fallout of their actions and that bothers me. It makes me suspcious. I'm for the animals, but not too the point it destroys livelyhood, families and the economy.

Now when I read an news article where a CBDlawsuit comes up, I know that nothing good can come of it. I now rank CBD, in my own mind, as a eco-extremist orginization, in the same class as HSUS, ALF, and maybe PETA. Granted, better lawyers, but since when is that an endorsement.

I distrust CBD when it comes to their efforts to ban lead ammuntion. The Center for Disease Control is the world's premier Public Health Orginzation and when they tell me in their reports, no significant health effects. I believe them, because they have no agenda. I can't say the same for CBD.

I'd like to encourage folks

I'd like to encourage folks to read our petition, available here: http://www.biologicaldiversity.org/campaigns/get_the_lead_out/pdfs/Final.... Although it's now almost a year old, it contains a fairly up-to-date list of peer-reviewed scientific articles (most of which are available on the web) that exhaustively demonstrate the problems with lead ammunition for both wildlife and humans. Studies confirming our arguments continue to be released; check our website for links to those.

The science regarding impacts of hunter-shot lead ammunition on humans is still very young, but it's already quite convincing. The fact is that harmful levels of lead can be and are consumed by people who eat hunter-shot game meat. Studies showing the long-term impacts of this consumption will take some time, but it is foolish to prejudge those studies and declare that there are no impacts whatsover. What I don't understand is, given the clearly demonstrated pathway for consumption of lead particles, why would hunters still want to take the risk--especially with children?

Regarding the difference between hunting ammunition and shooting-range, military, and law enforcement ammo: once the EPA's authority to regulate lead ammo is confirmed, the agency will engage in a public process to craft appropriate regulations. If some uses of lead ammunition have no harmful impacts on wildlife or humans, then obviously those uses shouldn't be regulated. It might not be as easy as folks think, though: sport shooters know well that indoor shooting ranges have many problems trying to ventilate and filter the lead dust they create. Many law enforcement agencies have switched to non-lead ammo for exactly that reason.

And one concern that we should all consider is that creating a "hunting" ammo category that is non-lead and a "sport" category that is leaded might be counterproductive, as it might make it too easy for folks to just ignore the regulations and use the "sport" ammo for all of their hunting, which would not solve the problem and would not help the cost and availability issues, either.

We recognize that there needs to be improvement in the price and availability of non-lead ammo; increasing the demand will accomplish this, and effective regulations are the best way to increase the demand.

Finally, the authors of the petition, including the Center for Biological Diversity, are not anti-hunting. There are hunters on our petition and our lawsuit, and we've received a lot of support from hunters across the country for our efforts. In fact, eliminating or reducing hunting would hurt our efforts to protect endangered species; a good example is the California condor, which is absolutely dependent on hunters for its wild food supply. We want hunters to keep producing gut piles and injured animals that condors feed on--we just want those food supplies to be safe for the species.

Adam Keats
Center for Biological Diversity

I've read and re-read the

I've read and re-read the petition. To be honest, it shattered the last of the wavering faith I had in the CBD's credibility as a progressive organization.

The misinformation and misleading hyperbole it contains reek of nothing less than a frustrated agenda. The fact that the challenge has been taken to the EPA, instead of the USFWS (where it more rightly belongs) illustrates the depths of that frustration... and even there, with a presumed "pro-environmentalist" at its head, the EPA denied the justification of your petition. There is no value to your argument.

There is absolutely NO justification for a general ban on lead ammunition. With the debatable exception of the California Condor, no species is threatened, including humans. Perhaps the medical research is still relatively "young", but the record is not. Lead poisoning from ingested bullet fragments or shot does not happen. The research has shown that even subsistence hunters (First Nation Cree) who have lived a lifetime eating lead-killed game show no indication of related lead-toxicity.

Factual education on this topic would have gone a long way toward turning some opinion, by the way. Get people thinking and making their own choices. Instead, the 800 pound gorillas of the CBD and NRA have faced off to turn this into a political donnybrook, and the first casualty has been the truth.

There's nothing wrong with pointing out to people that by eating lead-killed game, they may be exposing themselves, their families, and their friends to lead particles. But along with that, share the truth that there's no evidence that this exposure is particularly harmful. For those in the "Pound of prevention..." school, they can switch. But not switching is a legitimate choice as well.

There's nothing wrong with saying, "hey, some of the birds that feed on the offal that hunters leave in the woods may be sickened by lead toxicity."

