Dear
@Conor O'Gorman , I have looked at your webpage talking about this, and frankly found it pretty poor, borderline illiterate.
Who writes this stuff for you ?
I am a man who studies facts, data and evidence. Hopefully dispassionately. With a clear judgement.
So, let's unfold some of what you have just put up (literally unfold, you have to click on the down arrow to reveal it, so I can't post a direct weblink. Focussing on "
Where is the evidence? What are the risks identified through UK REACH that led to the proposed restrictions?"
"
Use title" what does that mean in proper English. Use case maybe. "E
stimated release to the environment (tonner per year)" You might want to fix that speeling misteake. "s
hot shell ammunition" I'm sorry but hereabouts we shoot cartridges. For shotgun, or rifle, by prefix.
What is a "shot shell BTW, I'd like to know how to recognise such a thing to differentiate it from an expended casing made from "single use" but eminently re-cyclable plastic"? As opposed to shotgun plaswads, which by their nature are single use. Whether "bio" or not. Entirely necessary for steel (soft iron) shot, as opposed to felt and cork construction that works for lead.
There is dichotomy going on, the only realistic alternative to lead, steel, for shotgunners, mandates the use of fully enclosed shot cups, rather than traditional wads made from felt and cork. Such pieces have to be engineered, difficult enough, even before considering bio-eco credentials.
But then we get on to how "bio" are the bio/eco/green whatever things, really, in the natural environment rather than a test lab. I've done my own experiments and found all of them lacking, except for a shot-cup made from cardboard/wood pulp. Loaded over felt and cork. Problem is that you can't patent cardboard. Or give it a whizzy name to differentiate your offering. For superior performance you need highly engineered products, which means plastic injection moulding, using whatever feedstock.
Nevertheless let me summarise these figures:, as provided by BASC, in "tonner" per year: If indeed the author has divined this properly. But seems awfully precise, down to 0.01%
Hunting with "shot shell" 6,567 "tonner" per year
Sports shooting (clays?) 1,680. I'd say that was a drastic under-estimate, and little of it recovered and recycled.
Hunting with bullets small calibre inc. airguns 14.5
Hunting with bullets large calibre, no data provided WTF ? Isn't this rather important ? Though I do not expect it to be very much
Outdoor sport shooting with bullets, 26.8
So, who are the bad boys here ? Well I do not think that it is we rifle shooters, either hunting (minimal impact and some of us are already using non-lead alternatives for ethical, and indeed practical reasons such as wanting to sell it to AGHEs, or target (probably much more). So, pretty please, leave us alone.
BASC does not purport to represent rifle shooters AFAIK, indeed Conor, you have said so yourself, that's down to another, or others, organisation.
ISTM that UK REACH are jumping the gun with all this, possibly some personalities anti-everything at the core. EU REACH will slowly come to some conclusion, with which we will certainly have to align, but that is dragging on rather.
As for the BASC "voluntary transition period", sorry but that does not seem to me to be turning out well, nigh on two and a half years in, nor much supported except for lip service by the real players (manufacturers of shotgun ammunition).
18 months or five more years ?