HSE Lead restriction extension

That is very kind of you and a thoughtful response. Thank you. The reason I asked I guess is because I was thinking from the POV that if you did not trust me then what would be the point of going to and fro with Q&As which as we have seen many times will have many others chipping in and it all ending in vitriol. However, my question was rather simplistic and your response has give me food for thought.
Always better to converse like grown ups and respectfully where possible, even if we come from different stand points -something the local BASC representative wasn't capable of doing. She should take some advice from you Conor. You have been an exemplar of diplomacy, and while I am still on my side of the fence, and you on yours, you have been a credit to BASC.
I drove around a corner the other day and was confronted by 2 groups of people bellowing at each other from either side of the road. All I saw was unpleasant people behaving badly. I had no idea of the cause and who was in the right - if anyone.
 
I understand that it's been illegal to use lead solder in plumbing since 1999 and almost every other use since 2006. So that's sorted.
Maybe lead flashing is still used but more and more alternatives like Wakaflex are being used. Here lead has been banned from new buildings since 2000 and for renovation of old buildings since 2007. I believe it can still be used for protected historical buildings. Funny thing is nobody really misses it or talks about it.
That I didn't know, however, it makes no difference to my argument. There are so many sources of naturally occurring lead compounds that we can do nothing about them. Nearly all houses, ancient and modern, have lead all over them. It is in the soil and water in far more unstable forms than solid metallic form and in quantities -in some areas- that according to the criteria of the HSE, should have them ring fenced and abandoned for the purposes of human habitation.
The tiny quantities used in shooting and stalking make not the faintest difference. The attack on lead shot and ammunition is not based in scientific fact. It is politically motivated. That the shooting organisations (on the run from an uneducated mob whipped up by animal rights activists here and in Europe) have jumped on their band wagon, shows how badly led they are and how little we can trust them.
The next fight, after they have surrendered lead on our behalf, will be the register of competent stalkers that BASC are promoting. You try getting stalking on new land without DSC2 once it gets going. Oh they'll say it will never happen, but getting stalking on ground owned by anyone other than private land owners and farmers now without it, is nigh on impossible. The inference will be made that if you are not on the register, you are not a competent stalker and therefore officially dodgy. Next, insurers of landowners will be demanding that stalking is only allowed where rifles have DSC2. Thank you BASC.
I attended a BASC DSC1 course. There were 2 or 3 in that group of 15 or so who wouldn't have known a deer (let alone its sex) from a donkey. They are now holders of DSC1. How our local firearms enquiry officer failed 3 times (while trying to demand it before issuing FACs for centrefires) is beyond me. My point here is that there are many recreational stalkers who -on their worst day- will be safer, better stalkers than many DSC2 holders on their best. Why should they be put under the heel of BASC's jackboot? There is no problem for landowners to find decent stalkers. Word of mouth is the best recruitment and vetting tool there is. BASC seem intent on answering the question that no-one asked. Of course they will tell you it is all in the interests of raising industry standards. Rubbish. A rogue with a ticket to say he is honest is still a rogue.
 
Will BASC consider asking for a judicial review of any unevidenced restriction proposals?
I don't know. The option would also depend on the legislative route taken - see Judicial review | Institute for Government

First there will be the HSE report with recommendations this autumn. Then its for the government to decide whether to act on the report recommendations with legislative proposals. The first round of battle would be lobbying for revisions to any proposals where there were concerns that they were unevidenced and would damage shooting. If such lobbying was needed hopefully we would see more people getting involved than we saw during the HSE consultations.
 
Further information on the HSE lead ammunition review is in the following BASC article in this week's Shooting Times:

Conor, with regards to

. It also conceded that target shooting with lead rifle ammunition should be allowed to continue at approved ranges.

Is that HSE who will approve the ranges? How will this work and at what cost?

As no other authority approves ranges the MOD stopped doing so years ago, so we have lots of ranges across the U.K. operating as zero and practice ranges, such ranges as I said require no approval from any authority be that NRA, NSRA, MOD, HSE or Police.
 
