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 of the 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) 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».

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 of the 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.org1 

## 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, 20112 EXECUTIVE SUMMARY

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

, Petitioners Center for Biol ogical 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 S ection 6 of TCSA to adequately protect against the unreasonable risk of injury to th e environment from fishing tackle containing

lead that are of the sizes and uses that are ingested by wildlif e, resulting in lead exposure. Fishing tackle, as used in th is petition, refers to and incl udes fishing weights, sinkers, lures, jigs, and other fishing gear.

Based on information extending back to Ro man 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 fr om 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 in cluding 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 expo sure to wildlife and to humans.

In recent decades the federal government ha s begun to implement regulations to reduce the exposure of human beings to lead in dr inking water, paint, gasoline, toys, toxic dumps, lead wheel balancing weights and both indoor and out door shooting ranges. Strict recycling regulations have been imposed on disp osal of lead-acid batteries. However, lost or discarded lead fishing we ights and tackle are uncontro lled and lead remains widely

encountered and distributed in the environment from these sources. Lead fishing tackle can accumulate in aquatic habitats, where anim als 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 pa inful lead poisoning deaths of waterfowl such as swans, ducks, geese and loons.

Tackle manufacturers now market a wide vari ety of non-lead, nontoxic fishing tackle that can replace lead tackle. There is no tec hnological 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 str ong argument for EPA regulatory action.

TSCA grants the EPA the broad authority to re gulate chemical substances that “present an unreasonable risk of injury to health or the environment” (15 U.S.C. § 2061). The EPA may regulate the manufactur e, processing, distribution, us e or disposal of such3 chemical substances. Specific control mechanisms include: prohibitions on an entire or certain use of a chemical substance; lim itations on allowable concentration levels; labeling or recordkeeping require ments; and obligations to issu e notice of risks of injury (15 U.S.C. § 2605(a)). The EPA has already decl ared 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 fish ing gear continue to have active fishing

communities that have successfu lly transitioned away from l ead products. Market forces

in these states have caused a full line of nontoxic replacement products to be made available to the public, demonstrating that co mmercially available alternatives exist and the economic consequences of removing toxic le ad from fishing tackle sources from the environment can be minimal. The EPA is oblig ated under TSCA to grant this petition and initiate a proceeding for the issuance of a ru le under Section 6 to protect wildlife and the

environment from unreasonable risk of l ead 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.....................................................................................................285 1. PETITIONERS AND STANDING TO FILE

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

et seq. ) provides that “any person” may petiti on 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 protec ting wildlife from l ead 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 Cent er 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 habita t and educate the public.

Petitioner Project Gutpile is an educationa l organization comprise d of hunters/wildlife biologists and anglers that pr ovides educational resources fo r 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 ap propriate proceeding. If the Administrator denies the petition, the Admi nistrator 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.org6 II. NATURE OF THE REQUESTED ACTION

Petitioners Center for Biol ogical Diversity, Loon Lake Loon Association and Project Gutpile request that the EPA evaluate the unr easonable 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 adequate ly 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 th at such a rulemaking is necessa ry to protect wildlife from the ongoing threat of lead poisoning.

TSCA grants the EPA the broad authority to re gulate 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 “prese nt an unreasonable risk of injury to health and or the environment” (15 U.S.C. § 2605(a )). The EPA may regulat e 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 th e 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 su bstance 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-bas ed paints, plumbing pipe and fixtures, and leaded gasoline, are already subject to st rict 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 cer tain lead manufacturers to submit unpublished health and safety reports to the EPA (73 Fed. Reg. 5109-5115; Jan. 29, 2008). Automobile wheel balancing wei ghts will be phased out with an EPA proposed rule scheduled for 2011. Manufacturer s 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 author ity to regulate lead fish ing tackle under the Toxic Substances Control Act in 1994 by proposi ng 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 dist ribution 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 i ssued in response to a citizens’ petition to require that the sale of lead fishing sinkers be accompanied by a labe l 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 th at other laws were, in fact, insufficient to

