Hunting & Ammunition: Lead. Another necessary reflection on the use of lead in hunting ammunition.
A still open problem. One of the most controversial aspects, promptly contained in all ISPRA opinions in recent years, is represented by lead-containing ammunition. In fact, the Institute claims that:
1. The use of lead-containing ammunition in both smoothbore and rifled guns for hunting ungulates and other huntable species would have adverse effects on the conservation of necrophagous raptor populations;
2. such use would also lead to a potential danger to human health, since the excessive fragmentation of the bullets would prevent the removal of lead residues during the slaughter and packaging of meat. The Institute therefore ends up, however, through a highly dubious formula, to suggest evaluating the opportunity to provide alternative ammunition for hunting ungulates, or to hope for the total gradual replacement of ammunition containing lead with so-called "non-toxic" ammunition. The conclusions of ISPRA cannot be accepted as they are the expression of a framework that requires further study by the scientific world, which currently has disagreements, and therefore are not, also by virtue of what was previously reported in any way binding, representing an excess of precaution which may not be taken into account in the drafting of the hunting calendar. As is known, art. 18, paragraph 2 of the law 11 February 1992, n. 157 (Rules for the protection of homeothermic wildlife and for hunting), establishes that the Regions may modify the hunting calendar, with reference to the list of huntable species and the period in which hunting is permitted, indicated in the previous paragraph 1 , by means of a procedure that contemplates the acquisition of the opinion of the National Institute for Wildlife, in whose competences the Higher Institute for Environmental Protection and Research - ISPRA has now taken over, pursuant to the Decree of the Ministry of Environment 21/05/2010, n. 123. Art. 18, paragraph 4, then establishes that, on the basis of the aforementioned opinion, the Regions publish, by June 15 of each year, "the regional calendar and the regulations relating to the entire hunting year, in compliance with the provisions of paragraphs 1, 2 and 3 ". The corresponding regional laws conform to this model, prescribing that the opinion must be requested from ISPRA on the draft hunting calendar adopted by the regional bodies.
With reference to the nature of this opinion and its binding nature, jurisprudence has now settled on the opinion that the opinion of ISPRA is undoubtedly mandatory, but not binding, given the nature of the Institute's technical support body. Therefore, the same opinion can be rejected by the Administration which, however, has the burden of taking on the procedural and substantive observations underlying the adoption of various conclusions (ex plurimis TAR Lombardia, Brescia, II, 2/11/09 n. 1827; TAR Sicily, Palermo, I, 19 October 2009, n. 1633 and TAR Marche, I, 24 October 2007, n. 1778). In other words, in order to be able to legitimately depart from the opinion of ISPRA, the active administration body must provide detailed reasons for the reasons why it deems it not to comply with the indications expressed therein, under penalty of nullity of the calendar due to excess of power. for unreasonableness and lack of motivation. It is therefore essential that any detachments with respect to what is suggested by ISPRA through the mandatory opinion are adequately motivated, in order to avoid the nullity of the calendar and consequent damage to the hunting activity and associated companies, in addition to the liability profiles. to the Administration.
Reference scientific studies. It is necessary to underline some aspects of fundamental importance:
1. With reference to the supposed negative effects on the conservation of the populations of necrophagous raptors deriving from the use of ammunition containing lead in hunting ungulates, it should be noted that the possibility that killed animals are not recovered concerns only hunting wild boar in hunt, and in in any case they represent a very small percentage, also due to the now usual use of the track dog, which allows to almost completely avoid that a spoil escapes the collection. In relation to the entrails and parts of the remains directly contaminated by lead, they constitute by-products of animal origin pursuant to Regulation (EC) no. 1069/20009 and are subject to the relative regulations on disposal, and therefore cannot be abandoned in the availability of necrophagous raptors. Therefore, also in relation to the consistency and distribution on the territory of the populations of necrophagous raptors, the possibility that the use of ammunition containing lead seriously damages their consistency appears to be completely remote and purely hypothetical.
2. With reference to the feared danger to human health in relation to the use of lead in hunting ammunition, it is believed that this danger is in fact excessively overestimated.
However, there are other approaches that can usefully be implemented, based on a correct treatment of the remains of the wild killed. It is all that set of practices, enclosed in the Anglo-Saxon term Handling, put in place after the shot and which, in particular in the case of ungulates and bovids, range from the recovery of the head that may have gone away injured to the preparation of the remains, providing for the elimination and correct disposal of bowels and parts intended for food consumption potentially contaminated by lead or other metals used as an alternative and which in any case may not be totally risk-free. Both the Producers' Associations and the Italian Hunting Associations are taking charge, also through a comparison and a dialogue already in place with ISPRA itself, to carry out a task of education and widespread awareness on the subject, in harmony with a similar line of action already being implemented across Europe. Lead is an unavoidable environmental contaminant and its widespread presence is also a consequence of past, and to a lesser extent, present human activities. Sources of exposure are numerous and include food, water, soil and dust, and air. The main source of exposure is food (including water).
