HSE final lead ammunition consultation launched

[Conor O'Gorman]

Today, the Health and Safety Executive has launched its final public consultation on lead ammunition restriction proposals, which runs until 10 December. BASC is reviewing the documentation and will publish guidance on responding to the consultation in the next few days.

https://consultations.hse.gov.uk/crd-reach/lead-in-ammunition/

 

[rbrowning2]

So lead shot prohibited within five or possibly two years for live quarry, no exemption for .410 or 28ga.

The industry is already struggling with high prices and lack of products, shooting will die a death except for the very wealthy.

Edited October 11, 2023 by rbrowning2

[Fellside]

1 hour ago, rbrowning2 said:

no exemption for .410 or 28ga.

Hi rbrowning2,

Have you heard anything about these small bores? I understood there was a potential derogation for the 410.

[Scully]

1 hour ago, rbrowning2 said:

So lead shot prohibited within five or possibly two years for live quarry, no exemption for .410 or 28ga.

The industry is already struggling with high prices and lack of products, shooting will die a death except for the very wealthy.

There can be no exemptions at all, given the reasons it is claimed the lead shot ban will address. 

[enfieldspares]

I have cut and pasted this from the linked document. What must not be allowed is this proposal that a self selected coterie of so called "international athletes" be exempted from the restrictions.

I hope that all here will write to their MP and that the shooting organisations will also lobby to the effect that:

1) There must be no Animal Farm where some are more equal than others. If there is to be a ban on lead shot for outdoor target shooting then let it be a ban for all.

THAT AS THIS MEASURE IS FOR THE WIDER BENEFIT THE INDIVIDUAL SHOOTER MUST BE COMPENSATED FOR THE COST THEY WILL INCUR AND THIS MUST ALSO INCLUDE THE COST OF ALTERING ANY GUN BY REBORING THE CHOKE AND/OR FORCING CONES AND REPROOF. THAT IF THE GUN THEN FAILS REPROOF THEN COMPENSATION FOR THE COST OF SUCH WORK PLUS THE VALUE OF THE NOW FAILED PROOF GUN MUST BE PAID.

2) There must be compensation where shooters may surrender to the police lead shot ammunition and be paid in full the replacement cost of non-lead ammunition that is suitable in any gun that they possess lawfully that cannot use steel ammunition

3) That there must be compensation where shooters may surrender to the police shotguns and be paid a fair compensation value for any shotgun that cannot use steel ammunition - such as damascus barrel guns, vena contracta guns, .22 Rimfire and 9mm Rimfire shotguns, other guns where steel cannot safely be used in that gun.

IF THIS CANNOT BE AGREED TO THEN ON THE SAME BASIS AS THERE BEING A DEROGATION FOR ATHLETES THERE MUST BE A DEROGATION FOR SUCH GUNS WHICH AS ALL ARE LISTED ON A HOLDER'S SGC COULD BE DONE BY MARKING SUCH WITH AN ASTERISK. So that if stopped by any authorities with such gun and lead ammunition the SGC need merely be shown with that asterisk against that gun.

ANYWAY HERE IS WHAT I HAVE CUT AND PASTED:

The Agency for UK REACH concludes that:
• for the environment there are risks that are not adequately controlled forlead shot (primary and secondary exposure), lead bullets (secondaryexposure) and airgun ammunition (primary and secondary exposure)
• amongst consumers of high volumes of game meat that has been shot with lead ammunition (shot or bullets), there is a risk to the health of vulnerable people (young children and women of child-bearing age) that isn ot adequately controlled.

Therefore, the Agency is recommending measures to restrict the use and placing on the market of some types of lead ammunition.
Live quarry shooting (LQS)1 Live quarry shooting with shot - Restriction on the placing on the market and use
Outdoor target shooting (TS)4 Outdoor target shooting with shot - Restriction on the placing on the market and use, with a derogation for individual athletes as identified by the appropriate sporting body
When used for target shooting, lead shot will remain on the surface of the ground where there is a risk of primary poisoning to birds and livestock unless it is immediately collected, which is not considered practical based on information received from ranges during the public consultation on the Annex 15 dossier (HSE,2022).

