UK REACH – Restriction Proposals 004 - Lead shot in ammunition

[Stonepark]

The consultation is open and lasts 6 months.

 

Before everyone puts in their individual responses, perhaps we should come up with PW responses to help those who may not have the time to respond themselves in detail?

 

https://consultations.hse.gov.uk/crd-reach/restriction-proposals-004/consultation/intro/

 

[rbrowning2]

• On the sale and use of lead shot
An unacceptable risk has been identified for both hunting with lead shot (environment and human health) and sports shooting (environment). There are no realistic ways to limit the amount of lead entering the environment or to eliminate the risk to humans from ingestion of lead when lead shot is used for hunting. When used for sports shooting, lead shot can remain on the surface of the ground where there is a risk of primary poisoning to birds and livestock unless it is immediately collected – this is not considered practical. Risk management measures may be available to manage the risks to soil and to livestock via secondary poisoning, but these are of secondary concern compared to the risk to birds. The most effective risk management option is therefore a complete ban on the sale and use of lead shot.
Lead shot is banned for use over wetlands within the UK, so alternatives are already available on the GB market, especially steel shot. Some shooters have already made the transition to these, and a number of UK shooting and rural organisations have voluntarily committed to using alternatives to lead shot for the hunting of live quarry by 2025, whilst some supermarkets have also committed to only selling game meat from animals killed using non-lead ammunition. Lead shot is not used for indoor shooting, so a ban on sale would not have knock-on consequences for low risk uses. It would also be readily enforceable as there would be no legal use for lead shot. A ban on the sale and use of lead shot is therefore considered practical.
This option would also be monitorable. Compliance with the existing lead shot bans over wetlands is thought to be low, so a total ban on the sale and use of lead shot would tackle this issue.
The Agency is aware that the use of lead shot is required for national and international competitions in some outdoor sports shooting disciplines. Therefore, an optional derogation could be considered, involving a licensing system to allow the relevant athletes to continue training, and suppliers to continue sales to these authorised athletes. This derogation would also include a licensing system for the shooting ranges where this training takes place to ensure that lead collection systems are in place to minimise the risks to the environment from this activity. This optional derogation requires further consideration to ensure it is practical and proportionate, noting that it would not be fully effective at removing all the environmental risks identified.

Edited May 6, 2022 by rbrowning2

[rbrowning2]

Recovery system for english sporting and FITAS will be challenging 
 

Transition periods
A transition period for the sale and use of lead shot cartridges of 18 months is proposed. If the optional derogation for use of lead shot in sports shooting is agreed, a transition period of 5 years is proposed for the ban on the sale and use of lead shot to give shooting ranges time to install the recovery systems required and for a licensing scheme to be developed and implemented. This extended transition period would apply to all uses of lead shot as it would not be practical for suppliers to sell only for sports shooting in the absence of appropriate vetting processes. Nevertheless, existing voluntary commitments by a number of UK shooting and rural organisations to use alternatives to lead shot by 2025 for the hunting of live quarry could still significantly reduce the risks arising from hunting during this period.
A transition period of 18 months is proposed for the ban on the use of large calibre lead bullets for hunting, due to the availability of substitutes. However, a transitional period of 5 years is proposed for the ban on the use of small calibre (including airguns) lead bullets for hunting, to allow additional time for the development and testing of alternatives.
A transition period of 18 months is proposed for the ban on the use of large calibre lead bullets for sports shooting, due to the availability of substitutes and the expectation that shooting ranges may already have risk management measures in place sufficient to meet the proposed derogation or that these can be readily installed. A transitional period of 5 years is proposed for the ban on the use of small calibre (including airguns) lead bullets for sports shooting, to allow additional time for the development and testing of alternatives.
Transitional periods between 6 months and 5 years are proposed for the mandatory labelling requirements, depending on the final derogations, to raise awareness of both the risks of lead and the timelines for transition to alternatives.
The preferred risk management options and potential derogations described above 22

are included in the consultation stage, to gather additional information about whether they are likely to be effective and proportionate. The derogations would also include a requirement to report to the relevant authority on the use of lead ammunition and the effectiveness of the risk management measures in place. These options have been taken forward for the socioeconomic analysis.

Edited May 6, 2022 by rbrowning2

[Conor O'Gorman]

In summary what's being proposed is:

• ban on the sale of lead shot
• ban on the use of all types of lead ammunition for live quarry shooting including lead shot, shotgun slugs, lead bullets and airgun pellets
• ban on the use of lead shot for outdoor target shooting with possible derogations for licensed athletes at licensed ranges with appropriate environmental protection measures
• ban on the use of lead bullets for outdoor target shooting with possible derogations for shooting at licensed ranges with appropriate environmental protection measures
• mandatory labelling of the packaging of lead ammunition regarding the hazards and risks of lead.

Proposed transition periods for the above restrictions to take effect would vary from 18 months to five years. Buy-back schemes for lead shot cartridges and rifle ammunition have been proposed.

