Conservation policy briefing on lead gunshot
Risks posed to health and the environment from lead gunshot: a UK perspective
Why is WWT providing this conservation policy briefing on lead gunshot?
Lead is a toxic metal and WWT is aware of a large body of evidence of continuing serious health impacts on wildlife, potential health and behavioural impacts in humans and environmental contamination by lead gunshot. We are raising awareness of the availability of this information to facilitate evidence-based policy positioning and decision making.
What are the risks from lead shot?
Lead is toxic to all animals including humans. Even low levels of exposure affect animals and no threshold has been identified below which the effects of lead cannot be seen.
The vast majority of shot fired from shotguns falls into the environment, and thus, in the case of lead, causes long term cumulative contamination. Wildfowl, and other birds, ingest lead shot that has been deposited in their feeding areas (such as wetlands and terrestrial habitats including agricultural land), probably mistakenly for grit or food.
Lead poisoning from shot ingestion has been known to kill wildfowl for more than a century (e.g. Beintema 2001; Franson and Pain 2011; Pokras and Kneeland 2009). In Europe, it has been estimated that approximately a million wildfowl (from 17 species), i.e. 8.7% of the population, could die every winter from this cause (Mateo 2009).
While some of the information on which this estimate was based is old and shot ingestion rates may now be higher or lower in some species, mortality is nonetheless very high. Not only does lead poisoning cause considerable avoidable wildfowl suffering and mortality, concern has also been expressed over the potential for lead poisoning to be contributing to the declines of certain species of common wildfowl, e.g. pochard and pintail - both of which are amber-listed ‘Birds of Conservation Concern’ (BoCC) in the UK (Eaton et al. 2009).
Lead is known to be a serious threat to certain globally threatened European wildfowl, e.g. white-headed duck (Mateo 2009). In addition, lead poisoning causes sub-lethal effects in many more birds and represents a significant welfare problem.
In recent times a body of evidence has accumulated detailing lead poisoning in terrestrial birds. These include upland game birds, which ingest spent lead shot while feeding in shot-over habitats, and raptors, that prey upon or scavenge game species and so ingest lead and fragments of lead from ammunition that has been shot in (Pain et al. 2009). Eight of the non-wildfowl species documented to ingest lead or suffer lead poisoning from ammunition sources in the wild breed regularly in the UK, and are red-listed or amber-listed in BoCC (Eaton et al. 2009). Clearly, it is important to avoid or reduce mortality from all causes in these species.
Negative human health impacts of lead are well established, and have resulted in policies to reduce exposure such as its removal from paint and petrol.
The potential risks associated with consuming game shot with lead ammunition have received more attention recently following an international conference held by the Peregrine Fund in the USA in 2008 (Watson et al. 2009).
As a small proportion of the lead from gunshot fragments into pieces invisible to the human eye when impacting game, consumers may inadvertently eat small lead shards/particles as well as lead solubilised within the meat during cooking. Research in the UK showed that a high proportion of game sold for human consumption had lead concentrations exceeding the European Union Maximum Levels (EUMLs - under Regulation 1881/2006 (EC 1881/2006)) of 100 ppb wet weight set for meat from bovine animals, sheep, pigs and poultry, some by several orders of magnitude (Pain et al. 2010).
The European Food Safety Authority’s expert Panel on contaminants (CONTAM) published a scientific opinion on lead in food (EFSA CONTAM 2010). This report details the potential health risks that may be associated with a diet rich in game. Recent research from the UK evaluates the potential health risks associated with different levels of consumption of gamebirds shot with lead gunshot (Green and Pain 2012) and finds that the consumption of less than one meal (of gamebirds) a week in children may be associated with a decreased IQ.
What has been the policy response to lead-poisoning mortality of wildfowl and has this been effective?
As a Contracting Party to the African-Eurasian Waterbird Agreement (AEWA), the UK has a legal obligation to phase out the use of lead shot over wetlands (AEWA 1999, 2002, 2008) (the initial deadline for this was 2000).
