Reasons why lead should not be banned

[Corker]

Yup....

Split, you should lift this post and paste it into a comment letter. I wouldn't change a word--just tell your story. Non-fishing regulators need to hear the real effects of the rule they are considering, and they need to hear it from ordinary citizens who be punished with a rule that's not justified by the arguments offered by the tree huggers.

[split handle]

I'll be doing that, but first want to get a better handle on exactly what the proposal is and what arguments I am countering. I don't want to come across as just a whiner who doesn't want to be inconvenienced. I also want to be able to acknowledge and rebut the contrary arguments.

[Corker]

I'll be doing that, but first want to get a better handle on exactly what the proposal is and what arguments I am countering. I don't want to come across as just a whiner who doesn't want to be inconvenienced. I also want to be able to acknowledge and rebut the contrary arguments.

There isn't actually a proposal on the table at this stage of the process--but that will happen soon. A rulemaking under TSCA can begin with a petition from citizens, organizations, or anyone who believes there are toxic substances that should be controlled. The 100 page petition that started this is here. Upon receiving such a petition, EPA issues a request for public comment on the pros & cons of the petition. This is where we stand at the moment.

After the comment period ends (9/15 in this case), EPA reviews the comments and decides whether to proceed with a regulation. The best outcome for us would be for EPA to announce that it won't pursue the issue further.

If our arguments today don't convince EPA to abandon the rulemaking, a proposed regulation will be written and published in the Federal Register for public comment. When that comment period closes (typically 60 days), EPA will review the comments and decide whether to amend the proposal or issue it as a final regulation.

[OGFWeatherby]

Found this. From Massachusetts by the Toxic Use Reduction Institute from 2005.

Fishing sinkers

Nearly 2,500 metric tons of lead are used each year in the United States to produce fishing sinkers. Many of these sinkers are lost during use. One study found that anglers lost, on average, one sinker every six hours of fishing. Lead sinkers are lethal to waterbirds, such as loons and swans. One study found that the most common cause of death in adult breeding loons was lead toxicity from ingested fishing sinkers. A number of states have placed limits on the use of lead fishing sinkers. In Massachusetts, lead sinkers are prohibited for use in the Quabbin and Wachusett Reservoirs, the two bodies of water that support the core of the state's loon population. Use of lead sinkers is restricted in several other states in the Northeast, and is restricted or banned in several countries. Many anglers produce their own lead sinkers at home. This activity can expose individuals and family members to airborne lead particles or vapors.

The Institute examined five possible alternatives to lead for use in fishing sinkers: bismuth, ceramic, steel, tin, and tungsten. For each alternative, the Institute examined human health, environmental, technical/performance, and cost criteria.

* Human health. All the alternative materials are superior to lead from the perspective of the human health criteria the Institute examined (carcinogenicity, developmental toxicity, and occupational exposure).
* Environment. The alternatives are generally superior to lead from an environmental standpoint as well. All of the alternatives are clearly less hazardous to waterfowl and other aquatic species than lead.
* Technical criteria. The principal technical criteria of interest for this application are density, hardness, malleability, melting point, and corrosion resistance.
o Tungsten is more dense than lead; all the other alternatives are less dense than lead.
o Harder materials are preferable for use in many sinkers. All the alternatives are harder than lead; pure tin is about equal to lead in hardness, while tin alloy is harder than lead.
o Greater malleability is an advantage for sinker applications where the sinker is crimped on to the fishing line. Tin has malleability equal to that of lead; all of the other alternatives are less malleable than lead.
o Low melting point is considered an advantage because it allows individuals to produce sinkers at home, although home production of lead sinkers also creates human health hazards. Bismuth and tin have lower melting points than lead; ceramic, steel, and tungsten have higher melting points.
o Carbon steel is less resistant to corrosion than lead. Stainless steel and all the other alternatives are similar to lead in this regard.
* Cost. The alternatives generally have a higher retail price than lead sinkers, although some steel sinkers are competitive in price with lead sinkers. Studies conducted in the 1990s suggested that fishing sinker purchases represent less than 1% of total expenditures by anglers on their sport, so an increase in fishing sinker costs would be unlikely to have a significant effect on users.


