Groups Seek Nationwide Ban on Traditional Lead Ammunition By Petitioning EPA

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Buckeye Dan

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Also Seeks Ban on Lead Fishing Tackle

8/5/10

This week, two environmental groups filed a petition with the U.S. Environmental Protection Agency (EPA) seeking a nationwide ban on lead ammunition and lead fishing tackle. Such a ban would drastically reduce sportsmen numbers and result in decimated funding for wildlife conservation programs due to a loss of revenue from licenses and taxes on sporting equipment.

The petition filed was filed under the Toxic Substances Control Act, which regulates dangerous chemicals, on August 3 by the Center for Biological Diversity (CBD), the American Bird Conservancy and several other groups. It claims that the use of traditional ammunition is dangerous to certain types of wildlife, including numerous birds, which scavenge on parts of game that remain in the field.

The U.S. Sportsmen’s Alliance (USSA) and other groups have repeatedly pointed out that scientific evidence connecting lead ammunition to the harm of most animal populations is inconclusive. However, there are real concerns that forcing sportsmen to purchase higher cost, non-lead ammunition will decrease the number of days spent in the field as it prices many out of the market.

“It is important for everyone to remember that the engine that drives wildlife conservation is fueled by the dollars generated by the American sportsman,” said Rob Sexton, USSA vice president for government affairs. “In fact, sportsmen contribute nearly every dime used for managing wildlife and habitat preservation from coast to coast. Given our history of over 100 years of successful wildlife conservation, you would in essence be killing the goose that laid the golden egg with this meat cleaver approach.”

Take Action! Sportsmen are encouraged to express their opposition to this petition by contacting the following Environmental Protection Agency staff. Let them know that sportsmen represent the foundation of America’s conservation movement and that this ban will result in a critical loss of funding for wildlife and other important programs:



Lisa P. Jackson
Administrator
U.S. Environmental Protection Agency
1200 Pennsylvania Ave., NW
Washington, DC 20460
(202) 564-4700
Fax: (202) 501-1450
Email: [email protected]

And

Steve Owens
Assistant Administrator, Prevention, Pesticides & Toxic Substance
U.S. Environmental Protection Agency
1200 Pennsylvania Ave., NW
Washington, DC 20460
(202) 564-2902
Fax: (202) 546-0801
Email: [email protected]


Note to mods:
Put this where it belongs and will get the most exposure if I selected the wrong forum. I highly recommend a sticky in every forum as it pertains to all things hunting and fishing.
 
Here was my e-mail to the 2 above posted people..

I am writing in regards to the current issue of the petition filed under the Toxic Substances Control Act seeking a nationwide ban on lead ammunition and lead fishing tackle. I feel it imperative to point out that sportsmen represent the foundation of America’s conservation movement and that this ban will result in a critical loss of funding for wildlife and other important programs.
Sportsmen contribute nearly every dime used for managing wildlife and habitat preservation from coast to coast and there are many of us that wish to raise our children in a fun, safe environment where hunting and fishing go hand in hand with just being close to wildlife. I ask you to take your time in considering this issue and the effects of your decision. Thank you very much for your time and consideration.

Sincerely,

[Redacted]
 
To play the devils adovacate...

Why should lead ammo and tackle not be banned?

If your bullets and fishing weights are no longer made out of lead will it really affect anything?

All I'm seeing arguing against the ban is something like "If we can't shoot lead and use it in our tackle we will stop shooting and fishing; and stop donating to wildlife conservation efforts!"

I just gotta ask why? Is lead the perfect ballistic material or something? Would the alternatives be inferior or too expensive?
 
In response to FourteenMiles - To my understanding there is not another material that can realistically be used to produce ammunition (thinking mainly of target rounds where expense and performance is the goal). The 'donations' is not the issue, it is the fact that states get their funds from money paid by sportsmen to hunt/fish/etc.
Example: Hunting permit here is $20 (roughly) I use the gun range offered by the Fish and Game protection association (which I am a member only because of the range). If I cannot afford to target shoot that $100/year does not go to the fish and game department.

