Lead restriction proposals - public consultation

I think we're on the same page here. I have no problem with looking at alternatives to lead ammunition. But not based on the evidence we've thus far been presented with as 'fact'

We are indeed on the same page .
I do think the public has the right to choose whether or not the food they consume may contain lead . I'd like to see more people eating game meats and let's be honest the public are easily put off .


@T.eddie, just messing with you. The reason BASC get a spanking is because the majority are members .

That's barely an opinion , not angry enough by far 😉
 
Here is what is going on in Europe. EU. I daresay that UK might adopt a similar position, once it is decided. SEAC have been looking into this.

Lead in shot, bullets and fishing weights - ECHA

Lead in shot in terrains other than wetland, other ammunition and fishing tackle
Intention to prepare restriction dossier 3 October 2019
Call for evidence 3 October 2019 –
16 December 2019
Submission of restriction dossier 15 January 2021
Consultation of the Annex XV dossier (if conformity is passed) 24 March 2021 – 24 September 2021
RAC opinion, draft SEAC opinion June 2022
60-day consultation on draft SEAC opinion Q3 2022
Combined final opinion of both committees early 2023
Draft amendment to the Annex XVII (draft restriction) by Commission Within 3 months of receipt of opinions
Discussions with Member State authorities and vote To be confirmed
Scrutiny by Council and European Parliament Before adoption (3 months)
Restriction adopted (if agreed) To be confirmed


Here is what UK REACH do.

REACH - HSE

Here is an old press release, from a year ago.

Plans announced to phase out lead ammunition in bid to protect wildlife

Here is how the first consultation started, and finished, 8 weeks later.

UK REACH – restriction proposals 001 - Questions for the call for evidence for the lead shot ammunition - Health and Safety Executive - Citizen Space

A foregone conclusion ? Well maybe those, in their bubble, thought so.

And a broadcast by the BBC, today, giving a Cambridge "researcher" full unquestioned airtime. Starts about 9 minutes in.

I have read that paper, and, if it has been peer reviewed at all, if so by whom ? would still question it. Nevertheless some valid points raised.

BBC Inside Science - Global food security during Ukraine conflict - BBC Sounds
 
Persistent for a purpose aren't you - my answer unequivocally and for the avoidance of any doubt is - NO Change there is no real evidence - do you recognise that !

Suddenly we are in a world where BASC is saving us - not from unreasonable restriction but from a world ban on lead which John Swift would have sold BASC for.
Obviously in BASC's case - the 'lady' is for turning.

kes/triton

I still don't think you answered the question - for shooting activities in England, Wales and Scotland - given the evidence, and mindful of not damaging shooting, what restrictions on lead shot would you support?

You say you shoot ducks in Wales. Do you support the current lead shot restrictions in Wales? And if so why? What new evidence did you review before and after 2012 and when did you change your mind to support the lead shot restrictions in Wales and what evidence made the difference for you?
 
Sorry but that stuff is meta studies upon meta studies (meaning dredging up of old poor quality data, of little statistical significance, going back to the 1970s, hedged about with ifs and buts, re- analysing it with a barely concealed agenda, and scaremongering that it's getting worse and worse. The merest skimming of such will show that.

TBH, not only is it very poor, but the (little) publicity that they have managed to get, except from the usual suspects, is counter-productive. There is certainly a debate, and a re-positioning, to be made. But this is not the way to do it.

Is this the best that you can do ? Three alternative links to the same BS pseudo-science report ? Not saying that some of what they have divined is not wrong. But neither is necessarily true.

The problem is, that an interested, open minded researcher, wanting to be looking at alternative interpretations of how to manage wildlife, in whatever environment, is automatically going to have a hard time. This is not a good career choice for someone who is not prepared to be , let's say, not be totally morally motivated and firm of their convictions. But if they are in-between, or just self-interested, well that's down to them I suppose. If they, fundamentally, have a problem with sporting, nevermind needed wildlife management, well that I suppose is

I am not just disappointed that you have brought this up. Very poor.

