November 16,2011 

via Federal Express overnight delivery 

Administrator Lisa P. Jackson 

Environmental Protection Agency 

USEP A Headquarters 

USEP A Ariel Rios Building (AR) 

1200 Pennsylvania Avenue N.W. 

Washington, DC 20004 

Dear Administrator Jackson, 

Please find enclosed a Petition for Rulemaking tmder Section 21 ofthe Toxic Substances Control 

Act ("TSCA"), 15 U.S.c. § 2620(b)(3). Petitioners Center for Biological Diversity, Loon Lake 

Loon Association, and Project Gutpile request that the EPA evaluate the unreasonable risk of 

injury to the environment from fishing tackle containing lead (including fishing weights, sinkers, 

lures, jigs and/or other tackle) ofvarious sizes and uses that are ingested by wildlife, resulting in 

lead exposure. Petitioners request that the EPA initiate a proceeding for the issuance of a 

rulemaking under Section 6 of TSCA to adequately protect against such risks (15 U.S.C. § 

2620(a); 15 U.S.C. § 2605(a)(2)(A)(i». 

TSCA requires that within 90 days after filing of a petition, the EPA shall either grant or 

deny the petition (15 U.S.C. § 2620(b)(3». If the Administrator grants the petition, the 

Administrator shall promptly commence an appropriate proceeding. If the Administrator 

denies the petition, the Administrator shall publish in the Federal Register the 

Administrator's reasons for such denial (15 U.S.C. § 2620(b)(3». 

We appreciate your consideration ofthe enclosed Petition and await your determination. 

Sincerely, 

Center for Biological Diversity 

Arizona • California • Nevada • New Mexico • Alaska • Oregon • Minnesota· Vermont· Washington, DC 

Adam Keats, Senior Counsel • 351 California St., Suite 600 • San Francisco, CA 94104 


Phone: 415-436-9682 x304 • Fax: 415-436-9683. akeats@biologicaldiversity.org 

1 

PETITION TO THE 

ENVIRONMENTAL PROTECTION AGENCY 

TO REGULATE LEAD FISHING TACKLE 

UNDER THE TOXIC SUBSTANCES CONTROL ACT 

Common loon photo courtesy of U.S. Fish and Wildlife Service

PETITIONERS 

CENTER FOR BIOLOGICAL DIVERSITY 

LOON LAKE LOON ASSOCIATION 

PROJECT GUTPILE 

PETITION FOR RULEMAKING UNDER THE TOXIC SUBSTANCES CONTROL ACT 

November 16, 2011 
2 

EXECUTIVE SUMMARY 

Pursuant to the Toxic Substances Control Act (“TSCA”), 15 U.S.C. § 2601 et seq., 

Petitioners Center for Biological Diversity, Loon Lake Loon Association and Project 

Gutpile formally petition the Environmental Protection Agency (“EPA”) to initiate a 

proceeding for the issuance of a rule under Section 6 of TCSA to adequately protect 

against the unreasonable risk of injury to the environment from fishing tackle containing 

lead that are of the sizes and uses that are ingested by wildlife, resulting in lead exposure. 

Fishing tackle, as used in this petition, refers to and includes fishing weights, sinkers, 

lures, jigs, and other fishing gear. 

Based on information extending back to Roman times more than 2,000 years ago, lead 

has long been identified as a highly toxic substance with lethal properties and numerous 

pathological effects on living organisms. Health effects from lead exposure can run the 

gamut from acute, paralytic poisoning and seizures to subtle, long-term mental 

impairment, miscarriage and impotence. Lead is a cumulative metabolic poison affecting 

a large number of biological functions including reproduction, growth, development, 

behavior and survival. Even low levels of exposure to lead can cause neurological 

damage, and there may be no safe level of lead in the body tissues of fetuses and young. 

Despite this knowledge, lead continues to be used in manufactured products, many of 

which are sources of toxic lead exposure to wildlife and to humans. 

In recent decades the federal government has begun to implement regulations to reduce 

the exposure of human beings to lead in drinking water, paint, gasoline, toys, toxic 

dumps, lead wheel balancing weights and both indoor and outdoor shooting ranges. Strict 

recycling regulations have been imposed on disposal of lead-acid batteries. However, lost 

or discarded lead fishing weights and tackle are uncontrolled and lead remains widely 

encountered and distributed in the environment from these sources. Lead fishing tackle 

can accumulate in aquatic habitats, where animals encounter and ingest small lead items, 

often mistaking them for grit or food. Lead fishing tackle such as sinkers, jigs and 

weights continue to cause the needless and painful lead poisoning deaths of waterfowl 

such as swans, ducks, geese and loons. 

Tackle manufacturers now market a wide variety of non-lead, nontoxic fishing tackle that 

can replace lead tackle. There is no technological or commercial reason why nontoxic 

fishing tackle with comparable effectiveness should not be substituted for lead. Several 

states in the Northeast have begun to require non-lead fishing weights and lures in an 

effort to protect loons and other wildlife. The EPA has long held that whenever a toxic 

substance customarily used in the manufacture of commercial products can be replaced 

by a nontoxic substitute, articles made of the toxic substance should be removed from the 

market. Fishing gear containing lead could economically be replaced with effective, 

nontoxic alternatives, thus making a strong argument for EPA regulatory action. 

TSCA grants the EPA the broad authority to regulate chemical substances that “present 

an unreasonable risk of injury to health or the environment” (15 U.S.C. § 2061). The 

EPA may regulate the manufacture, processing, distribution, use or disposal of such 
3 

chemical substances. Specific control mechanisms include: prohibitions on an entire or 

certain use of a chemical substance; limitations on allowable concentration levels; 

labeling or recordkeeping requirements; and obligations to issue notice of risks of injury 

(15 U.S.C. § 2605(a)). The EPA has already declared that lead is a toxic substance, and 

has removed nearly all products containing lead from the market. Eliminating lead 

exposure may be achieved through a range of alternatives, up to and including the EPA 

prohibiting the manufacture, processing, or distribution in commerce of a chemical 

substance for a particular use (15 U.S.C. § 2605(a)(2)(A)(i)). 

States that have mandated use of nontoxic fishing gear continue to have active fishing 

communities that have successfully transitioned away from lead products. Market forces 

in these states have caused a full line of nontoxic replacement products to be made 

available to the public, demonstrating that commercially available alternatives exist and 

the economic consequences of removing toxic lead from fishing tackle sources from the 

environment can be minimal. The EPA is obligated under TSCA to grant this petition and 

initiate a proceeding for the issuance of a rule under Section 6 to protect wildlife and the 

environment from unreasonable risk of lead poisoning from lead fishing tackle.
4 

TABLE OF CONTENTS

EXECUTIVE SUMMARY ...............................................................................................2 

I. PETITIONERS AND STANDING TO FILE .....................................................5 

II. NATURE OF THE REQUESTED ACTION......................................................6 

III. PREVIOUS EFFORTS TO REGULATE ...........................................................7 

IV. REASON FOR THE REQUEST..........................................................................9 

 A. Introduction................................................................................................9 

 B. Pathways of Lead Exposure....................................................................10 

 C. Sources and Quantities of Lead in the Environment from Fishing 

Activities....................................................................................................12 

 D. Toxic Effects of Lead on Wildlife ...........................................................12 

 E. Lead Fishing Tackle Poisonings by Species...........................................16 

 1. Loons .............................................................................................16 

 2. Swans.............................................................................................17 

 3. Other Birds...................................................................................18 

 4. Reptiles..........................................................................................18 

 F. Lead Fishing Tackle Risk of Exposure to Humans ..............................18 

V. AUTHORITY TO ACT.......................................................................................21 

VI. ALTERNATIVES TO LEAD FISHING TACKLE .........................................22 

VII. EXISTING REGULATIONS .............................................................................24

VIII. DESCRIPTION OF FEDERAL REGULATIONS REQUESTED.................26 

IX. CONCLUSION ....................................................................................................27

X. REFERENCES.....................................................................................................28
5 

1. PETITIONERS AND STANDING TO FILE

Section 21 of the Toxic Substances Control Act (“TSCA” or the “Act”, 15 U.S.C. § 2601 

et seq.) provides that “any person” may petition the Environmental Protection Agency 

Administrator (“EPA”) to initiate a proceeding for the “issuance, amendment, or repeal of 

a rule” (15 U.S.C. § 2620(b)(3)). Petitioners therefore have standing to petition the EPA 

to initiate proceedings to regulate lead fishing tackle under section 2605 of TSCA. 

Petitioner Center for Biological Diversity is a non-profit organization that works to 

protect endangered species and wild places through science, policy, education, citizen 

activism, and environmental law. The Center and its 320,000 online activists and 

members have an ongoing interest in protecting wildlife from lead poisoning. Since 2004, 

the Center has taken action through a “Get the Lead Out” campaign to change federal and 

state policies regulating lead, to prevent toxic lead from entering the food chain and 

affecting wildlife or human health. The Center has been a leading proponent of federal 

regulations on lead ammunition and fishing tackle to protect wildlife at risk from lead 

poisoning. 

