HSE final lead ammunition consultation launched

[rbrowning2]

1 hour ago, Scully said:

With the greatest respect ( because it seems like Groundhog Day with this topic ) there is NO difference between a steel shot proofed gun and a nitro proofed gun. 
Can anyone tell me what the difference is from a manufacturing point of view, or what you can do with a steel shot proofed gun that you can’t with a nitro proofed gun? 
 

Steel shot proofed guns are proofed to a higher pressure than a standard nitro proofed guns, so proof testing is done at a higher pressure.

standard steel cartridges, if they are to be fired from standard proof shotguns (i.e. those proved to 960 bar (transducer) or, previously, 850 bar (crusher)), or magnum proof shotguns (i.e. those proved to 1370 bar (transducer) or, previously, 1200 bar (crusher)) must not exceed the maximum admissible service pressure of 74 MPa (new units megapascals, in place of the old 740 bar) specified by the CIP and measured by means of a piezo-electric transducer.

 

High performance cartridges, whether 12/70 or 12/73 and longer (i.e. 12 bore cartridges for 70 mm (2 3/4in) or 73 mm chambers), can only be fired from 12 bore guns specially designed to fire steel shot ammunition and bearing the Steel Shot proof mark (this includes the words: Steel Shot and a Fleur de Lys ).

They must all observe the maximum admissible service pressure of 105 MPa (1,050 bar (transducer)). 

Shooting 1050 bar high performance cartridges in a standard nitro proofed gun designed for 740bar cartridges could damage the gun especially in the choke area of the barrel.

 

Edited November 3, 2023 by rbrowning2

[8 shot]

I spoke to two Cartridge manufactures when this first came out, one quoted "The pressure in steel cartridges have to be higher to get the performance to make them anywhere near affective for the british market. And when asked about the risk of using HP cartridges in Non HP guns he "You wouldn't over inflate your car tyres would you, you can, but you just wouldn't"

[Conor O'Gorman]

Thanks @PeterHenry @jall25 and @stockybasher for posting that you responded to the consultation.

As regards some of the other recent comments the following background might help:

There would be no review of lead ammunition by the Health and Safety Excutive (HSE) if it wasn’t for Brexit because the government needed to create new laws on the regulation of chemicals so that the trade in chemicals between GB and EU could continue (Northern Ireland trade being covered under the NI Protocol)

The HSE was tasked as the agency responsible for the implementation of the regulations (called UK REACH) and in 2021 it was announced that the first two substances to be reviewed would be lead in ammunition and certain chemicals in tattoo inks: emulating similar reviews in the EU.

The approach the HSE has taken, and is taking with many other reviews, is looking at the risks and investigating where it is feasible to reduce those risks to a ‘nil or negligible’ level.

The HSE does not create laws, it can only make recommendations and submit these to the Defra secretary of state for consideration. 

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

How to respond to the consultation

The survey response form contains mostly technical and confusing questions. However, there is a shortcut and it will take less than five minutes of your time.

Just skip to the last section of the survey and in ‘general comments’ tell them, in your own words, what you think about a lead ban proposals based on your own shooting interests and experience. 

Click the link below to complete the 'general comments' section of the HSE survey response form:

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

[Scully]

2 hours ago, rbrowning2 said:

Steel shot proofed guns are proofed to a higher pressure than a standard nitro proofed guns, so proof testing is done at a higher pressure.

standard steel cartridges, if they are to be fired from standard proof shotguns (i.e. those proved to 960 bar (transducer) or, previously, 850 bar (crusher)), or magnum proof shotguns (i.e. those proved to 1370 bar (transducer) or, previously, 1200 bar (crusher)) must not exceed the maximum admissible service pressure of 74 MPa (new units megapascals, in place of the old 740 bar) specified by the CIP and measured by means of a piezo-electric transducer.

 

High performance cartridges, whether 12/70 or 12/73 and longer (i.e. 12 bore cartridges for 70 mm (2 3/4in) or 73 mm chambers), can only be fired from 12 bore guns specially designed to fire steel shot ammunition and bearing the Steel Shot proof mark (this includes the words: Steel Shot and a Fleur de Lys ).

They must all observe the maximum admissible service pressure of 105 MPa (1,050 bar (transducer)). 

Shooting 1050 bar high performance cartridges in a standard nitro proofed gun designed for 740bar cartridges could damage the gun especially in the choke area of the barrel.