As you well know, we have discussed this, there is an ongoing analysis, and consultation, through ECHA and derogated to more clued up people. Which might put forward a proposal, mid this year, maybe to be finalised next year, then legislated later.

Based on more nuanced studies, far more interesting, which also exist. And are in the mix. I am only one man, but follow some science, and I'm sorry to say that if you, @Conor O'Gorman can only put up what you have, then you are are misadvised, ill-informed, and if suggesting that you might guide future legislative policy, well, politely, out of your depth. Impolitely, dangerous.

As and when that happens, I would expect the UK to follow. Unless, incredibly, the decision makers decide to take a different view, more appropriate to our individual circumstances.

Maybe

BASC purport to be represented there. I've looked, but can, as yet, find your contribution to that consultation. Perhaps you are putting it through larger European organisations ?

As for UK REACH, well I don't see it as being a priority for them. Much more important REACH stuff, to mainly do with chemicals, and keeping the UK aligned with the EU as to regulations, so they can still go in and out, post Brexit.

Ammunition, and exported game, being a tiny part of this, though our AGHEs and others seem to have got their knickers in a twist about this, egged on or in cahoots with BASC etc. by some retail outlets who have attempted to stir up a "holier than thou" approach to the provision of good wild game at enormous profit margin, whilst simultaneously denigrating anything else. Overall I do not think that they are friends to the business.

Neither, ISTM, has been BASC

ISTR that BASC registered UK REACH as being theirs, but may have mis remembered the details of that.

Got any contact with the real UK REACH people worrying about lead in ammunition ? If there are any. You used to claim to have the inside line, someone very well connected apparently, clubbable, mingled with the decision makers, dont ask, trust us, and we'll take those who are already onside out for grand influencing days at the usual place. To be properly declared of course.

As for most of the big pheasant shooting going on, that I suspect BASC might be the only organisation to unwholeheartedly continue to support. Lets just say, It's not my thing.

It complicated, certainly.
Thanks for the review and I agree with you on the paper - did you note the differing angles in the two press reports and the rather concerning 'Environment Dept' quote? We are challenging this.

As a man that follows the science, which papers would you recommend to SD members sceptical of the evidence on the impacts of lead ammunition?
 
We have the added complication in the U.K. of also declaring that not only would we move away from toxic shot but single use non biodegradable plastic wads, otherwise we create a significant issue of plastic pollution.
We are also limited for steel shot to a maximum velocity set by CIP unlike the states which are limited by pressure under SAAMI.

We are now seeing a race by manufactures to introduce biodegradable plastic wads under different environmentaly nice sounding names, like earth wad, hydro wad, green core however we have no benchmark or standard to measure their environmental performance/impact.
Most claim to be made from material compliant to BS EN 13432 however from the research I have done (and happy to be proved wrong) it is not the material that needs to conform to EN 13432 but the product Itself should be tested to confirm compliance and I see no evidence of that.

BS EN 13432 is aimed at recycling, composting throwaway plastic packaging in an industrial composting process not lying on a green field. Which is why the cartridge manufucature are not keen to publish figures on how long it takes for their wads to disintegrate (if they actually do) or suggest they need picking up to be recycled in an industrial composting process.

A question that has been put to one cartridge manufacture by a friend, hopefully they get a meaningful reply.

Clearly for shooting to be sustainable we need to ensure we truly do have an environmentally friendly cartridge, which is not just about the shot.

**

It should be noted that only articles or products can comply with BS EN 13432, but materials themselves (e.g. polymers, plastics or compounds) cannot.
This is because the dimensions may mean that disintegration would not take place within the time allowed of 12 weeks or mineralisation within the time allowed of six months. For example a 15 mm film may disintegrate within 12 weeks (and comply with the other requirements) but a 20 mm sample of the same film may not fully disintegrate. Thus the material cannot be claimed to be compostable, even though the 15 mm film can disintegrate fully.

