HSE lead ammo proposals - FAQs and updates

Conor O'Gorman

Well-Known Member
Official Member
@Apthorpe further follow-up on your query

The research at Cranfield has lead us to move away from a 2 shot size increase to a 1-2 size increase as the penetration benefit was negligible.

Lead vs steel - a question of lethality - The British Association for Shooting and Conservation

We are now recommending the 21g limit for older guns since recently meeting with the Birmingham proof house.

The table on page 7 is correct. It relates to high-performance steel as detailed in the text next to it.

This is CIP guidance which is related to high performance steel (CIP make no recommendations on chokes for standard steel loads – doubtful you can get a standard steel load in #2 at any rate. A standard steel load should be a shot diameter of 3.25mm or smaller).

The guidance states the choke requirement for certain diameter steel shot and larger, which is outlined in the table.

In relation to number of pellets, steel is less dense than lead, and therefore for a given cartridge weight, a steel cartridge will contain more shot that a lead load. So a lighter lead load will contain more pellets than one might assume.

We will continue to update and revise our advice to take account of new research, information and products.
 

Bowland blades

Well-Known Member
Why has the elephant in the room not been addressed?

Bans don't work if the majority choose not to comply, making enforcement either impractical/impossible or even counter productive if implementation is found to encourage further non-compliance... CV19 rules anyone? :stir:

With the rate that the UK government does U-turns or abandons ideas and never speak of them again, my level of concern is diminshing by the day.

Hope everyone has stopped burning 'wet wood', it'a banned you know!!! :rofl:
Oh, People have been prosecuted for using lead on Foreshore and more have been thrown out their club then black balled by the others . Thing is you can cast lead but as for making quality copper jacketed lead its not easy and get caught when its banned kiss goodbye to your FAC
Steel shot is perfectly good and i have shot thousands at wildfowl and pests . Only problem ? roost shooting in the wood last night i had to stop once i ran out of lead because ricochet is far more likely ( I have however found Barnes TTSX 6.5 100 grains less likely to ricochet after passing through even big stags i am finding many fully expanded bullets on the ground . A short skid in the grass and there is the bullet ( like i little palm tree 100% weight retention unless one petal is broken off on bone
 

Apthorpe

Well-Known Member
Thanks @Apthorpe

I have asked colleagues about your query on the refs to shot sizes and choke in the "Moving away from lead shot" booklet.


The five year voluntary transition is for lead shot and single use plastic in shotgun cartridges for live quarry shooting. The HSE proposals are for legal restrictions on lead shot, airgun pellets and bullets for live quarry and target shooting and we will be challenging many aspects of these proposals over the six months consultation and beyond.

The HSE process is outlined here:


"In forming opinions on whether to introduce the restrictions, HSE will engage with independent experts on the REACH Independent Scientific Expert Pool (RISEP), who will form a Challenge Panel to provide knowledge, scrutiny and challenge."

The members of the challenge panel have not yet been published and I have asked HSE for an update on this.

The role of accredited stakeholders such as BASC is interlinked with the above scrutiny. We have not received information yet on the other accredited stakeholders etc but this process will begin soon.


BASC has been consistently clear on its position since last March when the UK REACH review process was launched and in every update since then that further restrictions on lead ammunition must not be imposed until effective and affordable types of sustainable ammunition are available in sufficient volumes to meet demand.
At the point where effective and affordable types of sustainable ammunition were available in sufficient volumes, nobody rational would use lead ammunition, so restrictions on lead ammunition would be superfluous. Why is BASC saying it will support legal restrictions on shooting that are unnecessary at any time? The problem with your current position is that you’re binding yourself to supporting restrictions in principle, and are then at the mercy of someone else determining what type and quantities of ammunition are sufficient. We already see people on the shooting side making public statements that there are adequate replacements for shotgun and rifle ammunition when to a substantial degree there aren’t, and therefore the process is going to steamroll and over-ride users of various calibres and types of ammunition. They will say there are non-lead .22LR rounds and the fact that they are inadequate and largely unusable will be ignored.
I am also concerned that there is no recognition of the costs and losses to shooters of the thousands, or hundreds of thousands of guns which will be made redundant.
Further details around this are in the updates and FAQs on BASC's website here:

Thank you very much @Conor O'Gorman. Very helpful clarification on the HSE process.
 

muddy42

Well-Known Member
@Apthorpe further follow-up on your query

The research at Cranfield has lead us to move away from a 2 shot size increase to a 1-2 size increase as the penetration benefit was negligible.