 

Twaddle, especially this….’can only be fired from 12 bore guns specially designed to fire steel shot…..’ If that were true no nitro proofed guns could be submitted for HP steel shot proofing, (  and many are ) and none of it plays a specific part in the design; nitro proofed guns are designed and manufactured no differently from those proofed for steel; the only difference being the rate of proofing. However, none of that has anything to do with the manufacturing process; proofing takes place AFTER manufacturing. Proofing is not inbuilt. 
 

2 hours ago, 8 shot said:

I spoke to two Cartridge manufactures when this first came out, one quoted "The pressure in steel cartridges have to be higher to get the performance to make them anywhere near affective for the british market. And when asked about the risk of using HP cartridges in Non HP guns he "You wouldn't over inflate your car tyres would you, you can, but you just wouldn't"

That last paragraph is simply absolute rubbish! I’m sorry, but it just is. 
As I’ve already stated, if it were true then no one would be submitting nitro only proofed guns for steel shot proofing. 

[Scully]

1 hour ago, Conor O'Gorman said:

Thanks @PeterHenry @jall25 and @stockybasher for posting that you responded to the consultation.

As regards some of the other recent comments the following background might help:

There would be no review of lead ammunition by the Health and Safety Excutive (HSE) if it wasn’t for Brexit because the government needed to create new laws on the regulation of chemicals so that the trade in chemicals between GB and EU could continue (Northern Ireland trade being covered under the NI Protocol)

The HSE was tasked as the agency responsible for the implementation of the regulations (called UK REACH) and in 2021 it was announced that the first two substances to be reviewed would be lead in ammunition and certain chemicals in tattoo inks: emulating similar reviews in the EU.

The approach the HSE has taken, and is taking with many other reviews, is looking at the risks and investigating where it is feasible to reduce those risks to a ‘nil or negligible’ level.

The HSE does not create laws, it can only make recommendations and submit these to the Defra secretary of state for consideration. 

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

How to respond to the consultation

The survey response form contains mostly technical and confusing questions. However, there is a shortcut and it will take less than five minutes of your time.

Just skip to the last section of the survey and in ‘general comments’ tell them, in your own words, what you think about a lead ban proposals based on your own shooting interests and experience. 

Click the link below to complete the 'general comments' section of the HSE survey response form:

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

When Shifty was head honcho ( when all this was mooted first time around but BASC challenged it ) didn’t the FSA state that the risks of eating lead shot game as part of a normal diet were negligible? 

[rbrowning2]

22 minutes ago, Scully said:

Twaddle, especially this….’can only be fired from 12 bore guns specially designed to fire steel shot…..’ If that were true no nitro proofed guns could be submitted for HP steel shot proofing, (  and many are ) and none of it plays a specific part in the design; nitro proofed guns are designed and manufactured no differently from those proofed for steel; the only difference being the rate of proofing. However, none of that has anything to do with the manufacturing process; proofing takes place AFTER manufacturing. Proofing is not inbuilt. 
 

That last paragraph is simply absolute rubbish! I’m sorry, but it just is. 
As I’ve already stated, if it were true then no one would be submitting nitro only proofed guns for steel shot proofing. 

The grade of steel used and its conditioning after machining in current barrels and chocked used for High performance proofed cartridges may be completely different to that use in guns prior to the introduction of HP steel cartridges. The proof process is about safety and margins of safety yes you can submit your old browning A1 for steel proofing depending on its current barrel wall thickness it may pass or may fail many guns may be submitted how many pass and how many fail?  HP steel proofing was obviously decided necessary by the industry for safe use of HP steel cartridges.

technology moves on.

 

 

[Conor O'Gorman]

22 hours ago, Scully said:

When Shifty was head honcho ( when all this was mooted first time around but BASC challenged it ) didn’t the FSA state that the risks of eating lead shot game as part of a normal diet were negligible? 

Putting to one side the unnecessary disrespectful reference to a former BASC staff member juxtaposed with your question to me, my recollection is the same for the FSA advice, and they currently advise against frequent consumption of lead-shot game by toddlers, children, pregnant women and women trying for a baby. 

In response to the HSE lead ban proposals BASC has stated that there is no need for further regulation in this area given that shooting organisations remain committed to the voluntary transition away from lead shot and single use plastics for shotguns used in live quarry shooting.

