UK REACH lead ammunition review announced

[Apthorpe]

It's not clear to me from the OP that BASC is going to be opposing this process in all aspects as it has previously promised to, including repeated assurances since the advent of the " 5 year voluntary phased transition".

Perhaps @Conor O'Gorman could confirm definitively that BASC will oppose ANY increase in restriction beyond the current UK legal situation via this process?

 

[Conor O'Gorman]

It's not clear to me from the OP that BASC is going to be opposing this process in all aspects as it has previously promised to, including repeated assurances since the advent of the " 5 year voluntary phased transition".

Perhaps @Conor O'Gorman could confirm definitively that BASC will oppose ANY increase in restriction beyond the current UK legal situation via this process?

The position of the nine shooting organisations has not changed from that announced in February last year which is " In consideration of wildlife, the environment and to ensure a market for the healthiest game products, at home and abroad, we wish to see an end to both lead and single-use plastics in ammunition used by those taking all live quarry with shotguns within five years. We are jointly calling for our members to engage in this transition and work with us, the Gun Trade Association and the cartridge manufacturers to ensure that further viable alternatives are developed for every situation involving live quarry. This is an opportunity to take the initiative and ensure the reputation of the shooting community, as custodians of the countryside, is both maintained and enhanced."

With regard to the recently announced lead ammunition review I cannot confirm anything because there are no details yet on the process - as you know we successfully opposed the lead restrictions proposed for 2023 as an amendment to the Environment Bill recently - but for my part the following may help add context on the lead ammunition review:

BASC blog:

Two-year UK lead ammunition review - threat or opportunity? - BASC

BASC's Dr Conor O'Gorman considers what the announcement of a two-year UK REACH review on lead ammunition means for shooting.

basc.org.uk

Radio 4 Farming Today (6.45 mins onwards)

BBC Radio 4 - Farming Today, 25/03/21 Plans to ban lead shot; escape to the country and the impact on rural services

The government plans to ban lead shot to protect nature.

www.bbc.co.uk

 

[Tazz]

Here is an interesting table of Weights of metals per pound per cubic foot and the issue of replacing lead with a pound for pound replacement.
I'm sure that with more R&D there will be a suitable if not a more effective replacement to lead..

At the moment we are at the transition stage and nothing is working as we would like it to.

Aluminum 168.48
Antimony 419.99
Beryllium 113.70
Bismuth 611.00
Brass (Approx.)535.68
Bronze, Alum. 481.00
Bronze (Approx.) 541.00
Cadmium 540.86
Chromium 428.00
Cobalt 552.96
Copper 559.87
Gold 1206.83
Gun Metal (Aver.) 544.00
Iridium 1396.00
Iron 491.09
Iron,Cast Grey 442.00
Iron,Wrought 480.00
Iron,Slag 172.00
Lead 707.96
Magnesium 108.51
Manganese 463.10
Mercury 849.00
Molybdenum 637.63
Monel Metal 556.00
Nickel 555.72
Osmium 1402.00
Palladium 712.00
Platinum 1339.20
Rhodium 755.00
Ruthenium 765.00
Silver 654.91
Stainless Steel (18-8) 494.21
Steel, Cast/Rolled 490.00
Tin 455.67
Titanium 283.39
Tungsten 1204.41
Vanadium 374.97
Zinc 445.30.


Lead is dead as far as i'm concerned, like many of you I was vehemently opposed to copper and refused to change.Having been dragged kicking and screaming into the "copper" age, I really don't know what all the fuss is about, yes its not ideal but with demand will come more R&D and the effectiveness will improve and hopefully the cost.

Osmium at 1402 looks like the way to go for shotgun shells, it’s that heavy you could come down a few shot sizes, only downside I see is it’s around £350 an ounce, it would make you more disciplined in terms of what shots you took on, I doubt on the Pigeons you would fire that third semi auto shot as often

 

[Apthorpe]

The position of the nine shooting organisations has not changed from that announced in February last year which is " In consideration of wildlife, the environment and to ensure a market for the healthiest game products, at home and abroad, we wish to see an end to both lead and single-use plastics in ammunition used by those taking all live quarry with shotguns within five years. We are jointly calling for our members to engage in this transition and work with us, the Gun Trade Association and the cartridge manufacturers to ensure that further viable alternatives are developed for every situation involving live quarry. This is an opportunity to take the initiative and ensure the reputation of the shooting community, as custodians of the countryside, is both maintained and enhanced."

