HomeMy WebLinkAbout63 Gallant11/13/2019 Tarboo Ridge Gun Proposal Hearing - Comments Sub... - Planning Commission Desk
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Tarboo Ridge Gun Proposal Hearing - Comments Submitted by
Connie Gallant
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Planning Commission Members:
I am attaching a letter I sent to the BOCC on October 23, 2018 outlining the environmental
concerns surrounding the gun range proposal at Tarboo Ridge. Since the BOCC, the county
attorney, and the county manager ignored all of the environmental hazards attributed to such
facilities, I am hoping that you can review this material and make recommendations to
address these very critical issues. Please review it and feel free to confirm the findings.
The gun range proposal is not a NIMBY issue. It concerns all the residents of the county,
regardless of which area one happens to live in. It is more than concerns about the barrage
of shooting noise - although that by itself is grounds for not approving such a facility. Those
of us who have chosen to live here did so because of the beautiful and quiet environment
our area offers. If we wanted to live next to firearms noise, we'd moved closer to military
bases in WA.
Besides the noise and disturbance, the risks of an innocent bystander getting hurt increases
tenfold with members of the shooting range trampling through the woods playing war games.
Jefferson County is not designed to be training grounds for a war zone.
It is my hope that the Board of County Commissioners listens to your input/advice and not go
simply by what the attorneys or county manager express. Fear-mongering tactics, whether it
is through a lawsuit or shouting match, is not something any of us expect our elected officials
to succumb to. The county attorney and the county manager are NOT elected officials - yet
here they are doing a great disservice to our community by trying to ram this major decision
through.
The county attorney has acted as judge and executioner, ill advising the county
commissioners and placing fear about lawsuit threats. Since the county and commissioners
are insured for such an event, that advise is strictly meant as a scare tactic. It leaves one to
Connie Gallant <cg@conniegallant.com>
Fri 11/8/2019 3:57 PM
To:Planning Commission Desk <PCommissionDesk@co.jefferson.wa.us>;
6 attachments
Hunt 2009_Lead Bullet Fragments.pdf; 0111 Cornatzer.pdf; Condor-carcass.jpg; GoldenEagle-carcass.jpg; Pfund_burger-xrays_sm2.jpg;
Venison-bullet-fragments.jpg;
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wonder whether any type of arrangement has been made by the county attorney and the gun
facility owners. The fact that the county officials have met behind closed doors with the gun
facility owners and not allowed the group representing the voices of their constituents to join
in those private meetings is troubling enough. Such actions must not be allowed to occur in
our county - this is not, after all, the Chicago Mafia era where "you better do as we say,
otherwise you are history."
I am absolutely appalled at the manner in which these proceedings have occurred. The
majority of the residents of this county are not being heard - perhaps we will be heard at the
next election cycle.
Thanks to each of you on the Planning Commission for attempting to correct the county
errors and apparent malfeasance.
Respectfully,
Connie Gallant
Quilcene WA 98376
---------- Original Message ----------
From: Connie Gallant <cg@conniegallant.com>
To: Commissioners Jefferson County <jeffbocc@co.jefferson.wa.us>
Date: October 23, 2018 at 12:36 PM
Subject: Tarboo Ridge Gun Proposal Hearing - Comments Submitted by Connie Gallant
October 23, 2018
Dear Commissioners - I am unable to attend the public hearing on this issue but would like
to submit my written comments (with attached studies and photos) via email in opposition to
the proposed military training compound on Tarboo Ridge.
We are all aware of the many years endured trying to bring a Shoreline Management Plan to
our county that would protect our shorelines, lakes, streams, and overall environment. Simply
considering the materials that abound in a military training facility is enough to disqualify any
proposals from taking root. The quantity of lead, copper, and sulfur discharged at such
facilities would place the soil, water, humans, fish and wildlife in grave danger.
Gunpowder consists of a mixture of sulfur, charcoal, and potassium nitrate (saltpeter).
The sulfur and charcoal act as fuels while the saltpeter is an oxidizer. Because of its
11/13/2019 Tarboo Ridge Gun Proposal Hearing - Comments Sub... - Planning Commission Desk
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incendiary properties and the amount of heat and gas volume that it generates,
gunpowder has been widely used as a propellant in firearms, artillery, rockets, and
fireworks and as a blasting powder in quarrying, mining, and road building.
According to the Department of the Interior’s U.S. Geological Survey, an individual
range can go through between 1.5 to 20 tons of lead shot and bullets annually.
Outdoor ranges as a whole may use more than 80,000 tons in that same period.
The people and creatures who exist around lead are at the greatest risk for health
issues. Increased exposure to the toxic metal can cause paralysis, neurological damage,
and death. “In some circumstances, a waterfowl species could ingest one lead shot and
die, or perhaps even less,” Dr. Barnett Rattner, a scientist for the US Geological Survey,
has stated.
Indoor ranges in particular pose threats to humans: A blood test for one former
Kentucky gun range manager, as reported by the Seattle Times, detected lead levels 56
times higher than the average adult’s, putting him in danger of organ failure.
In many cases, ranges only confront the problem of toxic debris when so much has
accumulated that it attracts the attention of local government or outside activists.
(Ranges that shoot directly into or near bodies of water are at a higher likelihood of
environmental litigation or government action, for example, due to laws protecting
wetlands from hazardous waste.) Faced with the prohibitive costs of a massive cleanup,
some ranges are forced to close, leaving taxpayers with the bill.
