Prohibition of the use of lead shot over wetlands A consultation response from RSPB Northern Ireland, August 2008 The poisoning of waterbirds from lead gunshot pellets occurs when they mistakenly ingest pellets for grit to aid digestion1. This cause of bird deaths is avoidable, and the long‐term accumulation of lead pellets in sediments is a concern for the future. Effective, safe and reasonably priced non‐toxic alternatives to lead are now widely available following the introduction of regulations in the rest of the UK. Non‐toxic shot includes steel, bismuth and tungsten. To avoid the unnecessary poisoning of waterbirds, and for the UK to meet its commitments under the African Eurasian Waterbird Agreement (AEWA), the RSPB believes that there should be a ban on the use of lead shot over wetlands in Northern Ireland (in line with similar restrictions across the rest of the UK). We therefore welcome the proposals published by the Department of the Environment. However, we have some comments on the best model for the regulations in Northern Ireland. The proposed restrictions Of the three options that the Department has proposed, the RSPB can see advantages and disadvantages in adopting the different models already operating in Scotland and England/Wales. The model adopted in England and Wales restricts the use of lead shot below high water mark (HWM), over Sites of Special Scientific Interest for waterbirds and for shooting certain species of waterbirds. The benefits of adopting this model in Northern Ireland would be that HWM and ASSI boundaries are easily identified by shooters, and those enforcing the regulations, with the aid of a map. Restrictions on the shooting of certain species means that lead shot is unlikely to be used over most other, non‐notified, wetlands. However, this model could be unsuitable in Northern Ireland because:  Some nationally important wetland sites for waterbirds have yet to be declared Areas of Special Scientific Interest (ASSI)2;  It is not always clear to shooters where ASSI boundaries are located on the ground; and  Species that would be shot legally with lead could be taken over non‐ASSI wetlands, i.e. leading to continued contamination of the many small wetland sites in Northern Ireland. By contrast, the model adopted in Scotland, mirroring the Department’s preferred option, would ensure all wetlands are covered by the regulations. However, it may not be suitable for Northern Ireland because:  It will be more difficult to define the boundary of every wetland area, be it on a map or on the ground, making compliance and enforcement particularly difficult; and  The illegal shooting of waterbirds with lead over wetlands could not be detected through the monitoring of carcasses (i.e. there is no species schedule). Fisher, IJ, Pain, DJ & Thomas, VG (2006) A review of lead poisoning from ammunition sources in terrestrial birds. Biological Conservation 131, 42‐432. 2http://www.ehsni.gov.uk/pubs/publications/A_FORWARD_PROGRAMME_FOR_THE_DECLARATION_OF_ASSIs_IN
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The third option proposed by the Department is to restrict the use of lead shot on or over the foreshore and specified ASSIs known to be important for waterbirds, but not for the purpose of shooting certain species of waterbirds. Given that this model would not prohibit the use of lead shot over a large number of small wetland habitats that, cumulatively, would support large numbers of waterbirds at risk from lead poisoning, we do not see merit in this proposal. We are currently examining the data available for sites that could qualify for ASSI designation in Northern Ireland as nationally important sites for waterbirds. Preliminary analysis suggests the number of sites that remain to be designated is relatively small and that the most important sites for waterbirds have already been identified. Given that the ASSI network for nationally important sites for waterbirds may be largely complete and that the boundaries of these sites can be made available to shooters and those who will enforce the new regulations (i.e. the PSNI), on balance, the RSPB believes that the model adopted in England and Wales (Option 1 in the consultation paper) is the most appropriate for Northern Ireland. This ensures that areas below high water mark, wetlands notified for their waterbird importance, and, through the species‐focussed restriction, non‐notified wetlands are protected from continued lead deposition. Importantly, this should mean that waterbirds at risk of lead poisoning are protected from continued exposure to lead gunshot. We would expect the regulations to include a list of relevant ASSIs (which will require amendment as new sites are designated) and a list of relevant species to include ducks and geese. We are aware of evidence showing that waders, including snipe and woodcock can also suffer lead poisoning following ingestion of spent shot3. We recommend that the Department reviews this evidence, to ensure that appropriate safeguards exist to protect wading birds from unnecessary mortality and suffering. This may be important for curlew, the breeding population of which has undergone a significant decline in Northern Ireland over recent years. Further considerations Our experiences with lead shot restrictions elsewhere suggests there is a need to consider some other issues at this stage if the Department takes forward its proposals. We would expect to see:  Completion of the ASSI network for waterbirds in Northern Ireland, as soon as possible;  The introduction of a structured programme of compliance monitoring at the outset. This should include both direct monitoring of shooting practices through, for example, collecting spent cartridges in relevant areas for identification, and biological monitoring of quarry carcases;  Advisory material (including maps of ASSIs covered by the regulations) and best practice guidance as part of a structured and well‐resourced effort to raise awareness amongst hunters; and  Active enforcement of the regulations by PSNI and education of other interest groups and 3
Kaiser, GW, Fry, K and Ireland, JG (1980) Ingestion of lead shot by dunlin. Murrelet 61, 37. Hall, SL and Fisher, FM (1985) Lead concentration in tissues of marsh birds: relationships of feeding habits and grit preference to spent shot ingestion. Bulletin of Environmental Contaminants Toxicology 35, 1‐8. Veiga, J (1985) Contribution a lʹetude du regime alimentaire de la becassine sourde (Lymnocryptes minimus). Gibier Faune Sauvage 1, 75‐84. Pain, DJ (1990) Lead poisoning of waterfowl: a review. In; Matthews, G (Ed.) Managing waterfowl populations. IWRB, Slimbridge, pp 172‐181. Locke, LN, Smith, MR, Windingstad, RM, Martin, SJ (1991) Lead poisoning of a marbled godwit. Prairie Nat. 23, 21‐24. Locke, LN and Friend, M (1992) Lead poisoning of avian species other than waterfowl. In; Pain, DJ (Ed.) Lead poisoning in waterfowl, IWRB Special Publication 16, Slimbridge, pp. 19‐22. Beck, N and Granval, P (1997) Ingestion de plombs de chasse par la becassine del marais (Gallinago gallinago) et la becassine sourde (Lymnocryptes minimus) dans le nord‐ouest de la France. Gibier Faune Sauvage 14, 65‐70.
