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BASC response to HSE lead ammunition consultation


Conor O'Gorman
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BASC’s consultation response considered every shooting discipline, both live quarry and target, and the documents we submitted can be downloaded here:

In our response we made our position clear to the HSE that BASC was opposed to any further regulation on the use of lead ammunition in the UK for the following reasons:

  • Regulations are already in place to mitigate risks to wildfowl from the use of lead shot in wetlands.
  • There is clear evidence that lead shot poses a risk to a wide range of bird species in terrestrial habitats and a voluntary move away from lead shot for live quarry shooting with shotguns is reducing these risks.
  • The shooting sector must be allowed time to develop non-lead shotgun ammunition due to a world shortage of components and the need for manufacturers and assemblers to source new machinery to produce lead shot alternatives and biodegradable wads for all shotgun calibers.
  • Lead in game meat is potentially a risk to human health via secondary exposure and government guidance and market forces are managing risks via best practice.
  • Lead exposure pathways are not conclusive for livestock, soil, soil organisms, plants, and surface waters; and current legal and regulatory frameworks are in place to manage risks.

BASC remains committed to the voluntary transition away from lead shot and single-use plastics for live quarry shooting, which commenced in February 2020. The industry has made enormous strides forward in the development of lead-free shotgun ammunition and biodegradable wads to date, and BASC will continue to drive this process forward.

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we don't need a lead ban or non toxic shot there is thousands of house with lead pipes giving people their water and they have not got lead poisoning  also no proof the birds have died from eating lead shot lead shots sinks a lot deeper than ducks etc feed  its just another money making scam

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Game meat isn’t even a ‘ potential risk’ to human health unless you’re shovelling the stuff down on a daily basis.
What is it? Something like less than 1% increase in lead/blood levels? 
You and them are extracting the urine and should be embarrassed by your deceit. 

But you aren’t because there’s an agenda at work which none of us can do anything about, and which you have to abide with to ensure your survival. 
We know it, they know it, and you know it, but don’t worry, because we’ll tag along. It’s not like we have a choice is it. 

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12 hours ago, Scully said:

Game meat isn’t even a ‘ potential risk’ to human health unless you’re shovelling the stuff down on a daily basis.
What is it? Something like less than 1% increase in lead/blood levels? 
You and them are extracting the urine and should be embarrassed by your deceit. 

But you aren’t because there’s an agenda at work which none of us can do anything about, and which you have to abide with to ensure your survival. 
We know it, they know it, and you know it, but don’t worry, because we’ll tag along. It’s not like we have a choice is it. 

Well said Scully :good:

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So the last day to respond to this "Consultation" was on the 10th of this month, and you have just uploaded your response (4 days later) to let your members know what information they could have used in their answers.

A bit like publishing the winning lottery numbers the day after it was drawn.

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21 hours ago, Scully said:

Game meat isn’t even a ‘ potential risk’ to human health unless you’re shovelling the stuff down on a daily basis.
What is it? Something like less than 1% increase in lead/blood levels? 
You and them are extracting the urine and should be embarrassed by your deceit. 

But you aren’t because there’s an agenda at work which none of us can do anything about, and which you have to abide with to ensure your survival. 
We know it, they know it, and you know it, but don’t worry, because we’ll tag along. It’s not like we have a choice is it. 

It's fair enough if you disagree with the science - but to use the word 'deceit' is I think rather defamatory and inappropriate. Awareness and research is growing daily worldwide and that includes hunting communities across the world. Are they all in on this 'deceit'? If its worldwide conspiracies you are into then fair enough but to label me/BASC as deceitful....? Come on, I think you are better than that.

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3 hours ago, Graham M said:

So the last day to respond to this "Consultation" was on the 10th of this month, and you have just uploaded your response (4 days later) to let your members know what information they could have used in their answers.

A bit like publishing the winning lottery numbers the day after it was drawn.

We have been encouraging people to respond in their own words, based on their own experience, to the consultation since it opened, including on this forum. That experience is evidence. This was not the type of consultation for copy and paste answers off a script and it was a challenging survey response form to say the least so this was the approach we took. You may disagree, and that is fair enough.

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22 hours ago, Conor O'Gorman said:

It's fair enough if you disagree with the science - but to use the word 'deceit' is I think rather defamatory and inappropriate. Awareness and research is growing daily worldwide and that includes hunting communities across the world. Are they all in on this 'deceit'? If its worldwide conspiracies you are into then fair enough but to label me/BASC as deceitful....? Come on, I think you are better than that.

I think any method of ‘sexing up’ the expectations or results of a finding to generate an agendas outcome is deceit.
While I’m in no doubt that lead can prove fatal if ingested by wild and domestic birds and animals, didn’t some of the methods used to determine the toxicity of lead to ducks consist of pouring lead into a ducks gizzard via a funnel? I think we’d all find it detrimental to our health if we ate it in a similar method. 
Flying in an aeroplane is a ‘potential risk’ to health, as is crossing the road or indeed driving on it, and I do the latter much more frequently than I eat lead shot game. 
It’s agenda driven deceit. 