For locations abundant with wildlife, leaving lead undisturbed isn’t always an option. In
Stratford, Connecticut, the Remington Gun Club operated for almost seventy years on a
peninsula jutting into the Long Island until the mid-1980s, when a group of fisherman
asked what all that shot was doing to local shellfish. One study found that the club had
deposited 5 million pounds of lead and 11 million pounds of toxic target fragments on
its grounds and nearby waters. Half the ducks in the area had acute lead poisoning,
caused by ingesting the shot while diving for food. Mussels, clams, and oysters were
found to contain 10 times the normal level of lead. As a result, the town banned
shellfish harvesting on the site.
Numerous scientific studies have reached a consensus: Lead poisoning is the biggest
threat facing the successful recovery of the California condor. Semi-annual test results
show that the majority of free-flying condors at Pinnacles National Park have blood lead
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levels that exceed 10 ug/dL, which is the same threshold used by the Center for Disease
Control as an initial warning sign that a human child is at risk. Some condors have been
measured with blood lead levels as high as 570 ug/dL, a value that would potentially kill
a human. By the time condors at Pinnacles reach breeding age of 7 years old, almost all
of them have received emergency, life-saving chelation treatment at least once.
Numerous condors in the flock have now required multiple chelation cycles.
Condor eating carcass
Scientific studies have documented that the primary source of this lead is from spent
ammunition that remains in carcasses after they are shot. When a lead rifle bullet
traveling at almost 3 times the speed of sound strikes animal tissue, it quickly begins to
expand and loses hundreds of tiny pieces as it continues its journey. The organs and
other bloodshot areas that are trimmed away and left behind are usually contaminated
with these lead fragments. For instance, because condors feed on dead animals and are
group feeders, even small amounts of lead can sicken or kill many condors. Also, since
all of their meals come from dead animals, condors are more frequently exposed to
lead bullet hazards than most wildlife.
11/13/2019 Tarboo Ridge Gun Proposal Hearing - Comments Sub... - Planning Commission Desk
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Eagle eating fox carcass
Lead poisoning through ingestion of spent lead bullets and shell shot has been
demonstrated as being a serious factor for many other wildlife species too, including
our national symbol the bald eagle. Other scavengers that have documented as being
affected include golden eagles, hawks, ravens, turkey vultures, and grizzly bears. More
than 500 scientific studies published since 1898 have documented that worldwide, 134
species of wildlife are negatively affected by lead ammunition.
Studies are increasingly showing that lead fragments can also be found in wild game
meat processed for human consumption, even though best attempts are made in the
field to remove sections that are within the bullet wound channel.
A recently published scientific study (attached) examined the prevalence of lead bullet
fragments in packaged venison. Thirty different white-tail deer were harvested using
lead rifle bullets and then given to 30 different game meat processors. Researchers
randomly selected 324 packages of ground venison and whole cuts from the processors
and x-rayed them to document how many contained lead bullet fragments. Of the 324
randomly selected packages of ground venison, 34% contained metal fragments; some
packages contained as many a 168 separate pieces. Further analysis positively identified
the metal as 93% lead and 7 % copper. Also, when these tainted packages were fed to
domestic pigs, blood levels became elevated with 2 days of ingestion. This
demonstrates that while the results are preliminary and much further study needs to be
done to better assess risks to humans, it appears that the if lead bullets are used, odds
are high that you will ingest lead particles in ground game meat.
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In this X-ray of a package of processed meat, lead fragments are circled in red.
The reason lead bullets represent such a problem for anything that ingests them is that
they fragment into hundreds of tiny pieces when they strike an animal being shot.
Another study was conducted in North Dakota that examined ground venison packages that
had been donated by hunters to food pantries. It found that 59% of the packages had lead
fragments.
There are many studies throughout the nation and the world that have been conducted on
the detrimental and dangerous effects of sulfur, charcoal, and potassium nitrate – elements in
gunpowder. The costs to local governments and agencies to clean up gun range facilities is
very high. The detrimental effects to humans is very high. The detrimental effects to fish and
wildlife is very high. The detrimental effects to our waterways, creeks, and streams is very
high.
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Therefore, with all of these effects so evident and clearly proven, Jefferson County must not
approve the permit of such a facility anywhere in our county. To do so is to endanger the lives
of our citizens and our environment. In addition, it opens up the county and taxpayers to a
large and unprecedented expense to clean up the area.
As stated in other documents and letters, there are sufficient training facilities within our
district and state to accommodate the training needs of our law enforcement agencies.
Respectfully,
Connie Gallant
Quilcene
1
QUALITATIVE AND QUANTITATIVE DETECTION OF LEAD BULLET FRAGMENTS
IN RANDOM VENISON PACKAGES DONATED TO THE COMMUNITY ACTION
FOOD CENTERS OF NORTH DAKOTA, 2007
WILLIAM E. CORNATZER, EDWARD F. FOGARTY, AND ERIC W. CORNATZER
University of North Dakota School of Medicine, Southwest Campus,
Bismarck, ND 58501, USA. E-mail: doccornatzer@qwestoffice.net
ABSTRACT.—We studied randomly selected ground venison packages donated to the Community Action
Food Centers of North Dakota by the Hunters For The Hungry Association. These packages were studied
by high resolution computerized tomography imaging and x-ray fluoroscopy for qualitative detection of
metal fragments. Quantitative measurements of lead levels in both randomly selected and fluoroscopic im-
age guided site-specific subsamples from packages were performed. This study documented a health risk
from lead exposure to humans consuming venison. Received 30 July 2008, accepted 30 October 2008.