reduce the unreasonable risk of harm to heal th and environment from smaller-sized lead fishing sinkers (59 Fed. Reg. 11122). The EPA r ecognized that, in th e area of wildlife protection, there was some overlap between th e statutory authoritie s administered by the Department of the Interior and the EPA, but that “some activities, the regulation of which could protect wildlife (e.g., re gulation 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 a nd 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 lik ely 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, 104 th Cong. (March 6, 1995)). When introducing the bill, Senator Harkin declared that the proposed ban was not hing more than “government regulation run amok” and that the risks presented by lead sinkers were not unreasonable (Sen. 505, 104 th
Cong. (March 6, 1995), Senator Harkin, Stat ements 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 Conserva ncy, Association of Avian Veterinarians, Center for Biological Diversity, Project Gutp ile and Public Employees for Environmental Responsibility submitted a petition to the EP A under TSCA requesting that the EPA issue a proposed rule to prohibit the manufacture, processing, and distribut ion in commerce in the United States of lead ammunition (incl uding bullets and shotgun pellets) and lead fishing tackle (including sinkers , jig heads, weights, and a ll other fishing tackle). The EPA informally denied the petitioners’ request to ban lead in fishi ng 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 fish ing sinkers was necessary and that the petitioners did not demonstrate that th e requested ban was the least burdensome alternative. The EPA did not consider any ot her 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 th e sizes and uses most likely to result in lead exposure. The EPA’s deni al 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 asserti on 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 lik ely to be ingested by wildlife and result in lead exposure, posing unreasonable risk to the environment. Th is 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 inst ead asks the EPA to initiate a rulemaking for regulations that adequately pr otect wildlife against the unreas onable risk of injury from lead fishing tackle. The EPA has latitude under TSCA to consider a broad range of alternatives for addressing an unreasonable ri sk of injury, including prohibitions on an

entire or certain use of a chemical subs tance, limitations on allowable concentration levels, labeling or recordkeeping requirements, or obligations to issu e notice of risks of injury. This petition does not re quest a specific regulat ory 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 contri buted 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 know ledge that lead is a toxic substance with potentially lethal as well as numerous pat hological effects on liv ing organisms of all sorts. Despite this knowledge, lead has cont inued to be used in a wide variety of manufactured products, many of which are cont inued sources of toxic lead exposure to human beings and to wildlife.

The use of lead for fishing ac tivities dates back thousands of years. The lead poisoning effects of lead fishing tackle ingest ed by wildlife have been well documented. Recognizing this problem, some jurisdictions began placing re strictions 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 fi shing tackle, including lures, sinkers, lead core fishing line, downrigger ca nnonballs, weights, and a variet y of fishing traps and nets that employ the use of lead.

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

some environmental conditions it can be read ily 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 w ildlife, particularly dabbling and diving water birds such as such as swans, ducks, geese a nd loons. Absorbed or ingested lead can cause a range of biochemical, physiological, and behavi oral effects in species of invertebrates, fish, amphibians, reptiles, birds, and mammals . Wildlife can be exposed to lead through feeding in aquatic environments and ingest ing contaminated vegetation and sediments, feeding on invertebrates or vertebrates containi ng 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 biochemi cal interactions, with harmful effects on neurological functions, bone structure, renal function, repr oductive 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 neur otoxin, and numerous

studies indicate that blood lead concentrations even be low 10 micrograms per deciliter can have adverse developmental effects on inte llectual functioning and social-behavioral conduct in humans (Needleman et al. 1990; Canf ield et al. 2003; Ri s et al. 2004). Human fetuses and young children are part icularly sensitive to even low levels of lead exposure and can easily suffer permanent neurological dama ge. Clinicians now assert that there is10 no safe level of lead in the body tissues fo r fetuses and young childre n (e.g. Canfield et al. 2003; Lanphear et al. 2005, 2006; Carlisle et al. 2009).