With regard to the recently announced lead ammunition review I cannot confirm anything because there are no details yet on the process - as you know we successfully opposed the lead restrictions proposed for 2023 as an amendment to the Environment Bill recently - but for my part the following may help add context on the lead ammunition review:

BASC blog:

Two-year UK lead ammunition review - threat or opportunity? - BASC

BASC's Dr Conor O'Gorman considers what the announcement of a two-year UK REACH review on lead ammunition means for shooting.

basc.org.uk

Radio 4 Farming Today (6.45 mins onwards)

BBC Radio 4 - Farming Today, 25/03/21 Plans to ban lead shot; escape to the country and the impact on rural services

The government plans to ban lead shot to protect nature.

www.bbc.co.uk

Thank you for the link to your blog on this. While informative, in areas it is misleading. You state that it is an opportunity to "objectively evaluate the evidence", however it is entirely obvious that is not true. We had an objective evaluation of the evidence by the government less than six years ago. Since then, no significant new primary science on the topic has come to light. (There's no point debating that point because you have previously proven unable to cite a single such source of evidence.) What the government has actually announced is a consultation on completely banning the use of lead, not a consultation on whether lead ought to be phased out.

You seem to have abandoned the idea of this being voluntary any more and appear to support the concept of compulsory restrictions. This is the opposite to what BASC has repeatedly promised its members.

For the sake of clarity, your answer is that BASC has abandoned its opposition to compulsory restrictions on the use of lead shot or ammunition and is prepared not to oppose, or even welcome, further legal restrictions.

Can you confirm and publish that you have had written confirmation from the Gun Trade Association or ANY cartridge manufacturer that in four years' time viable and equivalently priced alternatives will be available for "every situation involving live quarry"? Or is this just more guff intended to dupe the gullible until it is too late?

Given that we last had an objective government review in 2016, which concluded the evidence did not justify a ban, and that BASC has been unable to produce any primary scientific evidence subsequent to that time capable of leading any reasonable person to change their mind, how does BASC explain its new position which is that it opposes the best interests of its members? You're not saying that BASC has any opposition to much of the case for banning lead - which is essentially based on the spurious and scientifically shoddy work of a very small clique of individuals opposed to shooting. The estimates for the harm lead does to wildfowl are speculative at best, yet you are not on the record criticising the poor methodology, the weak evidence, the excessive extrapolation etc.

I've been wanting to give this project by BASC the benefit of the doubt, and frankly would prefer to have alternatives to lead, but it's really proving very hard to believe anything other than that this is turning into a right royal, self-inflicted, f***-up.

It's disappointing that BASCs communications to its members on the topic are so tendentious and even mendacious, in part.

 

[Conor O'Gorman]

Thank you for the link to your blog on this. While informative, in areas it is misleading. You state that it is an opportunity to "objectively evaluate the evidence", however it is entirely obvious that is not true. We had an objective evaluation of the evidence by the government less than six years ago. Since then, no significant new primary science on the topic has come to light. (There's no point debating that point because you have previously proven unable to cite a single such source of evidence.) What the government has actually announced is a consultation on completely banning the use of lead, not a consultation on whether lead ought to be phased out.

You seem to have abandoned the idea of this being voluntary any more and appear to support the concept of compulsory restrictions. This is the opposite to what BASC has repeatedly promised its members.

For the sake of clarity, your answer is that BASC has abandoned its opposition to compulsory restrictions on the use of lead shot or ammunition and is prepared not to oppose, or even welcome, further legal restrictions.

Can you confirm and publish that you have had written confirmation from the Gun Trade Association or ANY cartridge manufacturer that in four years' time viable and equivalently priced alternatives will be available for "every situation involving live quarry"? Or is this just more guff intended to dupe the gullible until it is too late?

Given that we last had an objective government review in 2016, which concluded the evidence did not justify a ban, and that BASC has been unable to produce any primary scientific evidence subsequent to that time capable of leading any reasonable person to change their mind, how does BASC explain its new position which is that it opposes the best interests of its members? You're not saying that BASC has any opposition to much of the case for banning lead - which is essentially based on the spurious and scientifically shoddy work of a very small clique of individuals opposed to shooting. The estimates for the harm lead does to wildfowl are speculative at best, yet you are not on the record criticising the poor methodology, the weak evidence, the excessive extrapolation etc.

I've been wanting to give this project by BASC the benefit of the doubt, and frankly would prefer to have alternatives to lead, but it's really proving very hard to believe anything other than that this is turning into a right royal, self-inflicted, f***-up.

It's disappointing that BASCs communications to its members on the topic are so tendentious and even mendacious, in part.