Petitioner Loon Lake Loon Association is a nonprofit organization concerned about the 

common loon in the Pacific Northwest. The association works to protect the common 

loon, preserve their habitat and educate the public. 

Petitioner Project Gutpile is an educational organization comprised of hunters/wildlife 

biologists and anglers that provides educational resources for sportsmen about lead-free 

hunting and angling. Project Gutpile has been promoting non-lead ammunition and 

fishing tackle and raising awareness about lead in the hunting and angling communities 

since 2002. 

TSCA requires that within 90 days after filing of a petition, the EPA shall either grant or 

deny the petition (15 U.S.C. § 2620(b)(3)). If the Administrator grants the petition, the 

Administrator shall promptly commence an appropriate proceeding. If the Administrator 

denies the petition, the Administrator shall publish in the Federal Register the 

Administrator’s reasons for such denial (15 U.S.C. § 2620(b)(3)). 

Contact information for petitioners: 

Center for Biological Diversity 

351 California Street, Suite 600 

San Francisco, CA 94104 

Contact: Jeff Miller 

(415) 436-9682 x303 

jmiller@biologicaldiversity.org
6 

II. NATURE OF THE REQUESTED ACTION

Petitioners Center for Biological Diversity, Loon Lake Loon Association and Project 

Gutpile request that the EPA evaluate the unreasonable risk of injury to the environment 

from fishing tackle containing lead (including fishing weights, sinkers, lures, jigs and/or 

other tackle) of various sizes and uses that are ingested by wildlife, resulting in lead 

exposure. Petitioners request that the EPA initiate a proceeding for the issuance of a 

rulemaking under Section 6 of TSCA to adequately protect against such risks (15 U.S.C. 

§ 2620(a); 15 U.S.C. § 2605(a)(2)(A)(i)). This Petition sets forth facts presenting a 

reasonable basis to conclude that such a rulemaking is necessary to protect wildlife from 

the ongoing threat of lead poisoning. 

TSCA grants the EPA the broad authority to regulate chemical substances that “present 

an unreasonable risk of injury to health or the environment” 15 U.S.C. § 2601. TSCA 

mandates that the EPA must regulate chemical substances where there is a “reasonable 

basis to conclude” that such substances “present an unreasonable risk of injury to health 

and or the environment” (15 U.S.C. § 2605(a)). The EPA may regulate the manufacture, 

processing, distribution, use or disposal of such chemical substances. Specific control 

mechanisms include: prohibitions on an entire or certain use of a chemical substance; 

limitations on allowable concentration levels; labeling or recordkeeping requirements; 

and obligations to issue notice of risks of injury. (15 U.S.C. § 2605(a)). Regulations may 

be achieved through a range of alternatives, up to and including the EPA prohibiting the 

manufacture, processing, or distribution in commerce of a chemical substance for a 

particular use (15 U.S.C. § 2605(a)(2)(A)(i)). 

Lead used in fishing tackle is a “chemical substance” falling within the scope of TSCA. 

As defined by TSCA, “Except as provided in subparagraph (B), the term “chemical 

substance” means any organic or inorganic substance of a particular molecular identity, 

including (i) any combination of such substances occurring in whole or in part as a result 

of a chemical reaction or occurring in nature and (ii) any element or uncombined radical” 

(15 U.S.C. § 2602(2)(A)). 

Most other uses of lead, such as lead-based paints, plumbing pipe and fixtures, and 

leaded gasoline, are already subject to strict regulation (15 U.S.C. §§ 2681-2692). In 

January 2008, lead and lead compounds were added to the Priority Testing List (40 

C.F.R. 716.120; see also 15 U.S.C. § 2603(e)), requiring certain lead manufacturers to 

submit unpublished health and safety reports to the EPA (73 Fed. Reg. 5109-5115; Jan. 

29, 2008). Automobile wheel balancing weights will be phased out with an EPA 

proposed rule scheduled for 2011. Manufacturers of consumer products intended for use 

by children who also manufacture lead or lead compounds are required to report certain 

health and safety data to the EPA. However, there is currently no specific regulation of 

lead fishing tackle under TSCA.
7 

III. PREVIOUS EFFORTS TO REGULATE 

The EPA expressed its authority to regulate lead fishing tackle under the Toxic 

Substances Control Act in 1994 by proposing a ban on smaller sized lead sinkers 

(USEPA 1994). The EPA proposed a rule under section 6(a) of TSCA to prohibit the 

manufacture, importation, processing, and distribution in commerce in the United States, 

of fishing sinkers less than 25 mm containing lead or zinc, and mixed with other 

substances, including those made of brass, due to unreasonable risk of injury to human 

health or the environment. This proposal was issued in response to a citizens’ petition to 

require that the sale of lead fishing sinkers be accompanied by a label or notice that such 

products are toxic to wildlife. The EPA recognized the risk that lead sinkers presented to 

wildlife, and concluded that a labeling requirement would not go far enough to reduce 

this risk. The EPA preliminarily determined that other laws were, in fact, insufficient to 

reduce the unreasonable risk of harm to health and environment from smaller-sized lead 

fishing sinkers (59 Fed. Reg. 11122). The EPA recognized that, in the area of wildlife 

protection, there was some overlap between the statutory authorities administered by the 

Department of the Interior and the EPA, but that “some activities, the regulation of which 

could protect wildlife (e.g., regulation of the manufacture, processing, and distribution in 

commerce of chemical substances), are clearly within the purview of the EPA” (59 Fed. 

Reg. 11122). 

To date, the rule has not been finalized and the proposed regulations have apparently 

been abandoned. In 2005 EPA issued a proposal to withdraw the proposed rule, but has 

not done so (see 70 Fed. Reg. 27625). It is likely that the “Common Sense in Fishing 

Regulations Act,” introduced to the Senate in 1995, prompted the EPA to hold-off on a 

final rulemaking, as it directed the EPA not to issue the proposed ban on smaller lead 

sinkers (Sen. 505, 104th Cong. (March 6, 1995)). When introducing the bill, Senator 

Harkin declared that the proposed ban was nothing more than “government regulation run 

amok” and that the risks presented by lead sinkers were not unreasonable (Sen. 505, 104th

Cong. (March 6, 1995), Senator Harkin, Statements on Introduced Bills and Joint 

Resolutions). Although the bill was never passed the EPA has still not acted to regulate 

lead sinkers that pose lead exposure risks to wildlife. 

On August 3, 2010, the American Bird Conservancy, Association of Avian Veterinarians, 

Center for Biological Diversity, Project Gutpile and Public Employees for Environmental 

Responsibility submitted a petition to the EPA under TSCA requesting that the EPA issue 

a proposed rule to prohibit the manufacture, processing, and distribution in commerce in 

the United States of lead ammunition (including bullets and shotgun pellets) and lead 

fishing tackle (including sinkers, jig heads, weights, and all other fishing tackle). The 

EPA informally denied the petitioners’ request to ban lead in fishing gear in a November 

4, 2010 letter to the petitioners.1

 The EPA published the reasons for the denial in the 

November 17, 2010 Federal Register, stating that the petitioners did not demonstrate that 

a uniform, nationwide rule banning lead fishing sinkers was necessary and that the 

petitioners did not demonstrate that the requested ban was the least burdensome 

alternative. The EPA did not consider any other alternatives for regulating lead fishing 

 

1

 EPA denied petitioners’ request for a ban on lead shot and bullets on August 27, 2010. 
8 

tackle other than a blanket nationwide ban of lead fishing tackle. The EPA did not 

consider banning or regulating a subset of lead fishing tackle of the sizes and uses most 

likely to result in lead exposure. The EPA’s denial of that petition is currently the subject 

of litigation in the D.C. federal district court. 

This current petition before the EPA seeks very different relief under TSCA than the 

2010 petition, is brought by a different set of petitioners, and introduces new information. 

This petition responds to the EPA’s assertion that there is not evidence demonstrating 

that a uniform nationwide rule banning all lead fishing tackle is necessary. This petition 

requests that the EPA instead regulate a subset of lead fishing tackle – those sizes and 

uses of lead fishing tackle likely to be ingested by wildlife and result in lead exposure, 

posing unreasonable risk to the environment. This petition does not specifically ask for a 

ban, whether of all lead fishing tackle or a subset of lead fishing tackle most likely to 

result in lead exposure to wildlife. It instead asks the EPA to initiate a rulemaking for 

regulations that adequately protect wildlife against the unreasonable risk of injury from 

lead fishing tackle. The EPA has latitude under TSCA to consider a broad range of 

alternatives for addressing an unreasonable risk of injury, including prohibitions on an 

entire or certain use of a chemical substance, limitations on allowable concentration 

levels, labeling or recordkeeping requirements, or obligations to issue notice of risks of 

injury. This petition does not request a specific regulatory alternative. It is the obligation 

of the EPA to determine the least burdensome alternative that adequately addresses the 

unreasonable risk of injury. 
9 

IV. REASON FOR THE REQUEST 

 A. Introduction 

Lead has been used by humankind for millennia. Lead had numerous uses in ancient 

Egypt and it is believed that toxicity arising from the use of lead in water pipes, pottery, 

cosmetics, food and wine may have contributed to the fall of the Roman Empire 

(Hernberg 2000). The properties of lead as a biocide have been well known for hundreds 

of years. It is now unquestioned scientific knowledge that lead is a toxic substance with 

potentially lethal as well as numerous pathological effects on living organisms of all 

sorts. Despite this knowledge, lead has continued to be used in a wide variety of 

manufactured products, many of which are continued sources of toxic lead exposure to 

human beings and to wildlife. 

