Taking the lead on lead shot

[al4x]

So David how about some monitoring or pressure being put on game dealers? If there was a pro active approach and the sources of these birds had a wake up call then you would get high compliance straight away.

[David BASC]

I would agree Al4x that a multi lateral approach would be best

[jimmyb79]

Just picked this, sent to all my MEPs. Was quite surprised how many there were!

[Trevorevans]

My reply (the only one I've had so far).

 

 

Dear Mr.

 

Many thanks for getting in touch. While this is still developing, our

understanding was that the Commission was considering asking ECHA to prepare

a restriction proposal on lead in shot, however this was blocked. It is

important to noted that the Commission services did not ask ECHA to prepare

a restriction dossier.

 

At the moment it is difficult to say any concrete at the moment, but be

assured that I will make sure I keep you informed of any developments.

 

Regards,

 

Marcus Warner

Caseworker

Jill Evans.

[David BASC]

An odd reply from your MeP- The process involving the European Chemicals Agency (ECHA) and the threat of a restriction on lead / lead shot is currently a technical one, not a political one.

 

The adoption of any new restriction on the manufacturing, placing on the market, or use of substances involves 15 main steps, we are currently at step 1!

 

For more details see here:

http://www.basc.org.uk/en/media/key_issues.cfm/cid/CCB9D91A-9217-4238-9F6BDF36E4525FB7

 

David

[gunsmoke]

An odd reply from your MeP- The process involving the European Chemicals Agency (ECHA) and the threat of a restriction on lead / lead shot is currently a technical one, not a political one.

 

The adoption of any new restriction on the manufacturing, placing on the market, or use of substances involves 15 main steps, we are currently at step 1!

 

For more details see here:

http://www.basc.org.uk/en/media/key_issues.cfm/cid/CCB9D91A-9217-4238-9F6BDF36E4525FB7

 

David

 

I wonder where they get the idea of restrictions on the manufacturing of lead filled cartridges from?

 

Could have been from the BASC research Committee:

PG felt that a three-stage process would be appropriate, namely a ban on the manufacture of lead ammunition, followed by bans on sale and eventually, use. Compliance and enforcement, however, were also considered important factors in the success of any such process.

 

NO never, BASC are going to fight to retain lead shot for all shooting?

[David BASC]

To suggest ECHA take their lead on research issues from the BASC , but research committee is laughable.

 

You know ad well as I that BASC sits with all the other shooting organisation to give a united front on this issue, to defend lead shot.

 

Now please stop trying to turn this thread into yet another one of your pointless conspiracy theory attacks on BASC and stick to the topic..not least of all, tell us what your MEPs have said

[Zapp]

Deliberate derailment of threads is unhelpful, not to mention being against the house rules. Don't do it please. If you have a side issue to discuss then start another thread and leave this one be.

[poontang]

Thanks for spotting that Poontang, I will add the contractor name to the webpage update.

 

The contract was awarded to Amec Environment & Infrastructure UK Limited

Details published here

http://www.publictenders.net/node/1661614

 

Details of the prior open procurement procedure can be found here

http://echa.europa.eu/documents/10162/13617/tender_specifications_echa_2011_140_en.pdf

See page 69 Lot 4: lead in shots

 

Details of the report submitted by Amec to ECHA have not been made public.

When its made public I will provide a link, as things stand I have no idea when that will be.

 

Good morning Conor,

 

Thank you for the links.

 

Surely the AMEC report should be in the public domain, seeing as their report was compiled using public money?

 

One other quick question, did BASC/FACE have any input into the AMEC report, and if so can you say what that response was?

 

Cheers.

[Conor O'Gorman]

Good morning Conor,

 

Thank you for the links.

 

Surely the AMEC report should be in the public domain, seeing as their report was compiled using public money?

 

One other quick question, did BASC/FACE have any input into the AMEC report, and if so can you say what that response was?

 

Cheers.

 

Good afternoon! I still have no idea when the Amec report will be published but I know that FACE have been making enquiries on that. When details emerge an update will be provided on the webpage below, which in the context of your question on who had input to the Amec report, also explains the background on the FACE UK report to FACE, the FACE report to Amec, the Amec report to ECHA, the next steps in the process and so on.