Home compostable packaging​

There is a need for distinction between home compostable and industrially compostable materials. Articles that degrade in an industrial compostingvessel (high temperatures and air flow) may never degrade in a home compost heap. In addition to certification to BS EN 13432, it is also possible for a product to be deemed ‘home compostable’. The Association for Organics Recycling has launched a Home Composting Certification Scheme in conjunction with AIB Vincotte in Belgium.
 
kes/triton

I still don't think you answered the question - for shooting activities in England, Wales and Scotland - given the evidence, and mindful of not damaging shooting, what restrictions on lead shot would you support?

You say you shoot ducks in Wales. Do you support the current lead shot restrictions in Wales? And if so why? What new evidence did you review before and after 2012 and when did you change your mind to support the lead shot restrictions in Wales and what evidence made the difference for you?
What you think is largely irrelevant compared to the overall advancing restrictions in all areas and all avenues of shooting.
I am certainly not going to respond to your questions, since you have failed to see that I do NOT accept the 'evidence' - since it is disputed and you have ignored the evidence in the presentation in my post above..
Our historical shooting context makes a complete mockery of BASC's wholesale adoption of the 'evidence'. For one example I managed a shoot where the flight pond had seen ducks reared and shot over for 30 years and NOT ONE SINGLE duck died of lead ingestion - despite being fed on the shallows of the pond , all ducks were eaten by shoot members, surprisingly no members died of lead poisoning and all actually enjoyed their sport in the manner of true sportsmen.

I am quite prepared to accept the need for less lead in the environment not only for wildfowl but for all water dwelling species and pond life - the exception being John Swift.
This is the original and unchanged position since I DO NOT ACCEPT THE EVIDENCE YOU CLAIM (recently) for the toxicity of lead in shot game.
Got it ?
 
Thanks for the review and I agree with you on the paper - did you note the differing angles in the two press reports and the rather concerning 'Environment Dept' quote? We are challenging this.

As a man that follows the science, which papers would you recommend to SD members sceptical of the evidence on the impacts of lead ammunition?

To deal with this, one needs to deal satisfactorily with four questions:

1. Are the authors and the peer reviewers actually impartial?
The large majority of these papers have been produced by a very small number of scientists, many of them also activists and employed by or associated with anti-shooting organisations. Why is there very little to no evidence generated by researchers outside this group? Who are the people peer-reviewing these studies? Is this genuine independent review, or groupthink? I'd suggest you start by looking at those papers with large data sets, where it is clear that the animals in question have been acquired in proper representative samples, with a clear audit trail of custody etc., where the conclusions do not rely on extrapolating estimates from other small scale studies, which have been reviewed by independent scientists and statisticians outside the clique. (I think you'll find it hard to find anything)

2. Do the papers consist of credible studies? What is the quality of the work and the scientists?
There are serious unanswered questions about methodology and the validity of many of these papers. You highlight the latest which apparently involves post-mortems on 3000 dead raptors across Europe. Immediately one wonders how they legitimately obtained 3000 dead raptors, whether they form a representative sample of the populations of live, wild raptors (which they obviously don't because they are dead), whether the quality and reliability of the statistical analysis and modelling is sufficient to support the conclusions drawn and the necessity of passing laws on the strength of "overwhelming evidence" which does not consist of recorded data, but modelled estimates. We all know better than to trust to the reliability of modelled estimates these days - because their outputs are heavily skewed by the biases of their producers. These are not the top calibre of scientists either.


3. Do the correct answers to the questions above provide sufficient confidence to justify legislation in isolation, or when considered in the broader picture of the effects of this human activity on the species involved? (Clue: the latest paper indicated that the reduction in the populations of some raptor species (excluding the ones where they found no potentially harmful effect of lead) may be as little as 0.2% at one end of the confidence interval. That does not strike me as compelling.