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stakeholders. Secondary poisoning risk to humans and wildlife We have written to both the Minister for the Environment and the Minister for Health outlining new research from the US that illustrates the risks posed to public health by elevated levels of lead in game meat. A note outlining this research appears in Annex 1 of this response. We urge the Department to consider the implications of these findings when deciding on the appropriate level of restriction to place on the use of lead ammunition in Northern Ireland. We believe the risk of secondary poisoning to birds of prey and other terrestrial species by all forms of lead ammunition (shot and bullet fragments) away from wetlands merits further consideration by the Department and we are disappointed that this issue is not discussed in the consultation document. A recent review paper by Fisher et al. (2006)1 demonstrates that many non‐waterbird species are at risk from, and being affected by lead shot and bullet fragments either in terrestrial environments, or as a result of their prey being exposed in this way. The use of lead ammunition results in poisoning from the direct ingestion of spent shot, ingestion of lead shot or bullet fragments in the flesh of prey and/or long‐term environmental contamination through the deposition of lead. Those species affected by secondary poisoning include red kite, sparrowhawk, buzzard, golden eagle, white‐
tailed eagle and peregrine falcon, all of which occur in Northern Ireland and are protected under the Wildlife (Northern Ireland) Order 1985 (as amended) and the European Birds Directive 1979. Lead toxicosis in these and other species can result in potentially serious negative impacts to their populations. Red kites are particularly vulnerable. Pain et al. (2007)4 found 21% of red kites sampled showed elevated bone lead concentrations, with 9% of birds found dead having died because of lead poisoning. At the very least, it is a cause of unnecessary mortality and suffering that right‐minded people would find unacceptable. We believe the risk posed by secondary poisoning to birds of prey and other terrestrial species by all forms of lead ammunition (shot and bullet fragments) away from wetlands merits further consideration by the Department and Northern Ireland Government, in conjunction with the UK Government. For further information on the RSPB’s response, please contact Dr. James Robinson, RSPB Northern Ireland, Belvoir Park Forest, Belfast BT8 7QT, tel: 028 9049 1547, email: [email protected]. Pain, DJ, Carter, I, Sainsbury, AW, Shore, RF, Eden, P, Taggart, MA, Konstantinos, S, Walker, LA, Meharg, AA & Raab, A (2007) Lead contamination and associated disease in captive and reintroduced red kites Milvus milvus in England. Science of the Total Environment 376, 116‐127. 4
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Annex 1. Potential hazard to human health and wildlife from fragments of lead bullets and shot in tissues of game animals Professor Rhys E. Green (RSPB/University of Cambridge) Lead is known to be poisonous to humans and other animals. Injurious effects of lead on humans are numerous and can be caused by sustained low levels of exposure. For example, there is evidence of permanent adverse effects of lead on cognitive function in children with blood lead levels below 10 μg dL‐1 (Canfield et al. 2003). Exposure of humans to lead occurs by several routes including dietary exposure. Meat from game animals shot using lead ammunition is a potential source. It was previously thought that meat from game shot with lead bullets and lead shot posed a minimal hazard because nearly all of the mass of the projectile remained in one large piece, which either passed through the carcass or was removed during food preparation or at the table. However, recent radiographic studies in the United States show that edible tissues of deer shot with lead bullets often contained bullet fragments, which were detected up to 15 cm from the main wound channel (Hunt et al. 2006). Ninety percent of the deer carcasses examined contained bullet fragments which were mostly small (<2 mm) and numerous (mean 160 per carcass). Many of the lead fragments were sufficiently small and distant from obviously injured tissue that professional butchers did not remove them when trimming venison for human consumption. Eighty percent of 30 deer shot with lead bullets, each of which was processed by a different butcher, gave rise to at least one 0.9 kg package of minced venison containing one or more lead fragments and 34% of packages contained fragments (Hunt et al. in review). Similar bullet fragment contamination of red deer and wild boar meat has been reported from Poland (Dobrowolska & Melosik 2008). Recent studies have also raised concerns about lead contamination of the meat of game animals killed using lead shot and of gamebirds which had ingested spent lead shot. Breast