Gun Trade World - January 2023

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BASC responds to lead ammo ban proposals
A report circulated on 6 May this year by
the Health and Safety Executive (HSE) –
under UK REACH – proposed a complete
ban on outdoor recreational uses of all forms
of lead ammunition in England, Scotland
and Wales, with limited derogations. The
consultation on the proposals recently
closed.
BASC, The British Association for
Shooting and Conservation, prepared
a all-inclusive reaction, which we have
summarised below:
BASC’s response
- Online submission to the UK REACH
consultation
- BASC review of the UK REACH Annex
XV restriction dossier on lead ammunition,
supported by:
• BASC technical report: Accuracy and
penetration testing of lead-free
ammunition in .243 calibre
• BASC technical report:
Accuracy and penetration testing
of lead-free ammunition in .22lr -
rimfire calibre
• BASC technical report: Accuracy
and muzzle energy testing of leadfree
airgun ammunition in .177
and .22
• BASC technical report: Weight
retention of lead airgun pellets.
Live quarry shooting
There is clear evidence of risk of
primary poisoning of birds from
lead shot and of the human health
risk from exposure to lead in game meat.
Having assessed the evidence, BASC
concluded that restrictions on the sale and
use of both lead shot and expanding lead
rifle ammunition for live quarry shooting
would be effective at eliminating those
proven risks.
The transition periods for regulation of
lead shot and expanding rifle ammunition
must be agreed in close consultation with
the shooting sector and take account of
technical and global supply chain issues.
To support BASC’s position, it has
submitted a series of technical reports.
These demonstrate the need for raising
the threshold of ‘small calibres’ within the
UK REACH dossier to include any calibre
below 6.5mm. This would provide a longer
transition period for calibres such as .243.
For rimfire ammunition, BASC is asking
that restrictions are not implemented
until suitable lead-free alternatives can be
guaranteed at scale.
ASC maintains its view that airgun
ammunition should not be restricted as
the risk to human health can be managed
through existing sector guidance on game
meat handling. BASC has also prepared a
technical report demonstrating the inherent
unsuitability of existing lead-free airgun
ammunition for live quarry shooting.
BASC remains committed to the
voluntary transition away from lead shot
and single use plastics for shotguns used
in live quarry shooting. As such, it believes
that further regulation is not required in this
area.
Clay pigeon and target shooting
BASC says that the evidence presented by
the HSE on secondary exposure to birds,
plus lead exposure pathways to livestock and
other animals, soil, soil organisms, plants,
and surface waters, is not conclusive.
The association believes that the HSE has
failed to address uncertainty in the evidence
as is required by regulatory guidance. As a
result, restrictions based on these risks are
unnecessary and disproportionate.
BASC deems that lead shot could
continue to be used for clay pigeon /
target shooting at venues where risks of
primary exposure to birds is managed. It
also advocates that lead rifle ammunition
(non-expanding) can continue to be used
on ranges. BASC believes that current legal
and regulatory frameworks are effective and
further regulation risks the unnecessary
‘gold plating’ of environmental directives.
BASCs requests
BASC is also making the following requests
of the HSE:
1. Re-assess the use and risk of lead
ammunition in the UK context.
2. Uphold the transparency requirements
of the European Chemicals Agency
(ECHA) for Annex XV restriction dossier
preparation.
3. Reassess their estimate of lead shotgun
ammunition use.
4. Reassess their estimate of rifle
ammunition use.
5. Review their assessment of environmental
and human health impacts and benefits of
restrictions.
6. Ensure accurate costs are applied during
the forthcoming socio-economic impact
assessment.
7. Thoroughly explore the uncertainty in the
evidence in relation to secondary poisoning
of birds from lead ammunition.
8. Thoroughly explore the uncertainty in the
evidence in relation to impacts on ‘other’
animals from lead ammunition.
9. Thoroughly explore the uncertainty in
the evidence in relation to impacts on soil,
soil organisms and vegetation from lead
ammunition.
10. Exclude surface and ground waters from
its proposals.
11. Move the boundary for defining ‘large
calibre’ centrefire ammunition to
≥6.5mm.
12. Ensure that any restriction
and transition period for rimfire
ammunition is reviewed before
implementation.
13. Drop proposals for restricting
the use of lead airgun ammunition.
14. Consider providing extended
transition periods for small gauge
shotgun calibres of 28 bore and
smaller.
15. Revise restriction proposals,
ensuring that they are
proportionate to the evidenced
risk, make best use of existing legal
and regulatory frameworks and
avoid ‘gold plating’ existing environmental
directives.
16. Implement a buy-back scheme to: a.
Fairly compensate material loss resulting
from restrictions; b. Incentivise the
transition to lead free alternatives; c. Ensure
that the restrictions do not create a ‘false’ or
‘early’ cliff- edge for sales of lead products
that undermines manufacturers’ ability to
invest in development and production of
lead-free alternatives.
Next steps
The HSE and Environment Agency (EA)
will review the consultation responses
prior to preparing a final restriction report.
This report, expected to be published
in early summer 2023, will be a set of
recommendations to Defra. This will provide
the basis for legislation.
It is likely that a 60-day consultation
will launch in February 2023 as part of the
HSE’s Socio-Economic Impact Assessment
of proposals.
www.basc.org.uk
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