4. Was the paper published after 2015 ? Because all of the studies available prior to that time officially do not constitute good reason to ban lead ammunition - in the expert opinions of BASC.

I wonder whether you view the advice that BASC gave at that time to be false, and whether you view the government decision taken on reviewing the body of evidence at that time to be wrong?
 
Hmm, on the one side of the argument, we have the professional scientists of the GWCT and almost every shooting organisation. On the other, a self-inflating retired local authority road mender. I am in a quandary..
Well BASC has now managed to be on both sides of the argument on the strength of the same evidence. That's not making the road mender look like a fool.

The fact of the matter is that there is not sufficient scientific data to justify considering a ban on lead ammunition. There is a long and tedious campaign by very few activists to ban lead ammunition (or ideally shooting) on the justification of a series of very dubious extrapolations of small datasets of doubtful quality. You need to be careful to think about which side of the debate is really being unscientific.
 
Hmm, on the one side of the argument, we have the professional scientists of the GWCT and almost every shooting organisation. On the other, a self-inflating retired local authority road mender. I am in a quandary...

At least the road mender voiced his opinion and frankly , his findings appear to be just as scientific as some of the papers on the subject , if only on a smallerscale . . If you're opinions differ , why not post them. As requested by Conor , instead of taking cheap swipes at other members . Unless you really are in a quandary !

Then again your post may have been tongue in cheek . In which case I retract my comments on the matter . 🙂
 
Without pouring fire on the anti lead flames. Can someone kindly educate me as to how my shot if it were lead is poisoning anything.

Foreshore I’m shooting out into the sea/estuary which is subject to big tides and very silty assuming the shot goes a few hundred meters out then sinks. Flighting it’s shot over fields and no doubt will disperse a lot on missed birds.

How does it build up to become poisonous? Is it pricked birds that then get eaten?

Genuinely curious as to the mechanics of it.

Thanks.
 
Thanks for the review and I agree with you on the paper - did you note the differing angles in the two press reports and the rather concerning 'Environment Dept' quote? We are challenging this.

As a man that follows the science, which papers would you recommend to SD members sceptical of the evidence on the impacts of lead ammunition?
I would suggest that anyone interested start by reading:

ANNEX XV RESTRICTION REPORT
PROPOSAL FOR A RESTRICTION
SUBSTANCE NAME: LEAD
IUPAC NAME: LEAD
EC NUMBER(S): 231-100-4
CAS NUMBER(S): 7439-92-1
CONTACT DETAILS OF THE DOSSIER SUBMITTER:
EUROPEAN CHEMICALS AGENCY
P.O. BOX 400, FI-00121 HELSINKI, FINLAND
ECHA.EUROPA.EU
VERSION NUMBER: 2.0
DATE: 24 March 2021

There are 404 pages of it, but it is worth studying. It is well indexed, and arranged so you should be able to home in on the areas that interest you. A great deal of science is presented, I think quite dispassionately, and the uncertainty or limitations of the analysis explained. Together with socio-economic analysis.

You can download it from here:

https://echa.europa.eu/documents/10162/da9bf395-e6c3-b48e-396f-afc8dcef0b21

I could make some personal selective quotes from it that attracted my attention, but I'm not sure that would be particularly helpful.

Nevertheless here are a few:

Page 167. BTW there is a typo. Lead shot is estimated at 13,000 to 15,000 tonnes per year, not 1000. As you will see, lead bullets used for hunting are a tiny fraction of that. 130-160 tonnes/year. One percent. Albeit much of that lead ends up inside the animals, rather than mostly being scattered over the countryside.

To my mind, it is the shotgunning fraternity who are the problem, when it comes to considering detriment to wildlife. The rifle shooting is a tiny proportion in terms of tonnage, however, to my mind, of more concern to regular eaters of game. And to rare raptor populations that may ingest it from grallochs, carrion left shot for "nature" to gobble up, etc. I have little doubt that these top of the food chain long-lived birds who breed in such small numbers are vulnerable, though actual studies (as opposed to meta studies of studies, which I think is where this thread started), to investigate this are very difficult to do.