Similarly, risk management measures are not available at most ranges tomanage the risks to soil and to livestock via secondary poisoning from target shooting.

The most effective risk management option is prohibition on the placing on the market and use of lead shot. By restricting the placing on the market of lead shot for all uses (i.e., both live quarry shooting and target shooting), the effectiveness and compliance of this restriction is increased and subsequent enforcement simplified.
Several UK shooting and rural organisations have voluntarily committed to the use of alternatives to lead shot for live quarry shooting by 2025.

The Agency is aware that the use of lead shot is specified for international competitions in some outdoor target shooting disciplines.

A derogation is proposed to allow individual athletes as identified by the appropriate sporting body to continue to train and compete with lead shot, and suppliers to continue sales of lead shot to these identified athletes.

Transition periods
A transition period for the placing on the market and use of lead shot cartridges of 5years is proposed.

This is based on information provided by manufacturers on reasonable timescales required to scale up production to replace the amount of lead shot currently on the market. This transition period would apply to all uses of lead shot.

Existing voluntary commitments by several UK shooting and rural organisations to use alternatives to lead shot by 2025 for live quarry shooting could still reduce the risks arising from this use during this period, although the Agency notes that these voluntary commitments were not supported by shot manufacturers, who indicated that 2025 would not be achievable for them.
As such, the intended outcomes of the proposed restriction text are outlined below:

- The use of lead shot for live quarry shooting would be prohibited.
- The use of lead shot for target shooting would be prohibited.
However, a derogation will allow for a small number of athletes, as identified by the appropriate sporting body (for example British Shooting), that are required to continue shooting lead shot for the purposes of international competition and training.
- The sale or trade of lead shot (for a price or otherwise) would be prohibited.
However, a derogation will allow for those athletes referenced above to continue to source the lead shot required for international competition and training.

4.4.2.1.1 Shooter substitution costs
The Agency anticipates that, under a restriction on LQS with lead shot, a variety of costs would occur directly to shooters in moving away from lead shot to alternative shot. These costs can be classified as either one-off or on-going costs.
The Agency assumes that all shotguns in current use that can use steel shot do use it in the event of restriction. Steel shot has a significantly lower unit price than bismuth shot (and slightly lower than lead shot), in addition to performing similarly to lead. As such, the Agency does not see a rationale for a shooter choosing bismuth shot if they are able to use steel in their gun(s).
The Agency assumes that 73% of shotguns in use can instantly switch to(standard) steel shot without modification or re-proof.
Additionally, the Agency assumes that a further 5% of shotguns in use could use steel shot following modification.

4.4.2.1.3 Climate impacts
The Agency uses emissions factors (EF) provided by the Bureau of International Recycling (BIR, (2008)) to estimate the resulting change in greenhouse gas (GHG)emissions from a transition from lead shot to alternatives.
The worst-case scenario in terms of climate impacts is one where lead shot, under the baseline, is domestically produced entirely from recycled lead, and under a restriction steel shot is produced from 100% primarily produced steel imported from afar (presumed to be China based on information submitted by Blake International,2022 Organisation #132) (Hurley, 2022).
Under this worst-case scenario, the Agency estimates that a restriction will result in 2,239t CO2/annum compared to 286t CO2/annum under the baseline (from 2025onwards). This equals an annual addition of 1,954t CO2, roughly equal to the average annual carbon footprint of 210 UK citizens (WWF, 2023).
Derogations have been proposed to allow identified athletes to train and compete without obstruction. However, others who aspire to reach that level could be hampered by the inability to train with lead shot which is required for use in international competitions. The Agency will continue to engage with the relevant sporting bodies which are responsible for the selection of the athletes, to help ensure that the correct balance between environmental protection and competitive British shooting is maintained.

It is expected that there will be occasions where GB host international competitions(such as the Olympics) whereby overseas competitors will be required to shoot lead.For these short and infrequent periods of time, the relevant sporting bodies are likely to temporarily specify more athletes under the derogation.

