As the lead storm rages around us, Simon West of the Gun Trade Association tries to keep a calm head and suggest ways in which we might carry on.
Lead has been the key component of small arms ammunition for more than 500 years. It is readily available, easy to shape and dense enough to carry energy efficiently to the target. Over many years its less-attractive characteristics have become better known and, as a result, lead’s presence in the human environment has become far more difficult. In our lifetimes, lead has ceased to be an ingredient of paints and petrol.
It shouldn’t then be a surprise that dossiers have been assembled for the case against lead in ammunition. In fact, the latest European Chemicals Agency (ECHA) proposal for restrictions on the use of lead reach more than 300 pages.
Does that mean all of it is true? Probably not. There’s certainly plenty of scope for arguing the point on various aspects of its contents. Should it be challenged? Certainly. It would be wrong to let assumptions go unchallenged. Will challenging make a difference? As far as stopping all restrictions, I doubt it but there is plenty there we must engage with and ensure that change is justified on scientific and proportional grounds.
The salient point is that after using lead for centuries, there are no quick solutions to replacing lead in every type of ammunition. Ammunition makers in the UK and beyond have been working on lead-alternative technologies for generations.
That is why we already see sustainable ammunition on the shelves of our gun shops. Copper bullets for deer control, steel shot for game shooting—this is proof of the industry moving with the evidence and offering choice to the shooting public.
The ammunition manufacturers might have foresight; they might have invested in research and development; they might help promote sustainability through marketing and communications. What they can’t do, however, is solve all the problems overnight. Some alternatives may never be achieved.
If replacing plastics was easy, the supermarkets and soft drinks producers would have done it already. Despite the production of our millions of cartridges, we do not have the turnover that would allow us to beat Coca-Cola in the race for sustainable plastic. Despite shooting’s popularity, we cannot corner the market for international steel shot supplies.
With Brexit came the opportunity for the UK to make its own judgements, rather than submit to chemical controls dreamt up in Helsinki. How did we do? Well, just three months into our independence, DEFRA announced that it was going to plagiarise the European homework and launch a copycat version of the ammunition review.
So where do we stand?
Wetlands restriction passed: this affects Northern Ireland—which is aligned by treaty to the EU on REACH (chemicals restrictions)—with a ban on the use of lead shot near wetlands from January 2023, with a broad definition that will affect shooting over substantial areas.
Lead as a chemical: lead is on the Candidate List of ‘substances of very high concern’. If it becomes ‘listed’, then its use in the EU will be highly restricted, like mercury and arsenic. If listed in 2021, lead would be largely unavailable from 2024/25. On current evidence, DEFRA would be likely to follow suit.
Lead in all ammunition and fishing weights: the ECHA dossier has been submitted with the following recommendations to start in 2023:
- Shotgun ammunition – lead ban in five years
- Large calibre rifles—ban in 18 months
- Small calibre rifles—ban in five years
- Where members states decide: Olympic and international competition shooting where more than 90% of the lead can be recovered—no ban
- Other possible exemptions: indoor shooting; law enforcement and military; commercial shipping protection; self defence and security; test and proof; forensic or historical research
DEFRA consultation on restrictions on the use of lead in all ammunition to start in 2022 and last for two years. This means any restrictions are not likely to be enacted before about 2025.
The supermarkets made early indications of their desire to move away from lead shot game. That has led to the recent announcement from the National Game Dealers Association that it will not handle lead shot game—fur or feather—from July 2022.
Where does this put us all?
The ECHA proposed restrictions are still being hotly debated and although we are no longer in the EU, we can and must continue to engage. With our markets so closely aligned for guns and ammunition, we need to engage with the process, especially on the production realities and the socio-economic research on how the restrictions could affect British jobs and livelihoods. The GTA does this by submissions direct to ECHA and by working with the British Shooting Sports Council and IEACS (the European Gun Trade community) to mobilise political opinion.
The consultation starts in a year’s time. We have much evidence that needs to be submitted but it will be important to study the proposals and work across the shooting community to ensure that we do not face unnecessary and unjustified restrictions.
We must fight for derogations where science and industry cannot provide alternatives. We all want to avoid any cliff edges. It is vital we understand each other’s ability to transition away from lead. Where we can transition, we will but where there are no cost-effective or realistic alternatives, we must be able to provide evidence to protect our use of lead.
The shooting organisations were criticised a year ago for their failure to consult. The same might apply to the market drivers for change. Yes, we have new products that will allow game to be shot with sustainable, lead-free ammunition, but did anyone ask if we might have sufficient supplies by the 2022 season to ensure they can take the game they desire? The five-year ambition was bold; game dealer demands for a three-year timeline, that has included a pandemic, might have been worth a telephone call.
To sum up
Lead ammunition has served us well for centuries. It has helped us hunt for food and win wars. Now, our ever-developing scientific knowledge might call for certain changes to ensure a sustainable, healthy environment for us all. Transition is not an objective, it’s a relentless process. Where lead is a problem, let’s deal with it. Where lead’s impact is manageable, let’s manage it.
No one size fits all.There are highly intelligent, independent minds out there making balanced decisions about lead and the environment but, be in no doubt, there are also those who seek to damage shooting by twisting and exaggerating the evidence against us for their own purposes. We must work together, be ready with hard evidence and demand proportionality.