In recent decades the federal government ha s taken various regulat ory 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 shooti ng ranges. However, other lead sources causing si gnificant contamination are stil l uncontrolled. Lead exposure to wildlife has been widely documen ted yet is not adequately regulated.

As long as lead fishing tackle of the si zes and uses commonly ingested by wildlife remains available for purchase and use, numer ous species of wildlife will continue to be poisoned by lead. Human health is also thre atened 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 diam eter or less than one ounce in weight, there

is scientific evidence that some birds can i ngest 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 sinke rs 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 gizzar ds of waterfowl may be somewhat smaller at necropsy than at the time they were firs t ingested, due to the grinding action of the gizzard and the presence of sm all stones against which lead objects are abraded. The EPA must evaluate the risk of injury to wildlif e from all sizes, weights and types of lead fishing tackle and initiate a rulemaking to re gulate 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 wi ldlife species have been associated with small contaminated areas, such as around metal smelters, shooting ranges, lead paint contaminated buildings, or locations with inte nse 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 pain ts 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 balanc ing weights, and initiated a proceeding under TSCA to investigate potential lead hazards as sociated with the manufacture, processing,

and distribution in commerce of lead wheel weights (USEPA 2009). The EPA anticipates publishing a proposed rulemaking on regulati ng 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 th e EPA in 2010. The EPA has already solicited comments on that petition and issued an adva nce notice of proposed rulemaking on lead emissions from piston-engine aircraft us ing leaded aviation gasoline (USEPA 2010a, 2010b).11 Environmental distribution of lead from fishi ng is widespread, although it is difficult to estimate the magnitude of lead exposure comp ared to other sources, such as legacy residues of leaded gasoline exhaust depos ition, 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 a quatic habitats which could be solubilized and taken up by inverteb rates or fish (Stansley et al. 1992; Hui 2002). The fate of elemental lead in aquati c 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 sedi ment and soil particles. The bioavailability of lead is related to the presence of orga nic 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 inju ries to fish incurred by tack le (often containing lead) and small fragments passing through the digestive track of fish could release lead. Although there is no documentation of such lead uptak e or poisoning in fis h, 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 a ttached lead fishing tackle such as hooks and jigs, and become a potenti al pathway of lead exposure for predatory birds consuming fish containi ng such lead fishing gear.

There is a large body of evidence documen ting significant deposition of lead fishing tackle in aquatic environments and subseque nt ingestion by numerous bird species. There is extensive documentation of direct ingest ion of lead sinkers, jigs and other fishing tackle by dabbling and diving ducks, swans, l oons and other water bi rds. Water birds are lead poisoned from ingesting lead fishing sinke rs or jigs lost by a nglers on the bottom of water bodies. Sport anglers attach lead weight s 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 ba it 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 stone s 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 fish ing tackle seem to be the smaller weights used by sport anglers (Scheuhammer and No rris 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 diamet er. Observed sizes of lead objects in the gizzards of waterfowl may be somewhat smalle r 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 (F ranson and Cliplef 1992; Stone and Okoniewski12 2001; Evers 2004). Once ingested, lead objects re tained 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 potentia lly 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 mu ch 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 so ld in the U.S., assuming most or many sinkers are purchased to replace those lost while fi shing (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. (Sche uhammer et al 2003; US GS 2008). Studies of

sinker and tackle loss rates am ong 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 Ki ngdom (Bell et al. 1985). Angler s in the U.S. reported losing 0.18 sinkers/hour, and 0.23 hooks and lures/hour, with 2% of angler s 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 mete r of shoreline in areas of low angling pressure up to 0.47 sinkers/m 2 in areas of high angling pr essure (Duerr and DeStefano 1999), with much higher dens ities (up to 190 sinkers/m 2 ) 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 l ead 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 am ount 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 cau se significant lead exposure to wildlife.