The use of lead for fishing activities dates back thousands of years. The lead poisoning 

effects of lead fishing tackle ingested by wildlife have been well documented. 

Recognizing this problem, some jurisdictions began placing restrictions on the use of lead 

fishing tackle beginning in the 1970s and 1980s. These restrictions are geographically 

limited and significant amounts of lead continue to be deposited in aquatic habitats and 

enter the food chain from lost or discarded fishing tackle, including lures, sinkers, lead 

core fishing line, downrigger cannonballs, weights, and a variety of fishing traps and nets 

that employ the use of lead. 

Lead can remain in the environment relatively intact and stable for decades, or under 

some environmental conditions it can be readily released and taken up by plants or 

animals (ATSDR 2007). Lost or discarded lead fishing weights and other lead fishing 

tackle of smaller sizes can be ingested by wildlife, particularly dabbling and diving water 

birds such as such as swans, ducks, geese and loons. Absorbed or ingested lead can cause 

a range of biochemical, physiological, and behavioral effects in species of invertebrates, 

fish, amphibians, reptiles, birds, and mammals. Wildlife can be exposed to lead through 

feeding in aquatic environments and ingesting contaminated vegetation and sediments, 

feeding on invertebrates or vertebrates containing lead, or ingesting small lead objects or 

fragments directly, mistaking them for grit or food. Although lead is a naturally occurring 

metal in the environment, for biological systems it is a nonessential metal with no 

functional or beneficial role at the molecular or cellular level. Ingested lead substitutes in 

dysfunctional ways for calcium in biochemical interactions, with harmful effects on 

neurological functions, bone structure, renal function, reproductive functions, pancreatic 

functions, and muscular functions, among others. 

Lead is toxic to organisms at very low levels, and has lethal and severe sublethal effects 

at higher levels (IPCS 1989; NCM 2003). Lead can act as a neurotoxin, and numerous 

studies indicate that blood lead concentrations even below 10 micrograms per deciliter 

can have adverse developmental effects on intellectual functioning and social-behavioral 

conduct in humans (Needleman et al. 1990; Canfield et al. 2003; Ris et al. 2004). Human 

fetuses and young children are particularly sensitive to even low levels of lead exposure 

and can easily suffer permanent neurological damage. Clinicians now assert that there is 
10 

no safe level of lead in the body tissues for fetuses and young children (e.g. Canfield et 

al. 2003; Lanphear et al. 2005, 2006; Carlisle et al. 2009). 

In recent decades the federal government has taken various regulatory actions to reduce 

the exposure of humans to lead in drinking water, paint, gasoline, toys, toxic dumps, 

automobile wheel balancing weights, and indoor and outdoor shooting ranges. However, 

other lead sources causing significant contamination are still uncontrolled. Lead exposure 

to wildlife has been widely documented yet is not adequately regulated. 

As long as lead fishing tackle of the sizes and uses commonly ingested by wildlife 

remains available for purchase and use, numerous species of wildlife will continue to be 

poisoned by lead. Human health is also threatened by the use of lead fishing gear. 

Although the few existing state regulations regarding lead fishing tackle generally 

address lead weights less than 25 mm in diameter or less than one ounce in weight, there 

is scientific evidence that some birds can ingest lead fishing weights up to two ounces in 

weight and there is evidence of ingestion by loons of sinkers up to 2.75 ounces in weight; 

there is also evidence of ingestion of sinkers by water birds greater than 25 mm in 

diameter (Scheuhammer and Norris 1995; Franson et al. 2003). Observed and 

documented sizes of lead objects in the gizzards of waterfowl may be somewhat smaller 

at necropsy than at the time they were first ingested, due to the grinding action of the 

gizzard and the presence of small stones against which lead objects are abraded. The EPA 

must evaluate the risk of injury to wildlife from all sizes, weights and types of lead 

fishing tackle and initiate a rulemaking to regulate lead fishing tackle of the sizes, 

weights, and uses likely to cause unreasonable risk of injury. 

B. Pathways of Lead Exposure

Lead has been widely dispersed throughout the environment from activities such as 

mining, smelting, manufacturing, and engine combustion. Many historical documented 

instances of lead exposure among terrestrial wildlife species have been associated with 

small contaminated areas, such as around metal smelters, shooting ranges, lead paint 

contaminated buildings, or locations with intense hunting or fishing pressure (Blus et al. 

1991, Henny et al. 1991; Blus et al. 1995; Sileo et al. 2001; Lewis et al. 2001). 

Manufacture of leaded gasoline, lead-based paints and pesticides, and use of lead solder 

in cans has now been nearly eliminated in the United States. The EPA recently granted a 

petition to ban lead automobile wheel balancing weights, and initiated a proceeding under 

TSCA to investigate potential lead hazards associated with the manufacture, processing, 

and distribution in commerce of lead wheel weights (USEPA 2009). The EPA anticipates 

publishing a proposed rulemaking on regulating lead wheel weights in October 2012. A 

petition to phase out the largest remaining permitted use of leaded gasoline, that for 

piston-engine aircraft, was filed with the EPA in 2010. The EPA has already solicited 

comments on that petition and issued an advance notice of proposed rulemaking on lead 

emissions from piston-engine aircraft using leaded aviation gasoline (USEPA 2010a, 

2010b). 
11 

Environmental distribution of lead from fishing is widespread, although it is difficult to 

estimate the magnitude of lead exposure compared to other sources, such as legacy 

residues of leaded gasoline exhaust deposition, emissions from smelters, improper 

disposal of paint chips and dust, and lead ground to dust from lead wheel weights falling 

off vehicles. 

There is very little information on lead from fishing weights in aquatic habitats which 

could be solubilized and taken up by invertebrates or fish (Stansley et al. 1992; Hui 

2002). The fate of elemental lead in aquatic environments is influenced by water 

chemistry, wave action, water flow, and pH (see Scheuhammer and Norris 1995). In 

lakes, lead particles may be adsorbed onto sediment and soil particles. The bioavailability 

of lead is related to the presence of organic matter and sediments and acidity. In coastal 

ocean waters, lead sinkers may easily be abraded by wave action against rocks, releasing 

small fragments into the water column. 

Numerous studies describe injuries to fish incurred by tackle (often containing lead) and 

small fragments passing through the digestive track of fish could release lead. Although 

there is no documentation of such lead uptake or poisoning in fish, there are reported 

cases of lead poisoning of turtles that have ingested lead fishing tackle (Borkowski 1997; 

Scheuhammer et al. 2003). Hooked fish can ingest or retain attached lead fishing tackle 

such as hooks and jigs, and become a potential pathway of lead exposure for predatory 

birds consuming fish containing such lead fishing gear. 

There is a large body of evidence documenting significant deposition of lead fishing 

tackle in aquatic environments and subsequent ingestion by numerous bird species. There 

is extensive documentation of direct ingestion of lead sinkers, jigs and other fishing 

tackle by dabbling and diving ducks, swans, loons and other water birds. Water birds are 

lead poisoned from ingesting lead fishing sinkers or jigs lost by anglers on the bottom of 

water bodies. Sport anglers attach lead weights to fishing lines to sink the hook, bait, or 

lure into the water. Some anglers use lead-weighted hooks, called jigs. A sinker or jig can 

accidentally detach from a line and fall into the water or the hook or line may become 

tangled and the line may break or be cut. Aquatic birds may ingest lead objects while 

collecting gizzard stones or by preying on live bait or escaped fish with attached fishing 

gear. Many ducks and other water birds forage for food in the mud at the bottom of lakes. 

Most of these birds also swallow small stones and grit that aid in grinding up their food. 

Some of the grit may contain lead from fishing tackle. 

Since birds do not generally ingest lead fishing weights greater than 2 ounces, the 

greatest hazard to water birds from lead fishing tackle seem to be the smaller weights 

used by sport anglers (Scheuhammer and Norris 1995). However, Franson et al. (2003) 

found a pyramid sinker weighing 2.75 ounces in a common loon and found 5 sinkers in 

other water birds greater than 25 mm in diameter. Observed sizes of lead objects in the 

gizzards of waterfowl may be somewhat smaller at necropsy than at the time they were 

first ingested, due to the grinding action of the gizzard and the presence of small stones 

against which lead objects are abraded. Birds such as loons may ingest fishing weights 

while ingesting bait attached to tackle (Franson and Cliplef 1992; Stone and Okoniewski 
12 

2001; Evers 2004). Once ingested, lead objects retained within the ventriculus of birds 

will be abraded and will be partially dissolved by acid in the digestive tract, and absorbed 

into the blood with potentially toxic effects (IPCS 1989; Scheuhammer and Norris 1995, 

1996; NCM 2003; Scheuhammer et al. 2003; Pokras et al. 2009). 

