All means all, including target sports
I pay little attention to the REACH UK consultation. I see no prospect that what REACH UK does will be in any material way different from what will be put forward by ECHA, following the ongoing consultation, voted on by the EU Parliament, then legislated by REACH (EU). The UK pledged to align itself with REACH on 1 Jan 2021 (Brexit). REACH UK is the newly formed dept. of our HSE, now needed because we can no longer use the EHCA to do the hard work for us to maintain alignment. I expect that the personnel involved (if we have enough suitably qualified people interested in doing the work) will be on a very steep learning curve at the moment.
I suppose, in the worst case, REACH UK could take the lazy approach and just go for a 100% lead ban for the UK, regardless of the consequences, but surely they won't be that stupid ? I sincerely doubt either that REACH UK will instead opt for laxer rules for the UK than the EU, legally they cannot anyway.
What actually matters is the ECHA review, all in play there at the moment. I have commented about that on other threads. Suffice it to say that the ECHA review does not consider banning lead from projectiles (bullets and shot) used in target shooting in contained environments. Indoor range shooting, clay shooting on formal grounds etc.
The starting point was, yes, a total lead ban. But already some exceptions are agreed for formal target shooting, and the door is open for further derogations as the consultation and followup emerge. It is all in play still.
My thoughts on the relevance (or not) of the UK REACH consultation:
Sorry, what I you trying to tell me by this?? That you were all proved right? With last year’s announcement the became a self fulfilling prophecy. Either way, what ha it got to do with me shooting foxes with lead bullets or rabbits that don’t enter the food chain? because you and the other 8...
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My understanding of the ECHA consultation proceedings and timescales:
@Sharpie please visit the FACE website for more information on the work that has been taking place on these proposals. Also, the meaningful deadline for submissions is 5 May. Re. deadlines: I am pleased to hear that you, BASC, or the BSSC that you mentioned previously, or is it just FACE (the...
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The consultation considers not just toxicity, but socio-economic impacts, and their proportionality.
I have posted copious references on that thread for those who wish to take an informed interest in developments, rather than just indulge in speculation
I would expect (hope) that our big cartridge manufacturers will be making strong submissions directly to the ECHA consultation, or have already done so. As will the EU ones.
Finally, I see, as yet, no technical alternative to continuing to use soft lead in .22LR subsonics, which can and do expand significantly, in real life use (photo examples on another thread here) Bismuth alloys are a brittle material, OK for shotgun shot which is required to remain intact. Tungsten matrix, or Tungsten/iron, likewise, though less brittle, and shockingly expensive. Copper, or alloys are three times or more harder than lead, any expansion has to be engineered into them somehow.