Lead vs steel - a question of lethality - The British Association for Shooting and Conservation

We are now recommending the 21g limit for older guns since recently meeting with the Birmingham proof house.

The table on page 7 is correct. It relates to high-performance steel as detailed in the text next to it.

This is CIP guidance which is related to high performance steel (CIP make no recommendations on chokes for standard steel loads – doubtful you can get a standard steel load in #2 at any rate. A standard steel load should be a shot diameter of 3.25mm or smaller).

The guidance states the choke requirement for certain diameter steel shot and larger, which is outlined in the table.

In relation to number of pellets, steel is less dense than lead, and therefore for a given cartridge weight, a steel cartridge will contain more shot that a lead load. So a lighter lead load will contain more pellets than one might assume.

We will continue to update and revise our advice to take account of new research, information and products.

Conor can you elaborate on this "21g limit for older guns? I can't find this advice on the BASC website.
Are you saying that for older guns proofed before 1954, with wide chokes, the maximum load of steel that can be fired safely is 21g ? Does that apply to all shot sizes and wad types?
Thanks.
 

Apthorpe

Well-Known Member
@Apthorpe further follow-up on your query

The research at Cranfield has lead us to move away from a 2 shot size increase to a 1-2 size increase as the penetration benefit was negligible.

Lead vs steel - a question of lethality - The British Association for Shooting and Conservation
That’s an interesting link, and very helpful to see. That is persuasive that 3 shot steel is a good swap for 5 lead on penetration. I don’t see how it supports the change, but perhaps the study was more extensive and included other tests you haven’t published?
We are now recommending the 21g limit for older guns since recently meeting with the Birmingham proof house.

The table on page 7 is correct. It relates to high-performance steel as detailed in the text next to it.
I can see that now but think that the table would benefit from explicit labelling. I had to read the document in detail three times before it was clear to me. A lot of readers could make a very dangerous mistake.
This is CIP guidance which is related to high performance steel (CIP make no recommendations on chokes for standard steel loads – doubtful you can get a standard steel load in #2 at any rate. A standard steel load should be a shot diameter of 3.25mm or smaller).
Hang on? So there is never going to be a standard steel alternative available suitable for fox? Do farmers know that this renders most of their shotguns redundant?
So a standard older gun will in future never be useable on goose, fox or anything else we used sizes 2 through to AAA for? You kept quiet about that!
The guidance states the choke requirement for certain diameter steel shot and larger, which is outlined in the table.
I understand, but for say number 3 shot, there is no choke restriction after all?
In relation to number of pellets, steel is less dense than lead, and therefore for a given cartridge weight, a steel cartridge will contain more shot that a lead load. So a lighter lead load will contain more pellets than one might assume.
This is muddled and loses its way. For a given cartridge weight AND SHOT SIZE, a steel cartridge would contain more shot. However, not when you move up 2 shot sizes, and not when you are restricted as to the load weight.

I looked up the relevant tables and the numbers I quoted are correct.

BASC has substantially added to the confusion and misinformation swirling around this. Allow me to clarify.
1. Standard steel cartridges 2 sizes larger match performance of lead despite inferior calculated ballistics. Yes. The link provides clear objective data showing this beyond sensible doubt any more.
2. Standard steel shot, in fact, will only replace lead for lead shot sizes 4 to 5 and larger. What is news is that if one used size 3 lead or larger cartridges in a standard proofed gun, you now need to buy a new gun? Correct?
3. The choke recommendations are muddled. CIP and UK proof authorities do not have the same advice. UK proof authorities proofed the guns (post 1954) to the standard CIP specifies its ammunition for, yet the two authorities cannot provide consistent safety advice to the user. This means that following the information printed on the box of cartridges is not necessarily safe. Information on ammo follows CIP, right?
4. BASC has published that standard guns can be used with standard steel to shoot pheasants safely. This is on the strength of a study where 1000 rounds of 24g steel were fired through older guns. Other results from the same study, if I remember correctly (Cranfield 1991?), showed extremely rapid damage with normal weight loads.
5. Does BASC recommend 21 and 24g loads of standard steel as being ideal for use on pheasants, because this is what your publications are implying we use? I find this circle hard to square. Conventional advice for a century is to use a cartridge with 230-300+ pellets to give humane and effective patterns. Steel patterns a bit better, but fewer than 120 pellets is a very radical departure from universally accepted wisdom. This implies a minimum of 83% (rounded down) of size 3 (or 4, if any substantiation for the one-size shift is found) pellets in a 30 inch circle at 40m using less than half-choke. Does your team have data or test results showing that sort of grouping in practice?
We will continue to update and revise our advice to take account of new research, information and products.
@Conor O'Gorman Again, thank you very much.