As to human health implications, basically wild game is a tiny, if not zero, element of most people's diet. But can be a large amount for we few hunters who eat much more. I seriously don't think it is any public health problem for the general public, providing basic precautions are taken when it is properly processed. However since I, my friends and family, and our dogs eat rather more than the average person, I am very mindful of the potential short and long term hazards.

In this section the releases of lead to the environment in the EU27-2020 from uses of lead
related to different sectors (i.e. hunting, fishing and sports shooting) are reported.
Information on environmental concentrations are discussed in Annex B.
Lead from ammunition (hunting)
The Dossier Submitter has estimated the releases to the environment from different uses
related to the hunting sector. Estimates are presented in Table 1-10.
Table 1-10: Estimated amount of lead ammunition released (tonnes) in the EU for hunting
per year
Use # Ammunition type Estimated releases in EU 27-2020
[tpa in 2020]
1 Lead shot for hunting 1 000 (13 000 to 15 000)
[1]
2a Lead bullets for hunting - small calibre 24 (16 – 26)
2b Lead bullets for hunting - large calibre 122 (110 to 142)
5, 6 Air rifle, muzzle loading Not estimated (data not available)
Notes: [1] AMEC (2012) estimated that releases of lead shot from hunting on non-wetland areas accounted for
about 20 859 tonnes of lead per year. The sum of other estimates for Spain, Italy and the UK only (EU-28) ranged
from 15 600 to 29 000 per year with IT: 6 000 tonnes (Guitart and Mateo, 2006); ES: 1 600 to 10 000 tonnes
(Andreotti and Borghesi, 2012); UK:8 000 to 13 000 tonnes (Pain et al. (2014), based on numbers of birds killed
and likely numbers of cartridges used ‘per bird’, including misses).
Given that the proposed restriction on the use of lead in wetlands addressed a volume of
5 000 to 7 000 tonnes of lead per year, the Dossier Submitter estimates that total amount
of lead gunshot used and released by hunters in the EU-27 per year after the
implementation of the wetland restriction is in the order of 13 000 to 15 000 tonnes per
year.
Concerning lead bullets, the estimated baseline tonnage of lead use per year is based on
hunting statistics (i.e. the number of animals hunted per year in the EU-27) combined with
assumptions on the weight and use of lead bullets (Annex D). The Dossier Submitter
estimates that the total quantity of lead released from bullets used for hunting is 130 - 160
tonnes per year.


Page 192.

In the UK a voluntary initiative has been proposed by several of the larger hunting
associations to phase out the use of lead within five years (by 2025), inspired by an
increasing concern on the effects of lead on wildlife and human health. Also in more
practical terms, pressure has increased from supermarkets to supply game meat that
is free from lead. Although the UK is outside of the EU as of the first of January 2021,
this UK initiative is still of importance for the EU market as their initiative will create
an increased demand for non-lead shot and hence increase the availability of
alternatives to lead shot and lower their prices. Next to this the organisations leading
this voluntary move have asked the CIP128 to approve additional shot size and gauges.


Page 281:

