Lead ammunition - BASC statement in response to RSPB and WWT open letter

[Frank Homes]

So, in that context, what uses of lead ammunition will the HSE consider nil or negligible risks for people, wildlife or the environment and might thereby leave alone in their risk assessment? Not much, if the EU REACH restriction proposals published in February last year are anything to go by and which in summary (copy and pasted from weblink below) were as follows:

• ban on the sale and use of lead gunshot (with a five-year transition period). As current Olympic rules specify the use of lead ammunition for certain disciplines, ECHA also considered an optional derogation for use of lead gunshot for sports shooting only under strict conditions, i.e. when releases to the environment are minimised.
• ban on the use of lead in bullets and other projectiles (small calibre: five-year; large calibre: 18-month transition periods). Derogations for continued use if releases to the environment are minimised, i.e. when sports shooting ranges are equipped with bullet traps.

All news - ECHA

The European Chemicals Agency brings forward a proposal for further EU-wide restrictions on the use of lead in ammunition for hunting and outdoor sports shooting as well as in fishing. The proposal aims to address the risks of lead in these activities to protect people, wildlife and the environment.

echa.europa.eu

I thought we had left the EU, why the need to refer to what the EU does?

 

[Whitefront]

Sadly, a lot of public officials have made a career out of gold-plating EU-derived legislation, practices and conventions. They won't give it up just because the public had the temerity to vote to leave the EU.

 

[StephenToast]

There must be NO derogation for shotgun using "Olympic Sports". If this costs Team Great Britain a place on the medals podium in Paris in 2024 then let it be so. There should be no "officers only" "all animals are equal but some animals are more equal than others" nonsense. Let the Olympic shooters also suffer the ban because they've been bloody well silent about any opposition to it so far. So let them reap that harvest too.

The olympic shooters can just shoot steel so I'm not sure why they should get any special dispensation.

 

[Conor O'Gorman]

What have you as an organisation done to evaluate ‘the evidence’ ?

The shooting communities' best scientists at the GWCT have evaluated the evidence on the impacts of lead ammunition on wildlife, people and the environment.

Lead Ammunition - Game and Wildlife Conservation Trust

www.gwct.org.uk

I thought we had left the EU, why the need to refer to what the EU does?

We continue to follow EU laws until we deviate from them and there is a NI protocol to consider. As regards lead ammunition we have a new post-Brexit chemical regulations process that mirrors the one in the EU. The UK REACH proposals in the next 10 days may mirror the EU REACH proposals from last year. And the UK REACH proposals will affect England, Wales and Scotland. Policy developments on lead ammunition for NI follow the EU REACH process due to the NI protocol.

UK REACH explained - HSE

www.hse.gov.uk

For the latest on the EU REACH proposals see:

FACE | 1 IN 4 HUNTERS WILL STOP HUNTING IF PROPOSED BAN ON LEAD AMMUNITION BECOMES A REALITY

www.face.eu

 

[Liveonce]

So 1 in 4 hunters will stop hunting, exactly what the like of WJ want.

we want a headline like ban lead and another 5 million will start hunting as wild meat is then the most healthy of the lot.

 

[Liveonce]

The shooting communities' best scientists at the GWCT have evaluated the evidence on the impacts of lead ammunition on wildlife, people and the environment.

If our best scientists could not step forward to show the impact of lead when confined in small areas like indoor / outdoor ranges and clay grounds is negligible then we need new scientists.

 

[25 Sharps]

The shooting communities' best scientists at the GWCT have evaluated the evidence on the impacts of lead ammunition on wildlife, people and the environment.

If our best scientists could not step forward to show the impact of lead when confined in small areas like indoor / outdoor ranges and clay grounds is negligible then we need new scientists.

They are only interested in game shooting (ring any bells?!), to be honest the NRA need to step up, if target shooting is affected then hopefully they will but we will see over the net month or two I guess!