Replies above.
 

Conor O'Gorman

Well-Known Member
Official Member
Im not sure why you continue to ask to take the conversation offline Conor, what could be said between us is surely a matter for public interest ?
My 'concerns' as clearly stated are , what changed BASCs position after 2016 ?
Why in less than 4 years, were you proposing to phase out lead shot for live quarry, with no new studies done, no government push (at that time ) to restrict it, completely off your own bat , YOU proposed it , why ?
You could say , 'Well the writing was on the wall, the EU were going to do it , so BASC decided to make it known , without consulting the 150,000 members , that we were going to be good Europeans and do it too' ?

What new studies are the UK government using to justify the pretty extensive ban, from what I can see , they are using the same (vague) studies that preceded 2016, that resulted in a refusal to ban lead ?

Are we simply following the EU in our laws , despite them being inapplicable to UK law now weve left ?
What are other EU countries doing to fight it, have any other European shooting orgs proposed a phase out ?

The language I have seen coming from yourself and BASC lately, suggests that you agree with many of the proposals.
You suggest lead is 'highly toxic' and needs removing from the human food chain, you agree with the 100,000 birds a year dying from lead poisoning report , despite there being NO evidence of its veracity.
Forgive me if I dont believe yourself or BASC, really have any faith in 'the fight'

In fact , Ill go as far as to say , BASC has been the trojan horse that has driven this legislation to the fore.....

So you keep saying , yet what influence do you have on ammunition manufacture ?
The cartridge manufacturers in the UK have had no dialogue with BASC, they have stated fairly plainly they feel somewhat betrayed, and cannot develop and produce alternatives in the predicted time that we likely have.
So when you tell the government that they cant impose the ban until cartridge manufacturers catch up, what do you reckon are the chances of that happening ?

Lastly , are you willing to state how many members BASC have lost in the last couple of years ?
@Rewulf I thought a chat on the phone might be informative for us both given your interest in BASC? I read comments and post on this forum (for 10 years now!) to gain insights on people's views on various policy issues and I do try to take account of those in my work, especially for government consultations. But I find it helpful to also talk to SD members on occasion but no worries if that's not for you.

As regards the voluntary transition away from the use of lead shot and single use plastics in shotgun cartridges use for live quarry shooting announced in 2020 by the shooting organisations that was a strategic decision with the reasons outlined here:


And there is a recent update here:


The evidence has been analysed by scientists at GWCT and continues to be analysed and I trust their judgement. Do you? It's here:


The HSE proposals go too far, we have been clear about that, and we will challenge them in our response and there will be updates on that. We have also been clear that if after this consultation and others to come that we are not happy with the findings and recommendations that are submitted to the secretary of state, that we will challenge that. As per 2016.

BASC membership figures are published every year in the annual report and accounts. We currently have 150,000 members
 

NullMac

Well-Known Member
No your not, you’re still tied in to EU standards, agreements and directives, which is why your REACH proposals mirror the EU document.
We are not tied to EU standards. We have reached agreement that we will mirror some standards. A load of powers have returned to Westminster.

We can choose to renegotiate what we want when we want. EU may not like it and may well decide to retaliate but that is up to them.

It is only a deal. We can decide to go our own way as and when. We are not part of the EU and are not bound by anything that the EU decides of it’s own accord without reference to us. Those days are gone. You are, we are not.

Have a look at what is happening to the NI Protocol. That is how tied we are. Not.
 

Sharpie

Well-Known Member
We are not tied to EU standards. We have reached agreement that we will mirror some standards. A load of powers have returned to Westminster.

We can choose to renegotiate what we want when we want. EU may not like it and may well decide to retaliate but that is up to them.

It is only a deal. We can decide to go our own way as and when. We are not part of the EU and are not bound by anything that the EU decides of it’s own accord without reference to us. Those days are gone. You are, we are not.

Have a look at what is happening to the NI Protocol. That is how tied we are. Not.
I have been bighting my tongue about this @dunwater , not that this has anything to do with shotgun ammunition

As it happens I do have deep roots into Ireland, and that small colony up North that we will continue to recognise and subsidise for all sorts of good reasons Heck yes, the kids can play about in Stormont now again, until they once again get out of order. Which they will. Then probably have to be slapped down yet again.

TBH any intelligent Irish person, wishing their kids a good future will send them away, probably never to return. I should know, being godparent to a few, responsible for their moral guidance, and some practical instruction regarding rubber johnnies and so on. They have turned out well.