CORNATZER, W. E., E. F. FOGARTY, AND E. W. CORNATZER. 2009. Qualitative and quantitative detection of
lead bullet fragments in random venison packages donated to the Community Action Food Centers of
North Dakota, 2007. In R. T. Watson, M. Fuller, M. Pokras, and W. G. Hunt (Eds.). Ingestion of Lead from
Spent Ammunition: Implications for Wildlife and Humans. The Peregrine Fund, Boise, Idaho, USA.
DOI 10.4080/ilsa.2009.0111
Key words: Computed tomography imaging, health risk, humans, lead, venison.
STUDIES OF LEAD TOXICITY in the diet of California
Condors (Gymnogyps californianus) have shown
there are small particles of lead in the tissues of
deer shot with high velocity rifle bullets (Hunt et al.
2006). Reports from Canada and Greenland have
shown a statistically significant correlation between
elevated serum lead levels in people and the con-
sumption of wild game killed with lead bullets
(Bjerregaard et al. 2004, Dewailly et al. 2001, Tsuji
et al. 2008). Preliminary research presented at The
Peregrine Fund’s Board of Directors meeting in
May of 2007 (Parish pers. comm.) showed small
metal fragments in processed venison. Based on
these data, we conjecture that there might be lead
fragments from rifle bullets in venison consumed
by the general population.
METHODS AND MATERIALS
One hundred, one-pound ground venison packages
were randomly selected from the Community Ac-
tion Food Pantry program in North Dakota. The
venison had been donated by the Hunters for the
Hungry Program in the fall of 2007. The sample of
100 was selected from a total of 15,250 donated
one-pound packages. High definition CT scan and
fluoroscopy were performed on the sample for
qualitative detection of metal fragments. In con-
junction with the North Dakota Health Department,
fifteen of the 100 randomly selected packages were
punch biopsied in a blind fashion yielding 4-g tis-
sue biopsies; this gave 15 random sub-samples
from within the randomly selected packages. These
specimens were sent to the University of Iowa Hy-
gienic Laboratory for flame absorption atomic
spectrometry to detect and quantify the mass of
lead in sub-samples. An additional five samples ob-
‐ CORNATZER ET AL. ‐
2
tained from among the 100 CT screened packages
using fluoroscopic image-guided retrieval of metal-
containing venison were also submitted for analy-
sis. These image-guided biopsies yielded a maxi-
mum of four grams of combined ground venison
and metal (Figure 1).
Osirix® DICOM® workstation software running on
Mac OS X® was used for visual analysis of CT im-
age data for Hounsfield unit assessments of sus-
pected lead fragments. Objects having Hounsfield
unit measurements over 1500 were considered sus-
picious for metal fragments. Color look-up tables
from Osirix® were used for color encoding of CT
data.
RESULTS
Qualitative analysis of the randomly selected
ground venison samples showed 59 packages out of
the 100 had one or more visible metal fragments on
high definition computed tomography (Figure 2).
Quantitative analysis with flame absorption atomic
spectrometry of the fifteen random blind biopsies
showed one sample with 120 ppm lead (1 ppm = 1
milligram/kilogram). All five fluoroscopic image-
guided biopsies showed elevated lead concentra-
tions varying from 4,200 to 55,000 ppm lead dry
weight (Table 1).
Figure 1. Fluoroscopic image-guided fragment
sampling. The fluoroscopic image in upper left
shows forceps approaching a metal fragment within
a package of ground venison. The upper right image
shows a retrieved metal fragment embedded within
a small volume of ground venison contained in a
glass test tube. Photograph shows forceps pointing
to a metal fragment embedded in ground venison.
Figure 2. High definition computed tomography
(CT) image of ca. 20 one-pound venison packages.
Bright spots are metal fragments embedded in the
tissue.
Table 1. Lead concentrations of five venison sam-
ples retrieved by fluoroscopically guided biopsy.
Sample Lead Concentration
(ppm or mg/kg dry weight)
1 52000
2 34000
3 4200
4 55000
5 9700
‐ LEAD FRAGMENTS IN PACKAGED VENISON ‐
3
DISCUSSION
Our study has shown that 59% of 100 randomly se-
lected packages of ground venison donated to the
Community Action Food Pantry in North Dakota in
the fall of 2007 were contaminated with lead frag-
ments. Venison is a common dietary staple for
many families throughout the United States. Lead
has been shown to be a major health threat and in
children there is no safe minimum threshold of lead
exposure. Sources of dietary lead vary from country
to country. In the United States, paint chips, dust,
jewelry, toys, lead-based gasoline, and lead plumb-
ing (Markowitz 2007) have been identified as
sources of lead exposure in the past. Our study re-
veals lead-based ammunition residues in venison as
a source of lead exposure among the USA popula-
tion that is largely unrecognized as a threat to hu-
man health, other than among subsistence hunters
of the circumpolar north including Alaska and Can-
ada (Tsuji et al. 2008, Verbrugge et al. 2009, this
volume).
ACKNOWLEDGMENTS
We thank the assistance of Terry Dwelle, M.D. and
Sandy Washik of the North Dakota State Health
Department, Steven Pickard, M.D., Field Officer of
the CDC in the State of North Dakota, and Craig
Lambrecht, M.D., Bismarck, North Dakota.
LITERATURE CITED
BJERREGAARD, P., P. JOHANSEN, G. MULVAD, H.
PEDERSEN, AND J. C. HANSEN. 2004. Environ-
ment lead sources in human diet in Greenland.
