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PROPOSED BANNING OF LEAD SINKERS AND JIGS
There has been great furore raised recently regarding the proposed banning of lead sinkers and jigs. Some of this confusion appears to be misleading, or at the very least, befuddled.
For over nine years, the Canadian Association of Smallmouth Anglers has been attempting to get this legislation on the national agenda, so, as you can appreciate, the current resistance is most disappointing.
To clarify CASA’s position, which we have freely presented over the past few years, we thought it might be of assistance to respond to those particular areas that seem to be the focus of the majority of the objections. Perhaps this will assist in implementing a more reasonable dialogue that will prove to be of equal advantage to the environment, wildlife, anglers and the tackle manufacturing sectors.
The main areas of dissent seem to be generated by the following sub-headings;
- Lack of Consultation
- Faulty, Poor, or “Junk” Science
- Lack of Peer Review
- Misconceptions Regarding the Discussion Paper
- Validation for Banning Lead Sinkers & Jigs
Lack of Consultation
Please do not perpetuate the concept that there was no consultation, - this is the consultation. Environment Canada published and distributed a Discussion Paper. This is a reasonable approach as a “starting” point for any consultation and this discussion paper is the starting point. Each and every individual and/or organization now has the opportunity to review the paper; note the areas with which they are in agreement; note the areas where they might wish to express concern; and as part of the consultative process submit their areas of support and/or concern. To reject the whole proposal outright defeats the concept of discussion. In reading the paper, CASA has expressed a couple of minor concerns, but in general we wholeheartedly support the intent. In this way we are consulting with the government and we will press for changes where we feel they are necessary. After working for nine years to get this on the national agenda and then to miss this valuable window of opportunity would be a crime against the environment. If we do not support the general concepts expressed in the discussion paper now, there will be no political will to re-open this matter for discussion again for the next five years – at a minimum.
Faulty, Poor or “Junk” Science”
These phrases (which seem to be used interchangeably) are just plain wrong. No, worse than that, they can easily constitute libel. Those who have perpetuated these phrases through dissemination via email are grossly in error. One might suspect that not everyone has read Occasional Paper 108 in detail. The paper itself is 51 pages in length and the bibliography notes 134 separate published studies and unpublished papers that were the reference points for the paper. This was not something that was churned out over a long weekend. Dr. Tony Scheuhammer, a well-published, and much respected research scientist with a long history in this field (along with his associates Money, Kirk & Donaldson) spent considerable time, effort and expertise in the process. It is difficult to understand the rational use by some, that somehow the study falls short of professional standards and at the same time use excerpts from Occasional Paper 108 to bolster their own anti-ban arguments. All this leads nicely into our next point:
Lack of Peer Review
There have been suggestions that the paper somehow lacks validity since it was not “Peer Reviewed”. To those that hold this viewpoint, this assumption is wrong. Once an occasional paper is submitted to the editorial board of CWS, the author(s) then basically relinquishes control. A managing editor (in this case Dr. Hugh Boyd) would then assign the paper for review to other scientists. For this paper, drafts were not only reviewed by seven scientists attached to CWS, but it was also reviewed by three respected research scientists outside of CWS; Dr. D. Evers, Biodiversity Research Institute; Dr. V. Thomas, Guelph University and Dr. M. Pokras, Tufts University. The latter three are all respected research scientists with multi-publications bearing their names. In all probability, more “peers” than the average submission to a Scientific Journal, reviewed this paper. It is easy to understand why this came out as a paper rather then in a journal – the paper was much longer than the average journal would use and the number of tables (11) and figures (Maps & Charts – 24) – many in full colour - would be extremely expensive to publish – far more than average for a scientific publication.