C. Sources and Quantities of Lead in the Environment from Fishing 

Activities

Accurate quantitative information on how much lead is entering the environment from 

lead fishing weights and tackle sinkers is not available, but approximations can be made 

from the quantities of lead fishing tackle sold in the U.S., assuming most or many sinkers 

are purchased to replace those lost while fishing (Scheuhammer et al 2003), and from 

studies of sinker and tackle loss by anglers. Roughly 4,000 metric tons of lead fishing 

sinkers are sold annually in the U.S. (Scheuhammer et al 2003; USGS 2008). Studies of 

sinker and tackle loss rates among recreational anglers vary - a variety of factors can 

influence whether lead will be lost, including the type of fishing activity, the location of 

the activity, the time of year, and the skill of the angler. Fishers lost 2-3 sinkers per 

angling day in the United Kingdom (Bell et al. 1985). Anglers in the U.S. reported losing 

0.18 sinkers/hour, and 0.23 hooks and lures/hour, with 2% of anglers reporting losing a 

fish with tackle still attached (Duerr 1999). Radomski et al. (2006) reported average loss 

rates on Minnesota lakes of 0.0127 lures per hour, 0.0081 large sinkers per hour, 0.0057 

split shot sinkers per hour, 0.0247 jigs per hour, and 0.0257 hooks per hour; for a 

estimated total of one metric ton of lead lost for 6,000 anglers in 2004. 

Assessments of concentrations of lost or discarded lead fishing tackle along U.S 

shorelines have found 0.01 sinkers/square meter of shoreline in areas of low angling 

pressure up to 0.47 sinkers/m2

 in areas of high angling pressure (Duerr and DeStefano 

1999), with much higher densities (up to 190 sinkers/m2

) in studies in Europe (Cryer et 

al. 1987; Sears 1988). 

Amounts of lead fishing weights produced and approximations of lost tackle indicate that 

fishing can introduce significant amounts of lead into aquatic environments. The USEPA 

(1994) estimated in 1994 that 450 million toxic fishing sinkers containing lead or zinc 

were produced each year and potentially entering the environment; and that figure may 

now be higher. Compare that figure to the estimated 4 million pounds of lead thought to 

annually enter the environment due to lead wheel weights falling off cars and trucks 

(USGS 2003; USEPA 2011a). Based on this amount of lead entering the environment, 

the EPA initiated regulations requiring non-lead wheel weight alternatives. The amount 

of lead entering the environment from lead fishing tackle nearly two decades ago was 

thought to be in the range of more than 100 times the amount from wheel weights, and in 

sizes and locations much more likely to cause significant lead exposure to wildlife. 

 D. Toxic Effects of Lead on Wildlife 

Lead has long been recognized as a poison to living organisms (Grinnell 1894; Engsted 

1932; Horton 1933), with negative effects on general health, reproduction, and behavior 
13 

(Ris et al. 2004). Lead was highlighted as an important cause of mortality in wildlife 

populations in the late 1950s, when ingestion of spent lead shotgun pellets from hunting 

or lead fishing sinkers was recognized to cause death in a wide range of wild waterfowl 

(Bellrose 1959). Reports of poisoned wildlife have continued frequently since that time 

(e.g. Bates et al. 1968; Irwin and Karstad 1972; Sanderson and Bellrose 1986; Kramer 

and Redig 1997; Schulz et al. 2006). It is well recognized that lead can be absorbed from 

the gastrointestinal tract of birds and mammals, cause damage in various organs, and 

result in behavioral changes, significant illness, and even death depending on the amount 

ingested (Reiser and Temple 1981; Kramer and Redig 1997; Fisher et al. 2006). 

Lead objects or fragments ingested by birds may be rapidly regurgitated, retained for 

varying periods, or completely dissolved with the resulting lead salts absorbed into the 

bloodstream. The likelihood of a bird becoming poisoned is related to the retention time 

of lead items, frequency and history of exposure to lead, and factors such as nutritional 

status and environmental stress (Pattee and Pain 2003). A proportion of exposed birds 

will die, and mortality can occur following the ingestion of just one pellet of lead shot 

(Pain and Rattner 1988). Ingestion of lead particles usually results in some absorption, 

and in cases where sufficient lead is absorbed, poisoning ensues. Lead concentrations are 

generally highest in the blood directly after absorption, and in liver and kidneys for days 

to months after absorption. Lead deposited in bone can remain for years, and reflects 

lifetime exposure (Pain 1996). Lead is a non-essential element and the activity of blood 

enzymes appears to be affected by extremely low concentrations. Other than in cases of 

point source contamination, high concentrations of lead in the tissues of birds result 

primarily from the ingestion of lead ammunition or fishing weights. 

Various authors have attempted to define tissue concentrations in birds indicative of 

excessive lead exposure, sub-lethal poisoning and acute poisoning (Franson et al. 1996; 

Pain 1996), but there is no definitive consensus on “background” lead levels for wild 

birds. For example, the Diagnostic Center for Population and Animal Health (Michigan 

State University, Lansing MI) defined background blood lead levels as <35 μg/dL for 

eagles, while Pattee et al. (1990) defined background levels as <20 μg/dL, and 

Feierabend and Myers (1984) defined them as <10 μg/dL. The generally accepted blood 

lead levels for wild birds have been <20 μg/dL as background; 20 to <50 μg/dL 

indicating subclinical poisoning; 50 to 100 μg/dL indicating clinical poisoning; and >100 

μg/dL representing severe clinical poisoning (Friend 1985, 1999; Franson 1996; Pain 

1996; Pattee and Pain 2003). Background levels at or higher than 20ug/dl are now 

understood to indicate significant exposure, because animals held in captivity usually 

have background levels of 4 μg/dL or less (Walters et al. 2010). 

Environmental sources of lead are almost exclusively anthropogenic, with a small 

contribution from natural sources such as volcanoes. Lead is rarely found in nature in its 

elemental metal form, and the most common source is galena or PbS, which has a very 

low solubility in water. Wildlife can get low level exposure to lead from unknown 

sources, including natural accumulation in plants and ingestion by herbivores, and 

deposition by leaded gasoline exhaust, now attenuated with regulation. “Baseline” lead 

concentrations in wildlife can vary between taxa, and the diagnosis of poisoning is 
14 

usually based on signs of poisoning in combination with blood lead levels in live birds, 

and on tissue concentrations, sometimes in combination with evidence of exposure to 

lead in dead birds. 

A threshold toxic level for wildlife is difficult to measure because the effects on the 

nervous system at low doses can be subtle and difficult to detect without specific 

quantifiable behaviors. In addition, predisposition and susceptibility to lead can vary 

between individuals within a species (Pattee et al. 1981, Carpenter et al. 2003). There is 

probably no toxic lead threshold for any animal, as lead is a neurotoxin with no biological 

function. Lead salts are rarely encountered in the environment, and animals do not have 

well established metabolic or detoxification mechanisms to biochemically protect 

themselves from adverse effects of exposure. Even a minor decrease in fitness to a bird 

surviving in a hostile and competitive environment caused by small amounts of lead 

ingestion may result in a proximate death from many causes. In long-lived bird species, 

this has the potential to skew the normal age structure toward younger and non-breeding 

birds and negatively influence long-term population viability. It is unknown whether 

wildlife species sustain sublethal effects on coordination and cognitive behaviors similar 

to those demonstrated in humans, but it is likely that repetitive sub-lethal exposures to 

lead will cause permanent neurological and behavioral decrements in all species of 

wildlife (Canfield et al. 2003; Lanphear et al. 2003; Ris et al. 2004). 

Lead is a non-specific poison affecting all body systems. Birds can suffer from both acute 

and chronic lead poisoning (Bellrose 1959; Redig 1985; Sanderson and Bellrose 1986; 

Eisler 1988; Scheuhammer and Norris 1996). Birds with acute lead poisoning can appear 

normal, but experience massive tissue destruction to internal organs and death within a 

few days (Sanderson and Bellrose 1986). Birds with chronic lead poisoning may develop 

appetite loss, anemia, anorexia, reproductive or neurological impairment, immune 

suppression, weakness, and susceptibility to predation and starvation (Grandy et al. 1968; 

Kimball and Munir 1971; Finley and Deiter 1978; Hohman et al. 1995). 

