I have cut and pasted this from the linked document. What must not be allowed is this proposal that a self selected coterie of so called "international athletes" be exempted from the restrictions.
I hope that all here will write to their MP and that the shooting organisations will also lobby to the effect that:
1) There must be no Animal Farm where some are more equal than others. If there is to be a ban on lead shot for outdoor target shooting then let it be a ban for all.
2) There must be compensation where shooters may surrender to the police lead shot ammunition and be paid in full the replacement cost of non-lead ammunition that is suitable in any gun that they possess lawfully that cannot use steel ammunition
THAT AS THIS MEASURE IS FOR THE WIDER BENEFIT THE INDIVIDUAL SHOOTER MUST BE COMPENSATED FOR THE COST THEY WILL INCUR AND THIS MUST ALSO INCLUDE THE COST OF ALTERING ANY GUN BY REBORING THE CHOKE AND/OR FORCING CONES AND REPROOF. THAT IF THE GUN THEN FAILS REPROOF THEN COMPENSATION FOR THE COST OF SUCH WORK PLUS THE VALUE OF THE NOW FAILED PROOF GUN MUST BE PAID.
3) That there must be compensation where shooters may surrender to the police shotguns and be paid a fair compensation value for any shotgun that cannot use steel ammunition - such as damascus barrel guns, vena contracta guns, .22 Rimfire and 9mm Rimfire shotguns, other guns where steel cannot safely be used in that gun.
IF THIS CANNOT BE AGREED TO THEN ON THE SAME BASIS AS THERE BEING A DEROGATION FOR ATHLETES THERE MUST BE A DEROGATION FOR SUCH GUNS WHICH AS ALL ARE LISTED ON A HOLDER'S SGC COULD BE DONE BY MARKING SUCH WITH AN ASTERISK. So that if stopped by any authorities with such gun and lead ammunition the SGC need merely be shown with that asterisk against that gun.
ANYWAY HERE IS WHAT I HAVE CUT AND PASTED:
The Agency for UK REACH concludes that:
• for the environment there are risks that are not adequately controlled forlead shot (primary and secondary exposure), lead bullets (secondaryexposure) and airgun ammunition (primary and secondary exposure)
• amongst consumers of high volumes of game meat that has been shot with lead ammunition (shot or bullets), there is a risk to the health of vulnerable people (young children and women of child-bearing age) that isn ot adequately controlled.
Therefore, the Agency is recommending measures to restrict the use and placing on the market of some types of lead ammunition.
Live quarry shooting (LQS)1 Live quarry shooting with shot - Restriction on the placing on the market and use
Outdoor target shooting (TS)4 Outdoor target shooting with shot - Restriction on the placing on the market and use, with a derogation for individual athletes as identified by the appropriate sporting body
When used for target shooting, lead shot will remain on the surface of the ground where there is a risk of primary poisoning to birds and livestock unless it is immediately collected, which is not considered practical based on information received from ranges during the public consultation on the Annex 15 dossier (HSE,2022).
Similarly, risk management measures are not available at most ranges tomanage the risks to soil and to livestock via secondary poisoning from target shooting.
The most effective risk management option is prohibition on the placing on the market and use of lead shot. By restricting the placing on the market of lead shot for all uses (i.e., both live quarry shooting and target shooting), the effectiveness and compliance of this restriction is increased and subsequent enforcement simplified.
Several UK shooting and rural organisations have voluntarily committed to the use of alternatives to lead shot for live quarry shooting by 2025.
The Agency is aware that the use of lead shot is specified for international competitions in some outdoor target shooting disciplines.
A derogation is proposed to allow individual athletes as identified by the appropriate sporting body to continue to train and compete with lead shot, and suppliers to continue sales of lead shot to these identified athletes.
Transition periods
A transition period for the placing on the market and use of lead shot cartridges of 5years is proposed.
This is based on information provided by manufacturers on reasonable timescales required to scale up production to replace the amount of lead shot currently on the market. This transition period would apply to all uses of lead shot.
Existing voluntary commitments by several UK shooting and rural organisations to use alternatives to lead shot by 2025 for live quarry shooting could still reduce the risks arising from this use during this period, although the Agency notes that these voluntary commitments were not supported by shot manufacturers, who indicated that 2025 would not be achievable for them.
As such, the intended outcomes of the proposed restriction text are outlined below:
- The use of lead shot for live quarry shooting would be prohibited.
- The use of lead shot for target shooting would be prohibited.
However, a derogation will allow for a small number of athletes, as identified by the appropriate sporting body (for example British Shooting), that are required to continue shooting lead shot for the purposes of international competition and training.
- The sale or trade of lead shot (for a price or otherwise) would be prohibited.
However, a derogation will allow for those athletes referenced above to continue to source the lead shot required for international competition and training.
4.4.2.1.1 Shooter substitution costs
The Agency anticipates that, under a restriction on LQS with lead shot, a variety of costs would occur directly to shooters in moving away from lead shot to alternative shot. These costs can be classified as either one-off or on-going costs.
The Agency assumes that all shotguns in current use that can use steel shot do use it in the event of restriction. Steel shot has a significantly lower unit price than bismuth shot (and slightly lower than lead shot), in addition to performing similarly to lead. As such, the Agency does not see a rationale for a shooter choosing bismuth shot if they are able to use steel in their gun(s).
The Agency assumes that 73% of shotguns in use can instantly switch to(standard) steel shot without modification or re-proof.
Additionally, the Agency assumes that a further 5% of shotguns in use could use steel shot following modification.
4.4.2.1.3 Climate impacts
The Agency uses emissions factors (EF) provided by the Bureau of International Recycling (BIR, (2008)) to estimate the resulting change in greenhouse gas (GHG)emissions from a transition from lead shot to alternatives.
The worst-case scenario in terms of climate impacts is one where lead shot, under the baseline, is domestically produced entirely from recycled lead, and under a restriction steel shot is produced from 100% primarily produced steel imported from afar (presumed to be China based on information submitted by Blake International,2022 Organisation #132) (Hurley, 2022).
Under this worst-case scenario, the Agency estimates that a restriction will result in 2,239t CO2/annum compared to 286t CO2/annum under the baseline (from 2025onwards). This equals an annual addition of 1,954t CO2, roughly equal to the average annual carbon footprint of 210 UK citizens (WWF, 2023).
Derogations have been proposed to allow identified athletes to train and compete without obstruction. However, others who aspire to reach that level could be hampered by the inability to train with lead shot which is required for use in international competitions. The Agency will continue to engage with the relevant sporting bodies which are responsible for the selection of the athletes, to help ensure that the correct balance between environmental protection and competitive British shooting is maintained.
It is expected that there will be occasions where GB host international competitions(such as the Olympics) whereby overseas competitors will be required to shoot lead.For these short and infrequent periods of time, the relevant sporting bodies are likely to temporarily specify more athletes under the derogation.
4.6 Potential unintended consequences
It could be a transition period does not give time to gain access to replacement shot before the use of lead shot is restricted. Those using shot will have to stop shooting instead of running the risk of buying lead ammunition which they will be unable to use within a certain time period, or else be out of pocket for this ammunition.
