ECHA

ECHA is currently collecting information and evidence about the use of lead in ammunition for hunting and sports shooting, as well as in fishing. The investigation focuses on the potential risks that these uses pose to human health and the environment, and what measures can be taken to control them. The Agency’s findings and recommendation will be available in the autumn.

Setting the scene

The current investigation on lead uses is one of three EU-level actions initiated to reduce the exposure of humans, wildlife and the environment to lead.

First, in December 2015, the European Commission requested ECHA to investigate the risks that might be posed by the use of lead gunshot in wetlands. This investigation led to a restriction proposal which was supported by ECHA’s scientific committees and, at the moment, awaits a conclusion by Member States in the European Commission’s REACH Committee. If adopted, the restriction would provide the same level of protection for wetlands and wildlife across the whole EU as is already implemented through the African Eurasian Waterbirds Agreement (AEWA) in some EU countries.

Christiaan Logtmeijer. Image: ECHA.

“It is also important to understand that proposing a restriction does not necessarily mean a ban. A restriction can be any kind of condition on the use of a substance that is seen necessary to mitigate the risks.”

The second action also began in December 2015, when the Commission asked ECHA to additionally assess if there was a need to further control the use of lead in ammunition outside of wetlands, as well as in fishing. “We did our assessment and concluded that there is sufficient evidence to justify further measures to regulate the use of lead in ammunition and fishing. The Commission took our conclusions on board and asked us, in July 2019, to start preparing an EU-wide restriction proposal for these types of lead uses,” says Christiaan Logtmeijer, a Scientific Officer at ECHA responsible for coordinating the project.

And so the third action started in October 2019, when ECHA kicked off the REACH restriction process by announcing its intention and organising a call for evidence for stakeholders. The Agency also broadcast an online information session explaining the scope and what sort of information it is looking for. “We received information from almost 400 organisations or people from 24 different countries. The information received through the call for evidence and our earlier assessment will form the basis for our work,” Mr Logtmeijer says. Once an intention is submitted, ECHA has one year to build a potential restriction proposal.

Broad scope

The diversity of technical requirements and conditions of use for ammunition makes the job challenging. “We have many technical and economic issues to consider, for example, the incidence and severity of lead poisoning in wildlife in the EU as well as the performance and cost of alternatives to lead in different types of hunting and sports shooting ammunition,” says Peter Simpson, a Senior Scientific Officer at ECHA.

On the other side of the coin is the undisputed fact that lead is a well-known toxic substance and that reducing exposure to it can have many benefits. “The potential benefits could be, for example, better quality game meat and drinking water as well as preserving biodiversity,” says Mr Simpson.

The intention is not to stop hunting, sports shooting or fishing. “Our job is to establish if there are risks from the use of lead in these different activities and, if so, to explore how effective a regulation could be to control those risks and what the wider impacts of a regulation on different elements of society would be. We are interested in whether some or all of these activities could continue without lead or, with lead, but with specific risk management measures in place,” Mr Logtmeijer explains and continues, “The use of lead could continue if the risks are adequately controlled or where alternatives are not technically suitable or turn out to be too expensive. Regulation should not result in disproportionate socio-economic impacts.”

To manage the breadth of work, there are eight ECHA staff members working on different aspects of the investigation. They have expertise in human health or environmental risk assessment, impact assessment, and data modelling. The Agency is also collaborating with the European Food Safety Authority (EFSA), which holds scientific data about lead in food.

Focus on facts and evidence

Whenever the EU is seen to be infringing on individual rights or local traditions, a strong opposition rises. This topic is no exception.

“We understand that people have strong emotions for and against this work. However, ECHA remains objective, as in all our work, focusing on facts and evidence. While we are willing to listen to various views, the biggest weight will be given to those that are supported by scientifically robust data,” says Mr Logtmeijer.

Peter Simpson. Image: ECHA.