4.6 Potential unintended consequences
It could be a transition period does not give time to gain access to replacement shot before the use of lead shot is restricted. Those using shot will have to stop shooting instead of running the risk of buying lead ammunition which they will be unable to use within a certain time period, or else be out of pocket for this ammunition.

Edited October 11, 2023 by enfieldspares

[rbrowning2]

1 hour ago, Fellside said:

Hi rbrowning2,

Have you heard anything about these small bores? I understood there was a potential derogation for the 410.

No exemptions for lead shot regardless.  .410 will become obsolete unless you can afford to shoot bismuth or tungsten based shot.

Probably true also for the 28gauge, 24gauge and 32gauge that are still used by some.

Clay shooting has been a victim of the fact that they know that without a total lead ban then lead will still be used on live quarry, yet clay grounds operate within well defined areas with virtually zero risk to flora and fauna or people.

Going to be boom or bust for shooting, I fear the latter 

[udderlyoffroad]

Sorry,  @enfieldspares your rather ridiculous approach, viz. "Well if I can't have it nobody should" - is not, I'd suggest, a shining example of gamesmanship.  In any case it lacks consistency let alone practicality.  An asterisk printed on your SGC?  The licencing departments wouldn't cope with the 'reprints' of licences needed, let alone the process of identifying what would constitute an asterisk-able gun.

Far better would be to wait for BASC's guidance on the response, as well as similar guidance on what to write to your MP*.  Apparently the HSE received less than 3000 responses to the initial consultation.   That is frankly embarrassing.  They should've received one from every licence holder in the country.  Let's not make that mistake again.

This 'precautionary principle' the HSE is wedded to, might make sense for as-yet-unknown quantities such PFAS chemicals, but it is pure nanny state for substances that are, after all on the periodic table, that man has used for thousands of years.

*Not a template letter, those get binned quickly.

[enfieldspares]

12 minutes ago, udderlyoffroad said:

Sorry,  @enfieldspares your rather ridiculous approach, viz. "Well if I can't have it nobody should" - is not, I'd suggest, a shining example of gamesmanship.  In any case it lacks consistency let alone practicality.  An asterisk printed on your SGC?  The licencing departments wouldn't cope with the 'reprints' of licences needed, let alone the process of identifying what would constitute an asterisk-able gun.

 

I cannot agree. I saw this when pistols were banned this attempt to create some who were to be granted a privilege denied to everybody else. Far better is these international sportsmen instead protested a ban rather than take the "I'm alright Jack" benefit as a sop for them to remain silent. It isn't at all gamesmanship it is fairness. This lead shot toxicity isn't any less toxic if fired from the gun of an Olympic shooter or Commonwealth Games shooter.

And identifying such guns would be easy. This was done with pre-1919 pistols and could be done...the evidence is on the gun with the Proof Marks stamped on it...pre-1954 Rules of Proof guns. The timetable is five years. All existing certificates will be renewed by then so when the guns are inspected at that renewal they could be checked by reading the Proof Marks that on many guns are in fact adjacent to the serial number that would in any case be checked.

Edited October 11, 2023 by enfieldspares

[rbrowning2]

I am with enfieldspares on this issue, it’s not practical or sustainable, what happens going forward the 50 athletes retire or die who will be able to replace them, nobody. Then the practical side of it, George Digweed did not just practice at one clay ground only in the U.K. to become the athlete he is today, then cartridge manufactures who will bother to make a tiny number of lead cartridges, they will become very expensive to produce as cartridge manufacturing is about volume, big numbers not a few hundred thousands or even a million or two. Then the cost of licensing a grounds to allow  just 50 athletes to use lead shot  why would a ground owner want to take a financial hit on that when it has such a poor opportunity to recover the costs associated with it.

If (or now when) they ban lead they ban it for all.

 

[udderlyoffroad]

Respectfully, stop fighting the battles from the '90s and concentrate on the problem in hand in 2023.*

Anyway, giving away your compromise position is poor gamesmanship, and utterly defeatist.   We must respond to the consultation by pointing out how entirely disproportionale it is to the risk posed, and certainly massively out-of-step with other nations.

