Rationale for the regulated transition to non-lead products in Canada: A policy discussion paper

Lead gunshot, rifle bullets, and fishing weights are still allowed in Canadian provincially-regulated hunting and fishing, despite the contribution to lead exposure in humans, wildlife, and the environment. Non-lead gunshot and fishing weights are required in Canada only for waterfowl hunting, and angling in national parks and national wildlife areas. Lead wheel weights are also allowed and comprise a majority of the Canadian market. Effective non-lead substitutes for these products exist, and are already required in various American and European jurisdictions. Several analyses commissioned by the Canadian government in 2018 identified the problems of lead exposure attributable to these four lead products. Lead is already listed under Schedule 1 of the Canadian Environmental Protection Act (CEPA) that authorizes the government to undertake measures to reduce exposure. CEPA could require, simultaneously, use of non-lead ammunition, fishing weights and wheel weights at the national level, following an appropriate phase-in period. The low provincial and territorial licence fees for hunting and fishing in Canada would offset any costs associated with use of lead substitutes. Costs for non-lead wheel weights would comprise a small percentage of the costs of new vehicles and new tire purchases. This regulatory initiative would complement other Canadian national bans on lead products. Because there is no safe threshold level for blood lead, use of non-lead products would benefit the health of humans, scavengers, upland game species, and fish-eating birds.