Call for comments and evidence

Substance name: Lead and its compounds

EC Number: -

CAS Number: -

Scope: The purpose of the call for evidence is to collect information to assess the impacts of a possible restriction on the placing on the market and use of lead in ammunition (gunshot and bullets) and fishing tackle.

Compulsory fields are marked with an asterisk (*)

SECTION I. Personal information
(We may contact you about your comment and to request additional information

First Name: *
Family Name: *
Email: *
Country: *  
  Any personal data submitted is subject to ECHA’s data privacy rules.
 
SECTION II. Organisation
I am submitting information: *
Type of organisation/institution:
Country where the organisation or institution is legally established:
Name of organisation / institution:
  *Select one of the following options:
 
 
Note: the type and country of your organisation/institution will always be disclosed.
 
SECTION III. Non-confidential comments
Please provide your comments/answers in the comments boxes below (maximum 9 000 characters).
* I understand it is my responsibility to remove any kind of information I want to keep confidential from the comments box (the company name if declared confidential, emails, my signature etc.). ECHA will not be held liable for any damages caused by making the text publicly available.
GENERAL COMMENTS *
 
SPECIFIC INFORMATION REQUESTS
  1:

The scope of our investigation can be further elaborated to cover the following elements:

  1. Lead used in gunshot for hunting birds and other animals (e.g. rabbits) in terrestrial areas (i.e. outside of wetlands),
  2. Lead used in gunshot for ‘sports’ shooting, including training i.e. clay pigeons,
  3. Lead used in bullets/pellets for hunting any animal (e.g. deer),
  4. Lead used in bullets/pellets for ‘sports’ shooting, including training (indoor and outdoor) i.e. targets,
  5. Lead used in fishing tackle (weights, lures, jigs) for recreational fishing,
  6. Lead used in commercial fishing gear.

Please note that, in line with the terms of the Commission request, military uses are outside of the scope of the Commission’s request.

We will investigate the risks posed by lead to the environment as well as to humans via the environment (i.e. through the consumption of food).

The objective of this call is to gather information on the following topics for each of the uses A to F above:

Information on quantities of lead used and/or released to the environment and the resulting human health or environmental impacts. We are especially interested in information on:

  1. The quantity of lead present in products placed on the EU market and the potential for release to the environment during use;
  2. Information on the frequency and extent of lead poisoning observed in terrestrial species of birds, including predatory and scavenging species;
  3. Statistical information on the annual game meat consumption in a country or regional area? (Approximation of the weekly/yearly consumption in grams and/or the frequency of meals can be provided as well as the specific species consumed, if possible.);
  4. The consumption of game meat in specific groups such as infants, small children, women in childbearing age or high consumers (such as hunters and their families);
  5. Any differences between on- and off-hunting season consumption; is the game frequently e.g. frozen or otherwise preserved for later use;
  6. Information on the absorption rate of lead to human body from ingested gunshot and/or bullets or from some other analogous material;
  7. Information on the blood lead levels of game meat consumers and hunters;
  8. Any other relevant human health/exposure data related to lead containing gunshot and bullet or fishing tackle, or the alternatives of these articles?
  9. Information on the practice of ‘home casting’ of fishing tackle with lead and/or the re-filling of cartridges;
 
  2:

Current best practice (including effectiveness) to minimise lead exposure to humans or the environment during use, for example (please elaborate):

  1. best available techniques to remove lead from edible portions of meat prior to consumption;
  2. best available techniques to manage lead exposure on indoor and outdoor shooting grounds (including national or European standards or recommendations to capture lead and/or minimise environmental exposure to lead);
  3. Use of inert materials to encapsulate lead in fishing tackle.
 
  3:

Alternatives

  1. The volumes (tonnages) of lead shot, bullets and pellets as well as fishing weights of products placed on the EU market;
  2.  the identity of existing or emerging alternatives and any information on the existing market share of comparable products on the market that do not contain lead;
  3. technical and economic feasibility of potential alternatives, including information on product performance, the price differences between lead containing bullets, gunshot, pellets, fishing tackle and their alternatives, the number of products that could be affected, expected costs and timelines for full-scale production of the alternatives, etc.;
  4. availability of alternatives in sufficient quantities on the market: current and future trends;
  5. hazard and risk of the use of alternatives, including any impacts on animal welfare;
  6. other potential impacts stemming from the use of alternatives, e.g., discontinuation of certain products, changes in product performance, etc.
 
  4:

Information on other socio-economic impacts in response to a possible restriction

  1. costs and benefits to affected actors, e.g. producers, professionals, consumers (including producers of alternatives). Please provide data on key economic parameters, such as profit-loss, turnover, the number of people employed, current share of products containing lead, etc.
 
SECTION IV. Non-confidential attachments

If needed, attach additional non-confidential information (data available in excel format, reports, etc.) below. Do not attach the same information already provided in section III here. If part of the information is confidential, please use section V to share it.
Upload Attachment:
If you would like to submit more than one document, please create a zip archive where you include all files and upload the zip file as attachment. Maximum file size is 20 MB.
  *  I have removed/blanked the information I wish to keep/I have claimed confidential from all the attachments in section IV (for example: company name, company logo, personal names, email, signatures, other confidential business data).I understand that ECHA will not be held liable for any damages caused by making the attachments publicly available.
SECTION V. Confidential attachments
  If needed, attach confidential information below (for example: studies, laboratory tests, additional contact details, business data, etc.). Do not add the same information already provided in the previous sections here. Confidential information will only be used by ECHA, including its Committees, by the Member State competent authorities and by the European Commission.
  If you upload a confidential attachment, please justify the reasons for confidentiality of the information in the field below.
  This will facilitate ECHA’s work if it receives requests for access to documents.
Upload Confidential Attachment:
If you would like to submit more than one document, please create a zip archive where you include all files and upload the zip file as attachment. Maximum file size is 20 MB.

I have the following reasons enumerated in Article 4(1) or 4(2) of Regulation (EC) No 1049/2001 regarding public access to documents why the information submitted as confidential cannot be disclosed to persons requesting access to documents (please explain below in the commenting field those reasons; a reason could be that the protection of your commercial interests, including intellectual property, would be undermined).

 
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