D. Toxic Effects of Lead on Wildlife

Lead has long been recognized as a pois on to living organisms (Grinnell 1894; Engsted 1932; Horton 1933), with negative effects on general health, reproduction, and behavior13 (Ris et al. 2004). Lead was highlighted as an important cause of mortality in wildlife populations in the late 1950s, when ingesti on of spent lead shotgun pellets from hunting or lead fishing sinkers was recognized to cau se death in a wide ra nge of wild waterfowl (Bellrose 1959). Reports of poi soned 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 recogni zed that lead can be absorbed from the gastrointestinal tract of birds and mammals, cause dama ge in various organs, and result in behavioral changes, significant illness, and even death depending on the amount ingested (Reiser and Temple 1981; Kram er and Redig 1997; Fisher et al. 2006).

Lead objects or fragments ingested by bird s may be rapidly regurgitated, retained for varying periods, or completely dissolved with the resulting lead salts absorbed into the

bloodstream. The likelihood of a bi rd becoming poisoned is rela ted to the retention time of lead items, frequency and hi story of exposure to lead, a nd factors such as nutritional status and environmental stress (Pattee a nd Pain 2003). A proporti on 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 part icles usually results in some absorption,

and in cases where sufficient lead is absorb ed, poisoning ensues. Lead concentrations are generally highest in the blood di rectly 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-e ssential element and th e 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 tissu es of birds result primarily from the ingestion of lead ammunition or fishing weights.

Various authors have attempted to define tis sue concentrations in birds indicative of excessive lead exposure, sub-lethal poisoni ng and acute poisoning (F ranson et al. 1996; Pain 1996), but there is no definitive consensu s 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 μ g/dL for eagles, while Pattee et al. (1990) defined background levels as <20 μ g/dL, and Feierabend and Myers (1984) defined them as <10 μ g/dL. The generally accepted blood

lead levels for wild birds have been <20 μ g/dL as background; 20 to <50 μ g/dL indicating subclinical poisoning; 50 to 100 μ g/dL indicating clini cal poisoning; and >100

μ g/dL representing severe clinical po isoning (Friend 1985, 1999; Franson 1996; Pain 1996; Pattee and Pain 2003). Background leve ls at or higher than 20ug/dl are now understood to indicate significant exposure, be cause animals held in captivity usually have background levels of 4 μ g/dL or less (Walters et al. 2010).

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

contribution from natural sources such as volcan oes. Lead is rarely found in nature in its elemental metal form, and the most common s ource is galena or PbS, which has a very low solubility in water. Wildlife can ge t low level exposure to lead from unknown sources, including natural accumulation in pl ants and ingestion by herbivores, and deposition by leaded gasoline exhaust, now a ttenuated with regulation. “Baseline” lead

concentrations in wildlife can vary between taxa, and the diagnosis of poisoning is14 usually based on signs of poisoning in combina tion with blood lead le vels 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 di fficult to measure because the effects on the nervous system at low doses can be subtle and difficult to detect without specific quantifiable behaviors. In a ddition, predisposition and suscep tibility 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 envi ronment caused by small amounts of lead ingestion may result in a proximate death fr om many causes. In long-lived bird species, this has the potential to skew the norma l 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 cogniti ve behaviors similar

to those demonstrated in huma ns, but it is likely that repeti tive sub-lethal exposures to lead will cause permanent neurological and behavioral decrements in all species of wildlife (Canfield et al. 2003; Lanph ear 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 acu te lead poisoning can appear normal, but experience massive tissue destructi on to internal organs and death within a few days (Sanderson and Bellrose 1986). Bird s with chronic lead poisoning may develop appetite loss, anemia, anor exia, reproductive or neurol ogical impairment, immune suppression, weakness, and susceptibility to predation and starvation (Grandy et al. 1968; Kimball and Munir 1971; Finley a nd Deiter 1978; Hohman et al. 1995).

