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Lead ammunition review extended by 6 months after 'overwhelming response'


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50 minutes ago, Scully said:

Sat in beaters wagon this afternoon, after the final drive, and the conversation ( at no prompting from me ) got around to steel shot, and I took the opportunity to point out to a non-shooting beater the level of response to the consultation, and all of a sudden it went embarrassingly quiet and everyone found great interest in looking anywhere but at me……with one exception ( an ex copper ) who said ‘it’s going to happen anyhow’. 
I agreed, and then asked him if he cared.
He said of course he did, but when I told him his lack of response gave those who matter, the impression he didn’t, he just shrugged and started a conversation about something else. 🤷‍♂️

So there we have it, complete and utter apathy. 
All those who didn’t respond have no right to whine, absolutely none at all. You had the opportunity to tell those who oppose us exactly what you thought, and you couldn’t be bothered. 

I responded but when the Govt and your supposed representatives collude in a ban I would imagine apathy being quite common as it is very obviously a done deal, us being the ones done.  It's akin to a Classic Car organisation agreeing to a Petrol ban.  We all know it's a Political and not a science based decision but the question is why have we been sold down the river by BASC and the like?  I can only assume that BASC have been infiltrated by antis like Natural England and Tony Jupiter. What is the worst that could have happened if they opposed a Lead Ban and lost, eerrr a Lead Ban!

Edited by Weihrauch17
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Hi Conor,

Are BASC aware that the "World Forum on Shooting Activities" has financed a scientific study looking into lead ingestion in wild bird populations?

This study demonstrates that the current estimates of bird losses across europe, used by the European Chemicals Agency, were based on uncertain or generic assumptions. Which, according to the report are flawed.

The report is titled: "Method to assess the potential magnitude of terrestial european avian population reductions from ingestion of lead ammunition". This report is available to read/download from the scientific journal PLOS One (Public Library of Science).

It is interesting to note that a significant amount of the data used by the European Chemicals Agency to support their potentially flawed theories on lead shot ingestion, is sourced from the UK.

Davo.

 

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3 hours ago, MK11 said:

Hi Conor,

Are BASC aware that the "World Forum on Shooting Activities" has financed a scientific study looking into lead ingestion in wild bird populations?

This study demonstrates that the current estimates of bird losses across europe, used by the European Chemicals Agency, were based on uncertain or generic assumptions. Which, according to the report are flawed.

The report is titled: "Method to assess the potential magnitude of terrestial european avian population reductions from ingestion of lead ammunition". This report is available to read/download from the scientific journal PLOS One (Public Library of Science).

It is interesting to note that a significant amount of the data used by the European Chemicals Agency to support their potentially flawed theories on lead shot ingestion, is sourced from the UK.

Davo.

 

Hi Davo, yes both BASC and FACE are aware of the paper and its recommendations and thank you for highlighting it nonetheless.

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On 08/02/2023 at 09:16, Conor O'Gorman said:

Hi Davo, yes both BASC and FACE are aware of the paper and its recommendations and thank you for highlighting it nonetheless.

Conor, could you comment on whether BASC will be calling for a voluntary phase out of chocolate any time soon? 

https://www-yahoo-com.cdn.ampproject.org/v/s/www.yahoo.com/amphtml/lifestyle/avoid-lead-cadmium-chocolate-160000783.html?amp_js_v=a6&amp_gsa=1&usqp=mq331AQIKAGwASCAAgM%3D#aoh=16766291716270&csi=0&referrer=https%3A%2F%2Fwww.google.com&amp_tf=From %1%24s&ampshare=https%3A%2F%2Fwww.yahoo.com%2Flifestyle%2Favoid-lead-cadmium-chocolate-160000783.html

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Thanks @rewulf your quip did make me smile.

That said, as you know, nine shooting and countryside organisations have been encouraging a voluntary move away from lead shot for live quarry shooting since February 2020.

As per the OP, BASC has told the HSE that we are opposed to restrictions on lead rifle ammunition and lead shot for target shooting; and that we are opposed to restrictions on lead airgun pellets for live quarry and target shooting. The risks are either nil to negligible or can be managed to be so.

There are two main exposure risks from lead ammunition. 

Firstly, lead shot poses a risk for birds where it is available for them to pick up as grit. Secondly, there is a risk to human health from game meat containing traces of lead ammunition entering the food chain.