If my facts/logic is flawed please feel free to correct me..

And thank you for bringing up points you believe to be common sense, too many people these days take everything at face value..
 
I just gotta ask why? Is lead the perfect ballistic material or something? Would the alternatives be inferior or too expensive?

What if tomorrow the EPA mandated that cars no longer could have steel in them. It's not that there aren't alternatives, it's that in such a short timeframe no one would be able to AFFORD the alternatives. It might be fine to make your car out of titanium, but do you want to pay for it? Are the costs of the new material worth the tradeoff?

Even today, literally decades after steel shot was mandated for waterfowl hunting, it's more expensive than standard shotgun ammo.

And no grandfathering of the millions upon millions of rounds of ammo already out in the market? So the analogy is that not only would new cars need to be steel free, but all other cars already on the road would need to be parked.

So yes, it would be extremely expensive to force this change in such a very short timeframe, which is of course the point. This is about making it more expensive to hunt so that fewer people will do it.

And also if you read the current firearm laws you will find that it's actually illegal to use many metals in ammo without potentially making it "armor piercing".

So they want to ban lead yet lead is almost a requirement to avoid the armor piercing ammo laws.

Yeah, that makes perfect sense.

The definition of AP ammo is at 18 USC sec. 921(a)(17):

"(B) The term 'armor piercing ammunition' means-

(i) a projectile or projectile core which may be used in a handgun and which is constructed entirely (excluding the presence of traces of other substances) from one or a combination of tungsten alloys, steel, iron, brass, bronze, beryllium copper, or depleted uranium; or
(ii) a full jacketed projectile larger than .22 caliber designed and intended for use in a handgun and whose jacket has a weight of more than 25 percent of the total weight of the projectile.

So that leaves what, aluminum?

The AP law does contain this:

The term 'armor piercing ammunition' does not include shotgun shot required by Federal or State environmental or game regulations for hunting purposes, a frangible projectile designed for target shooting, a projectile which the Secretary finds is primarily intended to be used for sporting purposes,

But, EPA doesn't make that decision. They can't guarantee another agency will all of a sudden declare that soft iron or copper ammo for example is non AP. And that "sporting purpose" stuff has caused us an incredible amount of harm in what firearms can be bought and sold here already.

OK soapbox off :)
 
There will always be a group to ban something. The problem occurs when we listen to them.
from one or a combination of tungsten alloys, steel, iron, brass, bronze, beryllium copper, or depleted uranium;
I just learned that brass is armor piercing.
 
There are economic problems with giving up lead because it's so cheap. We essentially throw it away when we shoot so it has to be cheap. It has to be cheap to make as well or we can't afford to throw it away. Other materials aren't as cheap.

The problem is that in certain forms lead is highly mobile in the environment (and as we know highly toxic). In the form of spent ammunition it isn't very mobile because it forms a pasivation layer (think the oxide on aluminum) that protects "chunks". In acidic environments that doesn't get to happen or it doesn't happen well and it forms soluble salts that are mobile and can bioaccumulate causing problems. This becomes a problem when you have a range or mine/roaster or industrial source that acts as a point source for concentrating the contamination. When disbursed broadly, as in hunting away from waterfowling areas, there isn't a meaningful contribution to the environment.
 
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Also keep in mind that this is FAR more than a "hunting" issue. 99.99% of ammunition sold annually is used for purposes other than hunting.
 
This deserves full attention, and it's obviously a backdoor attempt to ban ammunition, but I don't see it going anywhere. There are already restrictions in place for migratory birds, I don't see where they can argue that there is a big problem with this anymore.
 
don't they already require steel shot in many waterfowl areas for just this reason? nothing new here. lead is toxic, they took it out of gas, we still have cars, better faster cars actually, that get better fuel mileage. is making our wetlands less toxic, that bad an idea? as to rifle, pistol ammo, im sure if we can put men on the moon, we can still make bullets for them too. It's just a suggestion for change, things change and that's what upsets alot of people. i'm sure there are those that think we should still have lead in gas.
 