It is a natural process, the brightest and best have always moved elsewhere, leaving behind a reduced gene-pool of the more or less dim-witted

I do subscribe to the Irish Times, and much of what I read beggars belief. Corruption, venality, the Garda Síochána , the church and state, You have had your good years in the EU, a Tiger Economy" no less, but your roads are still useless.

Sure, you have come up with some very dodgy tax breaks for global companies to exploit, and give nothing back, but hey-ho it makes you look bigger than you actually are.

Last road trip I took started off in the Mountains of Mourne, then all the way back to my old stamping grounds of West Cork and some sailing out of Kinsale. With a few days in Dublin along the way

Oh, the big man, (13th child of his mother) who introduced me to this lives in Belfast (amongst other places). He won't carry a pistol for personal protection despite urgings from the police, but pays others to look after him, and his loved ones. He has an aversion to firearms of whatever description., possibly having seen the results of their usage. He is a hard man who can still handle himself. And ruthless in business.

The "marching season" is coming soon enough. Nothing like a bit of sectarian violence to stir your spirits. The man will probably be at his place in Portugal for the duration, Might pop in for a chinwag and some first class nosh.
 

Utectok

Well-Known Member
People ONLY use lead ammunition because there are not suitable alternatives for their purposes.
Have you ever shot lead alternative ammo you sound very knowledgeable on the subject?
My experience brings into question the above statement at least for larger shotguns and cf rifles.
 

dunwater

Well-Known Member
We are not tied to EU standards. We have reached agreement that we will mirror some standards. A load of powers have returned to Westminster.

We can choose to renegotiate what we want when we want. EU may not like it and may well decide to retaliate but that is up to them.

It is only a deal. We can decide to go our own way as and when. We are not part of the EU and are not bound by anything that the EU decides of it’s own accord without reference to us. Those days are gone. You are, we are not.

Have a look at what is happening to the NI Protocol. That is how tied we are. Not.
If you have a deal it’s dependent on your compliance with the terms and conditions agreed between the parties.
You cannot unilaterally decide to abandon or renegotiate the deal whenever it suits you.
 

Rewulf

Well-Known Member
You cannot unilaterally decide to abandon or renegotiate the deal whenever it suits you.
Why not?
The EU does it all the time, bends it's own rules, ignores a lot of them.... As a corrupt entity, its up there with the best of them, there's talk of letting Ukraine join, even though it doesn't meet moral or economic criteria?
If Brussels don't like something we do, they can renegotiate too, trade between us is a 2 way street, with most of the benefits their way.
 

dunwater

Well-Known Member
Why not?
The EU does it all the time, bends it's own rules, ignores a lot of them.... As a corrupt entity, its up there with the best of them, there's talk of letting Ukraine join, even though it doesn't meet moral or economic criteria?
If Brussels don't like something we do, they can renegotiate too, trade between us is a 2 way street, with most of the benefits their way.
Your attitude would hardly inspire confidence in future potential trade negotiations.
Waive the rules if you want, your choice.
 

dunwater

Well-Known Member
I have been bighting my tongue about this @dunwater , not that this has anything to do with shotgun ammunition

As it happens I do have deep roots into Ireland, and that small colony up North that we will continue to recognise and subsidise for all sorts of good reasons Heck yes, the kids can play about in Stormont now again, until they once again get out of order. Which they will. Then probably have to be slapped down yet again.

TBH any intelligent Irish person, wishing their kids a good future will send them away, probably never to return. I should know, being godparent to a few, responsible for their moral guidance, and some practical instruction regarding rubber johnnies and so on. They have turned out well.

It is a natural process, the brightest and best have always moved elsewhere, leaving behind a reduced gene-pool of the more or less dim-witted

I do subscribe to the Irish Times, and much of what I read beggars belief. Corruption, venality, the Garda Síochána , the church and state, You have had your good years in the EU, a Tiger Economy" no less, but your roads are still useless.

Sure, you have come up with some very dodgy tax breaks for global companies to exploit, and give nothing back, but hey-ho it makes you look bigger than you actually are.

Last road trip I took started off in the Mountains of Mourne, then all the way back to my old stamping grounds of West Cork and some sailing out of Kinsale. With a few days in Dublin along the way

Oh, the big man, (13th child of his mother) who introduced me to this lives in Belfast (amongst other places). He won't carry a pistol for personal protection despite urgings from the police, but pays others to look after him, and his loved ones. He has an aversion to firearms of whatever description., possibly having seen the results of their usage. He is a hard man who can still handle himself. And ruthless in business.

