And a letter from Jim:
GOAL Files Request for Amendment to Toxic Chemical Bill
January 16, 2008
Dear Senator,
We are writing to express our concerns with S.2406 “An Act for a Healthy Massachusetts Safer Alternatives to Toxic Chemicals,” which will shortly come before you for action.
S.2406 authorizes the establishment of an advisory committee that would work with the Toxics Use Reduction Institute at the University of Massachusetts Lowell to establish a list of toxic substances in Massachusetts. The Institute is to develop a priority list of toxics, and come up with safer alternatives whose use would be mandated in the Commonwealth.
As the representative of the gun owners of the Commonwealth, GOAL is concerned that misplaced zeal combined with a lack of historical knowledge concerning the decade of work to create best management practices could easily lead to an unwarranted prohibition of lead ammunition in the Commonwealth. We have grave concerns about all of the power being placed into the hands of this one group.
Our concerns over the power of TURI were only magnified with the published work on the use of lead at shooting ranges from the Institute in 2007. In the creation of this report TURI failed to professionally carry out its charge, claiming a lack of funding and time, resulting in a less than accurate report. Failings in the 2007 “study” include:
· Claims that frangible ammunition is a viable alternative, without examining the commercial availability of this ammunition, which is limited;
· Claims that frangible ammunition is less of a health risk, despite recent evidence that tungsten, a major component, is also a carcinogen;
· Claims that copper and copper products are viable substitutes when copper toxicity has not been adequately studied;
· No examination of the economic impact on Massachusetts hunters and competitive shooters. A 2007 study of manufacturer’s price lists showed the non-lead ammunition is an average of 209% to 219% greater in cost.
When questioned as to the validity of their conclusions, the Institute’s excuse was that they ran out of money and time and needed to publish something to comply with the mandate. Based on this experience, Gun Owners' Action League believes that the Institute has demonstrated a lack of professional knowledge, credibility and thus the ability to evaluate anything regarding lead in ammunition.
As further proof, this report from TURI also did not include anything regarding the fact that Gun Owners’ Action League has been pro-actively involved with protecting the environment and managing lead at shooting ranges. Working with the state’s Department of Environmental Protection and the Environmental Protection Agency, we established the Lead Shot Initiative approximately ten years ago. GOAL has worked very hard over the last ten years to assist Massachusetts clubs to operate under a Best Management Practices plan, ensuring the protection of our natural resources. These non-profit clubs across the state have spent thousands of dollars working on these management practices and have received no recognition for their efforts and now may be forced to change everything they do again based on a less than credible source.
With these facts in place Gun Owners’ Action League requests the following amendments to S.2406:
· To insert after the word “include” on line 259:- lead as used in ammunition; and will not include
· To strike the words “sale: or” occurring in line 275, and replace with the following:- (9) present in crude or fuel oils used in combustion to produce electricity, steam or heat except when production of electricity, steam or heat is the primary business of a facility; or (10) present in ammunition or components of ammunition subject to but not limited to lead projectiles and expended lead projectiles including expended lead when discharged from ammunition.
The past history of TURI dictates that we seek these amendments to S.2406. The sponsors of this bill have stated publicly that their intent is not to ban lead ammunition. Because of that acknowledgement, and the TURI record, we would assume that the sponsors of this bill would have no objection to these proposed amendments. I thank you in advance for accepting these amendments and thus ensuring our shooting sports heritage may be passed on to the next generation.
Sincerely,
James L. Wallace
Executive Director