Misconceptions Regarding the Discussion Paper
The discussion paper is the starting point – not the end result. Most importantly, it is about banning lead – for a variety of substantive reasons. Yes, this does include reducing loon mortality, but it is so much more than that. Making an argument that there is no reason to ban lead because only “x” numbers of loons have died from poisoning is fallacious. We all know there are other reasons for loon mortality, as a matter of fact Gord Pyzer, a respected biologist based in Ontario has pointed this out in his letter posted on the web. The problems he outlines should also be dealt with, but this proposed legislation is not the vehicle. We also know from Paper 108 that the loon population appears to be stable, and in some areas, even increasing. But the reported stability is only a snapshot in time – valid when the studies were undertaken. Since loons have a relatively long life span (up to 20 years) these “snap shots” may, or may not, present an accurate picture. The only way the interpretive disagreements could be resolved is to undertake lengthy and very expensive studies across the loon’s habitat in Canada. This would add years to making a decision and (if I understand the type of studies that have been suggested) we would have to find hundreds of thousands of dollars, along with enough research scientists interested in the subject. Unfortunately, economics dictates that this isn’t going to happen. Too much emphasis, by both sides, has been placed on loon mortality as if it is the only reason for banning lead sinkers and jigs. There are many other valid reasons that should also be taken into consideration.
Validation for Banning Lead Sinkers & Jigs
The following points are the basis for CASA’s validation of a lead ban:
- The Canadian Environmental Protection Act classifies lead as a toxic substance.
- Lead has already been eliminated or restricted in paints, batteries, gasoline, pesticides, ceramic glazes etc.
- The use of small lead sinkers and jigs has already been banned in National Wildlife areas and National Parks.
- The International Joint Commission has targeted lead for virtual elimination from the Great Lakes.
- Lead, as introduced by human activity, meets the criteria for substances targeted for virtual elimination under the federal Toxic Substances Management Policy.
- The sale of lead fishing weights was banned in Great Britain, Hampshire, Maine and New York with regional bans in several other States, National Wildlife Refuges and Parks.
- Lead poisoning of piscivorous birds, including swans, loons, bald eagles, and other species have been well documented.
- In Canada, although there is disagreement about the actual numbers, we can state that a not inconsiderable amount of lead sinker and jig production is the result of home or small-scale production. The documented (U.S. studies) of elevated blood lead levels and lead poisoning of adults and children should be of further concern and a vital reason for the support of lead-free tackle.
- Lead accounts for less than 1% of the average annual fishing budget and high quality, affordable non-toxic alternatives are available.
- Canada has committed to follow and promote a cautionary approach to substance management as defined by Principle 15 of the Rio Declaration on Environment and Development: “Where there are threats of serious or irreversible damage, lack of full scientific certainty shall not be used as a reason for postponing cost-effective measures to prevent environmental degradation”.
Summary
Given the above reasoning, CASA sees little substantive reasoning for further delay. Lead is poison. Why would any thinking human being continue to allow its introduction into our environment? The answer seems so clear, particularly when there is an easy and inexpensive (all things considered) method of alleviating an environmental problem. All the surveys indicate that voluntary changes to a non-toxic material, does not work in the long run. Even all CASA members, where we have had a volunteer lead-free ban for years, do not totally comply. The discussion paper makes a great deal of sense in that it proposes banning the manufacture, importation and sale of lead sinkers and jigs – not the possession of them. This means that all anglers (if they wish) will have the opportunity of using up their existing supply of lead sinkers and jigs and ultimately replacing them with non-toxic material.
With over 5 million anglers in Canada, it would appear that the figure of 500 tones deposited in our waters would work out (and admittedly math is not a strong point) at four average weight sinkers or jigs lost per season.
There are all sorts of reasons to complain about the scope of this proposed legislation; it doesn’t cover down-rigger weights; it doesn’t take into consideration other sources of wildlife mortality; but. It actively attempts to resolve one important aspect of concern to the angling and other communities that share our water resources. This proposal deserves our active support by signing and emailing the letter of support (below) and sending copies to your local MP and the appropriate federal and provincial departments concerned with both angling and/or water resource management. Where available, email addresses are listed at the end of the letter.
The alternative is to sit on our hands and let the “big boys” fight it out.
For CASA, doing nothing has never been an alternative.
Michael N. Robinson
Canadian Association of Smallmouth Anglers
michaelr@ca.inter.net
Honourable Stéphane Dion, P.C., M.P.