 

14 minutes ago, enfieldspares said:

so when the guns are inspected at that renewal they could be checked by reading the Proof Marks that on many guns are in fact adjacent to the serial number that would in any case be checked.

Further proof that you're really dwelling in the past there...guns inspected at renewal?  When was that last 'a thing'?  You really haven't grasped the administrative headache of what your proposing.

 

*Though I would certainly agree the "I'm alright Jack" attitude of SGC holders contributed to the pistol ban, but Cherie Blair did for pistols, not disorganised response from organisations.  Wonder if someone should take Starmer's missus shooting?

[Fellside]

Still confused.com 

Where does the absolute assurance that a total ban (including 410 lead cart’s) will actually happen?

I know these are the stated aims of the HSE, however their proposals at the moment are just that - proposals. Unless I’ve missed something….. I may have done. I am aware that our orgs are pushing hard for necessary derogations, so the outcomes, I believe, are far from certain. I remain a ‘glass half full’ optimist until (or unless!) the 410 becomes extinct. 🤞

[rbrowning2]

5 minutes ago, Fellside said:

Still confused.com 

Where does the absolute assurance that a total ban (including 410 lead cart’s) will actually happen?

I know these are the stated aims of the HSE, however their proposals at the moment are just that - proposals. Unless I’ve missed something….. I may have done. I am aware that our orgs are pushing hard for necessary derogations, so the outcomes, I believe, are far from certain. I remain a ‘glass half full’ optimist until (or unless!) the 410 becomes extinct. 🤞

you can live in hope, but if the derogation is not in the HSE proposal it is very unlikely it will happen, and if it does for .410 then why not 28gauge?  and we can all swap to using .410 and 28gauge and keep lead shot.

However even if you got your derogation the price of lead cartridges would increase significantly, read the document they even considered a TAX on lead cartridges to encourage the movement away from lead.

We can only hope when the bill becomes before parliament it runs out of time, is delayed due to the general election or is voted down by all the MPs that own very expensive fine english shotguns.

[Scully]

1 hour ago, udderlyoffroad said:

  Apparently the HSE received less than 3000 responses to the initial consultation.   

Less than 1% if my maths are right. 😂

We truly get what we deserve. 

[udderlyoffroad]

28 minutes ago, rbrowning2 said:

We can only hope when the bill becomes before parliament it runs out of time, is delayed due to the general election or is voted down by all the MPs that own very expensive fine english shotguns.

It’s not a bill & it doesn’t need to go through parliament!
 

That’s why everyone must respond to the consultation 

[enfieldspares]

12 minutes ago, udderlyoffroad said:

It’s not a bill & it doesn’t need to go through parliament!
 

That’s why everyone must respond to the consultation 

Correct! We need to get writing!

[Mice!]

I can understand people on here being concerned firstly with how shotguns are affected,  but it is at least good news for airguns and 22lr/ HMR

[Fellside]

2 hours ago, rbrowning2 said:

you can live in hope, but if the derogation is not in the HSE proposal it is very unlikely it will happen, and if it does for .410 then why not 28gauge?  and we can all swap to using .410 and 28gauge and keep lead shot.

However even if you got your derogation the price of lead cartridges would increase significantly, read the document they even considered a TAX on lead cartridges to encourage the movement away from lead.

We can only hope when the bill becomes before parliament it runs out of time, is delayed due to the general election or is voted down by all the MPs that own very expensive fine english shotguns.

I can understand your reasoning, however it would seem that we don’t have a done deal yet. We are still in ‘anything could happen’ territory. Trying to remain positive here….. 🙂. I did hear a whisper, from a fairly good source that the 410 might be spared and that this is being pursued. Like you however I am cautious, but I am also hopeful. As much as we all like to indulge in speculation, predicting the future is very difficult, especially where politics are concerned. 

[udderlyoffroad]

3 minutes ago, Fellside said:

predicting the future is very difficult, especially where politics are concerned.

Once again, there are no politicians involved in this decision.  There is no bill to put before parliament, nor minister to approve this.

The HSE is acting unilaterally, under powers given to it as a result of Brexit*.