We can reduce these risks if we accept the science (visit www.gwct.org.uk/lead for advice from the shooting sector's best scientists) and stop shooting with lead shot cartridges in the open countryside and if we stop shooting small and large game destined for the food chain with lead ammunition - where the availability and suitability of non-lead options make that feasible.

However, the choice of an evidence-based logical phased approach via a sector-led voluntary transition could be taken away from us as an option depending on the policy developments ahead.

The six months extension to the lead ammunition review is an opportunity for the HSE to change course and set out focused and proportionate proposals that target the risks for birds from lead shot and the risks for humans from game meat containing lead, whilst considering the real world issues with both the availability and unsuitability of non-lead options. 

Further red tape and regulation is not the only path and on such a complex environmental, social and economic issue a voluntary approach should be recommended and supported.

As previously stated by BASC a key principle is that further legal restrictions on lead ammunition must not be imposed until effective and affordable types of non-lead ammunition are available in sufficient volumes to meet demand. And where evidence-based, proportionate restrictions are proposed, it will be critical that appropriate transition periods are secured. These timelines must be realistic, and guided by the shooting sector, to ensure that the range of products and their supply can meet market demands.

The next stage in the lead ammunition review process will be the publication of a draft socio-economic opinion on the impact of the HSE proposals later this year, which will be open to public consultation for 60 days (hopefully we can encourage several thousand more responses than to last year's HSE 6 month public consultation)

The review will culminate in recommendations being submitted to the Secretary of State for Environment, Food and Rural Affairs for consideration.

Thereafter, a legislative proposal will likely be subject to parliamentary scrutiny and consultation with devolved administrations.

If BASC has concerns that the resulting legislative proposals are disproportionate and will damage shooting, we will lobby for them to be revised.

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15 hours ago, Conor O'Gorman said:

Thanks @rewulf your quip did make me smile.

A quip it may be , but as a so called 'defence' against a total lead ammunition ban, it may be worth mentioning.

Cacao beans and powder , marketed as a health food, do contain lead.
Chocolate , derived from said cacao, does contain lead.
Many cereal crops contain trace lead.
Farmed poultry that eats these cereal crops, end up containing lead.
Lead in water pipes, the country wide.
Lead additives for petrol in older cars.

I could go on, and there are those that may say , these are all only trace levels , but the HSE has decide there is no safe level for lead ?

Yet BASC has decided that the science is correct, and lead ammunition for live quarry needs to go, to protect the minute amount of the population who eat shot birds, despite their being definitive evidence of only trace quantities of lead in said birds, and no record whatsoever of any detrimental health issues in that small part of the populace who eat shot game of any description.
Even world wide, there is no evidence that people who , for all their lives, have eaten shot game, and have not suffered any issues.

By siding with the so called science, despite a few years previously refuting the science, you have opened a Pandoras box of problems for shooting, and I get a nagging feeling that this is NOT a mistake, but by design.

Such an important move on the part of yourselves at BASC , and other shooting orgs, should have come from a popular vote the membership, and the fact that no such vote was offered or discussed , leads me to that conclusion.

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17 hours ago, Conor O'Gorman said:

Thanks @rewulf your quip did make me smile.

That said, as you know, nine shooting and countryside organisations have been encouraging a voluntary move away from lead shot for live quarry shooting since February 2020.

As per the OP, BASC has told the HSE that we are opposed to restrictions on lead rifle ammunition and lead shot for target shooting; and that we are opposed to restrictions on lead airgun pellets for live quarry and target shooting. The risks are either nil to negligible or can be managed to be so.

There are two main exposure risks from lead ammunition. 

Firstly, lead shot poses a risk for birds where it is available for them to pick up as grit. Secondly, there is a risk to human health from game meat containing traces of lead ammunition entering the food chain.

We can reduce these risks if we accept the science (visit www.gwct.org.uk/lead for advice from the shooting sector's best scientists) and stop shooting with lead shot cartridges in the open countryside and if we stop shooting small and large game destined for the food chain with lead ammunition - where the availability and suitability of non-lead options make that feasible.

However, the choice of an evidence-based logical phased approach via a sector-led voluntary transition could be taken away from us as an option depending on the policy developments ahead.