I know you are fully aware of this, but for those less aware, the organisations that announced their support for the voluntary transition away from lead shot and single use plastics for shotguns used in live quarry shooting are:

• BASC 
• British Game Alliance
• Countryside Alliance
• Country Land and Business Association
• Game and Wildlife Conservation Trust
• The National Gamekeepers’ Organisation
• The Moorland Association
• Scottish Land & Estates
• The Scottish Association for Country Sports

[Scully]

29 minutes ago, Conor O'Gorman said:

Putting to one side the unnecessary disrespectful reference to a former BASC staff member juxtaposed with your question to me, my recollection is the same for the FSA advice, and they currently advise against frequent consumption of lead-shot game by toddlers, children, pregnant women and women trying for a baby. 

In response to the HSE lead ban proposals BASC has stated that there is no need for further regulation in this area given that shooting organisations remain committed to the voluntary transition away from lead shot and single use plastics for shotguns used in live quarry shooting.

I know you are fully aware of this, but for those less aware, the organisations that announced their support for the voluntary transition away from lead shot and single use plastics for shotguns used in live quarry shooting are:

• BASC 
• British Game Alliance
• Countryside Alliance
• Country Land and Business Association
• Game and Wildlife Conservation Trust
• The National Gamekeepers’ Organisation
• The Moorland Association
• Scottish Land & Estates
• The Scottish Association for Country Sports

You only gain respect where it is deserved, and he certainly doesn't deserve it as far as I’m concerned.
I sat through a BASC audience with Swift many moons ago, at the Shepherds Inn, Carlisle, where he tried to convince everyone there that wildfowl were dying in droves via the absorption of lead shot. No one believed him and several told him so in very clear terms, with some asking where they all were, if that were the case. Swift replied that it was rare to find dead animals in the wild as carcasses were soon disposed of by other wild animals, a reply to which the same person asked ‘well if that’s the case how does anyone know how many are dying?’ Bit of an awkward silence after that one admittedly. 
Shooting organisations may well be committed to a voluntary transition away from lead shot, but I don’t know of anyone who is equally committed, organisation member or not. 
Every single shooter I know has stated they will use lead until it is no longer available. 

[Weihrauch17]

24 minutes ago, Scully said:

You only gain respect where it is deserved, and he certainly doesn't deserve it as far as I’m concerned.
I sat through a BASC audience with Swift many moons ago, at the Shepherds Inn, Carlisle, where he tried to convince everyone there that wildfowl were dying in droves via the absorption of lead shot. No one believed him and several told him so in very clear terms, with some asking where they all were, if that were the case. Swift replied that it was rare to find dead animals in the wild as carcasses were soon disposed of by other wild animals, a reply to which the same person asked ‘well if that’s the case how does anyone know how many are dying?’ Bit of an awkward silence after that one admittedly. 
Shooting organisations may well be committed to a voluntary transition away from lead shot, but I don’t know of anyone who is equally committed, organisation member or not. 
Every single shooter I know has stated they will use lead until it is no longer available. 

This respect is earned, Swift had zilch.  As for all the org's signing up to shaft their members (with no consultation)  they all deserve to dwindle to nothing supporting only the big shoots and absolutely nobody else.  Birds going into the food chain shoot with tooth breaking steel it's not hard and needn't effect everything, (how many actually are) the rest of us wish you to go forth and multiply and leave us alone to get on with things as we have done for hundreds of years with nobody ever dying from ingesting Lead Shot.  The whole thing is farcical and blatantly political to lessen gun ownership whilst supporting the rich who can afford this garbage.  

Edited November 4, 2023 by Weihrauch17

[yickdaz]

30 minutes ago, Scully said:

You only gain respect where it is deserved, and he certainly doesn't deserve it as far as I’m concerned.
I sat through a BASC audience with Swift many moons ago, at the Shepherds Inn, Carlisle, where he tried to convince everyone there that wildfowl were dying in droves via the absorption of lead shot. No one believed him and several told him so in very clear terms, with some asking where they all were, if that were the case. Swift replied that it was rare to find dead animals in the wild as carcasses were soon disposed of by other wild animals, a reply to which the same person asked ‘well if that’s the case how does anyone know how many are dying?’ Bit of an awkward silence after that one admittedly. 
Shooting organisations may well be committed to a voluntary transition away from lead shot, but I don’t know of anyone who is equally committed, organisation member or not. 
Every single shooter I know has stated they will use lead until it is no longer available. 

