Maladministration ruling on EU lead restriction consultation

[Conor O'Gorman]

The European Ombudsman has recognised a case of maladministration by the European Food Safety Authority regarding its failure to provide key documents in a timely manner during last year’s public consultation on EU lead ammunition restriction proposals.

The ruling was made following a complaint by the European Federation for Hunting and Conservation (FACE), supported by BASC, to the ombudsman that the European Food Safety Authority did not supply key evidence on lead concentrations in game meat.

This unseen data had been used to justify some aspects of the lead ammunition restriction proposals and it took over 8 months for the evidence to be provided to FACE. This was long after the consultation closed and when carefully checked, several issues were identified, which because of the time-lag could not be flagged in the consultation.

Following this ruling FACE is calling for the public consultation to be re-opened to ensure the process is undertaken again to ensure fair play.

More info from FACE:

FACE | Can we REACH fair play in the EU’s approach to restricting ammunition?

www.face.eu

What does that mean for the UK?

FACE complaint successful on EU lead restriction consultation - The British Association for Shooting and Conservation

The European Ombudsman has recognised a case of maladministration in relation to access to evidence during last year’s EU lead ammunition restriction consultation. BASC’s Dr Conor O’Gorman reviews what that means for us.

basc.org.uk

 

[Mike L]

……….. just waiting for the moth

 

[timbrayford]

Actually when you read the UK REACH document it makes a lot of assertive statements without citing any bona-fide peer reviewed research as evidence.

 

[Sika98k]

Phrases like “an estimated 1 million duck die every year from lead poisoning “. ring rather hollow to me. I didn’t think estimates had any place in factual arguments. Maybe it’s just me

 

[Woodenbeam]

“BASC will continue to challenge proposed restrictions in the UK and EU where there are no viable alternatives to lead, where socio-economic factors mean a transition isn’t appropriate, and where lead can continue to be used in settings that present negligible or no risk.”

I think BASC should alter their stance to push on the negligible or no risk element & forget the viable alternatives - an about turn admittedly but commonplace in the times we live in.
The marketplace should decide if non lead alternatives have a place not some townie bureaucrat pressured by a hairy hippy who only eats imported avocados while sitting down on their faux leather sofa being a keyboard warrior - sorry lost the plot a bit there, this non lead stuff gets me quite emotional

 

[Sharpie]

This is interesting, an also disturbing.

@Conor O'Gorman can you be more specific about the questionable details in the unseen data from the EU Food Safety Authority regarding actual amounts of lead contamination in game food for human consumption ? I presume that this is sufficiently damning to justify a request for another year's delay, and may have import regarding e.g. some GB AGHEs (NGDA members) decision to reject lead shot game, starting in six weeks time.

In reality, are the NGDA actually going to stick to that, or might a bit of pragmatism be on the cards. Not sure if they were somehow railroaded into that (ISTR with tacit support from BASC but maybe mis-remembered) or decided to do it off their own bat., maybe with a shove from Waitrose's in retrospect rather blatant campaign to dominate the supermarket sale of such stuff, by knocking all the others for not doing the same. No matter how well intended. Would be interesting to hear the background

I think this is rather important for the industry and everyone who prefers to see all game go into the food chain, as a healthy substance and recognised as such, even if, the horror, lead has been used in the killing.

The other concerns about distribution of lead into the environment of course are not changed

 

[robs5230]

Looks like the whole process should be halted and begin again, at the very least.

 

[Tim.243]

Phrases like “an estimated 1 million duck die every year from lead poisoning “. ring rather hollow to me. I didn’t think estimates had any place in factual arguments. Maybe it’s just me

BASC have bag reports sent to them from all the wildfowling club who are attached to them so that recorded data is to hand. @Conor O'Gorman

 

[sh1kar]

BASC have bag reports sent to them from all the wildfowling club who are attached to them so that recorded data is to hand. @Conor O'Gorman

Aren’t the bag reports shot by lead rather than poisoned by it?
S

 

[enfieldspares]

Aren’t the bag reports shot by lead rather than poisoned by it?
S

Erm...If in England and Wales they'd ALL be shot with something other than lead I'd hope? It's been illegal since the 1990s! In Scotland it'd be different and depend where they were shot.

 

[enfieldspares]

The European Ombudsman has recognised a case of maladministration by the European Food Safety Authority regarding its failure to provide key documents in a timely manner during last year’s public consultation on EU lead ammunition restriction proposals.

