The Industry position on lead in ammunition

The Industry position on lead in ammunition
The ammunition industry is committed to guarantee a sustainable future, enabling hunters and
shooters to continue their activities safeguarding environment and human health in compliance
with the existing legislation.
In this framework lead metal is and remains the basic substance for producing projectiles and
shots, because:
* the lead metal parameters, specifically density, malleability and hardness, can guarantee a
perfect combination of effectiveness and safety, as no other material can do;
* the lead used in projectiles and shots is in metal form; unlike compounds, intermediates, oxides
and so on, this form has a less than marginal impact on both environment and human health;
* there are no scientifically based eco-toxicological research results in favour of the use in
ammunition of material different from lead.
Producers are anyway proposing to users a range of products which includes ammunition using
different types of materials, designed and manufactured for specific niches of utilisation.
Aware that lead free doesn’t mean “problem-free”, the industry proposes new materials only if and
when they ensure the performances requested to ammo and are, at the same time, sustainable for
the environment, the users and the industry itself.
Be professional when talking about lead in ammunition
The use of lead in ammunition has been accepted without requesting any limitation by the
European Chemical Agency (ECHA) on the basis of an extensive dossier presented by the
Industry in 2010 within the REACH process, which is recognized as the most stringent regulations
regarding the use of chemical substances in Europe.
Consequently, no EU Directives and Regulations today are limiting any use of lead metal in
ammunition. Only local restrictions are in place, frequently decided without clearly distinguishing
facts & figures by ideologies & emotions.
Impact of lead on environment
Lead in ammunition is unlikely to be a poisonous source in wildlife. It is a metal that becomes
available only under certain circumstances, as opposed to the compound form which is easily
soluble and therefore bio-available to wildlife.
Specifically referring to wildlife health, an exposure scenario regarding the effects of lead shots
ingested by birds and mammals on their population level has been included in the Lead Reach
Dossier. The conclusions show that although it was observed the poisoning of individual animals,
there is no evidence of impact onto the “life trend” of the populations.
Impact of lead on human health
Only bio-available lead can be absorbed by the human body, when ingested.
Lead coming from ammo projectiles and bullets, even if ingested in fine fragments, cannot be
absorbed directly by the human body because is in metallic form.
A recent Swedish study demonstrates that only less than 1% of lead metal fragments, eventually
ingested by persons eating game meat is converted to ionic form and absorbed by human tissues.
Moreover the lead fragments in game meat are concentrated in areas regularly and completely
eliminated with the usual practices of slaughter.
All food, water, soft drinks, tea, coffee, alcoholic drinks, food supplements contain bio-available
lead ions in varying amounts: the European Food Safety Authority 2012 report asserts that “are
foods consumed in the largest quantities like grains, milk products, vegetables, tap water that
have the greatest impact on lead dietary exposure”.
Positive results recently achieved
The ban of lead in hunting ammo requested by the Convention on the Migratory Species (CMS)
is not binding.
On November 2014 the CMS Conference of Parties was called to vote a proposal asking the
phase-out of lead in ammunition across all habitats, wetland and terrestrial and its replacement
with non-toxic alternatives within the next three years.
The text of the original Resolution was modified, allowing each State to determine “whether or how
to implement” the guidelines regarding the possible ban of lead in hunting ammunition. In addition
it was decided that from now on the Industry will be recognised as stakeholder in all future CMS
meetings dealing with the lead in ammo issues.
The ban on lead in hunting has been cancelled in Norway.
On February 3rd 2015, with the consistent majority of 79 votes in favour and 16 against the
Norwegian Parliament voted to reintroduce, after a ten years ban, lead shots for hunting outside
The result was obtained demonstrating that non-lead ammunition does not work as cleanly and as
efficiently as lead, and therefore causes unnecessary suffering to animals and risks to hunters.
Moreover, it was highlighted that the potential adverse effects on health and the environment of
these materials were not studied at all in details.
The Metallic Lead Harmonized Classification as toxic substance process has been suspended.
The EU Risk Assessment Working Group of 5th February 2015 decided to suspend the
classification of lead as repro-toxic substance, confirming that no further decisions will be taken on
the issue until scientific evidences based on new hazard assessment methods will be available.
The decision is based on two arguments:
* it is not appropriate to classify all forms of lead as toxic because the bioavailability of massive
metal is not the same as that of others forms, in particular powder;
* the Specific Concentration Limit requested for the classification is unrealistic and inconsistent
with the existing EU legislation on risks management.
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