UK REACH lead ammunition review announced

[Conor O'Gorman]

Sorry, what I you trying to tell me by this??

That you were all proved right? With last year’s announcement the became a self fulfilling prophecy.

Either way, what ha it got to do with me shooting foxes with lead bullets or rabbits that don’t enter the food chain?

because you and the other 8 are going to take that away from me.

Are BASC going to pay me compensation for the guns that will need to be rebarreled or will become useless when lead is banned? Or pay me for the thousands of bullets I have for shooting vermin and paper once they are banned?

Genuine questions

I was hoping you might read the statements I linked to given that you continue to make comments about a 'lead ban' even to the extent of conflating the use of rifle ammunition with poisoning in wildfowl, which is not the case. You also continue to focus on BASC when in fact nine organisations stated the following in February last year:

In consideration of wildlife, the environment and to ensure a market for the healthiest game products, at home and abroad, we 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. The shooting community must maintain its place at the forefront of wildlife conservation and protection. Sustainability in our practices is of utmost importance.

Many years ago, wetland restrictions demanded a move away from lead shot and we believe it is necessary to begin a further phased transition. Recently, there have been significant developments in the quality and availability of non-lead shotgun cartridges, and plastic cases can now be recycled. For the first time, biodegradable shot cups for steel shot, with the necessary ballistics to ensure lethality, are available. These welcome advances are continuing at an ever-quickening pace, in response to demand from a changing market. Such advances mean that, over the coming years, a complete transition is achievable.

We are jointly calling for our members to engage in this transition and work with us, the Gun Trade Association and the cartridge manufacturers to ensure that further viable alternatives are developed for every situation involving live quarry. This is an opportunity to take the initiative and ensure the reputation of the shooting community, as custodians of the countryside, is both maintained and enhanced.

If you have genuine questions I would be happy to discuss them with you over the phone so how about messaging me or emailing me at conor.ogorman@basc.org.uk to arrange a time for us to discuss?

 

[Cambridge Pimpernel]

Connor thank you. What is BASC’s position on lead core/lead RIFLE ammunition, if the anti-lead lobby seeks to encompass it in any proposed ban, going further than the voluntary-move statement BASC issued 12 months ago? Will BASC fight such an extension? It seems to me that if lead RIFLE ammunition was excluded, ie could continue to be used, then those supplying eg venison into the food chain are de facto policed by the likes of the NGDA/food buyers stipulations, leaving those riflemen using lead ammuniton for a) vermin control, b) air-gunning, or c) those shooting deer for their own pot, free to continue to do so (at their own, ridiculously low, risk). Separately, I note also that currently all solids are currently banned from use on NRA ranges due to ricochet risk (this is documented and can be confirmed by the NRA). The Army also uses lead ammo and a lot of it. I am not convinced that the Army, which enjoys close and indeed formal links with the NRA, or the NRA are about to endorse a change to solids any time soon, the NRA on safety grounds, and the Army on cost grounds. BASC might well benefit from an early conversation with both organisations so that a defence of the continued use of lead in Rifle ammunition, the free choice to do so of which I would have thought many BASC members would welcome, can be better organised than has been the case with shotgun ammunition. Indeed, maybe BASC would consider polling its members as to their views on the matter, before issuing a blanket statement purporting to represent the view of all members...?

 

[Woodenbeam]

Conner a big gripe is the fact that the shooting organisations acted ‘on behalf’ of their membership without actually asking said membership and BASC seemed to be spearheading this change which is why I think you guys come in for most flack. I seem to recall a / some organisations stepping back a touch from the original statement.
I feel most people agree that in an ideal world lead would be a thing of the past however this is a far from ideal world we live in and a switch to something else is far from straight forward. This ‘lead’ topic has really split the elements of the shooting community and has been quite decisive which plays really well for the likes of Mr Packham, Avery & Co.
It seems almost a continuous anti lead rhetoric from all sides and things seem to be racing away before adequate replacements are available. The latest field sports lead v copper debate was interesting, real world testing etc etc but I noted not much .243 being tested & then quietly it being mentioned about possible issues with this calibre. Bullet weight, stabilisation & legalities with regard to deer - thank you very much I thought, I’m guessing I’m not the only casual stalker with a .243 who may be affected. Now you could argue it’ll come, and I’m sure it will but with everybody (inc shooting organisations) shouting lead is BAD it may happen as a knee jerk reaction and then where do we go............& these things do happen, general licenses spring to mind and that was an unbelievable balls up causing untold damage.
The issues I have with most of this is I’m of the opinion the dangers of lead in the shooting world are being over exaggerated to tug on the heartstrings and organisations are trying to appease as opposed to standing up for their members.
I do admire you though for continuing to frequent this forum (May not agree with much of your sales pitch but give you credit for being a voice)