But with that, include the fact that these deaths are not threatening the survival of the species and would probably go unremarked if not for the current volatility of the lead ammo issue.

Those individuals can then make an informed choice. But it should still be a choice, in the same way that it's a choice to drive a hybrid instead of a gas guzzler, or in the same way that it's a choice to drink alcohol or eat processed food products.

You can't justify a ban on lead ammunition simply because it hurts a few birds (or even a few million in the big picture). You can't justify it because a 90 year-old subsistence hunter showed slight lead deposits in his teeth and hair after a lifetime of consuming lead-shot game. If these were the criteria for a federal ban, then we'd have to put an end to pretty much every human endeavor from driving to agriculture.

Instead of trying to force an unjustified ban, focus on education and mitigation. Encourage hunters to remove the offal from the field, or bury it where scavenger birds can't get to it. Teach about other ways to minimize lead exposure, such as the use of bonded bullets, shotgun slugs, and muzzleloader bullets. Research has shown, several times, that some lead bullets present bigger risks than others.

Take the route of North Dakota and Minnesota, and provide educational material to commercial and private processors about how to minimize lead fragments in meat during the butchering and packaging process.

And of course, be honest about the fact that the vast majority of ammunition affected by such a ban is not used for hunting at all. It doesn't play into any of the scenarios addressed in the public conversation (risks to scavengers or humans from ingesting fragments in meat), yet it would be banned as well... forcing millions of gun owners to replace their ammunition with more expensive lead-free products IF THEY ARE AVAILABLE. For those who can't find lead-free ammo... what then? Wait a decade or more for the industry to get to them?

Raise people's consciousness to the level where there is a voluntary movement away from lead, and let the market lead the industry. You won't see 100% compliance, but I'll argue that 100% compliance is not necessary.

The proposition that the

The proposition that the alternative materials for projectiles, including copper, tungsten, steel, bismuth and zinc, are suitable due to claims on nontoxicity is not factual when other agencies actions are taken into account.

The National Park Service banned the use of tungsten projectiles in 2006, due to environmental cleanup concerns and the kinds of toxicity that the Department of Defense noted in ground water studies at Fort Edwards, Massachusetts. Newer research shows potential tungsten toxicity in kidney tissue and bone samples in mice, as well as carcinogenicity of tungsten fragments in wounds left untreated in test animals.

Copper is being banned or regulated as a toxic metal of concern for a number of uses. For example, Washington State and California have both banned the use of copper in brake pad linings, due to impacts on riparian environments such as Calleguas Creek in Ventura County, California. Condor mortalities related to elevated levels of copper have been documented in necropsies performed at under the general oversight of the US Fish & Wildlife Service as well.

While steel shot is usually held up as a "nontoxic", iron is a metal of concern in the Moshannon Creek watershed leading to the Susqehanna and the Chesapeake Bay. These last are currently under enhanced EPA oversight due to water quality problems in Chesapeake Bay. Other watershed with elevated iron levels will likely reveal themselves to the public at large.

Bismuth "poisoning" is a long held fact in medicine, with only dosages related to "sublethal" effects to be determined under existing protocols and criterion.

No honest birder that I know will deny the potential for toxicity of zinc to avians, despite the USFWS approval of zinc plated shot for waterfowl use.

As such, the various claims by the "anti-lead" forces do not follow facts, nor the material that can be gained by public records requests as to certain scientists and certain Endangered Species Program Cooperators are saying behind closed doors.

That these anti-lead forces continue to refuse to provide much of the raw data that they make their claims on, to the point of litigation, only highlights the how questionable some of their claims may be viewed by a skeptical public.

Those who are skeptical remain determined to acquire that raw data, knowing full well that past data acquisition efforts have revealed studies based on deleted data and special interest opposition to hunting and shooting sports.

I am a hunter who has

I am a hunter who has switched to non-lead for everything where it's not required because I CAN. I shoot a 12-gauge shotgun and a .270 rifle and substitutes are widely available. Because I have a good job, I can afford to pay more, and consider this one of those steps that I make to try to minimize harm I may cause.

But I am in Phillip's camp on this. While I can be brought to tears by a lead-poisoned raptor (which is, incidentally, precisely why I switched), we have to develop regulations to protect species, not individuals. If the latter is what we'd like to do, perhaps we should start by banning cars, which kill a ridiculous number of wild animals daily for nothing more than our convenience.