 

[Dunwaters]

In summary.
UK REACH proposals will most likely mirror EU REACH, which will mean a presumption against lead use unless theres no alternative.Thats “no alternative” an expensive alternative is an alternative.
REACH proposals are based on the medical and scientific advice that there is no safe level of lead ingestion for people or animals.
EU and UK proposals are going to be pretty tightly aligned.
I think we can agree that the voluntary process, the 5 year transition plan, is now dead in the water, there’ll be a regulatory policy and response which will render it useless, the only purpose its serving is to confuse the issue as both processes are bobbing along independently.
One single process that we can all understand and engage with please.
The lead ban is going to be pretty much all inclusive for ammunition, there’ll most likely be a long delay between implementation of the ban and commercial availability of alternatives for some minority use/specialised firearms
We’ll be doing well to hang on to the .22 rimfire, really specialist uses, like muzzle loading/black powder may well be lost.
When the ban does come it’ll be a fairly swift transition, even if you stock pile old stock you won’t be allowed to use it as most shooting grounds will stipulate non lead.
Not a pretty prospect, but it is what it is, once you rowed in behind REACH the writing was on the wall.

 

[enfieldspares]

It will also pretty much kill dead the use of historic pistols of s7.3 as these will have been designed for lead bullets or lead jacketed bullets.

 

[Dunwaters]

It will also pretty much kill dead the use of historic pistols of s7.3 as these will have been designed for lead bullets or lead jacketed bullets.

It’s going to effectively kill off just about any minority firearm use that’s lead dependent.
I’d be willing to bet that most shooting ground and ranges will be forced to go lead free.
Once you go down the REACH road which is guided by the medical advice which in turn says no safe levels of lead, there’s only going to be one outcome.

 

[Conor O'Gorman]

The restriction proposals published in the next 9 days and the 6 months of consultation that follows is not the end of the UK REACH process. That is the first stage – looking namely at the risks and the proposed restrictions to reduce those risks.

There will follow a socio-economic assessment of those proposals, which will be publicly consulted on.

Also over the next 12 months there will also be stakeholder consultations and BASC will be involved in that.

Around this time next year a report with the findings goes to the Secretary of State for consideration.

The last review was by the Lead Ammunition Group and in 2016 the Secretary of State decided that the report with the findings did not show that the impacts of lead ammunition were significant enough to justify changing government policy.

 

[enfieldspares]

The restriction proposals published in the next 9 days and the 6 months of consultation that follows is not the end of the UK REACH process. That is the first stage – looking namely at the risks and the proposed restrictions to reduce those risks.

There will follow a socio-economic assessment of those proposals, which will be publicly consulted on.

Also over the next 12 months there will also be stakeholder consultations and BASC will be involved in that.

Around this time next year a report with the findings goes to the Secretary of State for consideration.

The last review was by the Lead Ammunition Group and in 2016 the Secretary of State decided that the report with the findings did not show that the impacts of lead ammunition were significant enough to justify changing government policy.

Just, please, remind us who was the chairman of the LAG?

 

[Dunwaters]

The restriction proposals published in the next 9 days and the 6 months of consultation that follows is not the end of the UK REACH process. That is the first stage – looking namely at the risks and the proposed restrictions to reduce those risks.

There will follow a socio-economic assessment of those proposals, which will be publicly consulted on.

Also over the next 12 months there will also be stakeholder consultations and BASC will be involved in that.

Around this time next year a report with the findings goes to the Secretary of State for consideration.

The last review was by the Lead Ammunition Group and in 2016 the Secretary of State decided that the report with the findings did not show that the impacts of lead ammunition were significant enough to justify changing government policy.

Your in new territory now Conor, REACH, if it follows the EU model, is looking to minimise the impact of lead in the environment based on a zero safe level as advised by the medical and environmental experts.
They are going to restrict its use and minimise exceptions achieve this goal.
They will also ban the “sale, possession and use “ of banned lead ammunition after the implementation date.

Has UK REACH followed the EU model and also requested that lead weights be banned for non commercial anglers?

In light of the rapidly evolving legislative process to ban and restrict the use of lead, do you intend to continue with the parallel but uncoordinated voluntary process?

 

[Liveonce]

Reach you own conclusions to this and the publication timing.

More high lead levels in Waitrose game meat - Wild Justice

The story so far: Lead is a poison and has been removed from many formerly common uses such as for […]

wildjustice.org.uk

 

[Dunwaters]

You can’t really fault their findings and I think it’s a fair point that there are no limits to lead contamination in game for human consumption.
The problem is that there’s a gaping hole between what’s been promised in the voluntary transition and what’s actually happening, have a look at Conor’s OP and attachments and my reply.
There has been no response to the issues I raised to date.

