Sooner than expected, the Government has begun its “substitution of lead in ammunition” consultation which, Simon West explains, will require a fact-based and unified response.
There are few things the Government is quick at—but they have surprised us by starting the lead ammunition consultation six months ahead of time. The Health and Safety Executive (HSE) is leading the call for evidence under UK Reach.
Reach stands for Registration, Evaluation, Authorisation and Restriction of Chemicals and applies to most chemical substances; those used in industrial processes and daily life—for example in cleaning products and paints as well as in articles such as clothing, furniture and electrical appliances. The aim is to provide a high level of protection of human health and the environment from the use of chemicals.
The EU has been considering a restriction on the use of lead in ammunition for some time but with Brexit, the UK Government has sought to follow the same principles of EU Reach and therefore is now looking at lead in ammunition on this side of the Channel.
The HSE is gathering information and evidence to support the development of a UK Reach restriction dossier on risks to the environment and human health of the use of lead in ammunition in all habitats in Great Britain. Military and non-civilian use of ammunition is excluded.
The scope of the assessment is the use of lead ammunition in environmental habitats. “Outdoor shooting ranges are therefore included in the assessment, but indoor shooting ranges are not. Applying the same definition of sport shooting as the European Chemicals Agency (ECHA) (Shooting at any inanimate (non-living) target with a gun.
Includes practice, or other shooting, performed in preparation for ‘hunting.’ Examples of relevant types of targets are ‘clay pigeons’, paper targets, biathlon targets, silhouettes etc), we would like to gather GB-specific information on outdoor shooting ranges.”
The questions asked at this stage relate to:
- Measures to limit the release of lead into the environment at outdoor shooting ranges
- Recovery of lead at shooting ranges
- Areas of land used for hunting animals and birds
- Consumption of lead-shot game and lead in game meat
- Manufacture and supply of lead shot and ammunition
- Home casting of lead cartridges
- Substitution of lead in ammunition
- Impacts of lead ammunition on wildlife in GB
- Impact of the shooting organisations’ voluntary agreement so far
- Impacts of a possible restriction on businesses, hunters and shooters
The answers are asked to be supported by references and reliable data.
Of course, it was the shooting organisations’ aim in their voluntary five-year transition away from shooting live quarry with lead shotgun ammunition, to avoid the need for regulation. Now, after only 18 months of the five-year period, the Government is seeking to regulate—and regulate far more than just game shooting.
These questions cut right across huge swathes of our shooting and business future. Pandora’s box is now truly open and the opportunity for our detractors is there to try to manipulate the consultation to their advantage. You can imagine the misinformation that will be delivered on the impacts of lead ammunition on wildlife.
There will be nobody who can answer all the questions with the authority and data required, but I am committed to provide clear industry data to answer our relevant questions.
The industry is working hard to find alternatives to lead, but we all know there are real challenges in some areas. The five-year transition was a big ask, but since that we have faced a global pandemic, and now, serious component shortages. This has pushed back the dates where we can deliver effective solutions—in the right quantities to the market.
My biggest concern is that the shooting community lacks a unified message. Some shooting organisations continue to justify their transition objectives by briefing MPs and others about the effectiveness of alternatives—but rarely recognise these are early products that cannot yet be produced in anything like the quantities we will need.
I celebrate BASC’s Dan Reynolds’s recent statement: “A key principle we must not lose sight of is that further legal restrictions must not be imposed until effective and affordable types of sustainable ammunition are available in sufficient volumes to meet demand.”
We must also help educate the officials who are conducting the study. In the recent European dossier it stated: “The authors concluded that lead-free pellets would be suitable for recreational shooting but not for precision sports.” This demonstrates a complete failure to understand shooting at its most fundamental level.
I stand ready to work with all the other organisations in the shooting community to help us provide an accurate and coherent response to the consultation. This is not the time for independent conjecture and opinion; we must deliver facts and data. Our trade, businesses and livelihoods depend on it.