It's interesting to be reading this today, because I've been corresponding over the past few days with a hunter who would really like to switch to non-toxic, but he can't find 20 gauge 2 1/2-inch non-toxic shells (I think he said there was maybe one option available, for $65). He can't afford that, and her certainly can't afford new guns, so a lead ban would literally disarm him.

I'm not a fan of the pro-lead rhetoric. I do not believe that MOST people concerned about lead are anti-hunting and anti-gun. But the impacts of a ban would be very real, and I find it somewhat offensive that the concerns of a minority group - hunters - are so readily dismissed when the rest of the population inflicts collateral damage on wildlife daily without consequence.

Alex said "I was easily able

Alex said "I was easily able to find inexpensive lead-free shot for my primary rifle, an AR-15..."
Yeah right...

Frank, You mix so many

Frank,

You mix so many apples and oranges together, its hard to know where to start.

The lead banned in consumer products like gasoline and paint were inorganic lead compounds, not elemental lead as found in ammunition. The inorganic compounds are much more readily absorbed in the blood stream than elemental lead. Apples vs oranges.

You paint of a picture of a hunter indescriminately blasting the landscape with tonnes of lead, when this is far from reality. In my personal experience, I rarely take more than 3 shots per year while big game hunting. The truth it, most hunters are unsuccessful. The success rate in California for deer hunters hovers around 18%. That's really not that much lead going into the environment compared to the wheel weights littering our nations highways. 80% of the lead produced goes into lead acid batteries, not ammunition

As for lead-free ammuntion, its a matter of performance, cost and availability. There have some serious performace problems reported with lead-free ammuntion, ie. wounded and lost game. It's not fair to the animal or the hunter to use sub-standard ammuntion while hunting.

Cost: My ammunition went from $18 to $45 overnight. My practice time obviously suffered and that also is an ethics issue while hunting. Believe me, at around $2.20 per bullet, there's not much practice. My 12 ga copper slugs are $3 EACH.

Availablity: Honestly, there really isn't that many calibers available in lead free. Hunting is a family/social thing. Many people hunt with grandpas gun and suddenly there's aren't any bullets available. I have a hunting rifle thats been in the family four generations, 106 years. The have used that rifle to take countless deer. No more, lead-free ammo not available in that caliber.

I admire AZ's approach to lead ammunition, its a choice there and the state makes it an attractive choice, discount ammuntion, hunter eductation programs and other perks. It's not force fed.

If lead-free was as good, as available and at a reasonable price, the bulk of the hunting community would be onboard.

When the hunting community sees information published in articles that cherry picks data and statements from studies, thats disingenuous.

I read the story and comment

I read the story and comment posted on this debate. I am impressed with Lawrence G. Keane words. There are so many good points he told in the comments.

Thanks
Peter Pal Disuja

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Mr. Loughlin states as fact,

Mr. Loughlin states as fact, a point that's been under contention. It has been argued more than once that the Toxic Substances Control Act does not prevent the EPA from regulating components/hazardous substances within ammunition, despite a strong argument from the NRA that it does.

Beyond that, Mr. Loughlin makes an error of logic in suggesting that lead ammo not be regulated because "all of the birds Williams mentions are doing very well, despite over a century of lead ammunition use." That does not address the very real issue of ancillary damage which may not be attributed to lead as the article states. And that statement in no way proves that animals are not harmed by lead. It reasons that by numbers alone we are to deduce that animals are not harmed by lead. Statistically speaking, how many children died from ingesting lead paint before its regulation? If one were to judge the impacts of lead on human populations, the numbers wouldn't suggest any health effects either.

Furthermore, I find the hunters' argument in favor of lead ammo to be spurious at best, disingenuous at worst. It's well known that hunters fear the lead issue because of the viability of this argument in the hands of anti-hunters. But just because the issue may or may not be used as an argument against hunting doesn't take away the fact that lead does affect humans and animals both. Lead is regulated in other consumer products, from paints to gasoline, and I find it incomprehensible that lead so readily dispersed into the environment as ammunition, wouldn't be held to the same regulation. There are plenty of hunters and hunters groups who vocally advocate against lead, based on what they've learned about this environmental and health hazard.

Frankly, it dilutes the support I have for hunters when they refuse to accede a point like this. Suitable alternatives to lead ammo exist and are getting better, in spite of the fact that, yes, it has taken time to perfect non-lead options. A fight for something that causes harm to the wildlife and resources hunters purport to cherish and support -- when the lead simply isn't necessary -- falls flat on my ears.