Prices (per lb):

Lead .9643

Bismuth $8.50

Ceramic - Many different varieties from $1.00 to $42.00

Carbon Steel - $1.45

Pure Tin - $10.00

Tungsten - $13.00

[Corker]

Found this. From Massachusetts by the Toxic Use Reduction Institute from 2005.

There are two major problems with this analysis:
1. EPA's ban will not stop with "sinkers". The petition and EPA's preliminary comments use that term to mean sinkers, split shot, jigs, Road Runners, lead core line, and any other tackle product that contains lead.
2. It is unreasonable to assume that all lead items are produced to replace a comparable item which was lost. Jig fishermen stockpile large quantities of lures.

[ShilohRed]

Excise Taxes - Federal Excise Taxes Due
Read down the page. It shows that
What products must I pay excise taxes on?
Businesses must pay excise taxes on:
Environmental products, such as domestic petroleum oil spills and ozone-depleting chemicals.
Communications and air transportation taxes
Fuels used in business
Purchase of trucks, trailers, semi-trailers (at a percentage of the sales price)
Ship passenger tax (per passenger)
Manufacturers Taxes on coal, taxable tires, gas guzzlers, etc.
Foreign insurance taxes
Sport fishing equipment, fishing rods, poles, outboard motors, etc.
Floor stocks tax on ozone-

I have to pay 10% on each hook I buy to resale along any any products you make to fish with that is sold.. Say I make up a Fish Formula and sell it I have to add 10% to the price for the Excise Taxes along with any State and Fed tax's..
Pete

[Corker]

Federal Excise Taxes

So your point is that a ban on lead would result in an overall reduction in tackle sales which would, in turn, cut into federal tax revenue?

[ShilohRed]

So your point is that a ban on lead would result in an overall reduction in tackle sales which would, in turn, cut into federal tax revenue?

My point was someone was trying to find out for sure about the Excise taxes on fishing tackle..
And yes if they cut out lead it may well cut down on the revenue but doubt it as what ever they make us use is going to cost more therefor there will be more tax on that product. It sounds to me like someone has what ever they think will replace lead and there trying to get this pushed through to make a Killing on it there selfs..
I sure hope they don't ban it for a long time my self. And it does not matter that I have a few $$$ in Lead, Jig hooks and molds.. along with Poured sinkers . But its going to hurt everyone that sells tackle and also the ones using it.
Pete

[mduncan62]

Here are my top reasons to object to an EPA ban on lead jigs, sinkers, and other fishing tackle.

1. Loss of ability to make my own tackle. Home-making tackle is an enjoyable part of the fishing experience, but the melting point of alternate metals is too high for home production.
2. Cost. If home production of jigs, sinkers, and other tackle items is no longer legal, my tackle cost will increase.

What other reasons can be added to the list?

lead returns to its natural state in a very short time causing it to disapate back in to the earth and tin and other stuff takes a lot longger to decompose and return to its natural state

Corker, those are not valid arguments to overturn an EPA ban. Send that to them and they will trash it. To beat a movement like this, you'd have to prove that it's false. Adding the phrase "tree hugger" to your submission also will do little to further your cause.

It took me exactly 1 search to find a study that documented fishing gear in water foul. http://www.nwhc.usgs.gov/disease_inf.../03JCF.W01.pdf
which was a very small cross section of birds. Sure lead returns to it's normal state, assuming it isn't ingested by any living thing. And in it's natural state, it's still toxic to us and wildlife, correct?

In another post it even mentions that pouring your own lead puts you and your family at risk for carcinogens, poisoning, etc.

I'm not for or against the "tree huggers" I've made my submission to my local and state reps. But fighting something like this with "hobby lead work in my garage" submissions will not do a darn thing to further your cause. If lead was killing fish, or there was something else killing fish, I'm sure there would be a heck of a lot of people on here going bananas over it.

[flatfish46]

The #1 reason is Ducks don't feed in 15 plus foot of water They'll let China send everything in the world over here to KILL Our pets and Children and there so worried about the envioroment Why don't they put Their A------'s togather and take care of the working class in this country it's time people said something and chunck'im all out thi8s election plain and simple!