 

http://www.basc.org.uk/en/media/key_issues.cfm/cid/CCB9D91A-9217-4238-9F6BDF36E4525FB7

[al4x]

Dear Sir/Madam

 

Further to your recent email to Stuart Agnew MEP about the ECHA investigation into lead in ammunition and our initial reply, I am writing again to bring you up to date in regard to Mr Agnew’s activities relating to this issue.

As you know, he is strongly opposed to this potential legislation and intends to campaign against it. To this end, he has commissioned a research report into this issue, which he has asked me to pass on to you (see the attached). He hopes you will find it useful.

Mr Agnew will be closely monitoring the progress of the ECHA investigation and proposes to attend any European Parliamentary committee meetings at which it will be discussed.

We will write to you again with further updates, as and when events dictate.

 

Best wishes

Stuart Gulleford

Political Advisor to Stuart Agnew MEP

[David BASC]

All good stuff of course, but the facts still remain that:

 

1. There IS NO intention by any of the main UK political parties to bring in any further bans or restrictions on lead shot.

 

2. If ECHA suggests a ban in Europe, there will have to be a formal proposal – there is no evidence at all for this at the moment.

 

3. MeP’s have repeatedly told us that if ever gets as far as a formal proposal, it is likely to be several years from now, then MEPs would only have a very small role to play. What they have is the power of scrutiny over the final result as do national governments. This is the normal procedure for decisions made under what is known as comitology.

[wymberley]

Just had an update from my MEP, Julie Girling;

 

She says that the European Commission has confirmed in an answer to a parliamentary question by Vick Ford MEP (Cons) that there is no open dossier on lead shot.

 

She goes on to say that Sweden is working on lead in other areas and that she will keep an eye on the situation to ensure that lead in ammunition does not get caught up in this.

[poontang]

Wymberley,

 

Lead in ammunition wasn't on the Swedish agenda originally, but it certainly is now.

 

The European Commission and 'others' have asked Sweden to include lead in ammunition to their remit.

 

I wonder who the 'others' might be?

[wymberley]

Wymberley,

 

Lead in ammunition wasn't on the Swedish agenda originally, but it certainly is now.

 

The European Commission and 'others' have asked Sweden to include lead in ammunition to their remit.

 

I wonder who the 'others' might be?

 

Poontang,

 

To be honest, i'm not really following or au fait with this and only posted in case it was of interest. However, if you come up with any evidence backed info sing out and I'll get back to her as I have to say she doesn't seem like the average MEP drongo.

[poontang]

Report on the banning of lead shot in cartridges - August 2012 Rev 2

 

 

 

Introduction There is concern amongst the shooting fraternity of further restrictions and even a total ban on lead shot in shotgun cartridges. This has been brought about by information emanating from the European Chemicals Agency (ECHA) that unspecified member states and the European Commission have requested that Sweden adds lead shot in cartridges to their existing remit with Kemi (The Swedish Chemicals Agency) on the study of toxicity of other lead compounds initially requested by the Swedish authorities.

 

 

 

Extract from ECHA letter to the International Lead Association and other organisations

 

The European Chemicals Agency has appointed AMEC Environment & Infrastructure UK, under contract ECHA/2011/140, to collect up-to-date information on the costs of restricting the use of lead in shot for hunting purposes.

 

This substance is being assessed along with a number of others, which have been chosen on the basis of their potential relevance to risk management activities under REACH (Registration, Evaluation, Authorisation and restriction of Chemicals).

 

In addition, Sweden has communicated its aim to prepare a restriction proposal for lead and lead compounds in applications other than lead shot. In this context, other member states and the European Commission have asked Sweden to consider the use of ammunition. They will therefore evaluate whether it is feasible to propose a restriction on lead shots for hunting in the EU. Information under the current contract might be used to support the possible evaluation of whether such a restriction is feasible. It is important to have access to the most accurate and up-to-date information as this will help the Agency to prepare a proposal which is as well informed as possible. Therefore, your contribution to the project would be gratefully appreciated, and you are encouraged to respond in a timely manner to any requests for information AMEC might make. Mr. Kalle Kivela (kalle.kivela@echa.europa.eu) is available to provide further detail. Annankatu 18, P.O. Box 400, FI-00121 Helsinki, Finland I Tel. +358 9 686180 1 Fax +358 9 68618210 1 echa.eur0pa.e~

 

 

 

Preamble To summarise the situation as of August 2012:

 

(a) - Sweden's Chemicals Agency Kemi had been tasked with evaluating lead compounds by their government. 