Fritz, What I state as fact

Fritz,

What I state as fact has, in fact, been upheld. Even the EPA concedes that the current law prohibits them from regulating ammunition components. The CBD does as well, hence the suit to overturn the provision.

There is also no error of logic in my argument re: the number of birds dying from lead bullet fragments and shot. The EPA's role is not to protect individuals of any species, or they would, in truth, be forced to restrict almost all human activity including motorized transportation, power generation, livestock grazing, and more than I can even begin to list.

I did not deny that some birds are dying and lead ammo is the probably culprit. The point is "acceptable losses", and the truth is that the relatively small number of birds dying from ingestion of lead ammo particles is a tiny and irrelevant fraction of the total population. This is why the EPA rejected the initial request by the CBD to ban lead ammo and fishing tackle. There is no cause. No population is threatened, and indeed, while the huge numbers put forth by the CBD and their cohorts are largely inflated extrapolations based on nothing more (in most cases) than guesswork and bias, the truth is that they do no represent a threat to the populations of birds in question.

Should we be concerned even about the individuals of the species that are dying because of lead? Sure. And many hunters are. Some are voluntarily switching to lead-free for that very reason. Others would switch if they could, but either availability or price is holding them back.

I must point out that this isn't just about hunting either. The proposed ban on lead ammunition includes ALL ammunition for ALL purposes. While the cost of lead-free may not inhibit the hunter who won't shoot 20 rounds in a year, it will have huge repercussions for the trap and target shooters who go through thousands of rounds. There is also the question of law enforcement and military uses (although the most current proposal from the CBD suggests an exemption). The truth is that, even with lead ammunition, availability has been somewhat limited over the past few years. A ban, even phased, would severely ihibit supply.

If lead ammo were truly the environmental bane that some have declared, then perhaps these negative impacts would be an acceptable result. It's worth it to protect species from extermination, or to avoid the poisoning of ourselves and our children. But with the possible exception of the condor, no species is threatened by lead ammo, and there is no human health risk.

As Dan points out, the lead compounds that were regulated in gasoline additives and paint is far different than the metallic lead used in bullets and shot. It is not easily absorbed by the human digestive tract, and even when lead levels have increased, further research has shown that it appears to disperse relatively quickly. Nevertheless, the facts remain that there is no demonstrable human health risk from the ingestion of lead bullet particles or shot pellets. Is there reason for concern? I don't fault any individual for choosing to think so, and adjusting his or her behavior accordingly. But the science suggests that such changes are probably not necessary.

It is unfortunate that some hunters and shooters have become so vocally opposed to lead ammunition as to join in the movement to ban it. They've been sold a bill of goods, which isn't hard to do these days. The CBD and HSUS have very powerful propaganda machines, and people (hunters or not) are quite susceptible to fear-mongering and manipulation of the truth. It is telling that, in my experience, within a few minutes of a reasonable, factual discussion with most anti-lead hunters, their conviction wavers and they realize that what they've taken for truth is actually misinformation.

The bottom line is that nothing in the current body of research on either wildlife or human health supports the need for an outright ban on lead... either in ammunition or in fishing tackle. Switching to lead alternatives is, and should remain, an individual decision. I think it's a good decision, and it's one I've personally adopted (for the most part), but it's not one that the government should make for us.

I beg to differ from those

I beg to differ from those who support a pro-lead agenda.

First, I am the hardest-line pro gun advocate that one would find. So, I would hope not to be labeled by own party and others in the pro-gun lobby as a leftist or any other moniker.

However, as an avid sportsman and lifetime NRA member, I personally have grown increasingly uncomfortable with using lead ammunition. My concern started with the lead issue in wildlife, but then moved to the practical realization that every time I went shooting, I was inhaling the stuff and getting it all over myself in the form of lead dust. This meant that I was bringing it home to my kids, on the sofa, in the car, etc. While perhaps not a major, serious health concern, I also do know several heavy shooters who have been diagnosed with lead poisoning.

Lead is a bit different than other bad chemicals (like, for example, pesticides), in that it has no half life. It just sits there in the body, or wherever it lands. It can be cancer causing (although I doubt it's a huge issue), but why take the chance?

So I started to move to lead-free alternatives, starting with a lead alternative (bismuth) with my shotgun, and then moved to lead-free in the rest of my guns. I was easily able to find inexpensive lead-free shot for my primary rifle, an AR-15, but even my .38. As far as fishing, I've also done the same. When you fish and handle the lead weights, you're getting the stuff on your hands, which goes directly into the bloodstream.