The six months extension to the lead ammunition review is an opportunity for the HSE to change course and set out focused and proportionate proposals that target the risks for birds from lead shot and the risks for humans from game meat containing lead, whilst considering the real world issues with both the availability and unsuitability of non-lead options. 

Further red tape and regulation is not the only path and on such a complex environmental, social and economic issue a voluntary approach should be recommended and supported.

As previously stated by BASC a key principle is that further legal restrictions on lead ammunition must not be imposed until effective and affordable types of non-lead ammunition are available in sufficient volumes to meet demand. And where evidence-based, proportionate restrictions are proposed, it will be critical that appropriate transition periods are secured. These timelines must be realistic, and guided by the shooting sector, to ensure that the range of products and their supply can meet market demands.

The next stage in the lead ammunition review process will be the publication of a draft socio-economic opinion on the impact of the HSE proposals later this year, which will be open to public consultation for 60 days (hopefully we can encourage several thousand more responses than to last year's HSE 6 month public consultation)

The review will culminate in recommendations being submitted to the Secretary of State for Environment, Food and Rural Affairs for consideration.

Thereafter, a legislative proposal will likely be subject to parliamentary scrutiny and consultation with devolved administrations.

If BASC has concerns that the resulting legislative proposals are disproportionate and will damage shooting, we will lobby for them to be revised.

Conor the whole of NATO cannot keep up with the ammunition needs of ukraine, shotgun cartridges are already in short supply and going up and up in price but by magic you and the HSE consider a ban on lead shot is possible within two years, dream on.

 

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@rewulf there has been almost 3 years of consultation in the shooting sector so far on a voluntary transition away from lead shot for live quarry and the reasons for this - for birds and for people - which was outlined in my last post - and that is based on a review of the science (which is ongoing) by the shooting sector's best scientists at the GWCT at https://www.gwct.org.uk/lead

If you are a member of any shooting organisation, and you haven't already done so, please write to one or more of them with your views and suggestions as part of that ongoing consultation. 

If you have doubts about the science perhaps write to the GWCT with a list of your questions?

4 minutes ago, rbrowning2 said:

Conor the whole of NATO cannot keep up with the ammunition needs of ukraine, shotgun cartridges are already in short supply and going up and up in price but by magic you and the HSE consider a ban on lead shot is possible within two years, dream on.

 

BASC is fighting the HSE lead ammunition ban proposals.

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8 minutes ago, Conor O'Gorman said:

there has been almost 3 years of consultation in the shooting sector so far on a voluntary transition away from lead shot for live quarry and the reasons for this

I must have missed the membership vote then ?
The vote on which direction to go with this , when only a few years previously BASC and other organisations had fought hard on a possible lead ban?

Ive asked you this before, and youve never given an answer, what changed ?

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2 hours ago, Rewulf said:


Lead additives for petrol in older cars.
 

Indeed. If we apply the same logic as applies to the availability of leaded petrol for "classic cars" there should also be a ability to continue to buy and use lead shot in "vintage guns". Say those made before the recommended date for use of steel shot of post 1955 Rules of Proof made guns?

What percentage of such cars are used today against modern made cars as to the percentage of "vintage guns" as the numbers used relative to post-1955 Rules of Proof modern made guns? As a sample one could perhaps do a count of all s2 guns in a Holt's Sealed Bid sale?

I wrote this in my submission to DEFRA and I hoped that BASC and the CPSA might have also pushed on this.

The argument that these older guns can use bismuth is spurious, the Marie Antoinette position of "let them eat cake". For if bismuth is so expensive vis a vis leas as to be effectively unaffordable. So if similarly priced to lead alternative is not available for these "vintage guns" then it is a de facto ban. For taken to the ridiculous shooters could also use shot made from gold.

Edited by enfieldspares
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36 minutes ago, Rewulf said:

I must have missed the membership vote then ?
The vote on which direction to go with this , when only a few years previously BASC and other organisations had fought hard on a possible lead ban?

Ive asked you this before, and youve never given an answer, what changed ?

That was due to a change in strategic direction by the shooting organisations which was announced and explained in February 2020.

