The Proposal
Current regulation:
The use of lead shot for hunting migratory game birds is prohibited throughout Canada. There are currently no bans on the use of lead shot to hunt other species in B.C.
Proposed regulation:
Prohibit the use of lead shot for hunting any species in B.C. This regulation does not propose to restrict the use of lead shot for purposes other than hunting (i.e. target practice, skeet shooting, etc.).
Lead Poisoning
The B.C. Wildlife Federation recognizes that lead is toxic to humans and wildlife when ingested or absorbed by other means such as through skin, muscle tissue or breathing. Lead is known to cause cumulative poisoning in animals, meaning that lead is not easily removed by normal body processes and accumulates with successive exposures, which can result in chronic health problems or even death. The BCWF is sensitive to the issue of lead in the environment.
Lead shot is prohibited for hunting waterfowl in Canada following a phase in period starting in 1991 with site specific prohibitions in specific sensitive areas where heavy use caused a significant accumulation of lead in the environment. In 1997, Canada banned the use of lead shot for waterfowl hunting within 200 metres of watercourses and in 1999 Canada introduced a complete ban on the use of lead shot for hunting migratory game birds. This prohibition in Canada as well as other countries has had a measurable impact on reducing waterfowl mortality from lead poisoning.
Evidence is clear that exposure to lead is a serious problem for raptors, such as eagles, upon ingesting lead from carcases or entrails of harvested animals left in the field by hunters. The digestive processes in raptors dissolve lead much more readily than most other scavengers and a small amount of ingested lead can cause severe illness or death. While lead is a factor in the mortality of raptors such as eagles, anthropogenic causes such as collisions with vehicles and electrocution, exposure to poisonous materials other than lead (rodenticides), and avian influenza are significant contributors.
The B.C. Wildlife Federation’s Position on the Regulation Proposal
After reviewing the proposed regulation change for the 2026-2028 hunting and trapping regulation cycle, the BCWF cannot support the proposal to prohibit the use of lead shot for the purpose of hunting. The following provides the BCWF’s response to the rationale provided in the regulation proposal.
Waterfowl hunting tends to concentrate hunters in specific and smaller areas while the hunting of other game with lead shot does not concentrate hunters to nearly the same extent. Evidence that shows the magnitude of the issues specifically related to the use of lead shot for hunting upland game birds, or big and small game (as described in legal hunting methods in the B.C. Hunting and Trapping Regulations Synopsis) is often conflated with the use of a broader variety of lead ammunition beyond shot used in hunting. The evidence related to significant residual lead shot left behind in popular waterfowl hunting areas, which occurred before lead shot was banned for waterfowl hunting, is unquestionable, and hunters have responded with high compliance to the prohibition on the use of lead shot for waterfowl hunting.
The rationale for the proposal defines shot as “a cartridge manufactured so that it contains 8 or more roughly spherical projectiles.” This would impact everything from 12 gauge 00 buck cartridges often used for hunting large game like bears and deer to .410 field loads used for upland game birds. An unforeseen impact of the regulation proposal is to prohibit the use of a minimum of “No. 1” buck as mandated in regulation, as well as 0 and 00, which both can contain 8 or more pellets. Multiple provincial, regional and municipal regulations restrict the use of single projectiles for hunting for a variety of reasons including safety, but do allow shot — the proposal has not identified the consequences on the use of shot where single projectiles are not allowed.
The proposal says that non-toxic alternatives are available for roughly 10 cents per cartridge more than the equivalent lead shotshells. The BCWF could not verify such a small pricing differential after researching major retailers, even for steel shot, and certainly not for bismuth or tungsten alloy alternatives. The pricing differential increases for shotshells in the smaller bores such as .410 and 28 gauge, which are both popular for hunting upland game birds. Some jurisdictions have provided incentives such as giving hunters coupons to lower the price of non-toxic ammunition, which is something that B.C. could consider. Additionally, steel and tungsten alloys are not safe to use in older shotguns and even modern shotguns with fixed or interchangeable full chokes.
Since the rationale in the proposal does not identify any specific objectives related to the use of lead shot in hunting, it is not clear that the prohibition of lead shot for hunting in B.C. will make a significant difference in reducing the toxic impacts in scavengers and specifically “birds” as identified in the proposal. The BCWF does encourage its members and all hunters in B.C. to research the impacts of using lead shot for hunting and to make a personal decision about using lead shot for hunting. The BCWF supports the transition to non-toxic shot as a personal choice.
Should the Province decide to prohibit the use of lead shot for hunting any species in British Columbia sometime in the future, the BCWF provides the following recommendations:
- Provide evidence that prohibiting the use of lead shot for hunting in B.C. (other than waterfowl hunting) will meet objectives related to the reduction of lead levels in, disease occurrence in, and mortality in scavenger species such as eagles.
- Do not implement a province-wide ban on the use of lead shot for hunting but rather focus on specific areas. Several states in the US have taken this approach by prohibiting the use of non-toxic shot in specified wildlife management areas and conservation areas.
- Consider a phased-in approach over three to five years.
- Provide incentives for hunters to voluntarily transition from lead shot to non-toxic alternatives.
- Support the creation and distribution of educational materials on the issues of lead in the environment, its impact on wildlife, and science supported non-toxic alternatives for hunters. The BCWF commits to work with government to provide educational resources on the issues of using ammunition containing lead.