Ya got two ears though so suggest you use ‘em

 

[25 Sharps]

I was hoping you might read the statements I linked to given that you continue to make comments about a 'lead ban' even to the extent of conflating the use of rifle ammunition with poisoning in wildfowl, which is not the case. You also continue to focus on BASC when in fact nine organisations stated the following in February last year:

In consideration of wildlife, the environment and to ensure a market for the healthiest game products, at home and abroad, we 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. The shooting community must maintain its place at the forefront of wildlife conservation and protection. Sustainability in our practices is of utmost importance.

Many years ago, wetland restrictions demanded a move away from lead shot and we believe it is necessary to begin a further phased transition. Recently, there have been significant developments in the quality and availability of non-lead shotgun cartridges, and plastic cases can now be recycled. For the first time, biodegradable shot cups for steel shot, with the necessary ballistics to ensure lethality, are available. These welcome advances are continuing at an ever-quickening pace, in response to demand from a changing market. Such advances mean that, over the coming years, a complete transition is achievable.

We are jointly calling for our members to engage in this transition and work with us, the Gun Trade Association and the cartridge manufacturers to ensure that further viable alternatives are developed for every situation involving live quarry. This is an opportunity to take the initiative and ensure the reputation of the shooting community, as custodians of the countryside, is both maintained and enhanced.

If you have genuine questions I would be happy to discuss them with you over the phone so how about messaging me or emailing me at conor.ogorman@basc.org.uk to arrange a time for us to discuss?

I read the whole paper.

I also spoke to one of you directors on the matter last year and made my view and concerns known. I was invited to attend the AGM but obviously that did not happen.

You (BASC) and the other organisations don’t have shooters’ best interests at heart. At the very least you all should have made the case and consulted your membership before last year’s announcement.

The reason I focus on the BASC is I was a member for some years before and when this happened and you keep posting anti lead propaganda on here.

Out of interest, what will i shoot for gallery rifle out of my .357s the lead ban comes in? Have you even considered high volume target sports?

 

[25 Sharps]

Connor thank you. What is BASC’s position on lead core/lead RIFLE ammunition, if the anti-lead lobby seeks to encompass it in any proposed ban, going further than the voluntary-move statement BASC issued 12 months ago? Will BASC fight such an extension? It seems to me that if lead RIFLE ammunition was excluded, ie could continue to be used, then those supplying eg venison into the food chain are de facto policed by the likes of the NGDA/food buyers stipulations, leaving those riflemen using lead ammuniton for a) vermin control, b) air-gunning, or c) those shooting deer for their own pot, free to continue to do so (at their own, ridiculously low, risk). Separately, I note also that currently all solids are currently banned from use on NRA ranges due to ricochet risk (this is documented and can be confirmed by the NRA). The Army also uses lead ammo and a lot of it. I am not convinced that the Army, which enjoys close and indeed formal links with the NRA, or the NRA are about to endorse a change to solids any time soon, the NRA on safety grounds, and the Army on cost grounds. BASC might well benefit from an early conversation with both organisations so that a defence of the continued use of lead in Rifle ammunition, the free choice to do so of which I would have thought many BASC members would welcome, can be better organised than has been the case with shotgun ammunition. Indeed, maybe BASC would consider polling its members as to their views on the matter, before issuing a blanket statement purporting to represent the view of all members...?

Simple answer, they have included it in the voluntary ban, paving the way for a full ban.