The effects of toxicosis in birds commonly include distension of the proventriculus, green 

watery feces, weight loss, anemia and drooping posture (Hanzlik 1923; Quortrup and 

Shillinger 1941; Redig et al. 1980; Reiser and Temple 1981; Franson et al. 1983; Custer 

et al. 1984; Sanderson and Bellrose 1986; Mateo 1998). Sub-lethal toxic effects are 

exerted on the nervous system, kidneys and circulatory system, resulting in physiological, 

biochemical and behavioral changes (Scheuhammer 1987). Vitamin metabolism can be 

affected (Baski and Kenny 1978) and birds can go blind (Pattee et al. 1981). Over longer 

periods, lead poisoning can reduce haematocrit and hemoglobin levels. Lead toxicosis 

depresses the activity of certain blood enzymes, such as delta aminolevulinic acid 

dehydratase, essential for cellular energy and hemoglobin production, and may impair 

immune function (Redig et al. 1991; Grasman and Scanlon 1995). Finkelstein et al. 

(2010) found that sub-lethal concentrations of lead in blood (20 μg/dL), resulted in a 60% 

decrease in the levels of aminolevulinic acid dehydratase in condors. 

As a result of physiological and behavioral changes, birds may become increasingly 

susceptible to predation, starvation and infection by disease, increasing the probability of 
15 

death from other causes (Scheuhammer and Norris 1996). Lead can also affect 

reproductive success (Cheatum and Benson 1945; Elden 1954; Buerger 1984; Buerger et 

al. 1986). Grandjean (1976) showed a correlation between thin eggshells and high 

concentrations of lead in European kestrels (Falco tinnunculus). Lead poisoning 

significantly decreased egg production in captive Japanese quail, Coturnix japonica

(Edens and Garlich 1983). In ringed turtle doves (Streptopelia risoria), significant 

testicular degeneration has been reported in adults following shot ingestion and 

seminiferous tubules may be devoid of sperm (Kendall and Scanlon 1981; Veit et al. 

1982). Experimental studies on Cooper’s hawks (Accipiter cooperii) showed detectable 

amounts of lead in eggs when adults had high levels in their blood (Snyder et al. 1973). 

In nestlings of altricial species, such as the American kestrel (Falco sparverius), body 

length, brain, liver and kidney weights can be depressed (Hoffman et al. 1985a), along 

with reduced survival and disrupted brain, liver and kidney function (Hoffman et al. 

1985b). Lead exposure may also reduce the likelihood of birds returning to an area to 

breed (Mateo et al. 1999). 

Burger and Gochfeld (2000) found that chronic lead exposure resulted in delayed 

behavioral response time in both laboratory and wild herring gulls (Larus argentatus). 

Kelly and Kelly (2005) documented moderately elevated blood lead levels increased the 

risk of collision with overhead power lines for mute swans (Cygnus olor). Mallards (Anas 

platyrhynchos) experimentally fed lead exhibited hemolytic anemia during the first week 

of exposure and neurological impairment during the second week (Mateo et al. 2003). In 

experimentally fed turkey vultures (Cathares aura) and bald eagles (Haliaeetus 

luecocephalus), lead ingestion decreased weight and muscle mass and caused blindness 

(Pattee et al. 1981, 2003). Blood pressure increases and renal damage have also been 

observed in rodents after experimental lead exposure (Victery 1988; Staessen et al. 1994). 

Bagchi and Preuss (2005) found that acute lead exposure had lasting effects including 

lowered bone density and increased blood pressure one year after exposure in laboratory 

rats. 

In spite of the abundance of evidence that lead is toxic to wildlife, poisoning rates are not 

well understood. While massive die-offs are readily visible, daily losses of individual 

animals are more difficult to detect. This is because sick animals will often isolate 

themselves, and then are quickly predated upon after death. In one study, observers were 

given 30 minutes to discover 100 placed carcasses and only found 6 (Stutzenbaker et al. 

1983). In another study in which researchers planted carcasses, over 60% of the carcasses 

were gone within 3 days and over 90% were gone within 8 days (Humburg et al. 1983; 

Stutzenbaker et al. 1983). The non-lethal effects of lead toxicosis may be difficult to 

recognize at a distance in free-ranging wild animals. Subtle neurological signs are easy to 

miss even in domesticated animals that can be physically examined. Wild animals that 

have died from or have been debilitated by lead poisoning may elude capture due to 

behavioral or physiological changes, or be removed from the population if lead exposure 

is associated with high levels of mortality (Miller et al. 1998). 
16 

 E. Lead Fishing Tackle Poisonings by Species 

Lead fishing sinkers and jigs are documented to cause lead poisoning mortality in 

numerous species of water birds and wading birds, and the problem is particularly acute 

for loons, swans, cranes, geese, mallards and brown pelicans (Locke et al. 1982; 

Windingstad et al. 1984; Blus et al. 1989; Pain 1992; Pokras and Chafel 1992; USEPA 

1994; Scheuhammer and Norris 1995, 1996; Daoust et al. 1998; Friend 1999; Stone and 

Okoniewski 2001; Franson et al. 2003; Sidor et al. 2003). 

 1. Loons 

There is a direct link between ingestion of lead fishing tackle and mortality of loons. 

Lead poisoning from ingesting lead fishing sinkers or jigs is a significant cause of death 

for adult common loons (Gavia immer) in the United States and eastern Canada (USFWS 

2004). Lead poisoning from fishing tackle accounts for about 50 percent of mortality of 

examined dead loons, and is the single most important mortality source in for loons new 

England (Pokras et al. 1992). Evers (2004) reported that in New England, a 14-year study 

diagnosing causes of mortality in 522 common loons documented 44% of the breeding 

adults died from lead toxicosis, from ingesting either lead shot or lead fishing sinkers. 

Lead fishing tackle accounted for 52 percent of mortalities among adult and immature 

loons in New Hampshire from 1976 through 2000, by far the largest single cause of adult 

loon mortality in the state (Loon Preservation Committee). The U.S. Fish and Wildlife 

Service noted that ingestion of lead sinkers and jigs accounted for between 40 and 70 

percent of mortality of dead common loons recovered in New Hampshire from 1996 to 

2002 (USFWS 2004). Pokras et al (1992) examined 60 dead loons collected in New 

Hampshire from 1989 to 1992 and 27 (45%) had ingested lead sinkers. Pokras and Chafel 

(1992) found that 16 of 31 (52%) dead adult loons collected in New Hampshire from 

1989 to 1990 ingested lead sinkers. Stone and Okoniewski (2001) found that lead 

poisoning caused 21% of the deaths of 105 common loons examined from new York 

between 1972 and 1999; and Sidor et al. (2003) examined 254 dead or moribund and 

found that 44% died of lead poisoning.

Pokras et al. (2009) quantified the size, mass, and types of lead fishing gear regularly 

ingested by common loons, collecting loon carcasses from the six New England states 

between 1987 and 2000 and submitting them for necropsy. Of the 522 loon carcasses 

examined, 118 (22.6%) had ingested lead objects, and 73 of these 118 loons, 73 had more 

than one object in their gizzard, for a total of 222 lead objects recorded. Lead sinkers 

(48%) were the most frequently ingested object, followed by jigheads (19%), split shot 

(12%), ammunition (primarily shotgun pellets), lead wires or tapes, and unknown items. 

About 36% of loons with ingested lead had other fishing-related objects (mostly hooks, 

swivels and monofilament line) present in the gastro-intestinal tracts. All loons ingesting 

lead objects also had elevated liver lead levels consistent with lead poisoning. Of the 222 

lead objects ingested, 94% weighed less than 10 g and the largest object weighed 25 g. 

Ninety-four percent of the lead objects were less than 25.4 mm in length; 44% had a 

length of less than 10 mm. 
17 

Substantial rates of lead-related mortality are also known for loons in Michigan, 

Minnesota and Wisconsin. Ensor et al. (2002) found 17% of loons examined in 

Minnesota died of lead poisoning. Franson and Cliplef (1992) reported lead poisoning in 

7 of 77 common loons from Minnesota and 2 of 17 loons from Wisconsin. According to 

the Wisconsin Department of Natural Resources, about 35 percent of all loon deaths in 

Wisconsin are related to lead poisoning, from picking up and ingesting lead shot or lead 

fishing sinkers on the bottom of water bodies (Eisele 2008). Strom et al. (2009) reported 

that approximately 30% of dead loons in Wisconsin submitted for necropsy since 2006 

were found to be lead-poisoned, and lead fishing gear was recovered from the 

gastrointestinal tracts of loons in all cases where lead toxicity was a major contributor to 

the cause of death. 

Lead poisoning from fishing weight ingestion was the leading cause of deaths diagnosed 

for common loons in eastern Canada from 1983 to 1995, in areas where loon breeding 

habitats overlap with sport fishing (Scheuhammer et al. 2003). Scheuhammer (2009) 

concluded from a review of available data that ingestion of small lead sinkers or jigs 

accounts for about 20–30% of recorded mortality of breeding adult common loons in 

Canada in habitats that experience high recreational angling activity. Daoust et al. (1998) 

found that 5 of 31 common loons collected with ingested fishing weights from the 

Maritime Provinces in Canada between 1992 and 1995 had died of lead poisoning. 