The problem is that in certain forms lead is highly mobile in the environment (and as we know highly toxic). In the form of spent ammunition it isn't very mobile because it forms a pasivation layer (think the oxide on aluminum) that protects "chunks". In acidic environments that doesn't get to happen or it doesn't happen well and it forms soluble salts that are mobile and can bioaccumulate causing problems. This becomes a problem when you have a range or mine or industrial source that acts as a point source for concentrating the contamination. When disbursed broadly, as in hunting away from waterfowling areas, there isn't a meaningful contribution to the environment.
These are good points. Lead paint and leaded gasoline were harmful, lead shot in wetlands was a problem. I can even see banning lead ammo in some indoor ranges and some hunting areas, but you have to know when to quit banning things.

The anti-lead, can't-be-too-safe hysteria is getting out of control when we have to ban lead wheel weights and lead solder. They are now making lead-free circuit boards. Do netbooks and iPods need to be so non-toxic that you can eat them? Are people getting poisoned from lead in landfills? I really doubt it. All that lead came out of the ground in the first place.

There have to be thousands of abandoned trap ranges where tons of lead was shot into the woods. To hear how dangerous lead is, you would think every bird, deer, rabbit and squirrel in these areas would be dropping dead from lead poisoning. Walk through one and tell me what the problem is; you will see not one pile of bones from poisoned animals.

The world is a dirty place, always will be.
 
First. Where does lead come from? It is a base element metal that occurs naturally all over the globe. We mine it, although large portions of lead today comes from recycling. We can't manufacture lead. It's abundance is what makes ammunition so cheap. So to dispel one myth, when we use lead all we are doing is putting it back where we found it. In the earth.

Secondly. I am not aware of any modern ammunition manufacturer that uses lead in it's purest form. I could be wrong. Other metals are added to lead to make various alloys. Things like tin, antimony, nickel etc etc. are added to the lead. This changes it's consistency to make it better suited for traveling at high rates of speed without deforming. This also changes the chemical process of it's decomposition. Lead typically breaks down as soluble salts. This process can be slowed down or sped up depending on the other metals added to form the alloys.

The amount of lead typically used in hunting leeches these poisonous salts back into the ecosystem so slowly and gradually that it is virtually harmless. It's not transferable in nature unless it is ingested directly. Look up civil war lead bullets. You'll find oxidized lead bullets that are almost intact. Hunting and even wars do not concentrate lead in a single location densely enough to impact the environment. Just remember where the lead came from in the first place.

A shooting range, a mine, a dump that would allow lead to be stored and concentrated...Those are dangerous. Ingested lead even in alloy forms is dangerous. 50 ounces of buckshot over wetlands is not dangerous. The oxidation that takes place making the lead transportable or mobile in the ecosystem is so slow that it is actually less harmful than where lead occurs naturally.

Enough of the chemistry lesson. Do animals sometimes ingest our lead? Yes they do. Fish swallow sinkers and lures. Something eats the fish and it gets passed along. An unrecoverable animal that we have shot might drop dead and a predator or scavenger bird or mammal eats it and so on. Accidents do happen and sometimes our quarry gets away. The number of animals that suffer because of our stray lead? It's unrecordable. The instances are so few and far between and on such a broad scale no one can measure it. All it takes is a tree hugger to find one dead bird and it's too many. A panic has been created and we have been lied to based on emotion and speculation. There is very little science involved.

Saving kittens is far from what is really at stake here. That is the smoke and mirrors. What is really going on behind the curtain is this thing has a 90 day deadline. What happens in roughly 90 days? The elections. If the EPA says to the bird lovers *poof* your wish is granted who knows how this would be implemented? Well if the implementation is instantaneous...What else happens in 90 days? Hunting season in every state in the US. No time for the ammo makers to retool. Certainly not enough non lead alternatives on the shelves. Now are you concerned enough to SLAM the hell out of those those phone numbers and addresses? If you don't this has the potential to eliminate all gun hunting in the US. At least for a while.