muscle tissue from some seabirds killed for food using lead shot in Greenland was sufficiently high for sustained consumption to be potentially hazardous to human health, even though all visible shot were removed from the tissues before analysis (Johansen et al. 2004). Presumably, this arises because of the presence of small fragments which are difficult to see. It has also been shown that the southern European practice of marinading game meat in vinegar increases the concentration of lead in the edible tissues, when lead pellets are present (Mateo et al. 2006). Adult Inuit people in arctic Canada showed elevation of blood lead levels, the degree of which was positively correlated with the quantity of hunted waterfowl in the diet (Dewailly et al. 2001). Analysis of stable isotope ratios of lead in blood samples indicates that exposure to ammunition is the main cause of elevated blood lead in indigenous people in Canada (Tsuji et al. 2008). Waterfowl are not the only game species for which contamination from lead shot is a potential hazard. Liver lead levels in 40% of a sample of Canadian birds of several widely hunted non‐waterfowl species (turkey, pheasant, partridge) exceeded health guidelines (Kreager et al. 2008). The main source of lead in these species is thought to be spent lead shot ingested by the birds, having been mistakenly identified as grit. The purpose of this note is to bring these findings about a potential hazard to human health from UK‐
hunted and imported meat from wild game to the attention of authorities responsible for controlling human exposure to dietary lead in the United Kingdom. The long‐running UK Total Diet Study of the Committee on Toxicity of Chemicals in Food, Consumer Products and the Environment monitors the lead content of a wide range of foods (Peattie et al. 1983), but we are not certain that its coverage of wild‐killed venison and gamebirds and estimates of variation among individuals in the quantities of these foods consumed are adequate for the evaluation of this potential problem. Exposure of wildlife, especially scavenging birds, to lead from spent ammunition is already known to be a significant cause of mortality, which the ban on the use of lead shot in wetlands in the UK has probably reduced. However, recent research indicates that bullet and lead shot fragments from animals killed by hunters and pest controllers away from wetlands may be a larger hazard to wildlife than was previously thought (Pain et al. 2007). References 4
Canfield, RL, Henderson, CR, Cory‐Slechta, DA, Cox, C, Jusko, TA & Lanphear, BP (2003) Intellectual impairment in children with blood lead concentrations below 10 mu g per deciliter. New England Journal of Medicine 348, 1517‐1526. Dewailly, E, Ayotte, P, Bruneau, S, Lebel, G, Levallois, P & Weber, JP (2001) Exposure of the Inuit population of Nunavik (Arctic Quebec) to lead and mercury. Archives of Environmental Health 56, 350‐357. Dobrowolska, A & Melosik, M (2008). Bullet‐derived lead in tissues of the wild boar (Sus scrofa) and red deer (Cervus elaphus). European Journal of Wildlife Research 54, 231‐235. Hunt, WG, Burnham, W, Parish, CN, Burnham, KK, Mutch, B & Oaks, JL (2006) Bullet fragments in deer remains: Implications for lead exposure in avian scavengers. Wildlife Society Bulletin 34, 167‐170. Hunt, WG, Watson, RT, Oaks, JL, Parish, CN, Burnham, KK & Tucker, RL (in review) Lead bullet fragments in packaged venison: potential for human dietary exposure. Proceedings of the Conference on Ingestion of Spent Lead Ammunition: Implications for Wildlife and Humans. The Peregrine Fund, Boise, Idaho. http://www.peregrinefund.org/Lead_conference/default.htm Johansen, P, Asmund, G & Riget, F. (2004) High human exposure to lead through consumption of birds hunted with lead shot. Environmental Pollution 127, 125‐129. Kreager, N, Wainman, BC, Jayasinghe, RK & Tsuji, LJS (2008) Lead pellet ingestion and liver‐lead concentrations in upland game birds from southern Ontario, Canada. Archives Of Environmental Contamination And Toxicology 54, 331‐336. Mateo, R, Rodriguez‐de la Cruz, M, Vidal, D, Reglero, M, & Camero, P, (2006) Transfer of lead from shot pellets to game meat during cooking. Science of The Total Environment 372, 480‐485. Pain, DJ, Carter, I, Sainsbury, AW, Shore, RF, Eden, P, Taggart, MA, Konstantinos, S, Walker, LA, Meharg, AA & Raab, A (2007) Lead contamination and associated disease in captive and reintroduced red kites Milvus milvus in England. Science of the Total Environment 376, 116‐127. Peattie, ME, Buss, DH, Lindsay, DG & Smart ,GA. (1983) Reorganization of the British total diet study for monitoring food constituents from 1981. Food Chem Toxicol. 21, 503‐507. Tsuji, LJS, Wainman, BC, Martin, ID, Sutherland, C, Weber, JP, Dumas, P & Nieboer, E (2008) The identification of lead ammunition as a source of lead exposure in First Nations: The use of lead isotope ratios. Science of The Total Environment 393, 291‐298. 5