 

[25 Sharps]

I was hoping you might read the statements I linked to given that you continue to make comments about a 'lead ban' even to the extent of conflating the use of rifle ammunition with poisoning in wildfowl, which is not the case. You also continue to focus on BASC when in fact nine organisations stated the following in February last year:

In consideration of wildlife, the environment and to ensure a market for the healthiest game products, at home and abroad, we 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. The shooting community must maintain its place at the forefront of wildlife conservation and protection. Sustainability in our practices is of utmost importance.

Many years ago, wetland restrictions demanded a move away from lead shot and we believe it is necessary to begin a further phased transition. Recently, there have been significant developments in the quality and availability of non-lead shotgun cartridges, and plastic cases can now be recycled. For the first time, biodegradable shot cups for steel shot, with the necessary ballistics to ensure lethality, are available. These welcome advances are continuing at an ever-quickening pace, in response to demand from a changing market. Such advances mean that, over the coming years, a complete transition is achievable.

We are jointly calling for our members to engage in this transition and work with us, the Gun Trade Association and the cartridge manufacturers to ensure that further viable alternatives are developed for every situation involving live quarry. This is an opportunity to take the initiative and ensure the reputation of the shooting community, as custodians of the countryside, is both maintained and enhanced.

If you have genuine questions I would be happy to discuss them with you over the phone so how about messaging me or emailing me at conor.ogorman@basc.org.uk to arrange a time for us to discuss?

With regards lead ban vs lead shot ban

BASC are only ruling out a ban in a contained environment (I.e. a range butt)

Therefore it is reasonable to assume that you are looking at ALL bullets for live quarry shooting, pretty much confirmed in the conversation I had last year.

 

[Conor O'Gorman]

@Cambridge Pimpernel
@Woodenbeam

Thanks for the comments. I hear what you are saying and as BASC members we elect our BASC Council members and the decision making is carried out by our Council members.

Details for 2021 BASC elections and AGM are here:

BASC Council Elections 2023 - The British Association for Shooting and Conservation

BASC Council Elections 2023 Applications for BASC Council elections are now open Do you have the knowledge, experience and drive required to shape BASC’s future direction? Applications are now open for two national Council seats coming up for election in 2023. Regardless of background or length...

basc.org.uk

The 2020 BASC AGM was in July and you can read the AGM Q&As here:

AGM

Read all the minutes from the Annual General Meeting.

basc.org.uk

BASC does not have a position on the phasing out of lead core/lead rifle ammunition. BASC is amongst nine organisations that stated last year that they wished 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.

 

[Conor O'Gorman]

Simple answer, they have included it in the voluntary ban, paving the way for a full ban.

That is simply not true and as I posted earlier if you have genuine questions I would be happy to discuss them with you over the phone so how about messaging me or emailing me at conor.ogorman@basc.org.uk to arrange a time for us to discuss?

 

[25 Sharps]

That is simply not true and as I posted earlier if you have genuine questions I would be happy to discuss them with you over the phone so how about messaging me or emailing me at conor.ogorman@basc.org.uk to arrange a time for us to discuss?

How is it not true?

Are rifle bullets for quarry use not included into the FAQ answer I posted above?

The paper posted above that you have tacitly agreed with entirely promotes a full ban.

If it had simply been a food safety issue that’s one thing but as soon as you bring unintentional poisoning of wildlife and pollution of the environment you group of 9 will not be able to argue against a full ban.

 

[Pellet Pinger]

BASC does not have a position on the phasing out of lead core/lead rifle ammunition. BASC is amongst nine organisations that stated last year that they wished 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.

Do you not think the organisation should have a position, considering the huge impact a blanket ban on lead would have for the rest of the shooting community?

 

[Stevie/P]

Do you not think the organisation should have a position, considering the huge impact a blanket ban on lead would have for the rest of the shooting community?

they just dont care

 

[Sharpie]

Dear Conor, firstly thank you for continuing to engage with the SD Massive, warts and all.

You are in an invidious position over this. I am sorry, but passing the buck onto "the council" and "obeying orders" does not absolve you from reflecting upon your own position. You are an educated and I think honourable man, doubtless with your own opinions about many things, but must keep those to yourself.