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29 minutes ago, Scully said:

I think any method of ‘sexing up’ the expectations or results of a finding to generate an agendas outcome is deceit.
While I’m in no doubt that lead can prove fatal if ingested by wild and domestic birds and animals, didn’t some of the methods used to determine the toxicity of lead to ducks consist of pouring lead into a ducks gizzard via a funnel? I think we’d all find it detrimental to our health if we ate it in a similar method. 
Flying in an aeroplane is a ‘potential risk’ to health, as is crossing the road or indeed driving on it, and I do the latter much more frequently than I eat lead shot game. 
It’s agenda driven deceit. 

Who exactly is being deceitful? You seen to have asserted it is me and/or BASC. Please clarify. Then please outline what the agenda is.

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15 minutes ago, Conor O'Gorman said:

Who exactly is being deceitful? You seen to have asserted it is me and/or BASC. Please clarify. Then please outline what the agenda is.

Oh please! Don’t start that, please! I haven’t asserted anything of the kind! 
At the time all of this kicked off, Swifty was head honcho of BASC, but doing his best to undermine all the resistance BASC could summon! 🤷‍♂️
The Wetlands Trust along with Payne eventually admitted ( unless I’m very much mistaken ) under much duress, that part of the scientific process of proof that lead was toxic to wildfowl consisted of tipping the stuff into the poor things via a funnel! 
The effect of lead on human health via eating game meat hardly registers on any scale you care to mention unless you’re eating it in a similar manner to the unfortunate ducks! 
Like I’ve said, I totally understand the fact lead is toxic to flora and fauna, but the manner in which this information is sold to the general public as a ‘potential risk’ to human health, given the much more serious ‘potential risks’ we encounter on a daily basis, is nothing more than scaremongering, which is deceit. 

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33 minutes ago, Scully said:

Oh please! Don’t start that, please! I haven’t asserted anything of the kind! 
At the time all of this kicked off, Swifty was head honcho of BASC, but doing his best to undermine all the resistance BASC could summon! 🤷‍♂️
The Wetlands Trust along with Payne eventually admitted ( unless I’m very much mistaken ) under much duress, that part of the scientific process of proof that lead was toxic to wildfowl consisted of tipping the stuff into the poor things via a funnel! 
The effect of lead on human health via eating game meat hardly registers on any scale you care to mention unless you’re eating it in a similar manner to the unfortunate ducks! 
Like I’ve said, I totally understand the fact lead is toxic to flora and fauna, but the manner in which this information is sold to the general public as a ‘potential risk’ to human health, given the much more serious ‘potential risks’ we encounter on a daily basis, is nothing more than scaremongering, which is deceit. 

Thank you for clarifying that you did not assert anything of that kind. Here is the GWCT advice on the topic:

https://www.gwct.org.uk/advisory/lead-ammunition/effects-of-lead-on-human-health/

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11 hours ago, Scully said:

And thank you for posting a link which clarifies what? Well, er, nothing really. 🤷‍♂️

If that's how you want to be, then fair enough, but that does not change the fact that lead in game meat is potentially a risk to human health via secondary exposure and government guidance and market forces are managing risks via best practice. 

The potential risks and government guidance were outlined on the GWCT weblink - here it is again in case you didn't read it before commenting:

https://www.gwct.org.uk/advisory/lead-ammunition/effects-of-lead-on-human-health/

Also, I think you will be well aware of market forces from your game shooting experience and the figures from the 2022 GunsOnPegs Game Shooting Census and Shoot Owner Census survey undertaken by GunsOPegs estimated that:

• 70% of shoots will insist on guns going lead free.
• 43% were going lead free and encouraging other to do so.
• 60% had plans to go lead free for the coming season.
• 77% of guns said they would be happy to change of a shoot requested them 
to do so. 

As for the assertion that the various bans on lead shot for wildfowl and/or wetlands across the UK over 20 years ago were because some scientists were pouring lead into a ducks gizzard via a funnel to prove lead poisoning is just a tad ridiculous.

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1 hour ago, Conor O'Gorman said:


• 70% of shoots will insist on guns going lead free.
• 43% were going lead free and encouraging other to do so.
• 60% had plans to go lead free for the coming season.
• 77% of guns said they would be happy to change of a shoot requested them 
to do so. 

Evening Conor, Do you have or can you get the exact figures of shoots that have signed up to the Game Alliance assurance scheme ie Lead free. I've been beating and shooting on 8 different shoots (only 3 commercial) already this year and none are or have show any intension of joining. One shoot will have been sending 600 birds a week to a game dealer since the start of November all shot with lead as far as i know. I've not spoken to any Shooter,  Beaters or Pickers Up that know of a shoot using  Non Toxic shot.

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11 hours ago, Conor O'Gorman said:

If that's how you want to be, then fair enough, but that does not change the fact that lead in game meat is potentially a risk to human health via secondary exposure and government guidance and market forces are managing risks via best practice. 