Environmental Health Perspective 112
(15):1496-1498.
DEWAILLY, E. P., S. AYOTT, S. BRUNEAU, G. LE-
BEL, P. LEVALLOS, AND J. P. WEBER. 2001. Ex-
posure of the Inuit population of Nunivik (Arc-
tic Quebec) to lead and mercury. Archives of
Environmental Health 56:350-357.
HUNT, W. G., W. BURNHAM, C. N. PARISH, K.
BURNHAM, B. MUTCH, AND J. L. OAKS. 2006.
Bullet fragments in deer remains: implications
for lead exposure in scavengers. Wildlife Soci-
ety Bulletin 34:168-171.
MARKOWITZ, M. 2007. Lead Poisoning. Pages
2913–2918 in R. M. Kliegman, E. Behrman,
H. B. Jenson, and B. F. Stanton (Eds.). Nelson
Textbook of Pediatrics, 18th ed. W. B. Saunders
Co., Philadelphia, Pennsylvania, USA.
TSUJI, L. J. S., B. C. WAINMAN, I. D. MARTIN, C.
SUTHERLAND, J.-P. WEBER, P. DUMAS, AND E.
NIEBOER. 2008. The identification of lead am-
munition as a source of lead exposure in First
Nations: The use of lead isotope ratios. Science
of the Total Environment 393:291-298.
VERBRUGGE, L. A., S. G. WENZEL, J. E. BERNER,
AND A. C. MATZ. 2009. Human exposure to
lead from ammunition in the circumpolar north.
In R. T. Watson, M. Fuller, M. Pokras, and W.
G. Hunt, (Eds.). Ingestion of lead from spent
ammunition: Implications for wildlife and hu-
mans. The Peregrine Fund, Boise, Idaho, USA.
DOI 10.4080/ilsa.2009.0110
The Peregrine Fund, 5668 W. Flying Hawk Lane, Boise, ID 83709, USA.
E-mail: grainger@peregrinefund.org
Washington Animal Disease Diagnostic Laboratory, Pullman, WA 99164-7034, USA.
Department of Veterinary Clinical Sciences, Washington State University, Pullman, WA 99164, USA.
Department of Biology, Boise State University, 1910 University Drive, Boise, ID 83725, USA.
School of Earth & Environmental Sciences, Washington State University, Pullman, WA 99164, USA.
ABSTRACT.—Human consumers of wildlife killed with lead ammunition may be exposed to health risks
associated with lead ingestion. This hypothesis is based on published studies showing elevated blood lead
concentrations in subsistence hunter populations, retention of ammunition residues in the tissues of hunter-
killed animals, and systemic, cognitive, and behavioral disorders associated with human lead body burdens
once considered safe. Our objective was to determine the incidence and bioavailability of lead bullet frag-
ments in hunter-killed venison, a widely-eaten food among hunters and their families. We radiographed 30
eviscerated carcasses of White-tailed Deer (Odocoileus virginianus) shot by hunters with standard lead-
core, copper-jacketed bullets under normal hunting conditions. All carcasses showed metal fragments
(geometric mean = 136 fragments, range = 15–409) and widespread fragment dispersion. We took each
carcass to a separate meat processor and fluoroscopically scanned the resulting meat packages; fluoroscopy
revealed metal fragments in the ground meat packages of 24 (80%) of the 30 deer; 32% of 234 ground meat
packages contained at least one fragment. Fragments were identified as lead by ICP in 93% of 27 samples.
Isotope ratios of lead in meat matched the ratios of bullets, and differed from background lead in bone. We
fed fragment-containing venison to four pigs to test bioavailability; four controls received venison without
fragments from the same deer. Mean blood lead concentrations in pigs peaked at 2.29 g/dL (maximum 3.8
g/dL) 2 days following ingestion of fragment-containing venison, significantly higher than the 0.63 g/dL
averaged by controls. We conclude that people risk exposure to lead from bullet fragments when they eat
venison from deer killed with standard lead-based rifle bullets and processed under normal procedures. At
risk in the U.S. are some ten million hunters, their families, and low-income beneficiaries of venison dona-
tions. Reproduced with permission from PLoS ONE 4(4): e5330.6
6Reproduced in accordance with the Creative Commons Attribution License with permission of the authors from: Hunt, W. G., R. T.
Watson, J. L. Oaks, C. N. Parish, K. K. Burnham, R. L. Tucker, J. R. Belthoff, and G. Hart. 2009. Lead bullet fragments in venison
from rifle-killed deer: potential for human dietary exposure. PLoS ONE 4(4): e5330. doi: 10.1371/journal.pone.0005330.
‐ HUNT ET AL. ‐
2
HUNT, W. G., R. T. WATSON, J. L. OAKS, C. N. PARISH, K. K. BURNHAM, R. L. TUCKER, J. R. BELTHOFF,
AND G. HART. 2009. Lead bullet fragments in venison from rifle-killed deer: potential for human dietary
exposure. Reproduced in R. T. Watson, M. Fuller, M. Pokras, and W. G. Hunt (Eds.). Ingestion of Lead
from Spent Ammunition: Implications for Wildlife and Humans. The Peregrine Fund, Boise, Idaho, USA.
DOI 10.4080\ilsa.2009.0112
Key words: Bullet fragmentation, bush meat, game meat, lead, lead exposure, venison.