Did you get a chance to listen to the 5 mins interview on Farming Today this morning? There are many moving parts and opinions - not only your opinion - but the diverse views of all shooters - and there are the views of the public, the media, the politicians, scientists and so on.

There are nine organisations working together on lead ammunition policy developments. These are BASC, Countryside Alliance, Game and Wildlife Conservation Trust, British Game Alliance, Country Land and Business Association, Moorland Association, National Gamekeepers' Organisation, Scottish Land and Estates, and Game Farmers Association. If their position changes I will post an update on that. Following the announcement about the lead ammunition review there have been updates from GWCT, CA and NGO.

GWCT update:

Strong support for change as Environment Agency launches lead ammunition review - Game and Wildlife Conservation Trust

www.gwct.org.uk

CA update:



NGO update:

Review of lead ammunition

Read the latest update of the five-year voluntary phase out of lead shot

www.nationalgamekeepers.org.uk

 

[tusker]

"Smart" motorways have killed more people in 3 years than ingested lead has killed in 100.
Tusker

 

[timbrayford]

Can you honestly see the EU protectionism let that happen.
They set up with EU funding various factories that took UK work while we were a member. They will not be bothered about doing it even more openly now we are not.

To be frank by the time massed produced non-toxic is up and running I think that the EU Commission will be a busted flush.

 

[Liveonce]

I think basc, Tim Bonner, should open a used cars sales outlet they make great salesmen, say something enough times it must be true is their approach, no mention of the limitations like the end of 28ga and .410 guns unless you can afford bismuth or tungsten shot cartridges.

And Conor the nine organisations, how about the cartridge manufactures do they have a say?

 

[Apthorpe]

Did you get a chance to listen to the 5 mins interview on Farming Today this morning? There are many moving parts and opinions - not only your opinion - but the diverse views of all shooters - and there are the views of the public, the media, the politicians, scientists and so on.

There are nine organisations working together on lead ammunition policy developments. These are BASC, Countryside Alliance, Game and Wildlife Conservation Trust, British Game Alliance, Country Land and Business Association, Moorland Association, National Gamekeepers' Organisation, Scottish Land and Estates, and Game Farmers Association. If their position changes I will post an update on that. Following the announcement about the lead ammunition review there have been updates from GWCT, CA and NGO.

GWCT update:

Strong support for change as Environment Agency launches lead ammunition review - Game and Wildlife Conservation Trust

www.gwct.org.uk

CA update:



NGO update:

Review of lead ammunition

Read the latest update of the five-year voluntary phase out of lead shot

www.nationalgamekeepers.org.uk

This is still unsatisfactory. You don't deny that you've abandoned BASC's stated policy on lead without any good reason - twice now.

You won't say anything to support BASC's published claims that viable alternative ammunition will exist for ALL types of live quarry shooting in 4 years, while manufacturers are on record stating that it would be impossible. So that appears to be another unforced false claim.

Earlier this year you said this:

"BASC will continue to fight against disproportionate and unsubstantiated restrictions on the use of lead ammunition - after all we have been leading this fight for 40 years."

"In summary we are working to prevent bad laws from entering into force"

Now you disown your own words.

You're right that this is not a matter of my opinion, or anyone else's; it is supposed to be a matter of BASC doing what it has promised members and of objective evaluation of the facts - something you or BASC will no longer support.

It's extremely disappointing that BASC is now rejecting its own policy of fighting further restrictions to lead shot, and made worse by the use of spurious methods and obfuscation to hide this from your membership.

To clarify, let's distinguish fact from opinion here:

1. It is a fact that BASC has twice changed its policy on lead shot within 18 months while no new primary scientific evidence has come to light to justify this.

2. It is a fact that BASC will not stick to its previously stated policy of opposing further legislation or regulation restricting lead shot, nor properly challenge the sham government consultation recently announced.

3. It is also a fact that the consultation will not be an independent examination of the evidence on this matter.

4. It is a fact that BASC does not have any credible basis, nor assurance from any expert source, to justify its statement that viable alternatives to lead ammunition for "every situation involving live quarry" will be developed during the remainder of the "voluntary" five year sellout, I mean phased transition.

My opinions are largely irrelevant, but you're just sidestepping addressing the facts. When challenged you have failed to disagree with any of the four statements above. Can you show that any of the above four statements are false?

The last point which I think is extremely important and BASC would be very negligent not to secure assurances on is the issue of how the Government will compensate owners for the tens or hundreds of thousands of guns rendered redundant by the proposed course of action. BASC has been ominously silent on this. Replacing the redundant parts of my gun cupboard with equivalent guns capable of firing steel will cost something of the order of £25,000. Many members will be facing far more significant costs and frequently irreplaceable loss. BASC gives the impression of being blind to this.