I don't know. The option would also depend on the legislative route taken - see Judicial review | Institute for Government

First there will be the HSE report with recommendations this autumn. Then its for the government to decide whether to act on the report recommendations with legislative proposals. The first round of battle would be lobbying for revisions to any proposals where there were concerns that they were unevidenced and would damage shooting. If such lobbying was needed hopefully we would see more people getting involved than we saw during the HSE consultations.
If -as I suspect- the evidence against lead shot is not based on accurate scientific data using the only recognised acceptable test (lead isotope spectrometry), a failure to challenge any adverse finding on the part of BASC would be a clear validation of the view that BASC and others were selling us out.
Both GWCT and WWT have failed to confirm that they have used this method for the basis of their allegations as to the effect of lead in wildfowl digestive systems. They have admitted that their case against lead is based on "good reason to believe".
Yes. Seriously.
I am deeply concerned that in acquiescing in the face of a judgement against lead by the HSE and potentially DEFRA, BASC will have failed to properly defend shooting and irreparably harmed the industry for no better reason than political expedience. It would be a gross dereliction of their duty and clear proof that the shooting organisations are in fact slowly killing our sport through intellectual and moral cowardice.
"Oh it's a done deal, let's move on" will be the cry. Mark my words.
This is shameful stuff Conor. You give me no comfort.
 
Conor, with regards to

. It also conceded that target shooting with lead rifle ammunition should be allowed to continue at approved ranges.

Is that HSE who will approve the ranges? How will this work and at what cost?

As no other authority approves ranges the MOD stopped doing so years ago, so we have lots of ranges across the U.K. operating as zero and practice ranges, such ranges as I said require no approval from any authority be that NRA, NSRA, MOD, HSE or Police.
That has not been worked out as far as I know. We are a long way from anything, if anything, changing.
 
If -as I suspect- the evidence against lead shot is not based on accurate scientific data using the only recognised acceptable test (lead isotope spectrometry), a failure to challenge any adverse finding on the part of BASC would be a clear validation of the view that BASC and others were selling us out.
Both GWCT and WWT have failed to confirm that they have used this method for the basis of their allegations as to the effect of lead in wildfowl digestive systems. They have admitted that their case against lead is based on "good reason to believe".
Yes. Seriously.
I am deeply concerned that in acquiescing in the face of a judgement against lead by the HSE and potentially DEFRA, BASC will have failed to properly defend shooting and irreparably harmed the industry for no better reason than political expedience. It would be a gross dereliction of their duty and clear proof that the shooting organisations are in fact slowly killing our sport through intellectual and moral cowardice.
"Oh it's a done deal, let's move on" will be the cry. Mark my words.
This is shameful stuff Conor. You give me no comfort.
I am interested to understand why you consider 'lead isotope spectrometry' the only acceptable test?
 
That has not been worked out as far as I know. We are a long way from anything, if anything, changing.

Thank you for your reply, I think one needs to be careful in the words used in such situations, are they BASC words or copied from the HSE report? If the latter it shows incompetence on behalf of the HSE not to know that ranges are no longer approved. Or if it is the HSE intention to approve each range to determine they may operate as are a low risk of lead hazard then they should say so within the report.

Would have been more reassuring if the statement had just said

It also conceded that target shooting with lead rifle ammunition should be allowed to continue at ranges.
 
Thank you for your reply, I think one needs to be careful in the words used in such situations, are they BASC words or copied from the HSE report? If the latter it shows incompetence on behalf of the HSE not to know that ranges are no longer approved. Or if it is the HSE intention to approve each range to determine they may operate as are a low risk of lead hazard then they should say so within the report.

Would have been more reassuring if the statement had just said

It also conceded that target shooting with lead rifle ammunition should be allowed to continue at ranges.
This is from the HSE reports and is about agreed risk management measures for target shooting ranges that could continue to use lead ammunition and how they might be monitored and enforced. It is suggested that the details of this would be agreed with relevant shooting organisations. See the following document for an outline of what is proposed:

 
This is from the HSE reports and is about agreed risk management measures for target shooting ranges that could continue to use lead ammunition and how they might be monitored and enforced. It is suggested that the details of this would be agreed with relevant shooting organisations. See the following document for an outline of what is proposed:


So shooting organisations like the NRA and NSRA would agree such risk management measures for target ranges that are operated by whoever as zeroing and practice ranges and have currently absolutely nothing to do with NRA, NSRA, that will only end badly for such ranges given the empires both organisations like to build.

The HSE should be the ones that monitor and enforce such measures but due to resources and cost they will I bet look to pass that responsibility on to shooting organisations.
 
Most medical authorities consider that ingested lead in any quantity is poor for your health. It is not yet fully understood how, but it messes with the immune system.