Thank you for clarifying that BASC has no interest in, nor position statement upon, nor intention to lobby/influence/whatever about the future use of lead in sporting rifle shooting. Far too little and far too late. At least that is clear. TBH I think that the way that things are going to change, for rifle shooters, has long been seen as inevitable, the industry is tooled up for it, hunters, at least on here, are reasonably educated about it and mostly accepting of it (though we do like to moan and stir the pot). Personally I am quite accepting of it, even a minor zealot for it.

Your focus is entirely upon the shotgun side of fieldsports primarily and the industry that caters to it. Not sure which you see as the more important, to you. It seems to me to be in a dreadful muddle, and that BASC and other organisations are incoherent, confused, unable to react to changing events and public sentiment, flat footed, easily outwitted by a tiny number of, lets face it, highly intelligent, focussed and driven individuals. And still continue to try to defend the indefensible. Reactive (barely), pro-active, no, never. Alert to fast moving developments and responsive ?

Overly influenced by, say, one dominant indigenous manufacturer of such things, possibly. Who is manipulating whom, and in whose interests ?

Countryside matters seemingly very much secondarily.

How is your behind the scenes lobbying going, you had a chap doing that, clubbable, supposed contacts in high places (mostly in opposition to the current Govt.) As for the grand days out, preaching to the converted, mostly the same stale lot always up for a freebie, not necessarily declared as might have been thought necessary, well, how effective has that been ?

Your conservation work is still laudable, but others are also doing much more nowadays, ISTM.

I wish you well, but BASC does increasingly come across as an anachronism in this age. Looking on from the outside, rather than the echo chamber within.

 

[Liveonce]

With regards lead ban vs lead shot ban

BASC are only ruling out a ban in a contained environment (I.e. a range butt)

I think that could come down to an indoor range only.

Still can alway use an MOD range given any lead ban is unlikely to include the MOD.

 

[25 Sharps]

I think that could come down to an indoor range only.

Still can alway use an MOD range given any lead ban is unlikely to include the MOD.

That doesn’t really help my local gallery range though

 

[Sharpie]

That doesn’t really help my local gallery range though

No, it does not.

Nor does it allow any civilian use of lead ammunition, be it for rifle or shotgun, on outdoor ranges or for hunting whatsoever. Whether they be MoD or otherwise. The exemptions proposed are only for military, police, security and customs forces.

As proposed it amounts to a total ban on lead for any outdoor shooting activity.

This is the wording, as of 15/1/2021. This is the starting position, let's hope that it is adjusted sensibly.

"Placing on the market and use of lead in projectiles (for firearms and airguns), and in fishing sinkers and lures for outdoor activities. Outdoor activities include hunting, sports shooting, other outdoor shooting and fishing. Military uses of lead projectiles, along with other uses such as by police, security and customs forces, are outside the scope of the restriction proposal. Indoor uses of lead projectiles are also excluded from the scope of the restriction proposal."

Registry of restriction intentions until outcome - ECHA

echa.europa.eu

Here is the entry point for the legislation:

Lead in shot, bullets and fishing weights - ECHA

echa.europa.eu

The background to the new developments starting this year:

All news - ECHA

The European Chemicals Agency brings forward a proposal for further EU-wide restrictions on the use of lead in ammunition for hunting and outdoor sports shooting as well as in fishing. The proposal aims to address the risks of lead in these activities to protect people, wildlife and the environment.

echa.europa.eu

Here is the request for comments:

All news - ECHA

The European Chemicals Agency invites stakeholders to send in scientific and technical information on the use of lead in ammunition for hunting and sports shooting as well as in fishing by 24 September 2021.

echa.europa.eu

"Have your say on proposed restriction of lead in outdoor shooting, hunting and fishing
The European Chemicals Agency invites stakeholders to send in scientific and technical information on the use of lead in ammunition for hunting and sports shooting as well as in fishing by 24 September 2021.

Helsinki, 24 March 2021 – This six-month consultation opens on 24 March 2021 and closes on 24 September 2021 (23:59 Helsinki time). ECHA’s scientific committees for Risk Assessment and Socio-Economic Analysis welcome early comments by 5 May 2021 to assist them in the first discussions on the proposal in June 2021.