The effects of toxicosis in birds commonly incl ude distension of the proventriculus, green watery feces, weight loss, anemia and drooping posture (Hanzlik 1923; Quortrup and Shillinger 1941; Redig et al. 1980; Reiser a nd Temple 1981; Franson et al. 1983; Custer et al. 1984; Sanderson and Be llrose 1986; Mateo 1998). Sub-le thal toxic effects are exerted on the nervous system, kidneys and circ ulatory system, resulting in physiological, biochemical and behavioral changes (Sch euhammer 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 haematocr it and hemoglobin levels. Lead toxicosis depresses the activity of certa in blood enzymes, such as delta aminolevulinic acid dehydratase, essential for ce llular 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 concen trations of lead in blood (20 μ g/dL), resulted in a 60%

decrease in the levels of aminole vulinic acid dehydratase in condors.

As a result of physiological and behavioral changes, birds may become increasingly susceptible to predation, starva tion and infection by disease, increasing the pr obability of15 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 corr elation 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 sp erm (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 likel ihood of birds returni ng to an area to breed (Mateo et al. 1999).

Burger and Gochfeld (2000) found that chro nic lead exposure resulted in delayed behavioral response time in both la boratory 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 he molytic anemia during the first week of exposure and neurological impairment duri ng 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 increa ses 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 l ead exposure had lasti ng effects including lowered bone density and increased blood pressu re one year after e xposure in laboratory

rats.

In spite of the abundance of evid ence that lead is toxic to wi ldlife, poisoning rates are not

well understood. While massive die-offs are r eadily 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 carca sses and only found 6 (Stutzenbaker et al. 1983). In another study in which researchers pl anted 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 effect s of lead toxicosis may be difficult to recognize at a distance in free-ra nging wild animals. Subtle ne urological 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 el ude 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 documente d to cause lead poisoning mortality in numerous species of water birds and wading bi rds, and the problem is particularly acute for loons, swans, cranes, geese, mallard s 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; Daous t 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 ta ckle and mortality of loons. Lead poisoning from ingesting lead fishing sinke rs or jigs is a signi ficant cause of death for adult common loons ( Gavia immer ) in the United States a nd 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 s ource in for loons new England (Pokras et al. 1992). Evers (2004) re ported that in New England, a 14-year study diagnosing causes of mortality in 522 co mmon loons documented 44% of the breeding adults died from lead toxicosis, from ingest ing either lead shot or lead fishing sinkers. Lead fishing tackle accounted for 52 percen t of mortalities among adult and immature loons in New Hampshire from 1976 through 200 0, by far the largest si ngle cause of adult loon mortality in the state (Loon Preservati on Committee). The U.S. Fish and Wildlife Service noted that ingestion of lead sinke rs 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) exam ined 60 dead loons collected in New Hampshire from 1989 to 1992 and 27 (45%) had i ngested 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 Si dor 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, coll ecting 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 object s, and 73 of these 118 loons, 73 had more than one object in their gizza rd, for a total of 222 lead obj ects recorded. Lead sinkers (48%) were the most frequently ingested object, followed by jighead s (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) pr esent in the gastro-intestina l 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 l ead objects were less than 25.4 mm in length; 44% had a length of less than 10 mm.17 Substantial rates of lead-related mortal ity 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 a nd 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 Resour ces, 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 toxici ty was a major contributor to

the cause of death.

Lead poisoning from fishing we ight ingestion was the leadin g cause of deaths diagnosed

for common loons in easter n Canada from 1983 to 1995, in areas where loon breeding habitats overlap with spor t fishing (Scheuhammer et al. 2003). Scheuhammer (2009)

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

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

Canada in habitats that e xperience high recreatio nal angling activity. Daoust et al. (1998)

found that 5 of 31 common loons collected w ith 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 object s more frequently compared to 26 other species of water birds sampled across the Unit ed States (Franson et al. 2003). Franson et al. (2003) found that 11 of 313 common loons br ought 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 s how evidence of lead sinker i ngestion (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 pe rcent 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 b een 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 inge sting lead fishing

sinkers was documented as the cause of deat h 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 poisoni ng related mortality of a tundra swan that ingested a lead

sinker.18 A study in Britain found that lead poisoning fr om 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 i llegal use after the ban (Perrins et al. 2003).