More info available from the web-links below:

https://basc.org.uk/basc-statement-in-response-to-uk-reach-lead-proposals/

https://basc.org.uk/lead-ammunition-restriction-proposals-what-happens-next/

[mellors]

As i said on another thread it's a done deal. 

Absolutely nothing we say or do will change it now. 

 

[adzyvilla]

Yep, nothing we say or do matters its happening. Cheers BASC et al good job.

[rbrowning2]

4 hours ago, Conor O'Gorman said:

Buy-back schemes for lead shot cartridges and rifle ammunition have been proposed.

 

Think your buy-back proposal is a little premature, and why restricted to cartridges and ammunition, what about the guns which become obsolete?  Why would lead manufactures buy back, even if practical to do so when they then have no market to resell into.

2.4.2.2.4 RO4: Buy back scheme for lead bullets

Some gun owners may buy large quantities of lead ammunition at a time, which could remain unused for several years. In addition, shooters may import lead bullets from abroad (e.g. as unused bullets following a shooting holiday). To encourage a faster transition to lead alternatives, one option would be for either lead manufacturers or government to offer a buy-back scheme. This could also be implemented to support either a full or partial restriction, for example during or at the end of a transition period.
This option has not been fully explored or costed so no assessment of effectiveness, practicability, monitorability or enforceability has been done. This will be reviewed following analysis of information gathered during the consultation stage.

Then

• ban on the use of lead shot for outdoor target shooting with possible derogations for licensed athletes at licensed ranges with appropriate environmental protection measures

what practical use is that top clay pigeon shooters get to be that by shooting at lots of different grounds with different targets, not by just shooting at one ground.

 

Edited May 6, 2022 by rbrowning2

[enfieldspares]

As I have said here and/or elsewhere there must be no derogation for "licensed athletes" (that is Commonwealth and Olympic Games shooters) the ban if it is to come must be for everybody. For else wise those who could and would make a difference (that is Commonwealth and Olympic Games shooters) will have not interest in fighting a ban. Just as they had no interest in 1996 in fighting the Tory fullbore pistol and subsequent Labour small bore pistol bans. There must be no "I'm alright Jack" escape from any ban for a self-appointed coterie of "licensed athletes".

[grahamch]

Sadly this will cripple small scale, informal and club clay shoots run by local clubs on farm land where plastic wads will be a no go.

I can see my fowling club stopping all of its clay shoots as I doubt there will be sufficient biodegradable wads available to fulfill demand. 

Surely one of the conditions of a ban must include suitable wads being available for steel shot loads?

 

 

 

 

 

[Ferretlurcher1970]

How needs packham when you have basc

[enfieldspares]

15 minutes ago, Ferretlurcher1970 said:

Who needs packham when you have basc

Sadly you may be right. +1.

[mossy835]

glad i left BASC.

[clangerman]

41 minutes ago, Ferretlurcher1970 said:

How needs packham when you have basc

hear hear sold out yet again by the SELF appointed voice of shooting for their own ends 

[Old farrier]

6 hours ago, Conor O'Gorman said:

In summary what's being proposed is:

• ban on the sale of lead shot
• ban on the use of all types of lead ammunition for live quarry shooting including lead shot, shotgun slugs, lead bullets and airgun pellets
• ban on the use of lead shot for outdoor target shooting with possible derogations for licensed athletes at licensed ranges with appropriate environmental protection measures
• ban on the use of lead bullets for outdoor target shooting with possible derogations for shooting at licensed ranges with appropriate environmental protection measures
• mandatory labelling of the packaging of lead ammunition regarding the hazards and risks of lead.

Proposed transition periods for the above restrictions to take effect would vary from 18 months to five years. Buy-back schemes for lead shot cartridges and rifle ammunition have been proposed.

More info available from the web-links below:

https://basc.org.uk/basc-statement-in-response-to-uk-reach-lead-proposals/

https://basc.org.uk/lead-ammunition-restriction-proposals-what-happens-next/

Or propose that all game birds and wildfowl are shot with non lead 

allow all clay shooting to continue with lead along with pest control (unless destined for the food chain) 

Appreciate it is a done deal that’s why I’m wasting time offering a alternative as I don’t think I’ll get a response let alone any changes to the proposals 

[Weihrauch17]

6 hours ago, Conor O'Gorman said:

In summary what's being proposed is:

• ban on the sale of lead shot
• ban on the use of all types of lead ammunition for live quarry shooting including lead shot, shotgun slugs, lead bullets and airgun pellets
• ban on the use of lead shot for outdoor target shooting with possible derogations for licensed athletes at licensed ranges with appropriate environmental protection measures
• ban on the use of lead bullets for outdoor target shooting with possible derogations for shooting at licensed ranges with appropriate environmental protection measures
• mandatory labelling of the packaging of lead ammunition regarding the hazards and risks of lead.

Proposed transition periods for the above restrictions to take effect would vary from 18 months to five years. Buy-back schemes for lead shot cartridges and rifle ammunition have been proposed.

