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each shot, regardless of the type of shot or bullet used. The issue

of richochet of lead-free bullets or gunshot has not arisen as a

serious concern among US hunters, and has not been raised to

prevent a transition to their use.

How long would it take for

industry to ramp up production

of lead-free shot?

UK cartridge companies (Gamebore and Eley) currently make

two proprietary brands of non-toxic shot cartridges, Tungsten

Matrix and Bismuth-tin. At least five UK companies currently

make steel shot cartridges, and more distributors import steel

shot cartridges from European and American companies

(Thomas 2015). This array of steel shot is available for both

game and clay target shooting (Thomas 2013b). The majority

of cartridges made in the UK are made for clay target shooting,

rather than game shooting.

TheUKcompaniesalreadyhavethetechnologyinplacetoproduce

all the non-toxic cartridges that UK shooters will demand. What is

presently limiting production is the assuredmarket demand from

REFERENCES

ANDERSONWL, HAVERA SP, ZERCHER BW (2000).

Ingestion of lead and non-

toxic shotgun pellets by ducks in the Mississippi flyway.

The Journal of Wildlife

Management

64(3), 848-857.

CROMIE R, LORAM A, HURST L, O’BRIEN M, NEWTH J, BROWN

M, HARRADINE J (2010).

Compliance with the environmental

protection (Restrictions on Use of Lead Shot)(England) Regulations

1999. Defra, Bristol. Available at:

http://randd.defra.gov.uk/Default.

aspx?Menu=Menu&Module=More&Location=None&ProjectID=16075

.

Accessed: August 2015.

CROMIE RL, BROWN MJ, HUGHES B, HOCCOM DG, WILLIAMS G (2002).

Prevalenceofshot-inpellets inmallardpurchasedfromgamedealers inEngland

in winter 2001/2002.

Compliance with the Lead Shot Regulations (England) during

winter 2001/02.

RSPB. Sandy, UK.

CROMIERL,NEWTHJL,REEVESJP,O’BRIENMF,BECKMANNKM,BROWNMJ

(2015).

The sociological and political aspects of reducing lead poisoning from

ammunition intheUK:whythetransitiontonon-toxicammunition issodifficult.

In: Delahay RJ, Spray CJ (eds).

Proceedings of the Oxford Lead Symposium. Lead

ammunition:understandingandminimisingtheriskstohumanandenvironmental

health

. Edward Grey Institute, The University of Oxford. pp 104-124. Available at:

http://oxfordleadsymposium.info .

Accessed: October 2015.

FSA (2012).

Advice to frequent eaters of game shot with lead. Available at:

http://www.food.gov.uk/science/advice-to-frequent-eaters-of-game-shot-

with-lead

. Accessed: August 2015.

GARWOOD GT (1994).

Gough Thomas’s gun book: shotgun lore for the

sportsman.

The Gunnerman Press: Auburn Hills, Michigan, USA.

GREMSE C, RIEGER S (2015).

Lead from hunting ammunition in wild game

meat: research initiatives and current legislation in Germany and the EU. In:

Delahay RJ, Spray CJ (eds).

Proceedings of the Oxford Lead Symposium. Lead

ammunition:understandingandminimisingtheriskstohumanandenvironmental

health

. Edward Grey Institute, The University of Oxford. pp 51-57. Available at:

http://oxfordleadsymposium.info .

Accessed: October 2015.

GROUP OF SCIENTISTS (2013).

Health risks from lead-based ammunition in

the environment: a consensus statement of scientists. March 22, 2013 Available

at:

http://www.escholarship.org/uc/item/6dq3h64x .

Accessed: August 2015.

GROUPOFSCIENTISTS(2014).

Wildlifeandhumanhealthrisksfrom lead-based

ammunition in Europe: a consensus statement by scientists. Available at:

http://

www.zoo.cam.ac.uk/leadammunitionstatement/ .

Accessed: August 2015.

HAAS GH (1977).

Unretrieved shooting loss of mourning doves in north-

central South Carolina.

Wildlife Society Bulletin

5(3), 123-125.

IRBY HD, LOCKE LN, BAGLEY GE (1967).

Relative toxicity of lead and

selected substitute shot types to game farm mallards.

The Journal of Wildlife

Management

, 253-257.

KANSTRUP N (2015).

Practical and social barriers to switching from lead to

non-toxic gunshot – a perspective from the EU. In: Delahay RJ, Spray CJ (eds).

Proceedings of the Oxford Lead Symposium. Lead ammunition: understanding and

minimising the risks to human and environmental health

. Edward Grey Institute,

The University of Oxford. pp 44-50. Available at:

http://oxfordleadsymposium.

info

. Accessed: October 2015.

the shooting community. Voluntary measures to adopt lead-free

cartridges do not create a strongmarket demand that companies

can rely on. Also, a lack of compliance with existing non-toxic shot

regulations for shooting over UK wetlands (currently about 70+%

non-compliance) does not encourage companies to make more

non-toxic shot than is ordered.

Any regulations that would require greater use of lead-free

cartridges would require an appropriate phase-in time. The vast

majority of steel shot incorporated into cartridges originates in

China, and the Chinese companies would need adequate time to

increase projected production. The same consideration applies

to tungsten originating from Chinese mines and refiners. The

cartridge cases and shot cups designed for steel are not the same

as those used for lead shot cartridges, and so increasing their

production volume takes time. It also takes time for UKmakers to

make, test, advertise and distribute their cartridges, and for the

wholesalers to stock and prepare their products for sale. Given

the experiences of the USA, a transition time of three years to

the date of entrance of legislation appears reasonable, for both

UK and European makers. This is also the timeframe suggested

in the guidance to the CMS (November 2014) Resolution

recommending a phase out of the use of lead ammunition.

Key questions and responses regarding transition to use of lead-free ammunition