3. Other Birds

Lead fishing sinkers and jigs have contribute d 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 inge sting lead fishing weights (Windingstad et al. 1984) and an endangered Mississippi sandhi ll crane died of lead poisoning with an unidentified lead object in its gizzard (Franson and He reford 1994). Other species reported to ingest lead sinke rs 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 (M udge 1983; USEPA 1994; Scheuhammer and Norris 1995; Friend 1999; Fr anson et al. 2003; Scheuhammer et al. 2003).

4. Reptiles

There is evidence of freshwater turtles inge sting lead fishing wei ghts 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 Stat es has decreased as lead plumbing, paint, solder, toys, and gasoline have been phased out and replaced. Public health agencies have regulated lead in industrial ac tivities and consumer products, and have to varying degrees begun to address and remediate lead exposur e from shooting ranges, but have focused

little attention on fishi ng activities that may be an impor tant 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 thr ough 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, a pproximately 800,000 to 1.6 million people in19 the United States manufactured lead fishing we ights in their homes, often in enclosed garages or basements, representing approximate ly one-third of the lead sinkers produced in the country (USEPA 1994). The EPA warn s 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, wa lls, floors, furniture, clothing, toys, stuffed animals, etc. (USEPA 2011b). Anglers also risk lead exposur e 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 Roma n times (Nriagu 1983; Needleman 1999; Hernberg 2000; Tong et al. 2000; Nriagu 2009). Lead is an extraordinarily toxic element, and when i ngested it attacks organs and many different body systems, including the bl ood-forming, nervous, urinary, and reproductive systems (USDHHS 1999). Lead accumulates in humans mainly in bones, with lead in blood and other tissues reflecting more re cent exposure. The effects of lead poisoning can include: damage to the brain and central nervous sy stem; kidney disease; high blood pressure; anemia; and damage to the reproductive syst em, including decreased sex drive, abnormal menstrual periods, impotence, premature ej aculation, 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 brai n 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 occu r without obvious symptoms (USDHHS 1999). Lead exposure can adversely affect the ner vous system (resulting in impaired cognition, reduced motor coordination, and palsy), renal system, and cardiovascular system (IPCS 1977; Needleman et al. 1990; Goyer 1996; N eedleman 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 abor tion (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; Needle man 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 mi crograms of lead per deciliter ( μ g/dL) is currently considered an elevat ed level, although some researchers and health professionals have advocated for a threshold of 5 micrograms or even 220 micrograms. In the mid-20th century, the amount of lead in the bloodstream of a child

considered in need of medical in tervention was considered to be 60 μ g/dL, whereas today

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

there is evidence that blood lead levels less than 10 μ g/dL are associated with adverse health effects on development in children and reproduction in adult women, such as delayed puberty, decreased postn atal growth, reduced fetal gr owth, spontaneous abortion and preterm birth (NTP 2011); and studies show blood lead leve ls at and below 2 μ g/dL are associated with adverse effects (e.g. Wu et al. 2003; Denham et al. 2005). Children sustain permanent cognitive damage wh en they show an average of only 7.5 μ g/dL in blood before the age of five (Lanphear et al. 2005).

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

Health and Human Services concluded that blood lead concentra tions lower than the federally established levels of concerns are associated with advers e health effects and reports that even blood lead concentrations lower than 5 μ g/dL are associated with decreased academic performance and cogniti ve function, increased incidences of ADHD and behavioral problems in children (NTP 2011). The assessment also found that blood

lead concentration levels below 10 μ g/dL are associated with delayed puberty, reduced growth, decreased IQ, and d ecreased hearing in children, and increased blood pressure

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

researchers is that there is no safe level of lead exposure in yo ung children (CDC 2005).21 V. AUTHORITY TO ACT