European ammunition industry is very dependent on the EEA market as 69 % of the AFEMS
members turnover is made in the EEA market (AFEMS submission). Those manufacturers
who mainly produce for the European market face the severest difficulties. They will stop
producing ammunition for these 8 uses completely, at least temporarily. The duration is
dependent on their ability to substitute to another raw material and end-users’ willingness
to substitute. Only a few companies said they can substitute in the short term (0 - 3 years).
Most manufacturers outlined that they can substitute in the longer term (5 - 10 years).
These arguments seem to be echoed by recent discussion the UK where in reaction to a
recent call for a voluntary phase out of the use of lead shot, three (Eley Hawk, Gameborne,
Lyalvale Express) companies reacted176 by stating that:
We cannot make a complete switch over to these products within a five year period without
substantial investment into the industry. BASC and its fellow organisations do not have an
understanding of the manufacturing processes involved and are therefore in no position to
determine the length of time required to evolve.
Tungsten and Bismuth materials are very limited in their availability and significantly more
costly to produce than steel. This will result in huge increases in costs, based on raw
material prices, for smaller gauge shooters who cannot use steel. This may price many
shooters out of the sport.
Other sources indicated that security of supply of steel shot would be in threat if sports
shooting would be in scope of a ban on placing on the market as well.
The length of the transition period is of importance when large scope and large investment
costs arise. Of the restriction options analysed this would mean that the length of the
transition period has a significant influence on the costs of substituting lead shot and on the
cost of substituting lead bullets for small and rim fire calibres.



To understand how the review and consultation process works, you could watch the Helsinki webinar at

As I have posted before, the EU only halfway into the process. And since Brexit, the UK is detached from it. So REACH UK will have to make their own minds up about what will apply here. My personal view is that they will take some sort of lead from what is decided for the EU.

The timescale is as follows:

Intention to prepare restriction dossier 3 October 2019
Call for evidence 3 October 2019 –
16 December 2019
Submission of restriction dossier 15 January 2021
Consultation of the Annex XV dossier (if conformity is passed) 24 March 2021 – 24 September 2021


This is where they are at. If you want to read the responses to the consultation, you'll find them at Submitted restrictions under consideration - ECHA Specifically six Word documents.

1647630444145.webp
Next comes:

RAC opinion, draft SEAC opinion June 2022
60-day consultation on draft SEAC opinion Q3 2022
Combined final opinion of both committees early 2023
Draft amendment to the Annex XVII (draft restriction) by Commission Within 3 months of receipt of opinions
Discussions with Member State authorities and vote To be confirmed
Scrutiny by Council and European Parliament Before adoption (3 months)
Restriction adopted (if agreed) To be confirmed
 
Last year, a call for evidence on lead ammunition took place under the UK’s post-Brexit chemical regulations referred to as ‘UK REACH’ which covers England, Wales and Scotland (but not Northern Ireland, due to the NI Protocol).

The Health and Safety Executive (HSE) has been working with the Environment Agency to review the evidence submitted. This includes evidence on the uses of lead ammunition; risks to the environment, wildlife and human health; and the availability and viability of alternatives.

The HSE has been tasked as the ‘agency’ under UK REACH to produce a report that outlines the risks posed by lead ammunition. Where it believes those risks to be unacceptable, it has also been asked to propose restrictions to reduce those risks.

It is this ‘restriction dossier’ that is due to be published in April and will be subject to a six-month public consultation. The dossier will cover various uses of lead ammunition outdoors in England, Wales and Scotland.

This is an early heads up for SD members that may not have not read BASC briefings on this and I hope that many of you will get involved in this very important consultation.

Ahead of the consultation feedback most welcome either here, by DM or by email to conor.ogorman@basc.org.uk

For more context see BASC blog below


There is also a wider discussion in latest (Episode 20) BASC podcast here:

 
After seeing the results of a full season of different clients turning up with copper ammunition I think there needs to be a lot more research done to make sure they are fit for purpose we have had animals run a mile after being shot, the round as pencilled straight through the chest cavity exit hall as small as the entry and you had to look for it .
I have seen exit wounds bigger than my fist, I seen a Chinese water deer shot perfectly broadside and the bullet exited on the same side as it entered ricocheting off the opposite rib cage and coming back through the same side we had one client this year who brought both copper and lead and after the first two animals he resorted straight back to lead after seeing the results of the copper ammunition I was very open minded at the beginning of the season but after seeing the results time and time again there needs to be a lot of work completed before we do a complete swap for animal welfare in general
 

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Hopefully they have separated out from total lead shot production that used for clay pigeon shooting at that actually used for game and pest control.
 