Incidentally, cleaning a gun after shooting with lead-free I have found to be a breeze. It's way, way cleaner shooting. I just don't get the big deal.

The National Shooting Sports

The National Shooting Sports Foundation (NSSF), the trade association for the firearms, ammunition, hunting and shooting sports industry, opposes efforts to ban or restrict the use of traditional ammunition containing lead components for use in hunting or shooting unless there is sound science conclusively establishing that the use of traditional ammunition is causing an adverse impact on a wildlife population, the environment or on the human health of those consuming game harvested with traditional ammunition, and that other reasonable measures, short of restricting or banning the product, cannot be undertaken to adequately address the concern.

Recently, some have falsely claimed that the use of traditional ammunition poses a danger to (1) wildlife, in particular raptors such as bald eagles, that may feed on entrails or unrecovered game left in the field and (2) that there is a human health risk from consuming game harvested using traditional ammunition. Some also wrongly claim that the use of traditional ammunition at shooting ranges amounts, in essence, to polluting the environment, even though the U.S. Environmental Protection Agency does not consider expended ammunition at shooting ranges to be a problem.

Wildlife Populations

Wildlife management policy is based on managing population impacts, not on preventing isolated instances of harm to specific individual animals in a species. Absent sound scientific evidence demonstrating a population impact caused by the use of traditional ammunition, there is no justification for restricting or banning its use.

With very limited exceptions, such as waterfowl and possibly the California condor -- where the evidence of a causal connection to spent ammunition fragments is far from conclusive, there is simply no sound scientific evidence that the use by hunters of traditional ammunition is causing harm to wildlife populations. In the case of raptors, there is a total lack of any scientific evidence of a population impact. In fact, just the opposite is true. Hunters have long used traditional ammunition, yet raptor populations have significantly increased all across North America -- a trend that shows no sign of letting up. If the use of traditional ammunition was the threat to raptor populations some make it out to be, these populations would not be soaring as they are.

Benefits of Traditional Ammunition and Threats if a Ban Occurs

The excise tax dollars (11 percent) manufacturers pay on the sale of ammunition -- the very ammunition some groups choose to demonize -- is the primary source of wildlife conservation funding in the United States and the financial backbone of the North American Model of wildlife conservation. The bald eagle's recovery, a truly great conservation success story, was made possible and funded by hunters using traditional ammunition. In fact, recent statistics from the United States Fish and Wildlife Service show that from 1981 to 2006 the number of breeding pairs of bald eagles in the United States increased 724 percent. And much like the bald eagle, raptor populations throughout the United States are soaring.

Needlessly restricting or banning traditional ammunition absent sound science will hurt wildlife conservation efforts as fewer hunters take to the field thereby undercutting financial wildlife management resources.

Alternatives to traditional ammunition are not practical. The higher costs associated with this ammunition will price everyday consumes out of the market. This is evidenced by the low 1 percent market share of metallic nontraditional ammunition -- the higher cost is simply not justified.

Consuming Game Harvested with Traditional Ammunition

For more than a century, hundreds of millions of Americans have safely consumed game harvested using traditional hunting ammunition. Yet, in 2008, when a dermatologist from North Dakota who is on the board of the Peregrine Fund -- a group whose stated mission it is to ban the use of traditional ammunition for hunting -- claimed to have collected from food pantries packages of venison that contained fragments from lead bullets, many people became concerned and some officials overreacted to the allegations made at the time that this proved that consuming game harvested with traditional ammunition posed a human health risk.

North Dakota failed to conduct its own study. Instead, they merely accepted the lead-contaminated samples hand-picked by the dermatologist and submitted those samples to a lab in Iowa for testing. Based on those test results, North Dakota health officials ordered state food pantries to destroy all donated venison and to stop accepting further donations. The Iowa lab official in charge of the testing, Rick Kelly, was highly critical of North Dakota, "I think North Dakota is drawing the wrong conclusions. We did what they asked, but they did not take an arbitrary sample."

To put this issue in perspective, consider this statement from the Iowa Department of Public Health (IDPH), a state agency that has tested the blood lead level of Iowa residents for over 15 years: "IDPH maintains that if lead in venison were a serious health risk, it would likely have surfaced within extensive blood lead testing since 1992 with 500,000 youth under 6 and 25,000 adults having been screened." Iowa has never had a case of a hunter having elevated lead levels caused by consuming harvested game.