 

 

( B) - The European Commission and 'others' asked Sweden to add ammunition to Kemi's remit.an Commission asked their Chemicals Agency (ECHA) to evaluate Kemi's work on lead. On ECHA public register they mention work on lead compounds but not lead in ammunition. 

 

 

(d) - The Commission asked the ECHA to have the issue of lead in ammunition evaluated and, to assist this, their environmental contractor AMEC Environmental (ECHA/2011/140 Lot No: 4 Lot title: Lead in shot) sent a questionnaire out to various organisations: the contractor has prepared a database of information using feedback from these questionnaires and responded to the ECHA: the report is not yet in the public domain.

(e) - In the UK there is a study body called the Lead Ammunition Group; developing data to advise Defra and the FSA on:

 

 

(i) the key risks to wildlife from lead ammunition, the respective levels of those risks and to explore possible solutions to any significant risks;

 

 

(ii) possible options for managing the risk to human health from the increased exposure to lead as a result of using lead ammunition. The scope is limited to England (though relevant research and evidence may be drawn from anywhere) and focused on safety aspects for human food, impacts on wildlife and issues surrounding possible alternatives to lead. The Group will be established for an initial 12-month period, after which progress will be reviewed by Defra & FSA. The group comprises people from key sectors i.e. conservation, animal welfare, environment, human food safety, gun & ammunition makers/traders, and shooting and deer management interests.

 

 

 

Aims of the Group:

• To advise Defra/FSA on what the significant risks to wildlife from the use of lead ammunition are and what levels of risk these pose in the short, medium and long term. Also any perceived risks which the evidence indicates are not significant.
  
• To advise Defra/FSA on possible options for managing the risk to human health from increased exposure to lead resulting from the use of lead ammunition notably in terms of food safety (including game shot with lead ammunition and spent lead shot deposited on agricultural land).
  
• To advise Defra/FSA of any significant knowledge gaps that may hinder the identification or assessment of risks, the development of technical solutions or the development of government policy.
  
• To advise Defra/FSA on any communication issues, and possible solutions, concerning the relaying of balanced information on issues surrounding the use of lead ammunition to the media, general public and stakeholders.
  
• To advise DEFRA/FSA of any significant impacts of possible advice or solutions on shooting activity and associated recreational, wildlife management, economic and employment impacts.
  

 

 

 

 

 

 

Outputs from the group:

• At the end of the first year the Group must produce a written report on progress for Defra/FSA.
  
• During the year, the Group must inform Defra/FSA of any key findings as they become apparent.
  
• Any scientific data or research used to underpin the written report must be of a quality that would withstand peer review.
  
• The Chair will provide a single point of contact for the formal disclosure of advice from the Group to Defra/FSA. Individual group members must not disclose advice outside the Group.
  

 

 

 

(f) - The UK’s shooting, trade and countryside management organisations are working together via FACE UK (UK branch of 'Federation of Associations for Hunting and Conservation of the European Union') to collect and submit information on the lead shot issue to the ECHA. FACE currently counts Member Associations in 36 countries.

 

 

• It has regular contacts with the 736 Members of the European Parliament and works in particular close collaboration with MEPs taking part in the Sustainable Hunting, Biodiversity Countryside Activities & Forestry Intergroup. FACE has provided the Secretariat for this Intergroup since it was established in October 1985. EU legislation and issues of relevance to wildlife conservation and management, as well as to hunting, are discussed during these informal gathering of MEPs in Strasbourg. The outcome of its discussions often leads to a consensus view that becomes a useful tool when the Parliament has to vote on Proposals and Amendments.
  

 

 

• Already active at the very early preparatory stages of legislative proposals, FACE works to ensure that these texts are as realistic as possible even before they come to the attention of the general public. Since its foundation, FACE has had decisive input into all EU initiatives (Directives, Amendments and Regulations) relating directly or indirectly to hunting and wildlife management.
  

 

 

• It is recognised by the European Commission as the main discussion partner, representing Europe's 7 million hunters, and is consulted by the relevant Directorate-General during the elaboration and monitoring of EU legislation dealing with hunting, wildlife management, nature conservation, firearms, wild animal health, game meat hygiene, etc.
  