Common loons are known to ingest lead objects more frequently compared to 26 other 

species of water birds sampled across the United States (Franson et al. 2003). Franson et 

al. (2003) found that 11 of 313 common loons brought sick to rehabilitation centers or 

live-trapped had ingested lead fishing tackle, including weights, split shot, jig heads, and 

a pyramid sinker. Franson and Cliplef (1992) reviewed records of 222 dead loons 

examined between 1976 and 1991 and found that 14 died of lead poisoning, with lead 

fishing weights found in the stomachs of 11 of these loons. Water birds trapped when 

apparently healthy rarely show evidence of lead sinker ingestion (Franson and Cliplef 

1992). 

 2. Swans 

Efforts to restore trumpeter swans (Cygnus buccinator) in Wisconsin are being hampered 

by persistent die-offs due to lead poisoning. According to the Wisconsin Department of 

Natural Resources, about 30 percent of all trumpeter swan deaths in Wisconsin are 

related to lead poisoning from ingesting lead shot or lead fishing sinkers on the bottom of 

water bodies (Eisele 2008). Strom et al. (2009) reported that approximately 25% of 

trumpeter swan fatalities in Wisconsin have been attributed to lead toxicity, and about 

15% of live-sampled trumpeter swans in Wisconsin had blood lead levels above 

background concentrations (20 μg/dL). Lead poisoning from ingesting lead fishing 

sinkers was documented as the cause of death for 4 of 18 trumpeter swans examined in 

Montana, Idaho and Wyoming from 1976 to 1987 (Blus et al. 1989). Locke and Young 

(1973) reported the lead poisoning related mortality of a tundra swan that ingested a lead 

sinker.
18 

A study in Britain found that lead poisoning from ingestion of fishing weights was the 

leading cause of death (up to 90%) for declining mute swans (Cygnus olor) (Simpson et 

al. 1979; Birkhead 1982; Birkhead and Perrins 1985; Kirby et al. 1994), a trend which 

reversed when a ban on small lead fishing weights was implemented in Britain in 1987 

(Delaney et al. 1992; Owen 1992; Kirby et al. 1994; Perrins et al. 2003; Kelly and Kelly 

2004). Continued mute swan mortality in the region is thought to be from ingestion of 

lead weights lost prior to the ban or during illegal use after the ban (Perrins et al. 2003). 

 3. Other Birds 

Lead fishing sinkers and jigs have contributed to lead poisoning mortalities in Canada 

geese (Branta canadensis), mallards (Anas platyrhynchos) and brown pelicans 

(Pelecanus occidentalis) (Rattner et al. 2008). Two sandhill cranes (Grus canadensis) 

diagnosed with lead poisoning died after ingesting lead fishing weights (Windingstad et 

al. 1984) and an endangered Mississippi sandhill crane died of lead poisoning with an 

unidentified lead object in its gizzard (Franson and Hereford 1994). Other species 

reported to ingest lead sinkers include redheaded ducks (Aythya americana), pochard 

(Aythya ferina), greater scaup (Aythya marila), wood ducks (Aix sponsa), black ducks 

(Anus rubripes), red-breasted mergansers (Mergus serrator), white-winged scoters 

(Melanitta fusca), double-crested cormorants (Phalacrocorax auritus), white pelicans 

(Pelecanus erythrorhynchos), great blue herons (Ardea herodias), snowy egrets (Egretta 

thula), great egrets (Ardea alba), black-crowned night-herons (Nycticorax nycticorax), 

white ibis (Eudocimus albus), laughing gulls (Larus atricilla), herring gulls (Larus 

argentatus), royal terns (Sterna maxima), and bald eagles (Mudge 1983; USEPA 1994; 

Scheuhammer and Norris 1995; Friend 1999; Franson et al. 2003; Scheuhammer et al. 

2003). 

 4. Reptiles 

There is evidence of freshwater turtles ingesting lead fishing weights and suffering from 

lead toxicosis (Borkowski 1997; Scheuhammer et al. 2003). 

 F. Lead Fishing Tackle Risk of Exposure to Humans 

Human exposure to lead in the United States has decreased as lead plumbing, paint, 

solder, toys, and gasoline have been phased out and replaced. Public health agencies have 

regulated lead in industrial activities and consumer products, and have to varying degrees 

begun to address and remediate lead exposure from shooting ranges, but have focused 

little attention on fishing activities that may be an important source of lead exposure in 

certain communities, occupations or activities. 

Watson and Avery (2009) assessed the numbers and proportions of state populations that 

may be at risk of lead exposure from handling and using fishing gear, from handling and 

making lead sinkers, and through accidental ingestion of lead fishing gear. In 2006, 30 

million people (13% of the population) aged 16 years and older in the United States 

fished on 517 million days. As of 1994, approximately 800,000 to 1.6 million people in 
19 

the United States manufactured lead fishing weights in their homes, often in enclosed 

garages or basements, representing approximately one-third of the lead sinkers produced 

in the country (USEPA 1994). The EPA warns that anglers who cast their own sinkers, 

jigs or spinnerbaits at home may be exposed to potentially harmful airborne lead particles 

or vapors while melting and pouring lead into lead fishing sinker molds (U.S. EPA 

2011b). Additionally, airborne particles from melted lead can move around and spread far 

distances, covering soil, dust, walls, floors, furniture, clothing, toys, stuffed animals, etc. 

(USEPA 2011b). Anglers also risk lead exposure from putting lead sinkers in their mouth 

or biting down on slip shot, as well as from handling lead sinkers or cleaning out their 

tackle box (USEPA 2011b). 

The toxic effects of lead on humans have been known since Roman times (Nriagu 1983; 

Needleman 1999; Hernberg 2000; Tong et al. 2000; Nriagu 2009). Lead is an 

extraordinarily toxic element, and when ingested it attacks organs and many different 

body systems, including the blood-forming, nervous, urinary, and reproductive systems 

(USDHHS 1999). Lead accumulates in humans mainly in bones, with lead in blood and 

other tissues reflecting more recent exposure. The effects of lead poisoning can include: 

damage to the brain and central nervous system; kidney disease; high blood pressure; 

anemia; and damage to the reproductive system, including decreased sex drive, abnormal 

menstrual periods, impotence, premature ejaculation, sterility, reduction in number of 

sperm cells, damage to sperm cells resulting in birth defects, miscarriage, and stillbirth, 

painful gastrointestinal irritation, diarrhea, loss of appetite, weakness and dehydration, 

nerve disorders, memory and concentration problems, muscle and joint pain (USDHHS 

1999). In large enough doses, lead can cause brain damage leading to seizures, coma, and 

death (USDHHS 1999). 

Chronic overexposure to low levels of lead can cause health impairments to develop over 

time, and irreversible damage can occur without obvious symptoms (USDHHS 1999). 

Lead exposure can adversely affect the nervous system (resulting in impaired cognition, 

reduced motor coordination, and palsy), renal system, and cardiovascular system (IPCS 

1977; Needleman et al. 1990; Goyer 1996; Needleman 2004; Khan 2005; Cecil et al. 

2008). Lead is also implicated in decreased growth (Hauser et al. 2008), decreased brain 

volume (Cecil et al. 2008), spontaneous abortion (Borja-Aburto et al. 1999), kidney 

damage (Ekong et al. 2006), cancer, and cardiovascular disease (Menke et al. 2006, 

Lustberg and Silbergeld 2002). Lead is especially dangerous to fetuses and young 

children and poisoning is even more pronounced because the lead is absorbed faster and 

disrupts development, causing slow growth, development defects, and damage to the 

brain and nervous system (Schnaas et al. 2006). Some studies link elevated bone or blood 

lead levels with aggression, delinquent behavior, attention deficit hyperactivity disorder 

and criminal behavior (Nevin 2000; Needleman et al. 2002; Needleman 2004; Braun et 

al. 2006; Wright et al. 2008). 

Many studies show even very small amounts of lead can have permanent, debilitating, 

sub-lethal effects. In humans, blood lead concentration of 10 micrograms of lead per 

deciliter (μg/dL) is currently considered an elevated level, although some researchers and 

health professionals have advocated for a threshold of 5 micrograms or even 2 
20 

micrograms. In the mid-20th century, the amount of lead in the bloodstream of a child 

considered in need of medical intervention was considered to be 60 μg/dL, whereas today 

it is 10 μg/dL. The U.S. Department of Health and Human Services has concluded that 

there is evidence that blood lead levels less than 10 μg/dL are associated with adverse 

health effects on development in children and reproduction in adult women, such as 

delayed puberty, decreased postnatal growth, reduced fetal growth, spontaneous abortion 

and preterm birth (NTP 2011); and studies show blood lead levels at and below 2 μg/dL 

are associated with adverse effects (e.g. Wu et al. 2003; Denham et al. 2005). Children 

sustain permanent cognitive damage when they show an average of only 7.5 μg/dL in 

blood before the age of five (Lanphear et al. 2005). 