In adopting TSCA, Congress declared its po licy that (1) “adequate data should be developed with respect to the effect of chem ical substances and mi xtures on health and the environment” and (2) “adequate aut hority 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 recognizi ng that the EPA would not always act on its own, it authorized any person to peti tion 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 envir onment.” Factual certainty of the magnitude of risk to health and environment is not require d; the EPA may base it s decision not only on known facts, but also on scientif ic theories, projections and ex trapolations from available data, and modeling using reasonable assumptions (59 Fed. Reg. 11122, 11138, citing H.R. Rep. No. 1341, 94 th 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 s ubstances or mixture for various uses and the availability of substitutes for such uses, and (D) the reasonably ascertainable economic consequences of the rule, after cons ideration of the effect on the national economy, sma ll 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 Secti on 553 of the Administrative Procedure Act.

However, at the petition stage, the EPA mu st only review the petition and determine

whether there is a reasonab le basis to conclude that the manufacture, processing, distribution, use, or disposal of lead in fishing sinkers pres ents 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. Howeve r, 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 ru le, after consideration of the effect on the national economy, small business, technologi cal 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 ha ve to be made of lead. Nearly all fishing tackle products

available in lead are now av ailable in nontoxic alternativ e materials. Demonstrated technology indicates that all fishing tackle products co uld be produced in nontoxic alternatives within a short period of time , if manufacturers ar e 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 recy cled glass are widely available. Sinkers made of materials other than lead have gained varying levels of acceptance among anglers, with tradeoffs regarding cost and e ffectiveness. At least 10 substitutes for lead fishing tackle are on the market: tungsten (pla stic composites and putty), stainless steel, carbon steel, tin, tin/bismuth, bra ss, 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; Zdziarsk i 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 orga nizations 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 ne arly all states can currently identify gear containing lead, and can routinely avoid us ing lead-containing products, if they so choose. Not all states require a lead warni ng, 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 alterna tives to lead fishing tackle, is sold as a tungsten-plastic composite and as tungsten putty, a specialty it em marketed to flyfishers. Tungsten putty can be molded into varying sh apes and sizes and affi xed to fishing line, allowing anglers to vary the si nk rate of their fly presentati on. 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-m aking attributes that may attract fish in23 some situations. Tungsten is more expensiv e than lead, and tungs ten tackle requires plastic sleeves to cover sharp edges, at additional expense.

Stainless steel tackle is adve rtised as having fish-attracti ng 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 inte rnet. 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 th ree-way swivel to adjust the sink rate to hold bait on the bottom. This gear is gaini ng popularity in river fi sheries and steel is replacing lead in a variety of commercial traps. Iron is one of the less expensive alternatives to lead, but ha s the disadvantage of eventua lly corroding after continued

exposure to water.

Tin is a malleable metal that allows angler s to reuse split shot many times. The lower density of tin also allows for a slower sink ra te, 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 angl ers who manufacture their own jigs, partly due to better pa int 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 fi sh-attracting qualities. Brass is an alloy of copper and zinc, and me tallic 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 larg er and is currently more expensive than its lead equivalents. Certain types of glass can be made to “glow” af ter exposure to light, a quality purported to improve fish biting fre quency. Glass sinkers are available primarily through the internet. Ceramic fishing tackle is also considerably larg er 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 alternativ e, 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 ec onomic impact of banning smaller-sized lead fishing tackle would be nominal (EPA 1994). Similarly, when the National Wildlife Refuge System implemented “Lead-Free Fi shing Areas,” they acknowledged that nontoxics sometimes cost more than lead weight s but stated that as sinkers only comprise 3% of yearly equipment costs, the increase di d 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 consid er whether actions undertaken by the EPA under other federal laws adequately address th e risk of unreasonably injury, this petition presents information on existing regulatory e fforts in order to demonstrate that despite these efforts, there remains an unreasonabl e 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, th ey 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 wild life. The fact that there are some limited state regulations addressing lead sinkers has al so not ended lead poisonings of birds in those states, nor do those regul ations address continued lead poisoning and likely lead exposure to birds in numerous ot her states where there are not even limited state regulations. TSCA does not require a s howing of population-level impacts from lead poisonings to regulate toxic lea d, only that there is an unreason able risk of injury to the

environment.