There are treatments that have secured orphan drug status that remove lead from cancer patients, the results are remarkable and they are curing terminal cancers. Levels of lead in such patients are being measured in nano grams per litre - in other words very low levels.

There is plenty of lead all around us. It was a common building material and ingredient in paint, and like asbestos it’s not going to do any harm provided it’s not ingested through breathing dust, or consumed in food or liquid.

When you put a lead projectile through an animal or bird, the projectile frequently fragments leaving small microscopic particles in the meat. These are easily overlooked during processing and will enter the human food chain.

Meat is acidic, is often cooked with acidic ingredients- red wine etc. Regardless the stomach is acidic - about same pH as battery acid where lead plates dissolve - a typically a meal of meat may take several hours to digest.

The lead is dissolved and absorbed into the blood and then ultimately deposited into body tissues.

Quite why many still think that putting a highly toxic substance into food products is a good thing rather beats me.

Ditto the argument that it is naturally occurring also defies logic. Most stalkers are quite rightly paranoid about getting gut contents on the meat with all the attendant risks of bacterial infection, yet many still seem perfectly happy at contaminating the carcass with a substance for which there is no safe level of ingestion.
 
So shooting organisations like the NRA and NSRA would agree such risk management measures for target ranges that are operated by whoever as zeroing and practice ranges and have currently absolutely nothing to do with NRA, NSRA, that will only end badly for such ranges given the empires both organisations like to build.

The HSE should be the ones that monitor and enforce such measures but due to resources and cost they will I bet look to pass that responsibility on to shooting organisations.
Did you read the relevant sections of the document?
 
I am interested to understand why you consider 'lead isotope spectrometry' the only acceptable test?
I am interested to understand why you consider "good reason to believe" (read "hunch") an acceptable basis for tacitly accepting a ban on behalf of a membership and industry who are being misled with bad information and cooked up evidence?

By the way, I do not consider it to be the "only acceptable test". I simply refuse to accept "evidence" based on little more than guess work and gut feelings. I believe that the evidence thus far quoted by the leading organisations detailed is incomplete without it. As far as I can tell, this is a deliberate and dishonest omission, or possibly the act of fools. I believe it is omitted from the schedule of scientifically based evidence sources because the pure science does not support the scientifically illiterate standpoint that is currently passing for "THE TRUTH" that All LEAD IS BAAAD!

If BASC, the GCWT and the CA are in the business of representing myth, emotion and witchcraft as fact, I have been paying subscriptions for the last 30 years in error. Mea Culpa. I am not repeating that mistake.

Conor, we can do this all week if you like. The point is that neither BASC nor the WWT or GCWT (who, like the HSE, are apparently using the information pushed by WWT as the basis of their positions) have actually conducted a full suite of scientifically rigorous tests to properly confirm that insoluble solid lead shot is, or is not, harmful.

You are -in this scenario- a salesman on behalf of an organisation that has adopted a bent narrative based on group-think, pseudo-science and eco-babble...in my view. It is your job to sell "Black" even when it is plainly "White". Sadly for you on this issue those of us who are capable of independent thought and critical scrutiny, are not buying.

Your goal is to achieve a political end you think will take the heat off your position as a representative body.
When you eventually fail to deflect a ban, as you almost surely will, you will say you did your best but that the end result was "inevitable but ultimately for the general good".
In time BASC, the CA and the GCWT will dress up this incompetence or carefully orchestrated treachery (take your pick) as a victory for common sense and the moral advancement of a modernised industry. See "ESG" section soon to be added to BASC website. Probably. ;)

LIS - just to be clear, allows accurate identification of the source of lead present in a given sample. The reason no-one wants to do this, is because the results clearly illustrate the fact that solid lead from shot is not metabolised by humans, waterfowl or any other species following ingestion. Being found partially ground or as "fines" in the gizzards and digestive tracts of waterfowl is not the same as metabolised lead compound. Where lead is present in levels detrimental to the health of the subject, it is shown that this is (under normal circumstances) from sources of naturally occurring and artificially introduced lead other than solid metallic lead. These sources include -but are not limited to- dissolved lead compounds commonly and readily available in concentrations well above recommended safe levels in soil, air or water. These can be from mining, lead paint or volatilised compounds such as those from fuel additives. Lead soldiers were not poisonous, but the lead based paint they were covered in, was not good news.