5. Will BASC do anything to ensure that members and shooters are not out of pocket as a result of their eccentric policies?

6. Will BASC lobby to have the thousands of guns rendered obsolete removed from licensing requirements?

What have you heard from your extensive political contacts in relation to these points?

7. Is there anything credible you can say to reassure or guarantee members that BASC isn't lining up for an expensive betrayal of members' interests here? No member of BASC is advantaged by any further legislation to restrict lead ammunition.

 

[Apthorpe]

I think basc, Tim Bonner, should open a used cars sales outlet they make great salesmen, say something enough times it must be true is their approach, no mention of the limitations like the end of 28ga and .410 guns unless you can afford bismuth or tungsten shot cartridges.

And Conor the nine organisations, how about the cartridge manufactures do they have a say?

Did he ever get back to you with an answer on the capacity of manufacturers to produce sufficient steel shot of the necessary types?

 

[Apthorpe]

@Conor O'Gorman
One more thing, about the Daily Mail article you linked to. It said that about 60% of UK shot game goes to the EU. Have you challenged the veracity of that claim? What's the basis of it?

I don't think it sounds plausible to say that 12 million or so pheasants are exported. Previous studies you've cited indicate that barely a third of that number enter the commercial market at all. Is nobody at BASC dealing with this sort of misinformation?

I've also seen no challenge to the spurious claims about the numbers of wildfowl allegedly harmed by lead. Do you honestly expect that when we move away from lead shot, that the populations of wildfowl will increase as significantly as implied by antis propaganda? i.e. by at least a million or so? If not, why aren't you challenging this nonsense?
What is the evidence of increases on land where shooting doesn't occur? Um...none?

We're being fed a big, fat, bullsh1t sandwich here. BASC seems to be asking for seconds.

 

[Liveonce]

Did he ever get back to you with an answer on the capacity of manufacturers to produce sufficient steel shot of the necessary types?

No.

May be basc asked the government to undertake the two year review to save face as it will then be the government that announces the ban rather than a failed voluntary ban.
The motivation is that their will be no market for game shot with lead and then it is untenable to rear game and shoot it purely for sport.

 

[Apthorpe]

No.

May be basc asked the government to undertake the two year review to save face as it will then be the government that announces the ban rather than a failed voluntary ban.
The motivation is that their will be no market for game shot with lead and then it is untenable to rear game and shoot it purely for sport.

As far as one can determine, relatively little game ever enters the market, so that argument's something of a red herring.
One could argue that the existence of a game market is in itself sufficiently objectionable to be barely tenable.

 

[Liveonce]

The economics of using non-lead shot - A letter featured in Shooting Times - Game and Wildlife Conservation Trust

www.gwct.org.uk

Quite simply shooting is becoming a rich mans sport. Non toxic Cartridges with biodegradable wads will be around the £400 mark in 12ga and even more for other gauges for live quarry shooting.

However I do think it will take a legal ban to happen, unless by some miracle all the U.K. cartridge manufactures and importers stop offering lead shot in size 7 (2.4mm) and bigger. Leaving lead only in clay pigeon shooting sizes and loads, which will currently be committing business suicide and they know that.

 

[Conor O'Gorman]

And Conor the nine organisations, how about the cartridge manufactures do they have a say?

Yes of course they do and a number of companies had their say in the recent five year transition update:

An update on the five-year transition towards sustainable ammunition

This is a five-year transition not a one-year solution, says BASC.

basc.org.uk

Shooting Star, importers of BioAmmo and Jocker:
Shooting Star are pleased to be associated with the market leaders for sustainable shooting.
We import BioAmmo of Spain and Jocker of France offering new solutions in environmentally
friendly ammunition, such as a biodegradable wad and case, and a paper shot cup. Both brands
can be loaded with steel or ‘Alternative Shot’ which is made from bismuth, aluminium, nickel and zinc.
The reviews from the press and the shooters alike have all been positive and this coming clay season
we will be promoting both products so that shooters can get a feel for the quality and performance
before they try them on live quarries.

Gamebore and Hull Cartridge Company:
As leading manufacturers of shotgun cartridges, we are continually striving to improve our
products and reduce our impact on the natural world. Over the last few years we have each invested
heavily in ensuring we can move away from lead shot and embrace emerging alternatives to plastic.
This will not be an easy transition. Technology exists to produce such cartridges on a small scale, but
there remain technological and logistical challenges ahead to ensure that we can produce the volume
of cartridges required to achieve the ambitious proposal put forward by shooting and rural organisations.
For example, it takes considerably longer to make a bio wad, than it does a traditional one.
There are big challenges to meet all of these ambitions, but our investment in research and
development continues.