LEAD HAS BEEN IMPACTING the health of human-
kind since the Romans began mining it 2500 years
ago, and despite early knowledge of its harmful ef-
fects, exposure to lead from a wide variety of
sources persists to this day (Warren 2000). Gov-
ernment-based guidelines for acceptable degrees of
exposure prior to the 1970s were based upon
thresholds of overt toxicity and on apparent accep-
tance that norms in lead concentrations in a society
enveloped in lead-permeated exhaust fumes and
lead paint must somehow reflect organic tolerance.
Medical science has since concluded that virtually
no level of lead exposure can be considered harm-
less in consideration of its many sublethal, debili-
tating, and often irreversible effects (Needleman
2004). Lead quantities formerly regarded as trivial
are associated with permanent cognitive damage in
children (Lanphear et al. 2005), including those
prenatally exposed (Schnaas et al. 2006). Lead is
associated with impaired motor function (Cecil et
al. 2008), attentional dysfunction (Braun et al.
2006), and even criminal behavior (Needleman et
al. 2002, Wright et al. 2008). Release of lead stores
from bone exposes fetuses during pregnancy
(Tellez-Rojo et al. 2004), and adults late in life
(Schwartz and Stewart 2007, Shih et al. 2007).
Lead is implicated in reduced somatic growth
(Hauser et al. 2008), decreased brain volume (Cecil
et al. 2008), spontaneous abortion (Borja-Aburto et
al. 1999), nephropathy (Ekong et al. 2006), cancer,
and cardiovascular disease (Menke et al. 2006,
Lustberg and Silbergeld 2002).
Ingested residues of lead ammunition are a recently
identified pathway of lead exposure to human con-
sumers of gun-killed game animals. An analysis of
North Dakota residents showed that recent (≤ 1 mo)
consumers of game meat had higher covariate-
adjusted blood lead concentrations than those with
a longer interval (> 6 mo) since last consumption
(Iqbal 2008). Studies have linked elevated blood
lead concentrations of subsistence hunters in north-
ern Canada, Alaska, Greenland, and elsewhere to
consumption of shotgun-killed birds (Hanning et al.
2003, Levesque et al. 2003, Johansen et al. 2004,
2006, Bjerregaard et al. 2004, Tsuji et al. 2008a,
2008b, 2008c; see Burger et al.1998, Mateo et al.
2007). The hypothesis that rifle bullet fragments are
an additional source of human lead exposure is
suggested by radiographic studies of deer killed
with standard lead-based bullets, which show hun-
dreds of small metal fragments widely dispersed
around wound channels (Hunt et al. 2006, Do-
browolska and Melosic 2008, Krone et al. 2009).
The possibility of inadvertent lead contamination in
prepared meat consumed by hunters and their fami-
lies is noteworthy, considering the millions of peo-
ple who hunt big game in the USA (USFWS and
USCB 2006) and the thousands of deer annually
donated to food pantries for the poor (Cornatzer et
al. 2009, Avery and Watson 2009). In this report,
we test two hypotheses: (1) that fragments of lead
from rifle-bullets remain in commercially processed
venison obtained under normal hunting conditions
in the USA, and (2) humans absorb lead when they
eat venison containing bullet fragments.
MATERIALS AND METHODS
Ethics Statement.—Nine licensed hunters provided
the deer carcasses analyzed in this study, and ob-
tained them during the established hunting season
and in accordance with normal practices as permit-
ted under the authority of the Wyoming Game and
Fish Commission, Cheyenne, Wyoming. The latter
institution also granted permission to the authors to
convey the processed meat from each carcass to the
Washington Animal Disease Diagnostic Laboratory
at Washington State University, Pullman, for analy-
sis. The Washington State University Institutional
Animal Care and Use Committee approved the lead
bioavailability experiment involving eight swine.
‐ LEAD BULLET FRAGMENTS IN VENISON ‐
3
Deer Collection.—Hunters used conventional cen-
ter-fire hunting rifles to kill 30 White-tailed Deer
(Odocoileus virginianus) under normal hunting
conditions in Sheridan County, Wyoming in No-
vember 2007. All bullets were of 7-mm Remington
Magnum caliber and of identical mass (150 grains,
9720 mg); cartridges were of a single brand re-
ported in local mass-market vendor interviews as
the most widely sold to deer hunters. Bullets con-
sisted of a lead core (68% of mass) and a copper
jacket (32%); lead was exposed only at the 1.7-mm-
diameter tip of the bullet. Reported shot distances
averaged 116 m (range = 25–172 m). All deer were
eviscerated according to the hunters’ normal prac-
tice. Weights of 29 eviscerated deer averaged 33.8
kg (SD = 7.1). We recorded the positions of bullet
entry and exit wounds; 26 deer (87%) were shot in
the thorax, and some portion of the projectile exited
the animal in 92% of shots. We removed the skin
and head, and we excised from each animal a ≥4
cm section of tibia for isotope analyses and a ≥30 g
sample of muscle (shank) along the tibia to deter-
mine background lead levels in each deer.
Carcass Radiography.—We radiographed with
conventional veterinary equipment the area of the
wound channel (lateral view) of eviscerated deer
and adjusted exposures to maximize contrast. We
included along the margin of each radiograph a
strip of clear plastic tape containing arrayed sam-
ples of lead bullet fragments (obtained by shooting
through light plastic jugs filled with water), compa-
rably-sized samples of bone fragments, and locally-
obtained sand and gravel; only the lead fragments
were clearly visible in the radiographs at the ap-
plied settings. We scanned radiographs into digital
format and counted unambiguous metal fragments
under 400% magnification. We did not attempt to
distinguish between copper and lead in fragment
counts.