Incidentally, you are talking to someone who had a great uncle that refused to eat anything that had not been shot, caught or hunted. You could politely and fairly describe him as an eccentric. When he died he was subjected to autopsy which revealed a small "sac" in his gut containing a quantity of lead shot. His death certificate was endorsed with the reason for death as "lead poisoning". When asked why this was the case, the family doctor who signed the certificate, stated that it was kinder than any of the many other reasons that might have been given. These included (amongst many other equally likely things) the facts that he was 83 years old, an alcoholic and smoker of epic proportions -and severely overweight. Fudging the facts is nothing new. At least the good Doctor was trying to be kind.

The reason no-one on your side of the argument likes LIS or its resulting evidence, is that it does not fit the narrative BASC and associated mob of virtue-signalling eco-cronies wish to promulgate. "We don't like that evidence, so we will ignore it". How very "Bolshevik show-trial" of your side. Therefore again I say that this is not about what is right or factual, it is purely an agenda adopted for political reasons by badly led organisations that see surrender and capitulation as the preferred option. This is probably their view because it is cheaper and easier than telling the accurate truth and holding the line in the face of strong opposition.

All I can say Conor, is that it is a very good job BASC were not in charge in 1939. Strong opposition is no reason to turn tail. As The Hon. Robert Nesta Marley once sang "the hotter the battle, the sweeter the victory".

I hope the next stage in this discussion is not for you to become exasperated with the nut-job (me) on the Stalking Directory and disappear. You are the representative and apparent defender of your membership and industry's interests. I sincerely hope you will do some research and advocate a change of direction. I suspect that this level of optimism may be misplaced.

Show us what proper defence looks like Conor. Shed some sweat and blood for us on this issue. Surprise us. Why not commission some LIS analyses on behalf of the membership?

If you can produce incontrovertible science based evidence to shoot me down, I will happily concede and publicly apologise for wasting your time and being beastly. I am wrong about many things, many times a day and have no fear of admitting error. I am the only male in a house full of wives and daughters, The dogs are bitches and the chooks are all hens. Trust me, I know when to surrender.
Actually, I exaggerate, the guinea pig is a boy too. We are quite good friends.

I do appreciate you taking the time to answer me Conor. You are the only person in any office who has been brave enough to stand still and argue the toss with me. This is to your considerable credit. Hopefully, also, there are some who are reading this exchange and thinking more deeply about the subject than they might have before.
Keep well.
 
See page 42 and page 267 onwards 2.5.2.2.4 RO7: Ban on use of lead bullets for target shooting with a derogation for sites with appropriate risk management measures
As always the devil is in the detail, zeroing and practice ranges may only have a natural earth bank as a backstop, ok it would not be a hardship for a sand bank to be put in place, but such a range also allows airgun pellets to be distributed all over the area, so what’s the logic in recovering a relatively small tonnage of .22lr lead projectiles yet allow considerable more airgun pellets to lay where fallen on the ground?
 
No logic in shooting regulations.
How can you shoot pigeons and crows on a stubble field with lead shot in September yet you cant shoot ducks or geese on same field?

How can you shoot a roe in Scotland with .222 yet it jumps the fence in the Borders into Northumberland and you cant ?

As always idiots write the rules 😁
 
I am interested to understand why you consider "good reason to believe" (read "hunch") an acceptable basis for tacitly accepting a ban on behalf of a membership and industry who are being misled with bad information and cooked up evidence?

By the way, I do not consider it to be the "only acceptable test". I simply refuse to accept "evidence" based on little more than guess work and gut feelings. I believe that the evidence thus far quoted by the leading organisations detailed is incomplete without it. As far as I can tell, this is a deliberate and dishonest omission, or possibly the act of fools. I believe it is omitted from the schedule of scientifically based evidence sources because the pure science does not support the scientifically illiterate standpoint that is currently passing for "THE TRUTH" that All LEAD IS BAAAD!

If BASC, the GCWT and the CA are in the business of representing myth, emotion and witchcraft as fact, I have been paying subscriptions for the last 30 years in error. Mea Culpa. I am not repeating that mistake.

Conor, we can do this all week if you like. The point is that neither BASC nor the WWT or GCWT (who, like the HSE, are apparently using the information pushed by WWT as the basis of their positions) have actually conducted a full suite of scientifically rigorous tests to properly confirm that insoluble solid lead shot is, or is not, harmful.