An online information session on the proposed restriction will be held on 15 April from 11:00 to 13:00 Helsinki time. During the session, ECHA’s experts will explain the specific questions posed in the consultation and clarify how to submit comments. This session will be held in English and is open to everyone planning to take part in the consultation.

ECHA submitted its proposal to restrict lead in ammunition for outdoor shooting and in fishing tackle on 15 January and published it on 3 February 2021.
"

Doubtless BASC will be preparing a detailed submission. It is absolutely vital that all voices are heard.

Conor's statement that "BASC does not have a position on the phasing out of lead core/lead rifle ammunition." is indefensible.

Conor, please could you publish BASC's submissions to this consultation as soon as they are ready. This is not a matter that should be kept "behind closed doors". They will probably be published later, by ECHA for all to see.

For example, a previous, consultation report from back in June 2017

https://echa.europa.eu/documents/10162/c521de15-e940-dd95-daba-9416a21ca636

To return to the start of this thread " Responding to today’s UK REACH announcement regarding the consideration of further restrictions on all lead ammunition" Frankly this seems to me simply to be mirroring the new ECHA process, operating to a very similar timescale.

The UK must adopt EU REACH directives. This was cast in law on 1 January 2021 when we Brexited. UK REACH is merely the mechanism by which the UK will manage it's duty to maintain commonality with EU REACH, now managed by our HSE, outwith the ECHA. Whatever is decided in the EU will soon apply here, perhaps with some adjustments to things like timescales, definition of wetlands, phase out periods etc.

This is how I understand the current situation, please correct me if I am wrong.

Certainly our big shotgun ammunition manufacturers are going to have to comply if they wish to continue trading with the EU. As to what our remaining cottage industry of rifle cartridge manufacturers may be allowed to continue on doing, well who knows ? Any components that they source from an EU REACH territory, or further afield will of course have to be UK/EU REACH compliant.

I do not think it likely that the UK will be able to take a significantly different line than the EU in any discernible way. Nor do I think it likely that the big manufacturers will choose to keep making lines of none EU REACH compliant products for the home market, even if there is some sort of UK only derogation, which seems rather improbable to me.

 

[Sharpie]

Further, here is the ECHA consultation document. I think that the idea is to seek derogations from the 15 Jan 2021 position, rather than try to kick it into touch again.

Well worth a read, to see where they are coming from.

https://echa.europa.eu/documents/10162/7ad31735-de6b-e593-18aa-e845ae58dd5b

 

[25 Sharps]

Thanks Sharpie.

Seems we are doomed.

But as long as folk can shoot deer with copper bullets the fine, sod the rest of us

 

[andyk]

Three words in that report pretty much sum the proposal (and the EU’s approach to freedom of choice) ‘not adequately controlled’.

Assuming one accepts (and I’m not saying you should) all of the risks they highlight, the risks only justify a ban on use of lead in situations where it is likely to enter the human food chain or be consumed by animals. There really seems no justification (even on their own evidence) other than control for its own sake, to extend this to rifle ranges or clay grounds, with a possible exception if they are in sensitive areas.

The best bit is when they go on about the risk of handling lead ammunition or casting your own. That should be people’s own damn choice. So long as people can chose to smoke, it seems utterly disproportionate to say someone can’t choose to touch lead.

 

[Alantoo]

But as long as folk can shoot deer with copper billets fine then sod the rest of us

???

I have noticed you make that sort of comment a few times recently...

How are people who choose to shoot deer with copper bullets able to cause you any grief? And why do you think they would wish to?

How many people who shoot deer with lead free don't have air rifles, shotguns or 22LR rifles and shoot at open air ranges do you think?

As someone who shoots deer with lead free bullets, I have been sharing lead free bullets vs deer results on the Stalking Directory in part to counter some of the doom merchants' pronouncements that it is impossible to carry on as a stalker using lead free.

But my using lead free for deer and sharing information doesn't in any way affect or detract from your shooting activities, or any other form of shooting or ammunition. How can it?

Alan

 

[NigelM]

Does anyone know what the NRA are doing about a potential lead ban? They are the ones who should be defending target shooters and lobbying government on their behalf. The last post I can find on the NRA site or googling NRA Lead Ban is from July 2016 when they declared they had won the fight with the secretary of state.