 

 

• It is in regular contact with the Council of Ministers, directly as well as through its national delegations. The Council of Europe has granted FACE observer status at the meetings of the Standing Committee of the Bern Convention (T-PVS). FACE also takes active part at its Expert Groups (e.g. Threatened species, Large Carnivores, etc.) and has already organised several wildlife expert meetings for the Council of Europe. It also works closely with its NATUROPA Centre, to gather and distribute information about nature conservation issues, and to raise awareness among European citizens.
  

 

 

 

Possible developments from now – see reference1

 

The process involving the European Chemicals Agency (ECHA) and the threat of a restriction on lead shot is currently a technical one, not a political one, and the adoption of any new restriction on the manufacturing, placing on the market, or use of substances involves 15 main steps.

 

 

 

 

 

Conclusion

There has been some doubt expressed about the lack of/validity of scientific evidence put forward to ban lead in shot over wetlands and for waterfowl generally. Any concerted lobby group to oppose a ban on lead shot, must re-assess the evidence base for the original claims and run with factual not hearsay information. It should not be forgotten that in the country where this investigation was supposed to have started from, Sweden, there is no total ban there at this time. Any organised opposition to the proposal must therefore be factual and not rooted in conspiracy theories’.

 

 

Opportunities to resist: FACE will keep abreast of happenings in the European Parliament and report to its member associations and during the above 15 steps there will be ample opportunity to lobby our government(s) who will review the findings of the Lead Ammunition Group together with data published by the ECHA and if appropriate oppose any movements by the EU in this matter. It is hoped that a similar process will be followed in other EU countries also as it is within the competence of individual nations to apply and or enforce any regulations emanating

 

from the above process.

 

 

It is of paramount importance that the 'shooting fraternity' and 'fishing lobby' speaks as one about lead shot/weights within the UK and in other EU member states. It is only by working as a coordinated team that these types of initiative can be defeated by the populace; noting that there are an estimated 7,000,000 shooters and 15,000,000 Recreational fishermen in EU member states, (It is not known if 'shooters and fishers are working together yet).

 

 

 

References

 

1http://echa.europa.eu/web/guest/regulations/reach/restrictions/restriction-procedure/restrictions-process/steps#restriction_decision

 

 

 

http://www.google.co.uk/search?q=REACH&ie=utf-8&oe=utf-8&aq=t&rls=org.mozilla:en-GB:official&client=firefox-a

 

 

 

http://www.leadammunitiongroup.co.uk/reference.html

 

 

 

http://www.countryside-alliance.org/ca/file/Copy_of_FACE_UK_submission_to_FACE_-_AMEC_questionnaire.pdf

 

 

 

http://www.basc.org.uk/en/media/pressreleases.cfm/prid/EF58BE00-1F04-407B-95395510F06CCE4F

 

 

 

http://www.face.eu/aboutus_structure-en.htm

 

 

 

http://www.face.eu/aboutus_activities-en.htm

 

 

 

http://circa.europa.eu/

Edited September 5, 2012 by poontang

[wymberley]

P,

 

Yep that's the reason - I have it.

 

Cheers

[David BASC]

The current situation in Europe is this – text from the Commission in answer to a question from an MeP :

 

 

ECHA commissioned several studies in 2011 with the aim of establishing a capability to improve the assessment of the costs of reducing the use or emissions of hazardous substances.

 

Several concrete cases were chosen for this research exercise. As the contracting parties to the African-Eurasian Waterbird Agreement (AEWA) have agreed to phase out the use of lead shot in ammunition in wetlands, this case was selected to be part of the cost study.

 

This case (as well as the others selected) of the cost study will be placed on the ECHA website in the coming weeks. In the frame of this study, industry stakeholders were contacted in order to gather information. The study itself would not lead to any restrictions on the lead shot in ammunition.

 

The Commission did not ask ECHA to prepare an Annex XV restriction dossier. Sweden has notified its intention to prepare a restriction dossier concerning lead and lead compounds in articles intended for consumer use and the Commission understands that it is carrying out a preliminary investigation on the issue of lead shot in ammunition.

 

As concerns the procedure for adopting a possible restriction, if ECHA (at the request of the Commission) or a Member State proposes restrictions, the restriction dossier is made public on ECHA's website and the interested parties are invited to submit comments or information on socioeconomic aspects. Following the receipt of the opinion by the ECHA's Committees for risk and socioeconomic assessment, the Commission adopts the final decision in accordance with the regulatory procedure with scrutiny.