That last bit is a worst case scenario. Here is another concern. Where does your state stand on armor piercing ammunition? Because many of the alternatives to lead are just that. Pistol hunting is gone forever.

The definition of AP ammo is at 18 USC sec. 921(a)(17):

( B ) The term 'armor piercing ammunition' means-

(i) a projectile or projectile core which may be used in a handgun and which is constructed entirely (excluding the presence of traces of other substances) from one or a combination of tungsten alloys, steel, iron, brass, bronze, beryllium copper, or depleted uranium; or
(ii) a full jacketed projectile larger than .22 caliber designed and intended for use in a handgun and whose jacket has a weight of more than 25 percent of the total weight of the projectile.


If you people sleep at the wheel on this one or think it doesn't impact you? Guess again. It's not that far of a stretch to say if it's bad for the environment and animals then it would be ludicrous to allow it for use on humans. Think I am making that up?
http://www.tactical-life.com/online/news/m855a1-green-ammo-shipped-to-afghanistan/

All the top manufacturers have been playing with lead alternatives for years. Specifically copper. They knew this day would come. Well guess what? Copper is toxic to the environment too. In fact a single stray round can kill trees and plants. What happens after a copper bullet was discovered to be the reason a tree died that an endangered bat uses?

Lather, rinse, repeat. We give in a fraction on lead and you might as well start hammering your gun metal into broad heads. But we already know death by hemorrhage is constantly under attack on several other fronts. In the not so distant future no one but the elite will be able to afford to hunt. That assumes it is still permitted at all.

Make the phone calls, send the emails, raise hell and pass the word to everyone you know. If we loose this one...The snowball has rolled from the mountain top.
 
Been sayin' it for 20 years. They can't get the guns...on constitutional grounds...so they'll come after the ammunition, and it'll be in the name of the environment. They don't have to ban it. All they have to do is make it so prohibitively expensive that the average workin' stiff can't afford to buy it in greater quantities than 50 rounds a year.

It's not about the whales and the buzzards and the ducks and the geese...and it's not about the children. They couldn't care less about those things.

See to your ammunition stocks. When you buy a box...buy two...and store it carefully.
Dark days are coming as sure as the sun will rise tomorrow.
 
as to rifle, pistol ammo, im sure if we can put men on the moon, we can still make bullets for them too. It's just a suggestion for change, things change and that's what upsets alot of people. i'm sure there are those that think we should still have lead in gas.

Tetra-ethyl lead is not even REMOTELY the same chemical compound as lead used in tire weights and bullets.
 
So to dispel one myth, when we use lead all we are doing is putting it back where we found it. In the earth.

That's actually the myth, that we're just putting it back in the ground where we found it so it can't be doing any harm. It's not only not a factually accurate statement, but it isn't logical to think that if we move something from one place to another it can't produce any harm.

The form that we find it and how we come in contact with it is different for naturally occurring lead and the lead that we're concerned with. As has been said it's the solubility of the lead compounds that we encounter that produces the problem. Lead naturally occurs mostly as low solubility massive deposits of lead minerals PbS, PbSO4 and PbCO3 associated with copper, silver, and zinc ores. The ores are roasted, changing the insoluble lead minerals to lead oxide which is subsequently reduced in blast furnaces to metallic lead that we put to use. The ore minerals are not very soluble and not as much of an exposure or environmental problem as a result. The lead we need to be concerned with is the soluble forms we might be exposed to and those are the source of the concern of both public health, occupational health and environmental regulators. Not all lead we put into the environment is released in soluble forms, but much of it does. Further complicating the picture is that not only is the chemical form changed, but the lead that is in a smaller particle size is more readily soluble as well. That's the source of the concern about lead in the environment, not the low solubility lead ores that we derive these lead compounds from.