The potential risks and government guidance were outlined on the GWCT weblink - here it is again in case you didn't read it before commenting:

https://www.gwct.org.uk/advisory/lead-ammunition/effects-of-lead-on-human-health/

Also, I think you will be well aware of market forces from your game shooting experience and the figures from the 2022 GunsOnPegs Game Shooting Census and Shoot Owner Census survey undertaken by GunsOPegs estimated that:

• 70% of shoots will insist on guns going lead free.
• 43% were going lead free and encouraging other to do so.
• 60% had plans to go lead free for the coming season.
• 77% of guns said they would be happy to change of a shoot requested them 
to do so. 

As for the assertion that the various bans on lead shot for wildfowl and/or wetlands across the UK over 20 years ago were because some scientists were pouring lead into a ducks gizzard via a funnel to prove lead poisoning is just a tad ridiculous.

I’ve read it Conor thank you.
None of it is relevant however, to the level of deceit there has been regarding the ‘potential risk’ to human health. 
The circumstances for my ‘tad ridiculous’ claims are all on this very forum if you care to do a search. 
As for the percentages you’ve posted from shoot owners and guns in pegs, that's: 

70% ‘Will’ ….buy have they? 

43% ‘were’ …..but have they? 
60% ‘had plans’ ……but have they? 

70% of guns said they ‘would’……but have they? 
No doubt we all WILL at some point, but at this point I’m not aware of any shoots ( and I know dozens locally including two commercial shoots ) which have. 🤷‍♂️

It’s as meaningless as the ‘potential risk’ being bandied about. 

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13 hours ago, Scully said:

I’ve read it Conor thank you.
None of it is relevant however, to the level of deceit there has been regarding the ‘potential risk’ to human health. 
The circumstances for my ‘tad ridiculous’ claims are all on this very forum if you care to do a search. 
As for the percentages you’ve posted from shoot owners and guns in pegs, that's: 

70% ‘Will’ ….buy have they? 

43% ‘were’ …..but have they? 
60% ‘had plans’ ……but have they? 

70% of guns said they ‘would’……but have they? 
No doubt we all WILL at some point, but at this point I’m not aware of any shoots ( and I know dozens locally including two commercial shoots ) which have. 🤷‍♂️

It’s as meaningless as the ‘potential risk’ being bandied about. 

The voluntary transition is taking place for shoots across the UK and lead in game meat is potentially a risk to human health via secondary exposure and government guidance and market forces are managing risks via best practice.

Given your own experience do please respond to the following BASC survey, which closes at midday on 17 January 2024 - in relation to over 3 years consultation on the voluntary move away from lead shot and single use plastics for shotgun cartridges for live quarry shooting in the UK. 

https://www.research.net/r/BASC-VLST

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@Conor O'Gorman I have just completed this survey. Section 15 is very misleading. It requires the participant to rank in order of importance concerns over transition to steel. I have very few concerns but the survey forces me to list some that i do not have. For example. I have no concern about my guns, they are steel proof. I have no concern about damage to heirlooms, I have none. I have no concern about many more items but I am forced to rank them at levels which show concern when in fact I have none. All very misleading I feel. 

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I’ve just completed it 

very biased typically you can’t read it in full unless you have filled in parts 

absolutely nothing mentioned about clay shooting either lead is toxic to the environment or not
failure to mention that if your worried about the possibility of lead poisoning from game don’t eat it 

do they not realise that the sale of game products is insignificant to the majority of the shoots the guns and beaters have it 

it’s only the mega big days that have a problem with the disposal of excess 

as for heirloom guns and favourite guns there already valueless and obsolete 

no question about who’s going to pay for re proof or pay for choke reboreing 

honestly don’t think I have ever seen such a biased survey 

Apology for ranting a bit 

remember we were never consulted about the voluntary transition 

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10 hours ago, Old farrier said:

remember we were never consulted about the voluntary transition 

Indeed that's what hurts me the most, is a voluntary transition that was created by a group to try to fix the issue, but without consultation or desire from the populous. 

Also, you can't set a 5 year transition from 2020 which then expires in a year and change, if the other point of supply chain and affordable alternatives isn't in place either.

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12 hours ago, Conor O'Gorman said:

The voluntary transition is taking place for shoots across the UK and lead in game meat is potentially a risk to human health via secondary exposure and government guidance and market forces are managing risks via best practice.

Given your own experience do please respond to the following BASC survey, which closes at midday on 17 January 2024 - in relation to over 3 years consultation on the voluntary move away from lead shot and single use plastics for shotgun cartridges for live quarry shooting in the UK. 

https://www.research.net/r/BASC-VLST

‘……in relation to over 3 years consultation on the voluntary move away from lead shot……’ 

Sorry, I must have missed that bit! When did that happen? 
I had a tot up of all the shoots local to me and there are 26 that I know of, and there will be more that I don’t know of, including two commercial shoots. 
I don’t know of any that have made the move to non-toxic shot. It isn’t even discussed anymore, but no doubt that will change as and when legislation is introduced. 
I hope that our shooting organisations are quick to point out at seasons end, to those anti organisations which buy shot game to test them for lead shot, that there is absolutely no reason why they shouldn’t contain lead shot. It is still being manufactured and perfectly legal to use. 
It’s worth remembering Conor, that it was our shooting organisations which stated there would be a voluntary phase out; not the actual people doing the shooting. 

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