A new draft assessment by the National Toxicology Program of the U.S. Department of 

Health and Human Services concluded that blood lead concentrations lower than the 

federally established levels of concerns are associated with adverse health effects and 

reports that even blood lead concentrations lower than 5 μg/dL are associated with 

decreased academic performance and cognitive function, increased incidences of ADHD 

and behavioral problems in children (NTP 2011). The assessment also found that blood 

lead concentration levels below 10 μg/dL are associated with delayed puberty, reduced 

growth, decreased IQ, and decreased hearing in children, and increased blood pressure 

and cardiovascular disease in adults (NTP 2011). The consensus among medical 

researchers is that there is no safe level of lead exposure in young children (CDC 2005). 
21 

V. AUTHORITY TO ACT 

In adopting TSCA, Congress declared its policy that (1) “adequate data should be 

developed with respect to the effect of chemical substances and mixtures on health and 

the environment” and (2) “adequate authority should exist to regulate chemical 

substances and mixtures which present an unreasonable risk of injury to health or the 

environment” 15 U.S.C. § 2601(b). In recognizing that the EPA would not always act on 

its own, it authorized any person to petition the EPA to initiate a proceeding under 

several sections of the Act (15 U.S.C. § 2620(a)). A petition shall set forth the facts 

claiming that it is necessary to issue a rule under Section 6. After reviewing and granting 

a petition, the EPA then commences an appropriate rulemaking proceeding. 

To promulgate a rule under TSCA Section 6, the EPA must find there is a “reasonable 

basis to conclude” that activities involving a chemical substance “presents or will present 

an unreasonable risk to health or the environment.” Factual certainty of the magnitude of 

risk to health and environment is not required; the EPA may base its decision not only on 

known facts, but also on scientific theories, projections and extrapolations from available 

data, and modeling using reasonable assumptions (59 Fed. Reg. 11122, 11138, citing 

H.R. Rep. No. 1341, 94th Cong., 2d Sess. 32 (1976)). In promulgating a rule under 

Section 6, the EPA must consider and publish a statement with respect to: 

(A) the effects of such substance or mixture on health and the magnitude 

of the exposure of human beings to such substance or mixture, (b) the 

effects of such substance or mixture on the environment and the 

magnitude of the exposure to the environment to such substance or 

mixture, (C) the benefits of such substances or mixture for various uses 

and the availability of substitutes for such uses, and (D) the reasonably 

ascertainable economic consequences of the rule, after consideration of the 

effect on the national economy, small business, technological innovation, 

the environment, and public health 

15 U.S.C. § 2605(c)(1)(A)-(D). In issuing a rule, the EPA must employ the least 

burdensome requirements afforded by Section 6. In order to facilitate this rulemaking, the 

EPA shall proceed in accordance with Section 553 of the Administrative Procedure Act. 

However, at the petition stage, the EPA must only review the petition and determine 

whether there is a reasonable basis to conclude that the manufacture, processing, 

distribution, use, or disposal of lead in fishing sinkers presents an unreasonable risk of 

injury to health or the environment, necessitating the initiation of a rulemaking 

proceeding under Section 6 of the Act. 
22 

VI. ALTERNATIVES TO LEAD FISHING TACKLE 

In reviewing the petition, the EPA is only required to determine whether there is a 

reasonable basis to conclude that an issuance of such a rulemaking is necessary to protect 

against an unreasonable risk of injury. However, in promulgating a rule in response to a 

Section 6 petition, the EPA must consider “the benefits of such substance or mixture for 

various uses and the availability of substitutes for such uses” as well as “the reasonably 

ascertainable economic consequences of the rule, after consideration of the effect on the 

national economy, small business, technological innovation, the environment, and public 

health” (15 U.S.C. § 2605(c)(1)(C)-(D)). Therefore, this petition identifies commercially 

available alternatives to lead fishing tackle in anticipation of the promulgation of such a 

rule. 

Fishing sinkers and jigs do not have to be made of lead. Nearly all fishing tackle products 

available in lead are now available in nontoxic alternative materials. Demonstrated 

technology indicates that all fishing tackle products could be produced in nontoxic 

alternatives within a short period of time, if manufacturers are provided a transition 

period for expanding upon current designs and stocks of fishing gear. Inexpensive and 

ecologically sound alternatives to lead fishing weights made from non-poisonous 

materials such as tin, bismuth, steel, and recycled glass are widely available. Sinkers 

made of materials other than lead have gained varying levels of acceptance among 

anglers, with tradeoffs regarding cost and effectiveness. At least 10 substitutes for lead 

fishing tackle are on the market: tungsten (plastic composites and putty), stainless steel, 

carbon steel, tin, tin/bismuth, brass, ceramics, glass, pewter, and zinc (Scheuhammer and 

Norris 1995; Scheuhammer et al. 2003; MOEA 2006). However, metals such as bismuth 

and tungsten are more expensive than lead, and others such as zinc are known to be toxic 

to birds and other biota (Grandy et al. 1968; Zdziarski et al. 1994; USEPA 1994; 

Levengood et al. 1999). 

Most fishing tackle stores in the U.S. already carry alternatives to lead fishing tackle and 

sinkers (Scheuhammer and Norris 1995, 1996; Simpson 2001; Scheuhammer et al. 2003; 

Michael 2006). Some states and non-profit organizations offer small-scale programs that 

exchange angler-owned lead tackle for free non-lead substitutes. Fishing jigs and weights 

containing lead are required to carry a warning label in California (Proposition 65 

warning) because lead has been identified by California as causing cancer. As a result, 

retailers and purchasers of fishing gear in nearly all states can currently identify gear 

containing lead, and can routinely avoid using lead-containing products, if they so 

choose. Not all states require a lead warning, but because California is a large market, 

most manufacturers routinely label fishing gear packages that are retailed in most states. 

Tungsten, one of the more widely used alternatives to lead fishing tackle, is sold as a 

tungsten-plastic composite and as tungsten putty, a specialty item marketed to flyfishers. 

Tungsten putty can be molded into varying shapes and sizes and affixed to fishing line, 

allowing anglers to vary the sink rate of their fly presentation. Tungsten is comparable to 

lead in density and can be manufactured to be more dense than lead, allowing for smaller 

tackle. Tungsten tackle can also have noise-making attributes that may attract fish in 
23 

some situations. Tungsten is more expensive than lead, and tungsten tackle requires 

plastic sleeves to cover sharp edges, at additional expense. 

Stainless steel tackle is advertised as having fish-attracting qualities due to the noise it 

makes bumping along the bottom. Stainless steel tackle is larger than lead tackle of 

equivalent weights. Carbon steel tackle is available on the internet. Some carbon steel 

tackle is made from recovered waste steel mixed with resins, within a cotton sleeve. 

Anglers can add or subtract steel balls on a three-way swivel to adjust the sink rate to 

hold bait on the bottom. This gear is gaining popularity in river fisheries and steel is 

replacing lead in a variety of commercial traps. Iron is one of the less expensive 

alternatives to lead, but has the disadvantage of eventually corroding after continued 

exposure to water. 

Tin is a malleable metal that allows anglers to reuse split shot many times. The lower 

density of tin also allows for a slower sink rate, potentially keeping the bait in the “strike 

zone” longer. Tin tackle tends to be larger and more expensive than lead, but is widely 

available. Bismuth is a brittle metal that can be used in non-split fishing weights such as 

egg, worm, swivel, bullet slips, and jig heads (Scheuhammer and Norris 1995). 

Bismuth/tin compounds are popular among anglers who manufacture their own jigs, 

partly due to better paint quality on jig heads using this material. A disadvantage is that 

bismuth is a relatively expensive metal. 

Brass fishing tackle is also advertised as producing sound with fish-attracting qualities. 

Brass is an alloy of copper and zinc, and metallic zinc is known to be highly toxic to 

birds when ingested. Also, brass fishing tackle often includes lead mixed in with brass, 

and is not lead-free, even though the lead is bound in a state not thought to be toxic 

(MOEA 2006). 

Fishing tackle made of glass tends to be larger and is currently more expensive than its 

lead equivalents. Certain types of glass can be made to “glow” after exposure to light, a 

quality purported to improve fish biting frequency. Glass sinkers are available primarily 

through the internet. Ceramic fishing tackle is also considerably larger than lead tackle. 

Zinc was used as a replacement for lead sinkers until it was demonstrated that the 

industrial grade zinc used in the tackle is also toxic in aquatic environments. Lead-free 

pewter tackle is another potential alternative, but pewter is not in wide use and not 

currently available to consumers. It is expected that pewter tackle will need to be larger 

than lead equivalents and more expensive. 