Eley Hawk:
Over the last few years, we have invested significantly in new technologies that will make our
cartridges more sustainable. Moving away from lead shot and adopting certified bio-degradable
wadding, within a five year time frame, will be a significant challenge, but it is a transition that
we have already started and one we will continue working towards.

 

[Conor O'Gorman]

@Apthorpe you are replying to your own comments and presenting your earlier views as statements and then quoting your earlier statements as facts and then asking me to confirm or refute your 'facts' - it is rather difficult to disentangle in order to address your questions some of which could be quite constructive to explore. Perhaps you could email me at conor.ogorman@basc.org.uk with your BASC membership number and a list of your questions and I will try to get you answers to them all via colleagues at BASC.

 

[Liveonce]

Yes of course they do and a number of companies had their say in the recent five year transition update:

An update on the five-year transition towards sustainable ammunition

This is a five-year transition not a one-year solution, says BASC.

basc.org.uk

Shooting Star, importers of BioAmmo and Jocker:
Shooting Star are pleased to be associated with the market leaders for sustainable shooting.p
We import BioAmmo of Spain and Jocker of France offering new solutions in environmentally
friendly ammunition, such as a biodegradable wad and case, and a paper shot cup. Both brands
can be loaded with steel or ‘Alternative Shot’ which is made from bismuth, aluminium, nickel and zinc.
The reviews from the press and the shooters alike have all been positive and this coming clay season
we will be promoting both products so that shooters can get a feel for the quality and performance
before they try them on live quarries.

Gamebore and Hull Cartridge Company:
As leading manufacturers of shotgun cartridges, we are continually striving to improve our
products and reduce our impact on the natural world. Over the last few years we have each invested
heavily in ensuring we can move away from lead shot and embrace emerging alternatives to plastic.
This will not be an easy transition. Technology exists to produce such cartridges on a small scale, but
there remain technological and logistical challenges ahead to ensure that we can produce the volume
of cartridges required to achieve the ambitious proposal put forward by shooting and rural organisations.
For example, it takes considerably longer to make a bio wad, than it does a traditional one.
There are big challenges to meet all of these ambitions, but our investment in research and
development continues.

Eley Hawk:
Over the last few years, we have invested significantly in new technologies that will make our
cartridges more sustainable. Moving away from lead shot and adopting certified bio-degradable
wadding, within a five year time frame, will be a significant challenge, but it is a transition that
we have already started and one we will continue working towards.

Thanks Conor, but what is the definition of a biodegradable wad? My understanding is that the bioammo is made from bioplastic which is now being used in the packaging industry because it degrades when composted in land fill tips but does not degrade when just lying on the surface of a grass field.

Eley apparently are manufacturing theirs (and Rio’s) in Spain because the humidity is low and the wads are very hydroscopic.

Then the quantity of all these cartridges is tiny compared to traditional lead offerings and in what 12ga and 20ga.

Looks like a nail in the coffin for the other U.K. manufactures, if unable to source biodegradable wads from the limited capacity available from the one manufacture in the EU.

Then you have the not insignificant increase in price you expect all live quarry shooters to pay.

“It takes considerably longer to make a bio wad, than it does a traditional one.”

As it does to make steel shot compared to lead shot.

Aluminium shot, really for live quarry shooting, pull the other leg it’s got bells on it

 

[Liveonce]

@Apthorpe you are replying to your own comments and presenting your earlier views as statements and then quoting your earlier statements as facts and then asking me to confirm or refute your 'facts' - it is rather difficult to disentangle in order to address your questions some of which could be quite constructive to explore. Perhaps you could email me at conor.ogorman@basc.org.uk with your BASC membership number and a list of your questions and I will try to get you answers to them all via colleagues at BASC.

Conor if basc has nothing to hide then the questions and answers should be public for the mutual benefit of all.

 

[timbrayford]

Just out of curiosity, why are people scapegoating BASC and the other shooting organisations for what is a long term trend in consumer tastes?

 

[Apthorpe]

Just out of curiosity, why are people scapegoating BASC and the other shooting organisations for what is a long term trend in consumer tastes?

1. Because it has very little to do with consumer tastes. What evidence is available appears to support the view that only a minor proportion of game reaches the consumer market in any form. Nothing there merits vomiting restrictions onto everybody.
2. It's not scapegoating.