So, oversimplifying things and thinking "It came from the ground we should be able to put it back" is dangerous oversimplification. It came from the ground in an insoluble form, so we have to be careful to not put it back in a soluble form where it can harm wildlife, the environment and us.

The facts from various environmental studies at firing ranges is that lead is usually only a problem when the environment is acidic causing higher solution rates and greater exposure hazards.
 
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im sure if we can put men on the moon, we can still make bullets for them too.
We can't put people on the moon. Congress threw away that capability (and I'm NOT talking about the Constellation white elephant), just like some appear now to be trying to throw away the ability of companies to provide affordable ammunition to civilian shooters.

Adding inexpensive, nontoxic new metals to the Periodic Table of the Elements is a no-can-do; we're stuck with the metals we have. And if we don't want to have ammunition availability drastically curtailed and priced out of the reach of most of us, we're stuck with the cheap metals we have, unless we all become one-box-every-once-in-a-while shooters.

The problem is, most of the better non-lead substitutes are either more toxic than lead, not cheap enough or abundant enough to replace lead (gold would be perfect but...), are problematic from a performance standpoint (aluminum isn't dense enough, the Army's bismuth-core replacement for M855 has been a total flop, etc.), or are banned by Federal law (steel, brass, bronze).

There is no surer way to decimate the nonhunting shooting sports in the United States than to ban lead-core ammunition, methinks. And something tells me that the prohibitionists would sue to force lead-free primers too...so say goodbye to a long shelf life...
 
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We could make an iron or steel composite bullet since it wouldn't be a "steel" bullet. Centered brass and iron is viable, but the density will be different than lead so the ballistics will change.
 
I spent several years working on methods to detect heavy metal contamination... this legislation is not about the environment at all. The government has literally dumped millions of tons of lead, mercury, cadmium, arsenic, uranium, and other heavy metals into lakes and rivers before environmental restrictions were in place, and the current major sources of contamination are mostly related to batteries. The contribution from ammunition is really a drop in the bucket.

Lead, historically and in the present, is a very useful metal due to its softness, density, and in the last century, electrochemical properties. It is toxic, but lead contamination is very much proportional to population density: since everyone uses lead the contamination is where the people are. Lead contamination in wide open expanses where hunting is common is minimal. I make my students take water and soil samples for analysis in my lab as part of a laboratory course, and I have never seen more than a few parts per billion lead in any rural water sample, but the water in a lake near campus has at least 5 parts per million lead, depending on the season. The big problem with lead shot is that the pellets are very similar in size to the pebbles that certain birds swallow to aid in digestion. In their acidified stomachs, the lead is very harmful. I don't see how this is a problem with larger slugs at all.

However, I believe that a lead shortage is coming sometime in the next twenty years, as we are running out of wasteland suitable for starting new lead mining operations. I wonder if these restrictions are meant to reduce the amount of lead that is dispersed in such a way that it cannot be recycled. Recycled lead is going to be a hot commodity, and a lot of time and money will be spent making batteries using metal oxides other than lead. Unless the restrictions on what metals can be used for ammunition are lifted, ammunition is going to get a lot more expensive over the coming decades.
 
I work in the energy and environment section of a large tech firm. The legislation is based a "little knowledge is a dangerous thing". Lead is recognized as a public health, occupational and environmental hazard. The problem is that some forms are more of a hazard than others and some are more of a hazard in certain environments. Not discriminating between those forms of lead and the conditions is the oversimplified approach that leads to unwarranted concerns on lead in hunting ammunition. Sometimes it's simply done because inadequate research has been done creating an incomplete picture of the problem, sometimes it's what I refer to as the "hysterical" response where any form just has to be hazardous and we've just not recognized it yet or that there's no deminimus quantities accepted and in very rare instances it's a conscious attempt to twist the facts for a separate agenda.
 
Hso I think my second post was misunderstood. The rate in which we put the lead back as hunters in proportion to it's rate of decay is what makes lead ammunition used for hunting insignificant.