Consequently, restrictions on the use of lead were introduced in England in 1999 (HMSO 1999, 2002a, 2003), Wales in 2002 (HMSO 2002b), Scotland in 2004 (HMSO 2004) and Northern Ireland in 2009 (HMSO 2009). In England and Wales, the Regulations make it illegal to use lead shot for shooting wildfowl (and coot and moorhen) and over certain listed wetlands (SSSIs) and the foreshore.
However, a recent Defra-funded study in England (Cromie et al. 2010), illustrated very poor compliance with the regulations, with 70% of sampled duck found to be illegally shot with lead, despite more than a decade of awareness raising. As part of this compliance monitoring study, the British Association for Shooting and Conservation (BASC) conducted a questionnaire survey of its members in which 45% of respondents admitted to not always complying with the law (Cromie et al. 2010). Understanding of the spirit of the law was good but motivation to comply was low, partly due to lack of enforcement of the Regulations.
Enforcement is difficult where only partial restrictions exist (i.e. restrictions only for certain species, habitats and/or sites). In addition, current UK legislation permits the use of lead ammunition to shoot most species in some areas commonly used as feeding sites by wildfowl (e.g. non wetland agricultural areas).
Recent research conducted by WWT shows the proportion of birds recorded as dying of lead poisoning in Britain has not declined since the introduction of restrictive Regulations on lead gunshot and that levels of lead poisoning in wildfowl in Britain remain high; 42% of the whooper swans, 21% of pochard and 25% of pintail sampled in 2010/11 had elevated blood lead concentrations (Newth et al. 2012). A recent EU Member State survey (reported on in 2011) also suggested that enforcement is rendered difficult when bans concern only wetlands.
Were means found to ensure compliance with existing regulations in the UK, many wildfowl would continue to be exposed to lead shot. This is because many species, including our migratory swans, spend much time feeding in agricultural areas that may have been shot-over legally using lead gunshot.
Almost 30 years ago in the UK, the Royal Commission on Environmental Pollution (Southwood, 1983) comprehensively reviewed lead in the environment and concluded that ‘urgent efforts should be made to develop alternatives to lead shot and lead fishing weights’ and that ‘As soon as these alternatives are available, the Government should legislate to ban any further use of lead shot and fishing weights in circumstances where they are irretrievably dispersed in the environment’.
Non-toxic alternatives to lead shot have existed for many years and several European countries, including Denmark, the Netherlands, Norway and parts of Belgium have introduced total bans on the use of lead gunshot. This appears to be a more practical solution than partial bans introduced in many countries based on the shooting of selected species (i.e. wildfowl) or in selected habitats (i.e. wetlands).
We are also aware that German and Spanish Health Agencies have recently recommended that pregnant women, those wishing to become pregnant and young children should avoid eating the meat of game shot with lead ammunition and that its consumption should be limited in other groups (BfR 2011; AESAN 2012). In the UK the Food Standards Agency also produced health advice (http://www.food.gov.uk/news-updates/news/2012/oct/lead-shot) advising a reduction in intakeof lead-shot game by frequent consumers, especially in vulnerable groups such as toddlers and children, pregnant women and women trying for a baby, as exposure to lead can harm the developing brain and nervous system.
What are the barriers to replacing lead with non-toxic shot?
Some European countries use only non-toxic shot for all shooting (game sports shooting and target shooting); in Denmark this has been the case since 1996. However, in the UK debates over the use of non-toxic shot have been ongoing for many decades, and the issue remains controversial.
From both government-funded research (Cromie et al. 2010) and review of the shooting press and social media it is clear that there is a misconception that lead poisoning of wildlife is not a problem. This is often due to shooters not personally observing lead poisoned birds. It is understandable that some people might underestimate the importance of lead poisoning as birds die regularly and in small numbers and are rapidly removed by predators and scavengers.
In comparison, diseases like avian botulism occur infrequently but often involve large ‘die-offs’ of birds in one place at one time, thus are conspicuous even though they may kill far fewer birds overall. However, it is important to note that the vast majority of wildlife that dies disappears unnoticed, so the lack of obvious lead poisoned birds is not surprising.