Hopefully they have separated out from total lead shot production that used for clay pigeon shooting at that actually used for game and pest control.
Yes they have. Study it.

The "sporting" uses of shot, and rifle ammunition are discussed elsewhere in the document. Have you bothered to study it ? If not why not, because it is shaping policy. Unlike bleating abut here there and everywhere, and saying "it's not fair, destroying my way of life, no future etc.

TBH they were being a bit kind about lead shot used for game shooting, so subtracted a lot more based on assumptions about how their wetlands ban might reduce it going forward. ISTR between 15,000 tonnes and 17,000 tonnes. on top of the rest. Per annum. Already included in the proposals.

I am quite capable of having got some of these numbers wrong, it is hardly my day job
 
Without pouring fire on the anti lead flames. Can someone kindly educate me as to how my shot if it were lead is poisoning anything.

Foreshore I’m shooting out into the sea/estuary which is subject to big tides and very silty assuming the shot goes a few hundred meters out then sinks. Flighting it’s shot over fields and no doubt will disperse a lot on missed birds.

How does it build up to become poisonous? Is it pricked birds that then get eaten?

Genuinely curious as to the mechanics of it.

Thanks.
It seems that although it is dense and obviously sinks into the silt, that dabbling ducks and other wildfowl can and do eat the pellets from the silt in significant enough quantities to poison themselves. There is good and clear recorded evidence that that actually happens and significantly affects populations. It is not sensible to dispute a lead ban over wetlands.

Once you get out of wetlands, the picture is less clear, the scientific studies are lower quality and the claims are more spurious.
For raptors, because high levels of lead and poisoning have been found in Californian Condors from eating shot carrion (or lead paint flakes) they are used to support claims that the same happens in the UK. You don't need to be a scientist to spot the difference in environment between the Californian mountains and England. A relatively few other cases of UK species being poisoned with lead have been documented, along with a lot of anecdotal assertions from activists, and some papers alleging significant harm on the basis of extrapolations based on assumptions which are unverified.
For other birds, it is assumed that some species may be poisoned in numbers because they are thought to pick up lead shot off the ground and eat it. I believe some partridges have been found to have done this, although there are obvious questions about where this happened. A commercial partridge shoot is likely to be fairly heavily peppered and the birds likely to have been on hand to consume pellets off the ground at the same time of year.

On normal land, if you decide to be influenced only by proper scientific studies which collected data then there’s little cause for concern. If, on the other hand, you are inclined to be impressed by second-hand studies extrapolating and making possibly spurious assumptions, then you may find you’re worried.
 
Yes they have. Study it.

The "sporting" uses of shot, and rifle ammunition are discussed elsewhere in the document. Have you bothered to study it ? If not why not, because it is shaping policy. Unlike bleating abut here there and everywhere, and saying "it's not fair, destroying my way of life, no future etc.

TBH they were being a bit kind about lead shot used for game shooting, so subtracted a lot more based on assumptions about how their wetlands ban might reduce it going forward. ISTR between 15,000 tonnes and 17,000 tonnes. on top of the rest. Per annum. Already included in the proposals.

I am quite capable of having got some of these numbers wrong, it is hardly my day job
Can we clarify, for everyone’s benefit, that the figures of 15,000 to 17,000 tonnes of lead annually, refer to the amount estimated to be dispersed across the whole of Europe / the EU, and not the amount spread over the UK?
That comes to about a tonne per year over every 70,000 acres.

I think the rate of coverage in the UK is estimated, not recorded, to be somewhat higher. On one estimate I’ve seen put about by antis, it would be about a tonne for every 10,000 acres, or six cartridges per year over a football pitch.
 
Yes they have. Study it.

Have you bothered to study it ? If not why not, because it is shaping policy.

will do it was gone 10pm when I posted, past my bedtime at my age, but will study it over the weekend.

thank you for posting the link to it.
 
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