The EPA has already determined that the economic impact of banning smaller-sized lead 

fishing tackle would be nominal (EPA 1994). Similarly, when the National Wildlife 

Refuge System implemented “Lead-Free Fishing Areas,” they acknowledged that 

nontoxics sometimes cost more than lead weights but stated that as sinkers only comprise 

3% of yearly equipment costs, the increase did not create a burden for anglers (Federal 

Regulation 50 CFR 32 and 36, proposed rule).
24 

VII. EXISTING REGULATIONS 

While TSCA only requires the EPA to consider whether actions undertaken by the EPA 

under other federal laws adequately address the risk of unreasonably injury, this petition 

presents information on existing regulatory efforts in order to demonstrate that despite 

these efforts, there remains an unreasonable risk of injury to the environment. 

There are an increasing number of outreach and education programs by state and federal 

agencies and non-governmental organizations promoting the use of non-lead fishing 

tackle. While these programs are important, they have not resulted in a widespread switch 

to non-toxic fishing tackle by anglers and there is no evidence these programs by 

themselves have significantly reduced lead exposure to wildlife. The fact that there are 

some limited state regulations addressing lead sinkers has also not ended lead poisonings 

of birds in those states, nor do those regulations address continued lead poisoning and 

likely lead exposure to birds in numerous other states where there are not even limited 

state regulations. TSCA does not require a showing of population-level impacts from lead 

poisonings to regulate toxic lead, only that there is an unreasonable risk of injury to the 

environment. 

Federal Regulations 

Currently, there are some limited and inconsistent regulations regarding lead fishing 

tackle on some National Wildlife Refuges and National Parks. While these measures may 

have begun to reduce the risk of lead exposure to wildlife and humans in limited 

geographic areas, and demonstrate that regulation of lead is possible and that nontoxic 

tackle is available for fishing activities, they are no substitute for comprehensive, 

sweeping regulation by the EPA of lead fishing tackle that poses lead exposure risks to 

wildlife and humans. 

Lead tackle is banned on some U.S. National Wildlife Refuges (“NWR”) that have loon 

and swan populations and in one National Park. Currently, the National Wildlife Refuges 

with regulations prohibiting use of lead weights, sinkers, or fishing tackle include Bear 

Lake NWR in Idaho, Union Slough NWR in Iowa, Rachel Carson NWR in Maine, 

Patuxtent NWR in Maryland, Assabet River NWR in Massachusetts, Seney NWR in 

Michigan, Red Rock Lakes NWR in Montana, and Rappahannock River Valley NWR in 

Virginia (Franson et al. 2003; Michael 2006). Yellowstone National Park has banned 

leaded fishing tackle and weights small enough to be ingested by wildlife. In March 2009 

the National Park Service announced that it would begin to develop regulations to 

eliminate the use of lead fishing tackle in all National Parks by the end of 2010, but has 

yet to initiate any rulemaking. 

In 1999 the U.S. Fish and Wildlife Service (“USFWS”) announced it would establish 

additional lead-free fishing areas on more National Wildlife Refuges and wilderness 

areas used by loons, and waterfowl production areas on federal lands in Alaska, Florida, 

Maine, Minnesota, and Wisconsin (USEPA 1999; USFWS 1999). However, the USFWS 

has not followed through on regulations, and a final rule on the use of lead fishing tackle 

on federal refuges has never been made. 
25 

State Regulations 

A few states have moved forward with banning small-sized lead tackle associated with 

fishing activities. Only Maine, New Hampshire, New York and Vermont have established 

statewide bans on the sale and/or use of smaller lead sinkers and jigs. Massachusetts and 

Washington have partial bans, and the other 44 states have no lead fishing regulations at 

all. 

Maine 

Maine passed legislation in 2001 (effective January 1, 2002) that prohibits the sale of 

lead sinkers one-half ounce or less. 

Massachusetts 

Massachusetts currently prohibits the use of lead sinkers for fishing in certain reservoirs 

visited by loons (Quabbin and Wachusett Reservoirs) and starting in 2012 the use of lead 

sinkers, weights and fishing jigs less than one half ounce will be prohibited in all inland 

waters. 

New Hampshire 

New Hampshire was the first state to ban the use of small lead sinkers. Legislation passed 

in 1998 (effective in 2000) prohibits the use of lead sinkers up to one ounce and lead jigs 

up to one inch in length, in lakes and ponds throughout the state. This legislation was 

later expanded in 2006 to include all waters of the state. 

New York 

New York in 2004 prohibited the sale of lead fishing sinkers (including “split shot”) 

weighing one-half ounce or less. 

Vermont 

Vermont passed legislation prohibiting the use (effective January 1, 2007) and sale 

(effective January 1, 2006) of lead fishing sinkers weighing one-half ounce or less. 

Washington 

The Washington Fish and Wildlife Commission in 2010 approved restrictions on the use 

of lead fishing tackle at 13 lakes with nesting common loons. The new regulations, which 

took effect May 2011, prohibit the use of lead weights and jigs measuring one and one 

half inches or less along the longest axis at 12 lakes; Ferry and Swan lakes in Ferry 

County; Calligan and Hancock lakes in King County; Bonaparte, Blue and Lost lakes in 

Okanogan County; Big Meadow, South Skookum and Yocum lakes in Pend Oreille 

County; Pierre Lake in Stevens County; and Hozomeen Lake in Whatcom County. The 

commission also banned the use of flies containing lead at Long Lake in Ferry County. 

International 

Regulations banning smaller lead fishing tackle in other countries demonstrate the 

potential effectiveness of regulations in the United States. Restrictions on the sale and use 

of smaller lead fishing sinkers and jigs are in place in Canada, Denmark, and Great 
26 

Britain. In 1997, Canada amended its Wildlife Area Regulations to prohibit possession of 

any lead sinker or jig weighing less than 50 grams while fishing in any National Wildlife 

Area where sport fishing is allowed, and also amended the National Parks Fishing 

Regulations to prohibit the possession and use of lead sinkers or jigs while fishing in 

national parks. Great Britain banned the use of lead sinkers weighing less than one ounce 

in 1987, due to the harm lead was causing swans, diving birds, and wading birds, and 

after determining that voluntary efforts were ineffective. Reported cases of lead 

poisoning in swans from the River Thames in England dropped from a peak of 107 in 

1984 to 25 in 1988, one year after the ban on sale of lead fishing weights (Sears and Hunt 

1991).
27 

VIII. DESCRIPTION OF FEDERAL REGULATIONS REQUESTED

Petitioners Center for Biological Diversity, Loon Lake Loon Association and Project 

Gutpile formally request that the EPA: 

1) evaluate the unreasonable risk of injury to the environment and wildlife from 

fishing tackle containing lead (including fishing weights, sinkers, lures, jigs 

and/or other tackle) of various sizes and uses that are ingested by wildlife, 

resulting in lead exposure; and 

2) initiate a proceeding for the issuance of a rulemaking under Section 6(a) of TSCA 

to adequately protect against such risks (15 U.S.C. § 2620(a); 15 U.S.C. § 

2605(a)(2)(A)(i)). 

This petition sets forth facts presenting a reasonable basis to conclude that such a 

rulemaking is necessary to protect wildlife from the ongoing threat of lead poisoning. 

TSCA grants the EPA the broad authority to regulate chemical substances that “present 

an unreasonable risk of injury to health or the environment” 15 U.S.C. § 2601. TSCA 

also mandates that the EPA must regulate chemical substances where there is a 

“reasonable basis to conclude” that such substances “present an unreasonable risk of 

injury to health and or the environment” (15 U.S.C. § 2605(a)). The EPA may regulate 

the manufacture, processing, distribution, use or disposal of such chemical substances. 

Specific control mechanisms include: prohibitions on an entire or certain use of a 

chemical substance; limitations on allowable concentration levels; labeling or 

recordkeeping requirements; and obligations to issue notice of risks of injury. (15 U.S.C. 

§ 2605(a)). Regulations may be achieved through a range of alternatives, up to and 

including the EPA prohibiting the manufacture, processing, or distribution in commerce 

of a chemical substance for a particular use (15 U.S.C. § 2605(a)(2)(A)(i)). 
28 

IX. CONCLUSION

Section 6 of the Toxic Substances Control Act requires only that the EPA find that there 

is “a reasonable basis to conclude” that a risk to the environment or human health is 

unreasonable. Scientific theories, projections of trends from currently available data, 

modeling using reasonable assumptions, and extrapolations from limited data may help to 

establish risk (H.R. Rep. No. 1341, 94th Cong., 2d Sess. 32 (1976)). The data presented in 

this petition provides a reasonable basis to conclude that the risk is such that lead fishing 

tackle of certain sizes and uses should be regulated under TSCA to protect against 

unreasonable risk of injury to the environment. This petition has set forth the facts 

establishing the indisputable exposure and toxicity of lead fishing tackle of certain sizes 

and uses to wildlife. The scientific literature on the sources, quantities, and pathways of 

exposure of lead in the environment from fishing tackle is conclusive, as is information 

on the toxic effects and health risk of fishing tackle on wildlife. Many species of wildlife, 

particularly water birds, ingest lost or discarded lead fishing tackle. The widespread 

poisoning of many species of wildlife requires a response from the EPA to regulate 

certain sizes and uses of lead fishing tackle.
29 

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