The following recent BASC blog post explains a bit more of the context for that:

https://basc.org.uk/uk-reach-where-are-we-now/

Are you signed up to BASC Live weekly email newsletter? If not feel free to sign up to keep up to date on not only policy developments on lead ammunition but much more.

https://basc.org.uk/basc-live/

If you are interested in face to face discussion with BASC and ammunition reps about your concerns and any suggestions on the voluntary transition and trying out a range of non-lead cartridges have a look at events ahead here:

https://events.basc.org.uk/events/

As regards BASC holding a membership vote - that is not how BASC sets strategy nor can I recall it ever doing so in that way in the 20 years I have worked there - strategic direction is set by BASC Council - we each as members elect members onto Council - and we can each as members attend AGMs. If you think BASC should set strategy differently perhaps you could attend an AGM if you have not done so previously?

BASC's 2020 AGM was on 11 July 2020, five months after the voluntary transition announcement. The event was online and open to any member to submit questions to, and to attend. There was only one question on the voluntary transition announcement.

At BASC's 2021 AGM there were no questions on the voluntary transition and I don't think there were any at the 2022 AGM either.

You can read BASC AGM minutes here:

https://basc.org.uk/agm/

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19 hours ago, Conor O'Gorman said:

Firstly, lead shot poses a risk for birds where it is available for them to pick up as grit.

Would like to know exactly what level of risk otherwise this is a meaningless statement. Clay grounds would be an obvious source of a very heavy density of shot on the ground and yet we do not find dead birds that have died of lead shot poisoning nearby. This would be particularly prevalent during the breeding season when birds are largely territorial yet has even one bird ever been found near a clay shoot that has died of this cause let alone the hundreds that would prove this hypothesis?

Secondly, there is a risk to human health from game meat containing traces of lead ammunition entering the food chain.

It is an ******* miracle I and thousands of others are still alive then as I have been eating lead shot game for over 50 years. Again whilst I do not challenge that there is a risk this is an unqualified statement where the level of risk needs stating.

Both of these statements are akin to me saying that 'cars are dangerous and will cause death and injury' therefore they should be gradually taken out of use.

I responded to the review quoting the evidence that is currently being used in New Zealand as I had absolutely no faith in our shooting organisations also using this evidence.

From you response

https://basc.org.uk/basc-response-to-uk-reach-lead-ammunition-consultation/

'There is clear evidence of risk of primary poisoning of birds from lead shot and of the human health risk from exposure to lead in game meat.

As above.

I searched for .410 hoping against hope that you would have listened to your members who use this calibre for pest control and proposed a possible exemption. .410 does not appear in BASC's response despite me personally giving you links to the evidence from NZ several years ago.

Then later in the response we get 

7. Thoroughly explore the uncertainty in the evidence in relation to secondary poisoning of birds from lead ammunition.

But you have written

'Firstly, lead shot poses a risk for birds where it is available for them to pick up as grit.'

And in the BASC response

'There is clear evidence of risk of primary poisoning of birds from lead shot'

it will not just be me that queries the inconsistency of BASC's position, it simply looks unprofessional, as though the response has been created without recourse to legal opinion.

Overall I am simply disappointed. I expected BASC to be more professional.

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Hi Conor when the lead shot ban for wildfowl became law wildflowers had arguments about lead shot, about lead pipes and lead flashing and soakers . When arguments changed to discussion it was about the effect on the wildfowl. The lead that they ingested and the (rubbish) steel cartridges that could wound them. We made better cartridges not to kill more wildfowl but to kill the birds cleanly. The discussion was about the welfare of the wildfowl. If fifty million pheasants are released each year and twenty five percent die before the shooting season starts, except for the birds seen dead on the road has anyone seen the rest of them. Five million wood pigeons in the country (somewhere) with a lifespan of three years. I don’t see dead pigeons all over the place. (From natural causes). Or any other birds. Why would anyone think that they would find dead migrating wildfowl  we can’t find the birds that died from bird flu.to some extent the numbers of wildfowl can be monitored  by web counts.I noticed more pigeon shooters using steel cartridges, l don’t think it’s anything to do with the environment, it’s to sell the pigeons they have shot.Falconers take pigeons shot with steel pellets for their birds again nothing to do with the environment it’s because lead pellets will kill the birds of prey. I’ve not seen any argument or discussion about this anywhere. Maybe members on this site could say why they changed to steel and do they still use lead for other shooting. The Olympic Games shot gun competitions used lead cartridges and had nets to collect the spent shot. If they didn’t use nets no shooting. Lead shot is regulated and will be more regulated. The shooting  industry must be unique in the way it uses lead and sells meat containing  lead. 