Moreover, there are many myths perpetuated about the non-toxic alternatives to lead shot, despite the fact that only non-toxic shot has been used in a range of European countries for many years. For example steel shot, the most commonly used non-toxic alternative is roughly comparable in price to lead (and sometimes cheaper) and used widely and effectively across much of the world. While other alternatives to lead are more costly, they are less frequently used and were a guaranteed market to exist, economies of scale may reduce costs. There appear to be no technical or price barriers to using non-toxic alternative shot that cannot be rapidly overcome
What would WWT like to see happen?
We consider that the continuation of this long-standing problem in the UK needs to be dealt with as a matter of urgency to significantly reduce substantial but avoidable mortality and suffering in wildfowl and other birds, to meet our legal obligations under AEWA, to conform with the principles of ‘wise use’ enshrined in the Ramsar Convention and to contribute to the Convention on Biological Diversity Aichi Biodiversity Target (Strategic Goal B) on sustainable use.
Several European countries, including Denmark, the Netherlands, Norway and parts of Belgium have introduced total bans on the use of lead gunshot. This appears to be a more practical solution than partial bans introduced in many countries based on the shooting of selected species (i.e. wildfowl) or in selected habitats (i.e. wetlands). Partial restrictions on the use of lead shot in UK have not worked as measured by high levels of non-compliance with the law and no decline in lead-related mortality of wildfowl. A complete transition from toxic lead shot to non-toxic shot types would significantly reduce avoidable suffering and mortality of wildlife and environmental contamination.
We remain open and committed to working with all stakeholders to find mechanisms to minimise the avoidable mortality and suffering of wildfowl and other waterbirds, and contamination of wetlands, caused by lead ammunition.
AESAN (2012). Informe del Comité Científico de la Agencia Española de Seguridad Alimentaria y Nutrición (AESAN) sobre el riesgo asociado a la presencia de plomo en carne de caza silvestre en EspañaNúmero de referencia: AESAN-2012-002 Documento aprobado por el Comité Científico en su sesión plenaria de 22 de febrero de 2012. http://www.aesan.msc.es/AESAN/docs/docs/evaluacion_riesgos/comite_cientifico/PLOMO_CAZA.pdf(English abstract within).
African-Eurasian Waterbird Agreement (AEWA) (1999). Resolution 1.14 Phasing out of lead shot in wetlands. First Meeting of the Parties to the Agreement on the Conservation of African-Eurasian Migratory Waterbirds (AEWA), 6-9 November 1999, Cape Town, South Africa. http://www.unep-aewa.org/meetings/en/mop/mop1_docs/pdf/r14.pdf
African-Eurasian Waterbird Agreement (AEWA) (2002). Resolution 2.2 Phasing out of lead shot for hunting in wetlands. Second Meeting of the Parties to the Agreement on the Conservation of African-Eurasian Migratory Waterbirds (AEWA), 25-27 September 2002, Bonn, Germany. http://www.unep-aewa.org/meetings/en/mop/mop2_docs/resolutionsword/pdf/resolution2_2.pdf
African-Eurasian Waterbird Agreement (AEWA) (2008). Resolution 4.1 Phasing out of lead shot for hunting in wetlands. Fourth Meeting of the Parties to the Agreement on the Conservation of African-Eurasian Migratory Waterbirds (AEWA), 15-19 September 2008, Antananarivo, Madagascar. http://www.unepaewa.org/meetings/en/mop/mop4_docs/final_res_pdf/res4_1_phasing_out_lead_shot_final.pdf
Beintema, N.H. (2001). Lead poisoning in waterbirds: International Update Report 2000. Wetlands International, Wageningen.