Fair enough but you will end up using non toxic in the end, try using some steel carts you might be surprised by the results I haven't used lead  for 5 years steel only because I can sell on steel shot pigeons  you need non toxic   for Wildfowl so i thought stuff I I'll just use steel full stop so I'm more than ready for when lead is banned I'll just carry on as usual with no gripes 

[Weihrauch17]

12 minutes ago, yickdaz said:

Fair enough but you will end up using non toxic in the end, try using some steel carts you might be surprised by the results I haven't used lead  for 5 years steel only because I can sell on steel shot pigeons  you need non toxic   for Wildfowl so i thought stuff I I'll just use steel full stop so I'm more than ready for when lead is banned I'll just carry on as usual with no gripes 

It is not just about main stream 12 bore shooting it is about every other piece of shooting it potentially touches and there are many all for absolutely no reason.

[Andy H]

Having worked in the conveyor industry for many years and supplying the food industry there has to be a reject line for all foods and this is primarily initiated by a metal detector be it sandwiches , crisp's anything  packaged  or processed food's , The really only way I could conceve of any shot lead or steel entering the food chain is direct sales of shot bird's  to a retailing butcher , Even in a large butchering facility the chop's and various cut's of meat are packaged and have to pass through a metal detector that would reject the packaged item , so unless you are buying birds/rabbit's etc hung up in a butcher's I cannot see where they keep saying about lead entering the retail food chain in the quantities they reckon on.

Edited November 5, 2023 by Andy H

[Centrepin]

Does anyone eat clay pigeons, cos soon we'll have to shoot them with steel. 

How many people have died from lead poisoning from eating lead shot since records began, please remind me. Oh yes, zero.

[vmaxphil]

7 hours ago, Andy H said:

Having worked in the conveyor industry for many years and supplying the food industry there has to be a reject line for all foods and this is primarily initiated by a metal detector be it sandwiches , crisp's anything  packaged  or processed food's , The really only way I could conceve of any shot lead or steel entering the food chain is direct sales of shot bird's  to a retailing butcher , Even in a large butchering facility the chop's and various cut's of meat are packaged and have to pass through a metal detector that would reject the packaged item , so unless you are buying birds/rabbit's etc hung up in a butcher's I cannot see where they keep saying about lead entering the retail food chain in the quantities they reckon on.

That's a very good point 👍

[Sweet11-87]

im still onboard with BASC if im honest, i know people give them no time of day but i cant help think they seen all this coming and knew it would be a fight that might be lost to a major detriment.

the volantry transition away from lead for game shooting where the meat will enter the market food chain and single use plastics was a move to pacify and divert.  i dont know about any of you but id take that in a heart beat  now if they left smallbore, clays and game i shoot for personal consumption alone. the weight would then fall on the shoulders of big comercial shoots that all seem to have transitioned to none toxic 2 seasons ago with no issue.

 

 

[London Best]

27 minutes ago, Sweet11-87 said:

comercial shoots that all seem to have transitioned to none toxic 2 seasons ago with no issue.

 

 

I use commercial shoots all the time now and have yet to visit one using non toxic shot.

[Rewulf]

40 minutes ago, Sweet11-87 said:

the volantry transition away from lead for game shooting where the meat will enter the market food chain and single use plastics was a move to pacify and divert. 

I'm sorry, but that's not what the phase out stated. 

It was a phase out of lead shot for live quarry shooting, whatever the purpose for it. I don't see where BASC, or any other shooting org, had the authority to put this forward without any consultation whatsoever. 

It's also interesting how, within 1 month of the announcement, the HSE put forward it's proposals and consultation plans, upon asking if BASC et al had any idea this was coming, they stated categorically they did not. 

It's my belief there was collusion in some way, obviously it can never be proven, but it calls into question the aims and trustworthiness of our shooting orgs. 

[yickdaz]

18 minutes ago, Rewulf said:

I'm sorry, but that's not what the phase out stated. 

It was a phase out of lead shot for live quarry shooting, whatever the purpose for it. I don't see where BASC, or any other shooting org, had the authority to put this forward without any consultation whatsoever. 

It's also interesting how, within 1 month of the announcement, the HSE put forward it's proposals and consultation plans, upon asking if BASC et al had any idea this was coming, they stated categorically they did not. 

It's my belief there was collusion in some way, obviously it can never be proven, but it calls into question the aims and trustworthiness of our shooting orgs. 