I'm just glad that we don't have to worry about it now, nor its outcome, since BASC with NO CONSULTATION OF ITS MEMBERS led and then enrolled other "useful idiots" to sign up to a voluntary lead shot ban.

 

[Tim.243]

Aren’t the bag reports shot by lead rather than poisoned by it?
S

Wild fowling (well in Essex) is with steel so that data is on file
In Scotland and Northern Ireland it is permissible to use lead shot to shoot any species outside wetlands. All members of the shooting community are legally bound to comply with the lead shot regulations, and to ensure that only non-lead shot is used wherever lead shot is banned under those regulations.

So blame them lol

 

[Dunwaters]

Finally a glimmer of light..

 

[Woodsmoke]

Phrases like “an estimated 1 million duck die every year from lead poisoning “. ring rather hollow to me.

And yet again no mention is made of the load content in the vast quantities of grain and potatoes fed to birds on reserves where shooting has been prohibited for decades.

 

[Bowland blades]

I have no vast trust of Bureaucrats taking notice of little things like true and fair process ( especially in the EU which has become a dictatorship by stealth ). That said its a glimmer of hope that should be seized so we have a genuine chance of change.
Lets not forget the lead over the last few hundred years deposited by shooting will not be materially greater in volume if we had reasonable time to make the switch in manufacturing required

 

[B&W FOX]

I'm just glad that we don't have to worry about it now, nor its outcome, since BASC with NO CONSULTATION OF ITS MEMBERS led and then enrolled other "useful idiots" to sign up to a voluntary lead shot ban.

View attachment 258019

Can you do one of the CPSA with their head in the sand as they seem to be in denial

 

[kes]

I wonder if any of this evidence was used in the adoption of the 5 year voluntary ban ? Was Chris Packham involved?

 

[timbrayford]

I wonder if any of this evidence was used in the adoption of the 5 year voluntary ban ? Was Chris Packham involved?

I think that the 5 year voluntary phase out was an attempt to pre-empt the 18 month legal ban now proposed by UK REACH

 

[palmer_mike]

I think that the 5 year voluntary phase out was an attempt to pre-empt the 18 month legal ban now proposed by UK REACH

I’m glad that worked so well.
Entirely predictable outcome of BASC and the rest rolling over im afraid

 

[Sharpie]

I think that the 5 year voluntary phase out was an attempt to pre-empt the 18 month legal ban now proposed by UK REACH

Point of information BASC announced the five year voluntary transition to elimination of all lead for shotgun quarry shooting on 24 February 2019. So two years and nine months are all that's remaining of that period, taking us to February 2024.

Given that the HSE work is not due to be complete for six months consultation from this month (get your input in sooner rather than later), plus a further six months for socio economic consultation and deliberation, followed by at shortest 18 months transition (but could be as much as five years), you will see that, in reality the BASC initiated five year plan is running to the same exact timescale as that of the 18 month minimum HSE proposal. Unless I've got my dates wrong.

Their last update on progress was February 2021,

@Conor O'Gorman perhaps time is over-due for another joint statement assessing progress. Worth downloading the full 2021 version rather than just reading the summary on the web page, where you will find comments from some manufacturers that are interesting.

An update on the five-year transition towards sustainable ammunition - The British Association for Shooting and Conservation

It is not universally backed by the industry. Indeed, Lyalvale Express, recently acquired by Fiocchi in April, still state on the front page of their website Home - Lyalvale Express at that time speaking for all UK manufacturers, that:

Special Announcement
We, the UK’s leading shotgun cartridge manufacturers, hereby address the announcement made by BASC and other organisations on Monday 24th February, stating their “wish to see an end to both lead and single-use plastics in ammunition used by those taking all live quarry with shotguns within five years”.

Firstly, BASC and their fellow organisations had NO consultation with the UK cartridge manufacturers prior to the announcement being made. The UK manufacturers have now discussed the matter collectively. We believe the organisations have looked at a limited amount of products and assumed that these are a viable answer to the issue at hand. Unfortunately, this is not the case.

This is a major concern to us for a number of reasons, reasons we would have explained to the organisations prior to the publication of their announcement, had we been given the opportunity to do so.

My presumption is that that sentiment is still held by the new owners.

As for we rifle shooters, hunting and target, air, rim and centrefire, well yes it does at times seem as if we are being thrown under the bus, though I daresay that's not really the case. Though the more enlightened stalkers, for whom the price of the projectile is a minor part of the equation, indeed frequently on a par with the more premium lead bullet, at least have been cracking on for quite a few years now, and discovering that copper can out-perform lead in many ways Purely for functionality, irrespective of toxicity concerns.