Federal Regulations Currently, there are some limited and inconsis tent regulations rega rding lead fishing tackle on some National Wildlife Refuges and National Parks. While these measures may have begun to reduce the risk of lead e xposure to wildlife and humans in limited geographic areas, and demonstrat e 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 so me U.S. National Wildlife Refuges (“NWR”) that have loon and swan populations and in one National Pa rk. Currently, the Nati onal Wildlife Refuges with regulations prohibiting use of lead weight s, 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 Rive r NWR in Massachusetts, Seney NWR in Michigan, Red Rock Lakes NWR in Montan a, and Rappahannock River Valley NWR in Virginia (Franson et al. 2003; Michael 2006) . Yellowstone National Park has banned leaded fishing tackle and weights small e nough 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 fish ing tackle in all National Pa rks by the end of 2010, but has yet to initiate any rulemaking.

In 1999 the U.S. Fish and Wildlife Servic e (“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 fi nal 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 Hampshir e, 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, a nd the other 44 states have no lead fishing regulations at

all.

Maine Maine passed legislation in 2001 (effective Ja nuary 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 Reserv oirs) 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 (inc luding “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 fishi ng sinkers weighing one- half ounce or less.

Washington The Washington Fish and Wildlife Commissi on in 2010 approved restrictions on the use of lead fishing tackle at 13 lakes with ne sting 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 C ounty; Bonaparte, Blue and Lost lakes in Okanogan County; Big Meadow, South S kookum 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 contai ning lead at Long Lake in Ferry County.

International Regulations banning smaller lead fishing t ackle in other countr ies demonstrate the potential effectiveness of regulations in the Un ited States. Restrictions on the sale and use of smaller lead fishing sinkers and jigs are in place in Canada, Denmark, and Great26 Britain. In 1997, Canada amended its Wildlife Area Regulations to pr ohibit 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 po ssession and use of lead sinke rs 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 sw ans, diving birds, and wading birds, and after determining that voluntary efforts we re 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 we ights (Sears and Hunt 1991).27 VIII. DESCRIPTION OF FEDERAL REGULATIONS REQUESTED

Petitioners Center for Biol ogical Diversity, Loon Lake Loon Association and Project Gutpile formally request that the EPA:

1) evaluate the unreasonable ri sk of injury to the environment and wildlife from fishing tackle containing l ead (including fishing weight s, sinkers, lures, jigs and/or other tackle) of various sizes a nd 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 wildlif e from the ongoing threat of lead poisoning.

TSCA grants the EPA the broad authority to re gulate 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 s ubstances “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: prohibi tions on an entire or certain use of a chemical substance; limitations on allo wable 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 thr ough a range of alte rnatives, up to and including the EPA prohibiting the manufacture, processing, or distribution in commerce of a chemical substance for a particul ar use (15 U.S.C. § 2605(a)(2)(A)(i)).28 IX. CONCLUSION

Section 6 of the Toxic Substan ces Control Act requires only that the EPA find that there

is “a reasonable basis to conclude” that a ri sk to the environment or human health is unreasonable. Scientific theories, projections of trends from currently available data, modeling using reasonable assu mptions, and extrapolations from limited data may help to establish risk (H.R. Rep. No. 1341, 94 th 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 toxici ty of lead fishing t ackle of certain sizes

and uses to wildlife. The scientific literatu re on the sources, quanti ties, and pathways of exposure of lead in the environment from fish ing tackle is conclusive, as is information

on the toxic effects and health risk of fishing tackle on wild life. Many species of wildlife, particularly water birds, inge st lost or discarded lead fi shing tackle. The widespread poisoning of many species of wildlife requi res a response from the EPA to regulate certain sizes and uses of lead fishing tackle.29 X. REFERENCES

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