You are -in this scenario- a salesman on behalf of an organisation that has adopted a bent narrative based on group-think, pseudo-science and eco-babble...in my view. It is your job to sell "Black" even when it is plainly "White". Sadly for you on this issue those of us who are capable of independent thought and critical scrutiny, are not buying.

Your goal is to achieve a political end you think will take the heat off your position as a representative body.
When you eventually fail to deflect a ban, as you almost surely will, you will say you did your best but that the end result was "inevitable but ultimately for the general good".
In time BASC, the CA and the GCWT will dress up this incompetence or carefully orchestrated treachery (take your pick) as a victory for common sense and the moral advancement of a modernised industry. See "ESG" section soon to be added to BASC website. Probably. ;)

LIS - just to be clear, allows accurate identification of the source of lead present in a given sample. The reason no-one wants to do this, is because the results clearly illustrate the fact that solid lead from shot is not metabolised by humans, waterfowl or any other species following ingestion. Being found partially ground or as "fines" in the gizzards and digestive tracts of waterfowl is not the same as metabolised lead compound. Where lead is present in levels detrimental to the health of the subject, it is shown that this is (under normal circumstances) from sources of naturally occurring and artificially introduced lead other than solid metallic lead. These sources include -but are not limited to- dissolved lead compounds commonly and readily available in concentrations well above recommended safe levels in soil, air or water. These can be from mining, lead paint or volatilised compounds such as those from fuel additives. Lead soldiers were not poisonous, but the lead based paint they were covered in, was not good news.

Incidentally, you are talking to someone who had a great uncle that refused to eat anything that had not been shot, caught or hunted. You could politely and fairly describe him as an eccentric. When he died he was subjected to autopsy which revealed a small "sac" in his gut containing a quantity of lead shot. His death certificate was endorsed with the reason for death as "lead poisoning". When asked why this was the case, the family doctor who signed the certificate, stated that it was kinder than any of the many other reasons that might have been given. These included (amongst many other equally likely things) the facts that he was 83 years old, an alcoholic and smoker of epic proportions -and severely overweight. Fudging the facts is nothing new. At least the good Doctor was trying to be kind.

The reason no-one on your side of the argument likes LIS or its resulting evidence, is that it does not fit the narrative BASC and associated mob of virtue-signalling eco-cronies wish to promulgate. "We don't like that evidence, so we will ignore it". How very "Bolshevik show-trial" of your side. Therefore again I say that this is not about what is right or factual, it is purely an agenda adopted for political reasons by badly led organisations that see surrender and capitulation as the preferred option. This is probably their view because it is cheaper and easier than telling the accurate truth and holding the line in the face of strong opposition.

All I can say Conor, is that it is a very good job BASC were not in charge in 1939. Strong opposition is no reason to turn tail. As The Hon. Robert Nesta Marley once sang "the hotter the battle, the sweeter the victory".

I hope the next stage in this discussion is not for you to become exasperated with the nut-job (me) on the Stalking Directory and disappear. You are the representative and apparent defender of your membership and industry's interests. I sincerely hope you will do some research and advocate a change of direction. I suspect that this level of optimism may be misplaced.

Show us what proper defence looks like Conor. Shed some sweat and blood for us on this issue. Surprise us. Why not commission some LIS analyses on behalf of the membership?

If you can produce incontrovertible science based evidence to shoot me down, I will happily concede and publicly apologise for wasting your time and being beastly. I am wrong about many things, many times a day and have no fear of admitting error. I am the only male in a house full of wives and daughters, The dogs are bitches and the chooks are all hens. Trust me, I know when to surrender.
Actually, I exaggerate, the guinea pig is a boy too. We are quite good friends.

I do appreciate you taking the time to answer me Conor. You are the only person in any office who has been brave enough to stand still and argue the toss with me. This is to your considerable credit. Hopefully, also, there are some who are reading this exchange and thinking more deeply about the subject than they might have before.
Keep well.
Thanks, I may come back to you with my thoughts on some of these queries and assertions. I thought perhaps best to start with lead shot ingestion as a cause of death in birds due to the lead shot being eroded in the gizzard, after which toxic lead salts are absorbed into blood and later deposited in the kidneys, liver, bones etc. There are are various documented experiments that have looked into this that seem conclusive to me that the lead shot is a direct source of poisoning. Here is one on mallard.

Acute effects of lead, steel, tungsten-iron, and tungsten-polymer shot administered to game-farm mallards
 
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