Minister of the Environment
House of Commons
Ottawa, Ontario
K1A 0A6
Dear Minister:
We are writing in support of the Canadian Association of Smallmouth Anglers position regarding your department’s national initiative to extend the ban on lead sinkers and jigs
Despite the controversy that seems to have brought more heat than light to the discussions, and the consultative process, the rationale behind the implementation of this ban is a step in the right direction. A step we might point out that is important to all users of our water resources. We might also suggest that many of the people and/or organizations that would support this proposal (cottage owners are just one group that comes to mind) would be totally unaware of this proposed legislation and its intent
We support the proposed legislation for the following reasons;
- The Canadian Environmental Protection Act classifies lead as a toxic substance.
- Lead has already been eliminated or restricted in paints, batteries, gasoline, pesticides, ceramic glazes etc.
- The use of small lead sinkers and jigs has already been banned in National Wildlife areas and National Parks.
- The International Joint Commission has targeted lead for virtual elimination from the Great Lakes.
- Lead, as introduced by human activity, meets the criteria for substances targeted for virtual elimination under the federal Toxic Substances Management Policy.
- The sale of lead fishing weights was banned in Great Britain, Hampshire, Maine and New York with regional bans in several other States, National Wildlife Refuges and Parks.
- Lead poisoning of piscivorous birds, including swans, loons, bald eagles, and other species have been well documented.
- In Canada, although there is disagreement about the actual numbers, we can state that a not inconsiderable amount of lead sinker and jig production is the result of home or small-scale production. The documented (U.S. studies) of elevated blood lead levels and lead poisoning of adults and children should be of further concern and a vital reason for the support of lead-free tackle.
- Lead accounts for less than 1% of the average annual fishing budget and high quality, affordable non-toxic alternatives are available.
- Canada has committed to follow and promote a cautionary approach to substance management as defined by Principle 15 of the Rio Declaration on Environment and Development: “Where there are threats of serious or irreversible damage, lack of full scientific certainty shall not be used as a reason for postponing cost-effective measures to prevent environmental degradation”.
The fact that the EPA in the United States, just this week, has ordered increased monitoring for lead in municipal water supplies, water sources for schools, hospitals and day-care nurseries, should only further validate the direction your department is taking.
Yours truly,
Contacts:
Hon. Stephane Dion – Minister – Environment Canada - stephane.dion@ec.gc.ca
Nova Scotia - Hon. Kerry Morash – Minister of Environment & Labour - morashkg@gov.ns.ca
Nova Scotia - Hon. Chris d’Entremont, Minister of Agriculture & Fisheries - dentreca@gov.ns.ca
Alberta – Hon Guy Boutilier, Minister of Environment – fortmcmurray.woodbuffalo@assembly.ab.ca
B.C. - Hon. Bill Barisoff, Minister of Water, Land & Air Protection – bill.barisoff.mla@leg.bc.ca
Manitoba – Hon. Stan Struthers, Minister of Conservation – mincom@leg.gov.mb.ca
New Brunswick – Hon. Brenda Fowlie, Minister of Environment – brenda.fowlie@gnb.ca
Newfoundland & Labrador-Hon.Tom Osborne, Minister of Environment – tosborne@gov.nl.ca
NWT – Emery Paquin, Director Environmental Protection Services – emery.paquin@gov.nt.ca
Nunavut – Hon. Olayuk Akesuk, Minister of Environment – Fax # 1-867-975-5095
Ontario – Hon. Leona Dombrowsky, Minister of Environment – ldombrowsky.mpp.co@liberal.ola.org
PEI – Hon. James Bullem, Minister of Environment – jwbullem@gov.pe.ca
Quebec – Hon. Thomas Mulcair, Ministre de l’Environnement – minister@menv.gouv.qc.ca
Saskatchewan – Hon. David Forbes, Minister of Environment – dforbes@serm.gov.sk.ca
Yukon – Hon. Peter Jenkins, Minister of Environment – peter.jenkins@gov.yk.ca
C.A.S.A.
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