CDC Results

A study from 2008 by the U.S. Centers for Disease Control and Prevention (CDC) on blood lead levels of North Dakota hunters confirmed that consuming game harvested with traditional ammunition does not pose a human health risk. Calls to ban or restrict the product by groups opposed to traditional ammunition, like the Peregrine Fund, and anti-hunting groups, like the Humane Society of the United States (HSUS), are scientifically unfounded and nothing more than a scare tactic to advance their political agenda. In looking more closely at the CDC study results, perhaps most telling is the fact that the average lead level of the hunters tested was lower than that of the average American. In other words, if you were to randomly pick someone on the street, chances are they would have a higher blood lead level than the hunters in this study.

The Toxic Substance Control Act

The Toxic Substance Control Act (TSCA) expressly exempts ammunition from the oversight of the Environmental Protection Agency. However, this exemption is now being challenged by antihunting groups in court. Because of this, members of the firearms industry are urging members of Congress to support legislation S.838 and HR 1558 that would clarify Congress' original intent to exempt ammunition.

A ban on traditional ammunition will affect not only hunters and sportsmen, but also law enforcement, military and target shooters who may never go afield. Passing an amendment that will necessarily lessen the military and law enforcements ability to train puts the safety and well-being of all Americans at risk.

I just reviewed the CDC

I just reviewed the CDC study of the blood leads from the North Dakota study and your article is misleading. Honestly, I would have expected the Audubon to report the facts.

What CDC said was people that consumed game taken with lead ammuntion had a slightly elevated blood lead (0.3 ug/dl) than those that had not consumed lead shot game. Slightly elevated above the normal background lead found in most people. But not anywhere near a level to cause an adverse health problem.

Mr Williams obviously also has NOT priced lead-free ammuntion, it is neither cheap or readily available. On the average, a single lead-free bullet cost $2.20 or around $45 for 20 shells, and is still not available for many calibers.

This isn't what most folks

This isn't what most folks who read Audubon want to hear or believe, but the truth of the matter is that the EPA has no place regulating ammunition, lead or otherwise. They are barred by federal law from restricting ammunition or fishing tackle already. S838 only re-affirms this restriction.

With the exception of the condor, there is no threat to populations of birds or wildlife due to spent lead shot or bullets. All of the birds Williams mentions are doing very well, despite over a century of lead ammunition use. And if there were a threat to wildlife, the US Fish and Wildlife Service has jurisdiction to mitigate it, not the EPA. The EPA is being targeted here because it is the low-hanging fruit for the Center For Biological Diversity and other plaintiffs in this case. The agency is headed by a presidential appointee who is no friend to hunters and gun owners. The people behind this anti-lead movement are not stupid.

Likewise, there is no health threat to humans. I wish previously credible sources like Audubon would stop perpetuating this untruth. No research has shown any connection between lead ammunition and human health problems. There is not a single record of lead toxicity related to ingestion of bullet fragments or lead shot pellets. Not one.

Is lead perfect? No. It does kill individual birds that have ingested it from carcasses. I won't deny that, and no one with the slightest bit of current information on this topic will either. None of us hunters wants that outcome.

As hunters learn more about this situation, many of them are voluntarily making the change to lead-free when they can. This is a good thing. But voluntary is exactly what this change needs to be right now.

For many hunters, there is no lead-free option. It is another myth, perpetuated by individuals like Williams, that lead-free alternatives are "widely available" and "affordable." This is patently untrue, and easy enough to document should anyone bother to try.

Except for the most common chamberings (calibers and gauges), lead-free ammunition is very difficult to find... especially factory-made cartridges. For literally millions of firearms in the homes of millions of hunters and shooters, there is absolutely no factory-made, lead free ammunition available. A ban would, effectively take all of these firearms out of commission. This is why so many people believe the lead ammo ban is a gun ban.

Supplies for even the popular calibers are limited, with a resultant high cost. This is simple economics.

OK,sure, I can hear the argument... simple economics also dictates that, as demand increases so will supply. The industry will change if it has to. This may be true, but changing the ammunition industry this drastically is not quite as simple as people would like to believe. Lead has properties that are difficult to duplicate with other metals. Firearms technology has evolved around these properties, so just replacing a bullet with another metal doesn't work.

I could go on, but the point is that the solution is not banning lead ammunition. Education, using FACTS instead of myths, will help more hunters make the best decisions. And for those involved in this discussion who know nothing about guns or hunting need some education too... and by that I mean real education. Not the ranting of an egoist like Ted Williams.

Maybe the time will come when lead ammo can be realistically phased out of existence. But the time is not now.