 

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37 minutes ago, Gas seal said:

The shooting  industry must be unique in the way it uses lead and sells meat containing  lead. 

 

Just as "unique" as the tobacco industry in the way it uses tobacco and sells products containing tobacco?

Which would be with a health warning on the products' packaging so that consumers can decide whether to buy it...having been informed of the risk...or choose not to buy it?

Or the nut industry sells foodstuffs containing nuts? By the use of labels advising the presence of nuts? Just as is presently done with shot game and lead shot?

Or any food industry any food product containing any of the other of the sixteen or so food allergens? Wheat, lactose, celery, eggs, molluscs, lupins, etc., etc.?

So not really that unique at all?

And to be blunt is there any other foodstuffs producer that wouldn't be recalled and it's production facility closed down if it were known to its products contained small pieces of steel or small fragments of copper?

If lead shot is banned then that....pieces steel or fragments of copper...as a continuing presence of metal debris in meat will be next vehicle of the attack by "the ban it brigade" on game shooting.

Edited by enfieldspares
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Hi we have had discussions about tobacco sales and other products and lots of different things containing lead when lead was banned. Most of them were smoking at the time. Tobacco products aren’t advertised and are sold from (under the counter) maybe game meat will be sold in the same way. That’s a business matter. Lead has already been banned for a long time, now it’s banned from the top shooting competitions unless it’s collected from the site. It was banned, agree or disagree, for its impact on the wildfowl and the environment. It wasn’t because wildfowl was sold containing lead pellets. The next vehicle of attack, for game shooting, is the sssi and other sites regarding pheasant release and shooting. A lot of people are looking at the condition , when they were last reviewed and what is happening on these sites. 

Hi Conor regarding lead shot exemptions for small gauge shotguns and air rifles for pest control. I use a moderated.410 and a moderated air rifle. It’s obviously to minimise disturbance. It’s recommended on the general licence to use moderated shotguns or firearms to reduce disturbance for nesting birds. I have used steel pellets in.410 but I wouldn’t fire them through a fully moderated.410 this could be a valid reason for exemption when using the general license. Bismuth would be to soft steel would be to hard. When BASC tested non lead air gun pellets did they test them with and without a moderator. When tested in 12 fb guns did you increase the power to see if they improved any. I tested them in .177 12fb I thought if I could increase the power a bit at a time it would have improved the pellets. I don’t have a fac air gun. I know some guns do have adjustable power .

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On 18/02/2023 at 17:03, 243deer said:

I responded to the review quoting the evidence that is currently being used in New Zealand as I had absolutely no faith in our shooting organisations also using this evidence.

From you response

https://basc.org.uk/basc-response-to-uk-reach-lead-ammunition-consultation/

'There is clear evidence of risk of primary poisoning of birds from lead shot and of the human health risk from exposure to lead in game meat.

As above.

I searched for .410 hoping against hope that you would have listened to your members who use this calibre for pest control and proposed a possible exemption. .410 does not appear in BASC's response despite me personally giving you links to the evidence from NZ several years ago.

Then later in the response we get 

7. Thoroughly explore the uncertainty in the evidence in relation to secondary poisoning of birds from lead ammunition.

But you have written

'Firstly, lead shot poses a risk for birds where it is available for them to pick up as grit.'

And in the BASC response

'There is clear evidence of risk of primary poisoning of birds from lead shot'

it will not just be me that queries the inconsistency of BASC's position, it simply looks unprofessional, as though the response has been created without recourse to legal opinion.

Overall I am simply disappointed. I expected BASC to be more professional.

BASC staff are aware of the various lead ammunition restrictions in force worldwide, including New Zealand. I don't recall BASC commenting on the use of restrictions in other countries in its consultation responses to date.

For 28 bore and smaller (including .410) BASC has requested extended transition periods. 

A summary of BASC's consultation response to last year's 6-month HSE consultation is here:

https://basc.org.uk/basc-response-to-uk-reach-lead-ammunition-consultation/

An example of primary poisoning is where birds ingest lead when they pick up lead shot as grit. There is evidence this is happening in the UK.

An example of secondary poisoning is where predators or scavengers ingest lead when they eat animals containing traces of lead ammunition. In its consultation response BASC stated that there was no UK evidence which provides a causal link between lead shot and lead poisoning leading to mortality or sub-lethal effects on predatory or scavenging species.

