146
et al. 2010). Despite this, there have been no primary
prosecutions and only one secondary prosecution for
non-compliance with the regulations.
c. Birds such as gamebirds and wildfowl ingest spent lead
gunshot mistakenly for food or the grit that helps them
to grind up food in their muscular gizzards. Ingestion of
lead gunshot by waterfowl is associated with increased
death rates (Tavecchia et al. 2001). Large numbers of
birds of these kinds suffer and die annually in Europe
because of poisoning due to ingested ammunition-
derived lead (Mateo 2009).
d. Lead-based gunshot and bullets used to shoot wildlife
can fragment into numerous small pieces within the
animal, some of which may be distant from the wound
tract; many of these are sufficiently small to be easily
ingested by scavenging animals or incorporated into
meat prepared for human consumption (Hunt et al.
2009; Grund et al. 2010; Knott et al. 2010; Pain et al. 2010).
e. Although the effects of ingestion of spent lead
ammunition are best documented for waterfowl, they
have also been reported for more than 60 bird species
from other taxonomic groups (Pain et al. 2009). Lead
poisoning from the ingestion of spent lead-based
ammunition fragments in carrion and prey animals
is a significant source of poisoning and mortality in
predatory and scavenging birds of prey, including
European vultures (Donázar et al. 2002; Mateo 2009) and
the white-tailed eagle Haliaeetus albicilla, in parts of the
EU (Pain et al. 1993, 1997; Fisher et al. 2006; Nadjafzadeh
et al. 2013).
f. Lead-based ammunition is a significant source of lead
exposure in humans that ingest wild game (Hanning
et al. 2003; Johansen et al. 2006; Tsuji et al. 2008), and
blood lead levels in people consuming game meat
shot with lead-based ammunition have been shown
to be elevated in European countries and elsewhere,
in proportion to the amounts and frequency of game
consumed (Dewailly et al. 2001; Iqbal 2009; Meltzer et al.
2013; Bjermo et al. 2013).
g. High concentrations of ammunition-derived lead are
often found in edible tissues of both small and large
game animals shot with lead ammunition and can
be present in tissues at a considerable distance from
obvious wounding so that they are difficult to remove
during food preparation (Pain et al. 2010; FSA 2012a).
Meat from game animals contaminated in this way is
consumed by people associated with shooting and,
in some countries (such as in the UK), is also sold in
supermarkets and other food outlets to consumers who
are largely unaware of associated risks.
h. Several EU countries have produced advice on the
risks to human health of frequent consumption of
game meat shot with lead ammunition, particularly to
young children, pregnant women or women wishing to
become pregnant (BfR 2011; AESAN 2012; FSA 2012b;
VKM 2013).
4. Non-toxic alternatives to lead ammunition have been
developed, are widely available, and perform well (Thomas
2013). The sport of shooting and its associated trade in
ammunition and other supplies appears to remain viable
in countries where the use of lead shot in ammunition
has already been banned (e.g. within Europe, lead shot in
ammunition has been banned for all shooting since 1993 in
the Netherlands, since 1996 in Denmark and since 2005 in
Norway).
Based upon (1) overwhelming evidence for the toxic effects of
lead in humans and wildlife, even at very low exposure levels, (2)
convincing data that the discharge of lead-based ammunition
into the environment poses significant risks of lead exposure
to humans and wildlife, and (3) the availability and suitability of
several non-lead alternative products for hunting, we support
a phase out and eventual elimination of the use of lead-based
ammunition and its replacement with non-toxic alternatives.
Signed,
Dr Aksel Bernhoft, Senior Researcher, Norwegian Veterinary
Institute, Department of Health Surveillance, Postbox 750
Sentrum, NO-0106 Oslo, Norway
Professor Alan R. Boobis OBE PhD FSB FBTS, Professor of
Biochemical Pharmacology & Director of Public Health England
Toxicology Unit, Centre for Pharmacology & Therapeutics,
Division of Experimental Medicine, Department of Medicine,
Imperial College London, Hammersmith Campus, Ducane Road,
LondonW12 0NN, UK
Appendix 2