BfR (2011). BfR (The Federal Institute for Risk Assessment, Germany)Lead fragments in game meat can be an added health risk for certain consumer groups 32/2011, 19.09.2011. http://www.bfr.bund.de/en/press_information/2011/32/lead_fragments_in_game_meat_can_be_an_added_health_risk_for_certain_consumer_groups-127610.html
Cromie, R.L., Loram, A., Hurst, L., O’Brien, M., Newth, J.L, Brown, M.J. and Harradine, J.P. (2010). Compliance with the Environmental Protection (Restrictions on Use of Lead Shot)(England) Regulations 1999. Report to Defra, Bristol. Pp 99.EC 1881/2006. http://randd.defra.gov.uk/Default.aspx?Menu=Menu&Module=More&Location=None&ProjectID=16075
Eaton, M.A., Brown, A.F., Noble, D.G., Musgrove, A.J., Hearn, R., Aebischer, N.J., Gibbons, D.W., Evans, A. and Gregory, R.D. (2009). Birds of Conservation Concern 3: the population status of birds in the United Kingdom, Channel Islands and the Isle of Man. British Birds 102, pp296-341. http://www.bto.org/sites/default/files/u12/bocc3.pdf
EC 1881/2006. European Commission Regulation (EC) No 1881/2006 of 19 December 2006 setting maximum levels for certain contaminants in foodstuffs. Official Journal ofthe European Union 20.12.2006 L364/5-L364/24. http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=OJ:L:2006:364:0005:0024:EN:PDF
EC 1907/2006. European Commission Regulation (EC) No 1907/2006 of 18 December 2006 concerning the Registration, Evaluation, Authorisation and Restriction of Chemicals (REACH). http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=OJ:L:2006:396:0001:0849:EN:PDF
EFSA Panel on Contaminants in the Food Chain (CONTAM); Scientific Opinion on Lead in Food. EFSA Journal (2010). 8(4):1570. Pp 147, doi:10.2903/j.efsa.2010.1570. http://www.efsa.europa.eu/en/efsajournal/pub/1570.htm
Franson, J.C. and Pain, D.J. (2011). Lead in Birds, in: Beyer, W.N., Meador, J.P. (Eds.), Environmental contaminants in biota. Interpreting tissue concentrations. Taylor & Francis Group. Boca Raton, USA. Pp. 563-593.
Green, R.E. and Pain, D.J. (2012). Potential health risks to adults and children in the UK from exposure to dietary lead in gamebirds shot with lead ammunition. Food & Chemical Toxicology. 50(11), 4180-4190. http://dx.doi.org/10.1016/j.fct.2012.08.032
Her Majesty's Stationery Office (HMSO) (1999). The Environmental Protection (Restriction on Use of Lead Shot) (England) Regulations 1999. http://www.opsi.gov.uk/si/si1999/19992170.htm
Her Majesty's Stationery Office (HMSO) (2002a). The Environmental Protection (Restriction on Use of Lead Shot) (England) (Amendment) Regulations 2002. http://www.hmso.gov.uk/si/si2002/20022102.htm
Her Majesty's Stationery Office (HMSO) (2003). The Environmental Protection (Restriction on Use of Lead Shot) (England) (Amendment) Regulations 2003. http://www.opsi.gov.uk/si/si2003/20032512.htm
Her Majesty's Stationery Office (HMSO) (2002b). The Environmental Protection (Restriction on Use of Lead Shot) (Wales) Regulations 2002. http://www.hmso.gov.uk/legislation/wales/wsi2002/20021730e.htm
Her Majesty's Stationery Office (HMSO) (2004). The Environmental Protection (Restriction on Use of Lead Shot) (Scotland) (No. 2) Regulations 2004. http://www.opsi.gov.uk/legislation/scotland/ssi2004/20040358.htm
Her Majesty's Stationery Office (HMSO) (2009). The Environmental Protection (Restriction on Use of Lead Shot) Regulations (Northern Ireland) 2009. http://www.opsi.gov.uk/sr/sr2009/plain/nisr_20090168_en
Newth,J.L., Cromie, R.L., Brown, M.J., Delahay R.J., Meharg, A.A., Deacon, C., Norton, G.J., O’Brien M.F. and Pain, D.J. (2012). Poisoning from lead gunshot: still a threat to wild waterbirds in Britain. European Journal of Wildlife Research. http://dx.doi.org/10.1007/s10344-012-0666-7.
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Watson, R.T., Fuller, M., Pokras, M. and Hunt, W.G. (Eds.) (2009). Ingestion of lead from spent ammunition: implications for wildlife and humans. The Peregrine Fund, Boise, Idaho, USA. http://www.peregrinefund.org/subsites/conference-lead/2008PbConf_Proceedings.htm