Slides shared by ECHA in Webinar about call for information regarding #EUAmmoBan.
The material is stored here to provide stakeholders with information about the scope of potential restrictions and what kind of information ECHA is looking for to assess whether a restriction is needed or not.
All material is courtesy of ECHA and was shared by ECHA as a part of webinar 10th of October 2019.
Questions and Answers:
(Summary and Q&A is not from ECHA, but they were written down by participant as notes)
Questions: How often Commissions decision follows ECHA findings and recommendations?
Answer: (my understanding) very often…
Questions: Concerning how much lead is used in different activities; do these numbers match the production? Are they validated by the manufactures?
Answer: Manufacturers, trade associations should provide info to ECHA
Questions: You are talking only about sport shooting and hunting. Does it mean that lead bullets for self-defense will be excluded from restriction?Answer: Difference between civilian and non-civilian use of ammunition – police, military use is out of the scope
Self-defense is not very clear, apparently no info on this use case
Questions: Hi, on slide 21 you indicate information you need. If I want to send information, can I submit on few topics and not all?
Questions: How does ECHA handle the evaluation of a diverse product category where different products within the category have different exposure pathways?
Questions: What about the very old (historic) weapons? Are they in the scope of your work? Which information do you need to consider derogation?
Answer: What is old? What is the use of these weapons? What is the volume of lead used in these weapons? Is the cost of switching to different material
Questions: In terms of ECHA’s approach to its risk assessment, do volumes of lead consumption matter form a human health perspective?
When ECHA says there’s no safe limit?
Questions: The ECHA guidance note states that one of the “Elements of an Annex XV assessment” is “An analysis of the availability and technical performance of alternatives”: Does that also include evaluation of the toxicity of alternatives?
Answer: Again, mention that copper could be an alternative… Every alternative will be checked in terms of toxicity.
Questions: Military use of ammunition is going to be in the scope of the restriction?
Answer: Out of scope
Questions: What if there is limited evidence on a particular issue e.g. safety of a type of ammunition? How do you consider limited evidence on key issues?
Answer: What is available in terms of safety of ammunition? Other union members can give info on such topic.
Questions: important? All the ammunition alternatives (copper, zinc, tin, steal, wolfram…) are harder than lead, so there will be much more projectiles reflections
resulting in deadly injuries. This is a physical law principle. How are you going to cope with this?
Answer: Good question indeed… What issues may arise outside of wetlands, any info is welcomed…, scientific evidence, statistics, …
In wetland study, detailed report and scientific assessment came from Germany…
Questions: There are questions difficult to answer, eg about game consumption patterns, meat handling and preparation, tonnage of lead used in different
activities etc without undertaking new research. Will you use some sort of confidence assessment for such data?”
Questions: Some types of firearms have not been mentioned specifically (e.g. pistols and revolvers for target shooting on outdoor ranges). Is ammunition for these
firearms within the scope of this investigation?
Answer: in the scope right now.
Questions: I did read thoroughly an ECHA report, including all its sources and I noticed that only pro-ban arguments were collected from studies. (I wrote an
example here, but it’s obviously too long for that window). Can you explain this approach?
Answer: Restriction is emotional; ECHA is scientific organization, dispassionate view, and only look at the facts…
Questions: training and sport shooting shouldn’t be influenced by this restriction?
Answer: indoor shooting out of the scope, outdoor shooting grounds are in the scope.
Questions: Shall there be an investigation whether hunters actually suffer any harm from use of lead ammunition?
Questions: If there is a restriction: Is it planned to combine the wetland restriction with the terrestrial restriction in one REACH annex XVII entry?
Answer: Decision by the commission
Questions: Are you taking into consideration also cases where a lead ban was lifted (i.e. Norway)?
Answer: we need more info why the ban was lifted; this might be taken into consideration.
Questions: Do you need information on water and drinking water? Which type of information
Answer: Info linking outside shooting ranges with lead poisoning of water is much appreciated.
Questions: How does ECHA approach risk to birds? What if there’s no impact on populations of birds? How will ECHA approach risk in this respect?
Answer: Probably the most relevant info. Risk Assessment Committee (RAC) was involved in study on wetlands, again figure of 1 million birds dying every year due
to lead poisoning.
Questions: Have the ECHA used any reports from Norway in the study?
Answer: all scientific evidence has been collected and used.
Questions: How you will record the lead retention of game eating people in this short time of the investigation
Answer: European Food Safety organization has data on food poisoning…
Questions: Lead home casting:
Answer: We need to understand how this is done, difference compared to commercial lead casting.
Questions: How to split quantities of indoor and outdoor shooting?
Answer: industry, organizations should provide info to ECHA… How and why they have done the split? Certain types of ammunition used indoor and others used outdoors, maybe? Basically, they do not know.
Q&A document will be made public shortly, recording available online asap, call for evidence finishing by Dec. 16, we welcome all sort of information.
Workshop probably held in February, active participants will be invited.