 

Sadly I think your MeP will find that they have little or no say in the matter should there be a proposal for a restriction dossier and the subsequent process. However at stage 2, there will be further consultation with stakeholders.

 

There is a meeting of FACE as I type, and lead will be on the agenda; detials of the meeting will, I am sure, be published soon

 

David

[gunsmoke]

Answer to MEP qusetion from Mr Tajani from the EU Commission.

Answer to a written question - European Chemicals Agency (ECHA) investigation on lead in ammunition - P-006712/2012

 

Parliamentary questions

8 August 2012P-006712/2012

 

Answer given by Mr Tajani on behalf of the Commission ECHA commissioned several studies in 2011 with the aim of establishing a capability to improve the assessment of the costs of reducing the use or emissions of hazardous substances. Several concrete cases were chosen for this research exercise. As the contracting parties to the African-Eurasian Waterbird Agreement (AEWA)(1) have agreed to phase out the use of lead shot in ammunition in wetlands, this case was selected to be part of the cost study. This case (as well as the others selected) of the cost study will be placed on the ECHA website(2) in the coming weeks. In the frame of this study, industry stakeholders were contacted in order to gather information. The study itself would not lead to any restrictions on the lead shot in ammunition.

 

The Commission did not ask ECHA to prepare an Annex XV restriction dossier. Sweden has notified its intention to prepare a restriction

dossier concerning lead and lead compounds in articles intended for consumer use and the Commission understands that it is carrying out

a preliminary investigation on the issue of lead shot in ammunition. As concerns the procedure for adopting a possible restriction(3), if ECHA (at the request of the Commission) or a Member State proposes restrictions, the restriction dossier is made public on ECHA's

website and the interested parties are invited to submit comments or information on socioeconomic aspects. Following the receipt of the

opinion by the ECHA's Committees for risk and socioeconomic assessment, the Commission adopts the final decision in accordance

with the regulatory procedure with scrutiny.

(1)http://www.unep-aewa.org/

 

(2)http://echa.europa.e...alysis-in-reach

 

(3)Articles 69-73 of Regulation (EC) No 1907/2006 of the European Parliament and of the Council of 18 December 2006 concerning the Registration, Evaluation, Authorisation and Restriction of Chemicals (REACH), establishing a European Chemicals Agency, amending

Directive 1999/45/EC and repealing Council Regulation (EEC) No 793/93 and Commission Regulation (EC) No 1488/94 as well as Council Directive 76/769/EEC and Commission Directives 91/155/EEC, 93/67/EEC, 93/105/EC and 2000/21/EC, OJ L 396, 30.12.2006, p. 1.

Edited September 10, 2012 by gunsmoke

[David BASC]

GS,

 

I think this is a comprehensive analysis on the ECHA / AMEC /REACH issue.

 

However I think that this can all be summed up, as I said earlier, that we are at step 1 of a 15 step programme and no immediate idea as to when we go to step 2. Would you agree?

 

David

[gunsmoke]

If we are on step 2, then after the Face EU meeting that said there is no problem with spent lead shot we will now find that BASC will be fighting to stop the ECHA and all going to step 3.

 

We all that the work for the same hymn sheet.

 

I'm glad to hear from the FACE EU metting that BASC are now on my side.

[David BASC]

BASC's position re lead, FACE UK and FACE has not changed as you seem to be suggesting.

 

All the associations on FACE UK made an open statement on united front ages ago. For the avoidance of doubt the FACE UK position on lead shot is:

· Shooting in the UK provides considerable and proven social, economic and environmental benefits.

· For many centuries this has involved the use of lead ammunition.

· FACE UK does not believe that the case for further legislative or regulatory restrictions on the use of lead ammunition has been made at either national or international level.

· Members of FACE UK vigorously oppose any unwarranted further restrictions on the use of lead ammunition either from the UK or in Europe.

· Discussions and decisions at national and international level about lead ammunition must fully involve shooting interests.

· Statutory restrictions on the use of lead shot already exist across the UK to meet commitments under the African-Eurasian Waterbird Agreement (AEWA) and mitigate risk to wildfowl.

· In the absence of any relevant peer-reviewed scientific evidence, no further restrictions should be placed on the use of lead ammunition.

 

What is important is that all these organisations remain focussed on their objective and maintain the collegiate approach, flying off on individual campaigns is not going to help.

 

David

Edited September 19, 2012 by David BASC