Commercial Processing.—We transported each
deer carcass to a different commercial meat proc-
essing plant in 22 towns throughout Wyoming and
requested normal processing into boneless steaks
and ground meat in 2-pound (0.91 kg) packages; we
retrieved the processed, frozen, and packaged meat
usually within 4 days.
Radiography of Processed Meat.—We used digital
radiography (EDR6 Digital Radiography, Eklin
Medical Systems, Santa Clara, California) and fluo-
roscopy (MD3 Digital Fluoroscopy, Philips Medi-
cal Systems, Best, Netherlands) to scan all the
thawed ground meat packages (N = 234); we
scanned an additional 49 loin steak packages from
16 carcasses in which radiography had revealed
fragments near the spine. We unwrapped every
package showing visible radiodense fragments in a
subsample of 13 deer, flattened the meat to c. 1-cm
thickness on a light plastic plate, and rescanned.
We marked the vicinity of each visible fragment
with a stainless steel needle and then used a 2.8-cm
diameter plastic tube as a “cookie-cutter” to obtain
samples of meat with radiodense fragments.
Analysis of Metal Samples.—Each of the fragment-
containing meat samples was weighed and then di-
vided into approximately 5-g subsamples, each of
which was completely digested in a known volume
of concentrated nitric acid. Inductively coupled
plasma (ICP) analysis was then used to measure the
concentrations of lead and copper in each subsam-
ple. The lower detection limit for both metals was 2
µg/g. The analysis was performed commercially by
the Analytical Sciences Laboratory, University of
Idaho, Moscow, where quality management con-
forms with applicable Federal Good Laboratory
Practices (40 CFR Part 160); the Laboratory is ac-
credited through the American Association of Vet-
erinary Laboratory Diagnosticians, which stipulates
ISO 17025 quality assurance measures.
Lead Isotope Analysis.—We analyzed bullet, bone,
and meat samples for lead isotope compositions.
Bullet fragments were cleaned in dilute (1M) HCl,
leached with 2 ml of 7M HNO3, and then removed
from the acid leachate. The leachate was then dried
and treated with 2 drops of 14M HNO3. Bone and
meat samples were digested in 14M HNO3, dried
and treated with 2 drops of 14M HNO3. Lead was
separated using standard HBr and HCl on an anion-
exchange column (Bio Rad, AG 1X8). Isotope
compositions were determined with a ThermoFin-
nigan Neptune MC-ICPMS at the Washington State
University GeoAnalytical Laboratory. Reproduci-
bility of the lead standard (NBS-981), run before,
during, and after the samples, was <0.012% (2 SE,
n = 4) for Pb206/Pb204, and <0.018% for Pb208/Pb204.
‐ HUNT ET AL. ‐
4
Lead concentrations in the procedural blanks
were negligibly small.
Bioavailability Experiment.—We tested the
bioavailability of ingested bullet fragments by feed-
ing processed venison known by radiography to
contain radiodense fragments to pigs. The latter
were considered a good model for the absorption of
lead from the human gastrointestinal tract (USEPA
2007). We used eight female Yorkshire/Landrace
and Berkshire/Duroc cross-bred pigs, 70–82 days of
age and weighing 28.2–32.7 kg (mean 30.3 kg) at
the termination of the experiment. All were initially
fed 1.36 kg of standard pelleted pig grower ration
divided into two meals per day, then acclimated for
7 days to consuming cooked ground commercial
beef patties mixed with the pellet ration. We gradu-
ally increased the amount of ground meat from
113 g per meal to 500 g, as pellet amounts were
correspondingly decreased. We withheld all food
for 24 hours prior to the venison feeding trial.
Ground venison and venison steaks from four deer
were used in the feeding trial. Each of the eight pigs
consumed 1.26–1.54 kg of meat over two feedings
24 hours apart on days 0 and 1 of the experiment;
no pig consumed meat from more than one deer.
Four pigs received venison containing fluoroscopi-
cally visible metal fragments. The total amount of
lead fed to each pig was unknown, but quantitative
analysis of similar packages from other deer in the
study showed 0.2–168 mg (median 4.2 mg) of lead.
The four control pigs were simultaneously fed
equivalent amounts of venison with no fluoroscopi-
cally visible fragments from the same four deer. We
assessed background levels of lead in each deer
from shank meat, collected well away from any po-
tential bullet contamination. All venison for the test
and control pigs was either already ground, or
finely chopped if steaks, and cooked in a micro-
wave oven until brown. For feeding, we mixed the
cooked venison in a bowl with small amounts of
pig ration to improve palatability. We verified that
all meat was eaten, and we monitored the pigs for
signs of illness.
We collected anticoagulated blood samples (2 ml
whole blood in EDTA) from each pig at 1 hour
prior to feeding venison on day 0, and on days 1, 2,
3, 4, 7 and 9 after feeding venison, and stored the
samples at 4oC until testing. Lead levels were de-
termined by inductively coupled plasma mass
spectrometry (ICP-MS) with a lower detection limit
of 0.5 µg/dL; we assigned all values below the de-
tection limits as 0.5 µg/dL. We compared mean
blood lead concentrations between control pigs and
test pigs on days 0 through 9 using 2-way ANOVA
with repeated measures and restricted maximum
likelihood (REML) estimation; we performed linear
group contrasts for each day. A single outlier datum
among control pigs on day 4 (6.8 µg/dL) was an
order of magnitude higher than a retest of the same
sample (0.54 µg/dL); the latter was consistent with
all other control samples. We omitted both results
from statistical analysis, resulting in a sample of
three rather than four control pigs on day 4. We
used JMP (SAS Institute, Cary, NC, USA, Vers.