“We strive to recommend, where necessary, fit-for-purpose risk management that will effectively decrease the risks while being proportionate.”

Reaching a well-founded conclusion requires a thorough understanding of the topic being investigated, its nuances and interlinkages. This can only be achieved through open and constructive dialogue with stakeholders.

“We need extensive collaboration with our stakeholders to get to grips with the different variables. To that end, we held a workshop in February with some of the participants of the call for evidence. The opportunity to engage and discuss with them face-to-face was really appreciated,” says Mr Logtmeijer.

People, companies or organisations can also be contacted as a follow up to individual comments submitted through calls for evidence. These might open up new paths of investigation. One example of such an activity was a visit to a shooting range at the invitation of the Finnish Sports Shooting Federation. “During our visit, we were able to see in practice how lead ammunition can be captured and collected rather than being dispersed into the environment. This was a good example of risk mitigation,” Mr Logtmeijer explains.

“We’ve learnt about interesting developments through our stakeholder cooperation. For example, in the UK the major shooting and hunting organisations have expressed their wish to see an end to both lead and single-use plastics in ammunition used in shotguns within five years,” Mr Simpson adds.

Active stakeholder collaboration can also help clarify the aim of the work and avoid misunderstandings. “For our stakeholders, it is also important to understand that proposing a restriction does not necessarily mean a ban. A restriction can be any kind of condition on the use of a substance that is seen necessary to mitigate the risks,” Mr Logtmeijer says.

What next?

With four months of the preparatory period remaining, it is premature to speculate the outcome. “Our findings and recommendations can be expected in October 2020. We might propose restricting the use of lead in one or more of the applications, if the final results of our assessment indicate that there are risks that are not adequately controlled,” says Mr Logtmeijer.

If a proposal is submitted, it will move to ECHA’s scientific committees for opinion making. The decisions on REACH restrictions are always made in the European Commission by the EU Member States and scrutinised by the European Parliament and Council.

ECHA’s investigation is a balancing act between available evidence on the impacts of lead in ammunition and fishing tackle for humans and the environment and the availability and feasibility of alternative substances. “We strive to recommend, where necessary, fit-for-purpose risk management that will effectively decrease the risks while being proportionate,” Mr Simpson concludes.

Why lead?   Lead is a known toxic substance. Exposure to lead is associated with a wide range of negative health effects, including reduced fertility, developmental effects in babies and children, damage to organs through prolonged or repeated exposure, and cancer.   Current evidence suggests that there is no safe level of lead consumption.   Lead is also an environmental toxin. Lead gunshot that is dispersed into the environment or absorbed into groundwater from shooting ranges can end up in the food chain.   Around 21 000-27 000 tonnes of lead are estimated to be dispersed into the EU environment each year from the uses in the scope of the current investigation.   At the EU level, the risks related to the use of lead are managed in many ways, for example, in fuels, paints, pipes, food, pencils, jewellery and other consumer products. There is a limit value for occupational exposure to lead, which must also be observed, for example, at indoor shooting ranges.

What is ECHA investigating?   The current investigation concerns:   Lead used in gunshot for hunting birds and other animals (e.g. rabbits) in terrestrial areas (i.e. outside of wetlands). Lead used in gunshot for outdoor sports shooting, including training (e.g. clay pigeons). Lead used in bullets for hunting any animal. Lead used in bullets for outdoor sports shooting, including training (e.g. targets). Lead used in fishing tackle (weights, lures, jigs) for recreational fishing. Lead used in commercial fishing gear. Military uses of lead ammunition, along with other non-civilian uses of lead ammunition such as by police, security and customs forces, are outside the scope of the investigation. Indoor uses of lead ammunition are also excluded from the scope of the investigation.

Further information:

Hot topics – lead in shot, bullets and fishing weights

ECHA’s intention

REACH restriction process

Interview by Hanna-Kaisa Torkkeli

Published on: 28 May 2020

Top image: © Unsplash/Seth Schulte

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