Lo European Shooting Sports Forum (ESSF), the platform composed of the European sector associations of which ANPAM is a part for our country through IEACS and of which it holds the secretariat, has just published an article on the Euractiv website concerning the numerous inaccuracies and inconsistencies contained in the ECHA restriction proposal on the use of lead-based ammunition in terrestrial areas, recently published. The article, available in its original version at the following link and below in its translation, is the first of a series of activities on the communication front that will be implemented by the ESSF, thanks to an important and ambitious European project aimed at address in a concrete and credible way the restrictions promoted by ECHA on the use of lead in ammunition.
TEXT TRANSLATED
Only a few months have passed since the adoption of the much-discussed ban on the use of lead shot in European wetlands, and we are already facing a much broader ban, covering all lead-based ammunition in other types of soil. . Those who had hoped that the current proposal would follow a less controversial path, based on reliable data and scientific reasoning, will be sorely disappointed. Before deepening the analysis of Annex XV, the so-called Restriction Report of ECHA (currently under public consultation), it is worth recalling the tumultuous path of the previous restriction on the use of lead in wetlands. After being rejected several times by Member States during discussions in the REACH committee, the proposal barely got through to Parliament with just 52% of MEPs in favor. Having just exceeded the necessary number of votes, this ambiguous and difficult-to-implement measure will be applicable from February 2023. Similarly, the new ban proposal got off to a bad start and history looks set to repeat itself. Upon closer inspection, ECHA's restriction report contains several flaws. Some of the main ones are outlined below.
RISK ASSESSMENT FOR HUMAN HEALTH
ECHA's human health risk assessment is incorrect because it is based on arbitrarily selected parameter values, which do not reflect reality and ignore existing scientific literature. As a result, it has unprecedented levels of lead exposure, which are proposed as the European standard. LEAD EXPOSURE = the average amount of game meat consumed × the average concentration of lead in game meat derived from lead ammunition. ECHA estimates that the average adult (weighing 70 kg) consumes 80,89 kg of game meat per year, a number that is four to eight times higher than even the most extreme consumption rates of any available study. published by the European Food Safety Agency (EFSA), as well as for studies carried out by any other National Food Agency in Germany, France and Scotland. EFSA defines consumers of a "large amount of game meat" as those who eat 4 kg per year. The National Food Agencies of Germany, France and Scotland have set the amount for 'extreme / high end' consumers to be between 2 and 18,2 kg per year. But that is not all. The second parameter, that relating to the average concentration of lead in game meat, also seems not to be supported by the available scientific evidence. To begin with, ECHA states that the concentration of lead in game hunted with split ammunition is almost 7 times higher than that in game hunted with whole ammunition. This is counterintuitive, as lead concentrations in small game, such as pheasants and partridges, hunted by shotguns should be higher than in large game, such as moose. However, the estimated lead concentrations, for example in moose, could be based on meat samples taken around the wound canal, thus ignoring most of the meat away from the bullet and not contaminated. Furthermore, the data on the mean concentration of lead used by ECHA (0,366 mg / kg for game shot with lead shot and 2,515 mg / kg for game shot with lead shot) are not in line with any of the available scientific evidence. provided by EU National Food Agencies, such as FSAS (Scotland) or SNFA (Sweden). Thus, if it is true that lead exposure = the average amount of game meat consumed × the average concentration of lead in game meat from lead ammunition, it is also true that the overestimation of both parameters renders the entire risk assessment.
ENVIRONMENTAL RISK ASSESSMENT
Looking at the environmental risk assessment, the first thing that comes up is the fact that the estimates of the annual release of lead shot into the environment seem extremely excessive, both for hunting and for sport shooting. The release of 14.000 tonnes of lead per year (tpa) resulting from hunting with smooth-bore shotguns, whose cartridges contain 34 g of lead shot, would mean that each hunter in the EU shoots an average of 67 rounds of gunfire all over the country. year (404,6 million cartridges / 6 million hunters in the EU), which is frankly a high average reference estimate. Regarding the emission of lead into the environment deriving from sport shooting, the ECHA hypothesis of 10.000 kg / year of lead used "on a typical outdoor shooting range" refers to a cd worst-case scenario, based on a sample site, cannot therefore be considered as 'typical', as the values are not 'representative'. The resulting overestimated value of lead released into the environment, 35.000 tpa, does not correspond to reality, as more accurate estimates are less than half of this quantity. Looking at the study of primary poisoning of terrestrial birds, it is immediately evident that many bird species have not been specifically studied or are assumed to have feeding ecologies and probabilities of exposure comparable to other species, even though they live in completely different ecosystems. . In the end, it was not possible to identify which species were considered “at risk” in the assessment, thus not allowing the verification of the estimate provided. Of the approximately 20 studies used in the ECHA report, only five were identified and found to be more or less representative, which is further skewed by geographical limitations, as these studies come from only three countries: United Kingdom (2) Spain (2 ) and Denmark (1). These studies also follow the "single death count" approach without evaluating the significance of mortality at the species population level. Furthermore, most of the studies took place in intensive shooting areas (UK and ES), and therefore lead poisoning estimates in such locations are not representative of most hunting contexts in Europe, as the areas of intensive shooting are small compared to the area where hunting and shooting sessions take place on a national scale. More importantly, the assessment completely ignores other routes of lead ingestion from environmental sources, such as food or poisoning caused by exposure to high concentrations of lead in the vicinity of mines, waste disposal sites and industrial plants. Simply put, lead poisoning mortality is only a fraction of total mortality. Finally, ECHA estimates that 135.429.204 birds (not one more bird and not one less bird) are at risk of lead ammunition poisoning and 1.354.292 birds actually die from lead poisoning each year (taking into account a mortality rate of 1%): very precise figures, considering that no one knows how they were calculated. In conclusion, it is clear how the use of arbitrarily chosen parameter values, the neglect of the existing scientific literature on specific topics, the lack of adequate scientific evidence in some contexts and the use of statistically unreliable data make the ECHA report scientifically imperfect and generally inaccurate. Hunting Federation).
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