7.0.1) for all statistical analyses.
RESULTS
Bullet Fragments in Venison.—Wound radiographs
of all 30 eviscerated deer showed metal fragments
(median = 136 fragments, range = 15–409) and of-
fered a measure of fragment dispersion, albeit two-
dimensional. Extreme distance between fragment
clusters in standard radiographs averaged 24 cm
(range ± SD = 5–43 ± 9 cm), and maximum single
fragment separation was 45 cm. Radiography re-
vealed visible metal fragments in the ground meat
of 24 (80%) of the 30 deer. At least one fragment
was visible in radiographs of 74 (32%) of 234
packages of ground meat; 160 (68%) revealed no
fragments, 46 (20%) had one, 16 (7%) had two, and
12 (5%) showed 3-8 fragments. An average of 32%
of ground meat packages (N = 3–15 packages,
mean 7.8) per deer showed metal fragments (range
= 0–100% of packages). The ground meat derived
from one deer showed more fragments (N = 42)
than counted in the radiograph of the carcass (N =
31), and two ground meat packages (2 deer) each
contained a single shotgun pellet which had not
been detected on the carcass radiographs. No rela-
tionship was apparent between the number of metal
fragments counted in carcasses and those subse-
quently counted in ground meat from the same in-
dividual (correlation coefficient 0.06). In the aggre-
gate, we observed 155 metal particles in the ground
meat packages, 3.1% of the 5074 we counted in the
carcasses. Of 16 deer carcasses with metal frag-
‐ LEAD BULLET FRAGMENTS IN VENISON ‐
5
ments near the spine, four (25% of selected deer,
8% of 49 packages) showed fragments in processed
loin steaks (1–9 fragments). Additional fragments
may have occurred in 220 unscanned packages of
steaks derived from all animals.
ICP analysis of radiodense fragments excised from
ground meat packages from 13 deer identified lead
in 25 (93%) of 27 samples; aggregate lead fragment
mass per package averaged 17.2 mg (range ± SD =
0.2–168 ± 39.8 mg) or 0.03% of the lead compo-
nent of bullet mass. Nine samples contained copper
at levels above background values, including the
two samples with no detectable lead. Lead concen-
trations in unprocessed muscle tissue collected
from the shank and well away from the bullet path
of the same 13 deer were all below the detection
limit of 2.0 µg/g and served as internal controls for
measures of lead in ground meat.
The ratio of lead isotopes 206/204 plotted against
207/204 ratios (Figure 1a) and 208/204 ratios
(Figure 1b) showed that meat samples with elevated
lead levels from four deer, and lead from bullets
from the same boxes (N = 3) supplying the bullets
used to kill those deer, formed tight clusters distinct
from ratios of background lead in tibial bone.
Variation in the bone ratios apparent in Figure 1
likely represent long term, cumulative lead expo-
sure encompassing varied sources of natural and
anthropogenic lead.
Bioavailability Experiment.—All the pigs con-
sumed all the venison provided to them within 2
hours. None of the experimental animals showed
any signs of lead toxicosis or other illness for the
duration of the experiment; none exhibited vomit-
ing or diarrhea which might have affected gastroin-
testinal physiology or retention times in the stom-
ach or intestines.
Blood lead concentrations in the four control pigs
ranged from below the level of ICP-MS detection
(0.5 µg/dL) to 1.2 µg/dL throughout the experiment
(mean ± SD = 0.63 ± 0.19 µg/dL; Figure 2). Blood
lead concentrations in pigs fed metal fragment-
containing venison ranged from below the level of
detection to 1.4 µg/dL on day 0, immediately prior
to feeding venison. The 2-way ANOVA revealed a
significant interaction between treatment (feeding
venison either with fragments or no fragments) and
day (F6,35.32 = 3.413, P = 0.009; Figure 2). Mean
blood lead concentrations in the pigs fed fragment-
containing venison were significantly elevated
above those of control pigs on days 1, 2 and 3 post-
exposure (linear contrast: F1,39.79 = 10.39, P = 0.003,
F1,39.79 = 17.76, P = 0.0001, and F1,39.79 = 14.71, P =
0.0004, respectively; Figure 2); the maximum ob-
served value was 3.8 µg/dL. Blood lead concentra-
tions did not differ (P >0.05) between the control
pigs and exposed pigs on days 0, 4, 7 and 9 (Figure
2).
Figure 1. Plots of lead isotope ratios in ground meat samples containing radiodense fragments from four
deer. Ratios from lead-in-meat samples clustered with those of unfired bullets but were distinct from bone
lead ratios. Note that there are four meat data points (open triangles) in each graph, but two have almost
identical positions and are superimposed.
‐ HUNT ET AL. ‐
6
DISCUSSION
Our findings show that people risk exposure to lead
when they eat venison from deer killed with stan-
dard lead-based rifle bullets and processed under
normal commercial procedures. Evidence includes
a high proportion (80%) of deer showing at least
one bullet fragment in one or more ground meat
packages, a substantial frequency of contamination
(32% of all ground meat packages), a majority
(93%) of assayed fragments identified as lead, iso-
topic homogeneity of bullet lead with that found in
the meat, and increased blood lead concentrations
in swine fed fragment-containing venison. Consid-
ering that all the carcasses we brought to the proc-
essors contained fragments (15-409 fragments
counted in radiographs), the high rate of removal
evident in the ground meat implies meticulous care
on the part of the processors to avoid contamina-
tion, but an apparent inability of 80% of them to do
so entirely. We conclude that, in a majority of
cases, one or more consumers of a hunter-killed,
commercially-processed deer will consume bullet
lead.