More info available from the web-links below:

https://basc.org.uk/basc-statement-in-response-to-uk-reach-lead-proposals/

https://basc.org.uk/lead-ammunition-restriction-proposals-what-happens-next/

Thanks Conor, sold us all down the river.  Let's hope BASC soon goes to the wall.

[8 shot]

Lets get it done, the sooner this short term complete ban on shooting comes the sooner the BASC etc. will disappear. Then hopefully the younger generation just starting in shooting just may get a chance to of a reorganised future without these worthless organisation. At least 2 billion pounds is what shooting is worth to the economy along with one hell of a lot of conservation all gone. We've been sorting out gamecover this week with several shoots, everyone has said to a person, that if they stop shooting all the gamecrop, wild bird cover, and envro. schemes stop too. In other words there shooting subs. the schemes.

[Weihrauch17]

27 minutes ago, Old farrier said:

Or propose that all game birds and wildfowl are shot with non lead 

allow all clay shooting to continue with lead along with pest control (unless destined for the food chain) 

Appreciate it is a done deal that’s why I’m wasting time offering a alternative as I don’t think I’ll get a response let alone any changes to the proposals 

Why all Game birds, most do not end up at Game Dealers and nobody I know has had any issues with eating Lead shot Game.  Let big Commercial shoots use steel and leave the rest of us out of it.  Why ban rifle and airgun ammunition for Vermin, it's an absolute joke.  

Edited May 6, 2022 by Weihrauch17

[grahamch]

14 minutes ago, Weihrauch17 said:

Why all Game birds, most do not end up at Game Dealers and nobody I know has had any issues with eating Lead shot Game.  Let big Commercial shoots use steel and leave the rest of us out of it.  Why ban rifle and airgun ammunition for Vermin, it's an absolute joke.  

You may think its a joke, but is sadly reality and sooner folk accept it and get over themselves the better. 

[Old farrier]

6 minutes ago, Weihrauch17 said:

Why all Game birds, most do not end up at Game Dealers and nobody I know has had any issues with eating Lead shot Game.  Let big Commercial shoots use steel and leave the rest of us out of it.  Why ban rifle and airgun ammunition for Vermin, it's an absolute joke.  

Because then it’s policeable and there going to ban lead for something and as there using the guise of food and selling game it seems to a simple solution to a total mess

also they can’t say no one offered a compromise or alternative 

 

 

it’s a consultation put your idea’s forward   

it is a done deal we have been sold down the river and it seems there’s a bunch of antis working in the organisation’s with a agenda

 

[adzyvilla]

Basc and the others will not be negotiating from a position of strength, they showed their hand a long time ago either through stupidity or misjudgement (that they were ok with banning lead). What possible influence can they have on the consultation now? HSE are pretty clear in their stated aims and when do these quangocrats ever listen to the public? Basc sadly don't have a brain between them, now would have been the time to state their position but they gave away what influence they had. They are now about as effective a voice of shooting as the monster raving loony party.

[TIGHTCHOKE]

Perhaps BASC should add another A to their name?

British

Association

AGAINST

Shooting

Conservation

[Touchstone]

I'm another member that won't be renewing at the end of this month.  I have only kept my membership going over the last few years because it's an easy route to insurance and for the odd time that I might need a pointer on firearms legislation.  I fail to see what BASC offers to shooters.  It certainly isn't a good read every couple of months.  I find the magazine is more effective than a general anaesthetic.

T

[TIGHTCHOKE]

I just looked on line and BASC still maintain they have 150 000 Members.

Struggling to accept that as a genuine figure I am afraid.

[McSpredder]

20 hours ago, Stonepark said:

Before everyone puts in their individual responses, perhaps we should come up with PW responses to help those who may not have the time to respond themselves in detail?

https://consultations.hse.gov.uk/crd-reach/restriction-proposals-004/consultation/intro/

It is difficult to respond to a consultation until you know exactly what is being asked.   I have only looked at the opening page, which demands contact details (and consent to use of unspecified cookies) before even the first question can be revealed.

Can anybody (perhaps one of the shooting organisations) can reveal the full content?

[Fellside]

51 minutes ago, McSpredder said:

It is difficult to respond to a consultation until you know exactly what is being asked.   I have only looked at the opening page, which demands contact details (and consent to use of unspecified cookies) before even the first question can be revealed.

 

Can anybody (perhaps one of the shooting organisations) can reveal the full content?

Hi McSpredder,

I have completed the consultation questionnaire. There is nothing personal or sensitive being asked for. I think they just want your details to avoid any inappropriate flack - quite a normal thing with government forms. 

Some of the questions are a little strange - as they assume that you’re a clay shooting ground owner - asking about feasibility re lead shot recovery  etc. There is also a section on muzzle loaders - which I couldn’t answer - as I have no relevant experience. You will find most of it relevant however. 

There is plenty of room for comment - so you can make your case. They ask for evidence based points where possible……but your experience is evidence right?!

I would encourage anyone to complete it.