Typical estimates put US hunter numbers at roughly 20 million per year. That is all hunting for all animals. License sales in 2005 indicated 14.5 million hunters. Not everyone is required to purchase a license. Land owners, seniors, veterans etc are often exempt from license sales in some states. They say that hunting numbers have been in decline for at least that long. So for the purposes of this example I am going to assume 20 million hunters is an accurate representation for 2010.

I deer hunt. Last year I fired 4 rounds while hunting any game. I used 1 ounce sluggers. So in 2009-2010 hunting season I am responsible for 4 ounces of lead being reintroduced into the environment as a result of hunting. The rate of decay for that lead is so minor and so localized on such a grand scale it is insignificant. Assuming I hunt for 50 years and my results are the same each year I will have produced 12.5 pounds of lead contamination in my lifetime. That assumes I fire 4 rounds each year or even get to fire a round at all.

A single civil war battle did that in a matter of minutes. Those bullets are still virtually intact today. Those bullets are leeching so slowly it's going to take a 1000+ years for them to fully decompose. The lead that we return to the earth with it's typical decay rate is no more poisonous to the environment than naturally occurring poisons and disease.

A visit to Gettysburg will make my case conclusively. The wildlife is in full bloom. The lead flung during that conflict is in a highly localized area compared to hunting practices. 160,000 soldiers saturated the area for 3 days. How is the predatory bird wildlife there? See for yourself: http://www.gettysburgdaily.com/?p=1256

Bird watching and wildlife is alive and well in Normandy too. Normandy probably had 100x the lead flung than the Gettysburg battle. The pacific islands are alive and well too. We all know how delicate the island ecosystems are.

1 pelican swallowing 1 fish that swallowed one lead bullet or sinker and the science can be altered to show anything they want. Explain the predatory and scavenging wildlife that thrives on war torn battle fields please?

This ban is something else and it has nothing to do with the environment. We must give them nothing. Period.
 
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I just gotta ask why? Is lead the perfect ballistic material or something? Would the alternatives be inferior or too expensive?


It is cheap, it is soft, and it is dense.

A large number of inexpensive alternative materials are banned under federal law as "armor piercing". This includes most that are hard and cheap.


Very few materials are as dense as lead. Most of those which are are either very rare, produced in small quantities, or more toxic than lead.


Many "lead substitutes" on the market contain a significant percentage of lead combined with something else.
Bismuth is primarily mined as a byproduct of lead, and the total amount mined and available in the world is very small. If people were forced to use it then the minimal supply would skyrocket in price, and as an example when it went up in price in 2007 it would have cost nearly 14-17 times as much per bullet as lead.

Density is very important in ammunition, a given weight for a given size. Performance rapidly drops off if you use lighter materials, as does accuracy, effects from crosswinds, drop over distance etc.
Pull up the periodic table of elements and take a look at anything nearly as heavy as lead.
Most of it is extremely toxic (as in deadly in trace amounts) or expensive. Lead is neither.

Finally lead is soft and malleable. This means it won't damage rifling, and it can be shaped very easily without much if any wear on tools.
Harder materials wear away whatever is being used to shape them, and cost more per round to produce even with cheap materials because of that additional wear.
In additional your common affordable hard materials are banned as "armor piercing handgun" rounds under federal law (even most rifle calibers.)
Harder materials are also more difficult for your typical hobby loader to manufacture rounds from.
 
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One important point--this is not seeking to regulate the use of lead for HUNTING on FEDERAL LAND. It is seeking a ban of all lead ammo. Including self defense ammo, target ammo and so on used or just stored on private land, state land or anywhere. That constitutes a ban on about 99% of the ammunition used for all purposes. And it's not reasonably related to the purpose of protecting wildlife. Ammunition expended at ranges is ALREADY subject to many local and federal cleanup standards. It is not being shot in habitat, but into berms. But this would see it banned regardless.

This is not a wildlife protection bill, but an attack on firearms.
 
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