What do you think their aim is ?

 

[Sweet11-87]

49 minutes ago, London Best said:

I use commercial shoots all the time now and have yet to visit one using non toxic shot.

are they the big ones?

 

[London Best]

3 minutes ago, Sweet11-87 said:

are they the big ones?

 

They are doing from 70 to over 100 days/season.

[Weihrauch17]

1 hour ago, Rewulf said:

I'm sorry, but that's not what the phase out stated. 

It was a phase out of lead shot for live quarry shooting, whatever the purpose for it. I don't see where BASC, or any other shooting org, had the authority to put this forward without any consultation whatsoever. 

It's also interesting how, within 1 month of the announcement, the HSE put forward it's proposals and consultation plans, upon asking if BASC et al had any idea this was coming, they stated categorically they did not. 

It's my belief there was collusion in some way, obviously it can never be proven, but it calls into question the aims and trustworthiness of our shooting orgs. 

They acted without any consultation with their members which is truly appalling from all, talk about biting the hand that feeds you.  The EU has reviewed Lead use in 2021 and banned it's use over wetlands in February this year so we already had equivalence with them.  There was absolutely no need for the HSE to review the use of Lead.  I totally agree with the collusion theory, it stinks to high heaven. 

[clangerman]

still waiting to see both all these dead birds from ingesting lead and the claimed rush to eat steel shot game luckily I can spot rubbish when I hear it! 

[Scully]

3 hours ago, Sweet11-87 said:

im still onboard with BASC if im honest, i know people give them no time of day but i cant help think they seen all this coming and knew it would be a fight that might be lost to a major detriment.

the volantry transition away from lead for game shooting where the meat will enter the market food chain and single use plastics was a move to pacify and divert.  i dont know about any of you but id take that in a heart beat  now if they left smallbore, clays and game i shoot for personal consumption alone. the weight would then fall on the shoulders of big comercial shoots that all seem to have transitioned to none toxic 2 seasons ago with no issue.

 

 

I’m more or less still on board with BASC to be honest, but only because I think UK shooting would be in an even worse farcical state than it already is, but I refuse to fund them because I did for many years, naively feeling I was doing my bit but constantly and increasingly let down and disappointed as to how just how ineffective they really were/are. 
This isn’t necessarily the organisations fault; a lot of which has to be borne by us UK shooters, who it is has to be said, are largely the most lethargic bunch of people I know. 
Anyhow, I won’t apologise regarding Swift, who cosied up to agenda driven groups such as the Wetlands Trust in a campaign of deceit and dishonesty regarding the effect of lead shot on flora and fauna.
Not something I expected of the head man of a shooting organisation I subscribed to. 
I believe the BASC campaign for the voluntary phase out of lead shot for live quarry is one of damage limitation and brought about by a heads up from political contacts; why else would they do it? 
Im not sure where you get the ‘all’ big commercial shoots have moved to steel shot from; I beat on one and the vast majority of spent cases I pick up after each drive are lead shot….last Friday I collected RC 32grm 5’s and 24grm 7.5s for example.
There may have been some using steel, and I have indeed picked up steel cases over the last couple of seasons, but the majority are lead. 
All the birds go into a commercial chiller and then collected by a dealer. 
Mate has been beating on various moors four to five days a week since August, and had his beaters day yesterday, where all the guns used lead.
He told me some time ago there has been no stipulation regarding lead shot on the moors he’s been on, although many have chosen to use Bismuth; if you can afford to pay £220.00 +vat per brace, you can afford to use Bismuth. 

[wymberley]

1 hour ago, clangerman said:

still waiting to see both all these dead birds from ingesting lead and the claimed rush to eat steel shot game luckily I can spot rubbish when I hear it! 

There used to be - and probably still is although I can't be certain as I'm out of touch having been out almost twice as long as I was in - two related sayings in HMFs. The first was/is widely known and relates to what it is that does what to what. The second, not so well known, details which what should never be attempted. The result of not abiding by the second is immediately obvious as the perpetrator looses all credibility and/or respect. Sound familiar? If not, think about it for a bit

[wymberley]

2 hours ago, Weihrauch17 said:

so we already had equivalence with them. 

This has already been mentioned more than once and I fancy is not a good argument. Just need to be careful what we wish for as there is one equivalent which would decimate UK shooting at a stroke.