 

[Conor O'Gorman]

@dunwater you were asking about the voluntary transition away from lead and single-use plastics in ammunition used by those taking all live quarry with shotguns.

Here is a joint statement in 2020 by 9 organisations:

A joint statement on the future of shotgun ammunition for live quarry shooting - Game and Wildlife Conservation Trust

www.gwct.org.uk

Here is an update in 2022:

The lead shot transition: solid progress on the ground

A new study purports to show the voluntary transition away from lead shot for live quarry shooting to be in stagnation, despite progress on the ground.

basc.org.uk

The voluntary transition continues. There are no legislative proposals as yet. That may change. Or it may not. Are there spreadsheets and plans? Yes. And there are numerous things happening in parallel. UK REACH. EU REACH. NI protocol for Brexit. Devolved powers (Wales, Scotland and NI may make their own rules on lead ammunition). Market forces for ammunition. Cultural change. Lobbying for immediate bans in Westminster and devolved governments. Policy developments on single-use plastics. And so on.

I hope that helps address your queries.

May I ask if you are a member of a shooting organisation involved in the voluntary transition?

 

[Dunwaters]

@dunwater you were asking about the voluntary transition away from lead and single-use plastics in ammunition used by those taking all live quarry with shotguns.

Here is a joint statement in 2020 by 9 organisations:

A joint statement on the future of shotgun ammunition for live quarry shooting - Game and Wildlife Conservation Trust

www.gwct.org.uk

Here is an update in 2022:

The lead shot transition: solid progress on the ground

A new study purports to show the voluntary transition away from lead shot for live quarry shooting to be in stagnation, despite progress on the ground.

basc.org.uk

The voluntary transition continues. There are no legislative proposals as yet. That may change. Or it may not. Are there spreadsheets and plans? Yes. And there are numerous things happening in parallel. UK REACH. EU REACH. NI protocol for Brexit. Devolved powers (Wales, Scotland and NI may make their own rules on lead ammunition). Market forces for ammunition. Cultural change. Lobbying for immediate bans in Westminster and devolved governments. Policy developments on single-use plastics. And so on.

I hope that helps address your queries.

May I ask if you are a member of a shooting organisation involved in the voluntary transition?

Thank you Conor.
I’m resident in the ROI, so we will be directly affected by REACH, however all of our ammunition is imported, primarily from UK and EU so we will be affected by changes in both markets.
I am a member of CA and NARGC and I’ve been following the lead debate for the last 30 years or so.
From what I can see the debate ended and we were left facing a struggle to salvage what we could from a complete ban once REACH referred the issue to the Ammunition group instructing them to review the use of lead ammunition given that there is no safe level and that therefore EU policy was zero lead.
That policy change at EU level has changed the landscape completely for all of us. There is now an official bias against the continued use of lead and that attitude is likely to become UK policy too.
From being stalled and fought at every stage in every country the banning of lead will now progress rapidly, to believe otherwise is to delude ourselves.
Interesting times.

 

[Ratel]

when the next hurdle comes after the lead ban (not that if affects mw!) comes along i will find a solution and I will carry on a little longer to the point where I’m completely hacked off with it and then I shall call it a day!

I don't think you will find a solution to the next hurdle, and you won't get the chance to call it a day, the Govt will do it for you.

 

[Ratel]

What does make me laugh, on one piece of ground I shoot this guy always turns up within 1 minute of a rifle shot, red kite, he’s been doing this for at least 4 years and presumably feeding on the gralloch.

Why is he not dead?
(Photo taken Sunday morning straight after shooting a Munti doe)

View attachment 252953

He's not dead because raptors have been eating lead shot grallochs etc for centuries. Their numbers now are the highest they have ever been. From dieldrin in the 40s and 50's and the massacre of peregrine's in WW2 the recovery and numbers of raptors is amazing, and far in excess of previous numbers. As I write this 4 kites are circling over the pond on the adjacent land, where they continually take broods of day old mallard.

 

[Kersnow]

They are only interested in game shooting (ring any bells?!), to be honest the NRA need to step up, if target shooting is affected then hopefully they will but we will see over the net month or two I guess!

Why have a dig at the GWCT, they do very valuable work, surely the representative bodies for indoor range users etc. should be contributing something?