@Gas seal thanks for sharing your perspective and experience on the lead shot restrictions that came in over 20 years ago for wildfowling. Very useful context for us all to consider in the face of proposals for wider restrictions. I will raise your query about moderators with colleagues at BASC, I don't think BASC has raised this issue with HSE but other organisations may have.

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BREAKING NEWS! 

The British Association of Master Chocolatiers {BAMC} has just announced, without consulting its membership, that its going to go  forward with a voluntary phase out of cacao from all chocolate products nationwide, this is due to the minute chance that the lead in cacao might harm you or your dog. 

The industry has been informed, and they have 5 years or less to find an alternative, in many cases though, there simply isn't one, so you all have to have sickly white chocolates, or none. 

There are unconfirmed reports that the water companies cannot guarantee lead free content in water, so they too must stop supplying you shortly. 

Remember kids, there is no safe level of lead, so it's best to be on the safe side, and ban it all. 

 

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14 hours ago, 243deer said:

Please may we have links to the published scientific papers?

Sure. Let's start with grey partridge.

A GWCT study published in 2005 found that 4.5% of discovered dead birds contained lead shot in their gizzards and estimated that 1.2% of living wild grey partridges contained ingested lead shot at any one time.

Potts, G.R. (2005). Incidence of ingested lead gunshot in wild grey partridges (Perdix perdix) from the UK. European Journal of Wildlife Research, 51:31–34.

https://link.springer.com/article/10.1007/s10344-004-0071-y

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Hi I was watching an international top class shooting competition on tv . I noticed fine nets in the background it was to collect spent shot. Lead shot was banned from the site, I think it was Birmingham were the competition was. I’ve also seen nets in the USA shooting competitions. I’m sure the clay shooters will know about it. Its not the first time, or the last time this will happen. No doubt the HSE will point this out to target shooters. 
hi Conor I doubt anyone has raised the issue of moderators with the HSE I don’t think anyone has noticed it on the general license. It’s  also applicable to.22 rime fire. I have tested and used non lead pellets in.177 for the range of my air rifle they will work. I’ve not seen or used any non lead.22 rime fire rounds. Rime fire.22 that are used for pest control most will have a moderator fitted. I doubt if any lead would remain in the animal or birds shot , unless from segmented rounds. The spent round would be to large to be picked up by birds for grit .if birds ingest lead pellets it won’t kill them outright, it’s a poison like it or not. The long term problem could be addled eggs or chicks not surviving. We have a license for pest control, moderated firearms are part of the license. The way I see it is moderated fire arms should be exempted from any legation regarding lead. I think that’s a good response for some of the shooting I do. 

 

 

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8 minutes ago, Gas seal said:

Hi I was watching an international top class shooting competition on tv . I noticed fine nets in the background it was to collect spent shot. Lead shot was banned from the site, I think it was Birmingham were the competition was. I’ve also seen nets in the USA shooting competitions. I’m sure the clay shooters will know about it. Its not the first time, or the last time this will happen. No doubt the HSE will point this out to target shooters. 
hi Conor I doubt anyone has raised the issue of moderators with the HSE I don’t think anyone has noticed it on the general license. It’s  also applicable to.22 rime fire. I have tested and used non lead pellets in.177 for the range of my air rifle they will work. I’ve not seen or used any non lead.22 rime fire rounds. Rime fire.22 that are used for pest control most will have a moderator fitted. I doubt if any lead would remain in the animal or birds shot , unless from segmented rounds. The spent round would be to large to be picked up by birds for grit .if birds ingest lead pellets it won’t kill them outright, it’s a poison like it or not. The long term problem could be addled eggs or chicks not surviving. We have a license for pest control, moderated firearms are part of the license. The way I see it is moderated fire arms should be exempted from any legation regarding lead. I think that’s a good response for some of the shooting I do. 

 

 

nets work for clay shooting trap disciplines but impossible for english sporting and FITASC where target can be in woodland settings. Also very doubtful most clubs could afford for such netting to be installed even if it was possible.

 

Edited by rbrowning2
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Aside from the unduly high lead content of certain chocolate products( which has largely been ignored) I have not seen any mention of the lead content in many agricultural crop spray chemicals. How much environmental contamination ensues from spray application and the subsequent washing out of the spraying appliances?

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