In 2012, the European Food Safety Authority (EFSA) produced a Scientific Report (https://www.efsa.europa.eu/it/efsajournal/doc/2831.pdf) on the exposure of the European population to lead. Exposure estimates were made by EFSA in accordance with nearly 150.000 analytical data in food and dietary information across European countries. These studies show that although the levels of lead in game are generally higher than those found in meat or other by-products of farmed animals, the food with the highest concentrations does not necessarily contribute significantly to the total intake; instead, the greatest impact is provided by foods consumed in larger quantities. In particular, less than 6% of the contribution to total lead intake is due to meat consumption in general, and based on these data, it must be concluded that, since the frequency of consumption of game is less than 1% of the total number of occasions in which meat or other animal derivatives were consumed, is irrelevant compared to the total intake, also because of its evident episodicity. It is important to underline that EFSA has made a calculation of game intake that can be superimposed on the Italian average, so that the results of the study fit perfectly.
Lead and its trade
It is important to understand the extent of the ammunition trade in Europe to assess the potential impact of any possible legislative changes regarding the use of lead in ammunition. To understand the importance of our sector, consider that Europe has more than 12 million lead users (balls and balls). The largest number of hunters and sport shooters are found in France with more than 1.600.000 hunters and shooters, in Spain about 1.500.000 users and in Italy about 1.150.000. It is worth noting the high number of users compared to its small population of some northern European states such as Sweden (550.000 users), Finland (335.000) hunters), Denmark (289.000 civilian users and hunters).
A comparison on the price between lead and its possible alternatives
The average market price of lead shot cartridges is € 0,35 / unit excluding VAT.
The average market (end user) on the final prices of cartridges with alternative materials, always excluding VAT, are the following:
- zinc € 1,60 / unit
- steel / iron € 0,68 / unit
- tungsten 3,10 € / unit
- bismuth 2,15 € / unit
The ammunition trade currently accounts for around 25% of the retailer market in Europe; a rise in prices could certainly cause enormous harm to thousands of small businesses and merchants.
Some hypotheses of presumptive costs
On average a hunter consumes about 200 cartridges in a year (we are low) his potential cost increase would be equal to € 250 more per year. The cost to fix the shotguns considering that each hunter owns 3 shotguns on average would be around € 300. The installation of new chokes (around € 50 per shotgun): € 150. The purchase of new weapons (2 new shotguns) per hunter): € 2.500. Think of competitive shooters with a very high consumption of cartridges, they may have to face a very considerable wear of their barrels forcing a frequent replacement of their weapons for their competitive activity. It should be noted that the average hunter is on a tight budget and usually allocates a certain amount of money to his weapons / ammo. A substantial increase in prices relating to these products will only result in a reduction in the quantities that are acquired and in some cases also forcing the abandonment of hunting. All these numbers must be related to the number of users in Europe: more than 12 million Euros!
Final thoughts: but is it real risk?
It should be emphasized that the studies referred to by ISPRA, from which it can be deduced that a high consumption of game hunted using munitions containing lead is associated with an increase in blood lead values, mostly concerning populations living in areas close to the Arctic Circle (Canada, Alaska, Greenland, northern Russia), where, due to particular conditions, the consumption of game is particularly high, and has a percentage effect on the diet to an extent that is absolutely not comparable to that found in Italy, even in areas where such consumption is higher. With reference, in particular, to the supposed danger to human health of the use of lead-containing ammunition for hunting ungulates, the study by the Swedes Ulf Qvarfort (Swedish Defense Research Agency) and Christer Holmgren (Swedish Environmental Agency) from title “Lead in Game meat. Bioaccessibility of metallic lead fragments ”, also available in Italian (https://agricoltura.regione.emilia-romagna.it/approfondimenti/2013/piombo-nelle-munizioni/conclusioni-studio-svedese/view).
With reference to the risks associated with the direct ingestion of lead shot or fragments, escaped during the preparation of game meat, which got stuck in the digestive system (generally in the appendix), the scientific literature reports cases that have caused high levels of lead blood and, sometimes, signs of lead poisoning (saturnism). However, these are too rare eventualities to constitute a statistically appreciable risk, however related to a pathological condition of the subjects to whom the event occurred. We must have the courage to reach a conclusion considering that, in accordance with what EFSA has defined, on the basis of available data and taking into account Italian food consumption, the risk of a significant increase in the body load of lead for the Italian consumer of game hunted using leaded ammunition is inconsistent. On the basis of EFSA data it is in fact possible to argue that the contribution of lead contained in the meat of game is negligible, since, even in the worst case, it does not foresee a higher contribution to the current intake of lead through food. Therefore, the need for any limitation in the use of lead-containing ammunition for hunting can be excluded.