The "marching season" is coming soon enough. Nothing like a bit of sectarian violence to stir your spirits. The man will probably be at his place in Portugal for the duration, Might pop in for a chinwag and some first class nosh.
I never said we were perfect, poke around and people are the same pretty much all over the planet.
We have more than our fair share of gobshites, but don’t go blaming us for Northern Ireland. Your government created it and supports it.
We might aspire to have them join us but until that happens it’s all yours.
 

griff

Well-Known Member
We are not tied to EU standards. We have reached agreement that we will mirror some standards. A load of powers have returned to Westminster.

We can choose to renegotiate what we want when we want. EU may not like it and may well decide to retaliate but that is up to them.

It is only a deal. We can decide to go our own way as and when. We are not part of the EU and are not bound by anything that the EU decides of it’s own accord without reference to us. Those days are gone. You are, we are not.

Have a look at what is happening to the NI Protocol. That is how tied we are. Not.
The problem lies in our exports, if the EU decides to implement a ban on lead then our exports as in Venison would not meet the EU regulations, just as others regulate their imports from countries deemed top be non compliant. If you think the price of venison is bad at the moment if an EU ban was to come into effect well who knows what would happen..
 

NullMac

Well-Known Member
And have your goods sent back at the ports, be barred from entry and face sanctions or repercussion for reneging on trade agreements.

So much for integrity.... 🙄
Yeah I always thing this reputation/integrity argument is weak and whiny.

If the worst thing about exercising Article 16 (or ending any treaty for that matter) is that people will not like us anymore then there isn't really a good reason in favour of the treaty. Clearly there are which is why I think the DUP will end up under the bus again after a bit of noise and some dancing, as is Boris's style.

"Reputation" is all a bit playground, but wi bigger words.
 

Rewulf

Well-Known Member
The problem lies in our exports, if the EU decides to implement a ban on lead then our exports as in Venison would not meet the EU regulations, just as others regulate their imports from countries deemed top be non compliant. If you think the price of venison is bad at the moment if an EU ban was to come into effect well who knows what would happen..
How much venison us actually exported?

Plus, if venison were that popular over there, surely they would just use local or farm it.
Either way, a UK lead ban to facilitate meat exports is a pretty weak argument.
 

Woodenbeam

Well-Known Member
The problem lies in our exports, if the EU decides to implement a ban on lead then our exports as in Venison would not meet the EU regulations, just as others regulate their imports from countries deemed top be non compliant. If you think the price of venison is bad at the moment if an EU ban was to come into effect well who knows what would happen..
& this is where personal choice comes in to it which is where my issue lies. If you wish to export fine - shoot deer lead free. For the vast majority of stalkers and shooters though that isn’t the case so why bring about a nanny state approach which affects so many and so much of the industry for a minority?
Same olde thing, those who shout loudest (irrelevant of the cause) get listened to and if it can become a headline so much the better. No matter if the cause is a load of political ball-aks.
Going lead free isn’t going to save the game shoot fraternities either - that’s an absolute load of cobblers. Commercial shoots really do need to invest in a huge PR campaign to sell themselves to the non shooting community, putting down thousands of birds to be shot is always going to be a hard sell though.
I feel the majority of shooters irrespective of what they shoot & what they’re shooting with are possibly going to be affected by something that is being driven through with no true justification - we do not live in some perfect world where all is good and no harm is ever done.
 

griff

Well-Known Member
& this is where personal choice comes in to it which is where my issue lies. If you wish to export fine - shoot deer lead free. For the vast majority of stalkers and shooters though that isn’t the case so why bring about a nanny state approach which affects so many and so much of the industry for a minority?
Same olde thing, those who shout loudest (irrelevant of the cause) get listened to and if it can become a headline so much the better. No matter if the cause is a load of political ball-aks.
Going lead free isn’t going to save the game shoot fraternities either - that’s an absolute load of cobblers. Commercial shoots really do need to invest in a huge PR campaign to sell themselves to the non shooting community, putting down thousands of birds to be shot is always going to be a hard sell though.
I feel the majority of shooters irrespective of what they shoot & what they’re shooting with are possibly going to be affected by something that is being driven through with no true justification - we do not live in some perfect world where all is good and no harm is ever done.
This is where it is confusing, SD is awash with threads on the price of venison at the gamedealers leading a lot of us to think that the "majority" sell to a GD.
Game shoots, is and has always been the target of the anti's,in their view you cannot put down millions of birds and then shoot them, the vast majority of which then nobody wants. Unfortunately the rest of the shooting fraternity has to suffer the fallout.
 
Top