We interpret the absorption of lead into the blood-
stream of all four test pigs as clear evidence of the
bioavailability of lead from ingested bullet frag-
ments (Figure 2), and we infer that human con-
sumption of venison processed under prevailing
standards of commerce results in increased blood
lead concentrations. The rate of bioavailability can-
not be calculated from our experiment because the
exact amounts of lead in the meat packages were
unknown. Rather, we directed our test at the condi-
tion experienced by human consumers of venison
from rifle-killed deer of variable amounts of lead
patchily distributed as fragments in ground meat or
steak.
Depuration of lead in blood does not imply its ex-
cretion, but rather the sequestration of a substantial
proportion in soft tissues and ultimately in bone
from which it may eventually be mobilized, as dur-
Figure 2. Mean blood lead concentrations observed during swine feeding experiment. Mean (± SE) blood
lead concentrations (µg/dL) in four pigs fed venison containing radiographically dense fragments (Frag-
ments) compared with four control pigs fed venison without visible fragments (No Fragments) on days 0
and 1. Asterisks indicate days when means differed significantly between test and control groups.
‐ LEAD BULLET FRAGMENTS IN VENISON ‐
7
ing pregnancy (Tellez-Rojo et al. 2004) or in old
age (Schwartz and Stewart 2007). The observed
elevations in blood lead concentrations, while not
considered overtly toxic, would nevertheless con-
tribute to cumulative lead burdens, and would be
additive with further meals of contaminated veni-
son. Observed blood lead concentrations of up to
3.8 µg/dL, and daily means of 2.3 and 2.2 µg/dL in
the experimental animals, do approach what is con-
sidered significant with respect to adverse effects in
humans by contemporary assessments (Gilbert and
Weiss 2006, Levin et al. 2008). Whereas the CDC
advisory level for intervention in individual chil-
dren is 10 µg/dL in blood (CDC 1991), studies now
associate as little as 2 µg/dL with increased risk of
cardiovascular mortality in adults (Menke et al.
2006) and impaired cognitive function in children
(Jusko et al. 2008). Hauser et al. (2008) detected an
impact threshold of 5 µg/dL on male maturation
rates, and Lanphear et al. (2005) concluded that
“…lead exposure in children who have maximal
blood lead concentrations <7.5 µg/dL is associated
with intellectual deficits.” These latter values would
appear attainable with the repeated consumption of
venison possible among deer hunting families, es-
pecially those incurring additional exposure from
other sources.
Factors that may influence dietary lead exposure
from spent lead bullets include the frequency and
amount of venison consumption, degree of bullet
fragmentation, anatomical path of the bullet, the
care with which meat surrounding the bullet wound
is removed, and any acidic treatments of the meat
that would dissolve lead, i.e., coating the hanging
carcass with vinegar or the use of acidic marinades
in cooking. Exposure to lead from spent bullets is
easily preventable if health-minded hunters use
lead-free copper bullets now widely available and
generally regarded as fully comparable to lead-
based bullets for use in hunting (Carter 2007). The
potential for toxic exposure to copper from these
bullets is presumably insignificant because little or
no fragmentation occurs (Hunt et al. 2006), and
there is no meat wastage from having to discard tis-
sue suspected of contamination.
Fragmenting lead bullets have been in use for hunt-
ing since the early 1900s (Stroud and Hunt 2009).
Although hunter numbers have diminished slightly
in recent years, there were 10.7 million big game
hunters in the United States in 2006, the majority of
whom still use lead-based bullets (USFWS 2006,
Watson and Avery 2009). Many state wildlife
agencies annually issue multiple deer harvest per-
mits to individuals, effectively offering venison as a
year-round protein staple for some families; game
meat is the principal source of protein for a consid-
erable proportion of Alaska’s population (Titus et
al. 2009). Hunter-donated venison to food pantries
and shelters for low income families in most states
produced an estimated minimum of 9 million veni-
son meals associated with the 2007/08 hunting sea-
son (Avery and Watson 2009). With these con-
cerns, we anticipate that health sciences will further
examine the bioavailability of lead from bullets and
shot, the epidemiology of exposure, and the possi-
ble consequences among hunters, their families,
and others who consume venison.
ACKNOWLEDGEMENTS
The data were collected as part of The Peregrine
Fund's California Condor Restoration Project,
which is supported by the U.S. Fish and Wildlife
Service, Arizona Game and Fish Department, Bu-
reau of Land Management, The Charles Engelhard
Foundation, Liz Claiborne and Art Ortenberg
Foundation, Nina Mason Pulliam Charitable Trust,
Grand Canyon Conservation Fund, National Fish
and Wildlife Foundation, Jane Smith Turner Foun-
dation, and other important donors. We thank P.
and L. Widener, R. Berry, P. Jenny, B. Mutch, A.
Montoya, P. Juergens, B. Oakleaf, R. Green, T.
Hunt, A. Siedenstrang, the Wyoming Game and
Fish Department, the University of Idaho Analyti-
cal Sciences Laboratory-Holm Research Center,
and The Peregrine Fund Research Library for help
with this project. S. McGeehan and T. Case per-
formed laboratory analyses for heavy metals. D.
Lewis, G. Turner, G. Van Orden, and J. Luft pro-
vided care for the pigs and performed blood collec-
tion.
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