 

*Yes we'd be in a similar boat, but have even less say in the matter, were we still in the EU.  That said, the fact that EU Reach appears to be rowing back from a total lead ban might help our case.

[grahamch]

Why don't folk move with the times and accept change is coming and get on with it?

They have used steel shot on the continent for years for clays and game without too many issues. 

If we want the sport to survive then maybe we have to move on and evolve?

The three Wigeon and a Pintail I got on the shore on Friday were shot at a sporting range with steel 4s through my 690-3 and stone dead.

 

 

 

Edited October 11, 2023 by grahamch

[Fellside]

1 hour ago, udderlyoffroad said:

Once again, there are no politicians involved in this decision.  There is no bill to put before parliament, nor minister to approve this.

The HSE is acting unilaterally, under powers given to it as a result of Brexit*.

 

*Yes we'd be in a similar boat, but have even less say in the matter, were we still in the EU.  That said, the fact that EU Reach appears to be rowing back from a total lead ban might help our case.

Yes I understand the process and the point you make. My reference to politics was the ‘political environment’ which always has an effect of sorts. 

Still we speculate…..?! 

[rbrowning2]

1 hour ago, Fellside said:

I can understand your reasoning, however it would seem that we don’t have a done deal yet. We are still in ‘anything could happen’ territory. Trying to remain positive here….. 🙂. I did hear a whisper, from a fairly good source that the 410 might be spared and that this is being pursued. Like you however I am cautious, but I am also hopeful. As much as we all like to indulge in speculation, predicting the future is very difficult, especially where politics are concerned. 

Not sure, think the proposal is a done deal, may be Conor will know, but as i read the following HSE statement the risk assessment that has resulted in the proposal is not up for negotiation. 

 

Please note that this consultation seeks information on socioeconomic factors that need to be taken into account. We are not seeking comments on aspects of the risk assessment (in particular sections 4.1 and 4.7.1). The draft Background Document, an updated version of the Annex 15 dossier previously consulted on, is also being made available for reference.

 

https://consultations.hse.gov.uk/crd-reach/lead-in-ammunition/

 

[rbrowning2]

1 hour ago, grahamch said:

Why don't folk move with the times and accept change is coming and get on with it?

They have used steel shot on the continent for years for clays and game without too many issues. 

If we want the sport to survive then maybe we have to move on and evolve?

The three Wigeon and a Pintail I got on the shore on Friday were shot at a sporting range with steel 4s through my 690-3 and stone dead.

 

 

 

Without too many issues?

In 2014, Norway reintroduced lead shot for live quarry hunting outside wetlands after a lengthy campaign by the Norwegian Association of Hunters and Anglers. Their argument at the time described the lack of risk, away from wetlands, associated with the predominantly low-density type of shooting that takes place in Norway.

Then Denmark has a big problem with plastic wad pollution on the foreshore.

For 12gauge then so be it, but not everyone shoots a 12gauge.

 

[Fellside]

16 minutes ago, rbrowning2 said:

Not sure, think the proposal is a done deal, may be Conor will know, but as i read the following HSE statement the risk assessment that has resulted in the proposal is not up for negotiation. 

 

Please note that this consultation seeks information on socioeconomic factors that need to be taken into account. We are not seeking comments on aspects of the risk assessment (in particular sections 4.1 and 4.7.1). The draft Background Document, an updated version of the Annex 15 dossier previously consulted on, is also being made available for reference.

 

https://consultations.hse.gov.uk/crd-reach/lead-in-ammunition/

 

Yes you make a fair point rbrowning2. Call me over optimistic if you like, but if the consultation has any worth whatsoever (and I know this is questionable) the draft proposal has to be open to change. It may well be that the ‘socioeconomic’ opinions they seek could become relevant. It will be interesting to read the BASC response. 

[jan8p]

The consultation survey is a joke.  They propose banning all lead shot, including clays, yet all their questions are around live quarry and expanding ammunition.  They don't want to make it easy to count those who object to banning for target shooting.

[Conor O'Gorman]

BASC update here:

www.basc.org.uk/new-consultation-launched-on-lead-ammunition/