Dr Conor O'Gorman, head of policy and campaigns at BASC, answers some more of your questions and concerns about the health and Safety Executive's proposals for a lead ban in the UK as part of the settlement of the country's post-Brexit UK REACH regulations

Why would BASC challenge the UK REACH proposals when it seems to have accepted that steel shot is the way forward?

A voluntary move away from lead shot for live quarry shooting, with steel shot as one of the alternatives, does not mean we should not fight restrictions being imposed on us, especially when they attempt to impose one-size-fits-all restrictions on all outdoor recreational uses of lead ammunition. Most of the proposals are not evidence-based and, on lead shot for live quarry shooting, the timescales are too short. (Read steel shot vs lead shot – the hard facts.)

Steel shot is among a number of lead alternatives that ammunition manufacturers have been producing and improving on for decades – the catalyst in the UK being restrictions on the use of lead shot for wildfowl and/or wetlands that came into effect from the 1990s onwards.

Since 2020, BASC has been running events across the country giving people a chance to try out several types of steel cartridges for 12-bore shotguns. The options available all contain different types of non-plastic wads.

While these introductory events are focused on steel shot, on the policy front we are looking out for all shooting disciplines and the use of modern and historic firearms as we fight the UK REACH proposals.

BASC has recently published its position on the restriction proposals, which in summary are as follows:

Lead rifle ammunition and lead shot for live quarry shooting

• The restrictions must be evidence-based and proportionate to the risk, and work to realistic transition periods that account for global supply chain issues

Lead rifle ammunition and lead shot for target shooting

• BASC is opposed to the restriction proposals

Lead airgun pellets for live quarry and target shooting

• BASC is opposed to the restriction proposals.  More information and FAQs can be found here.

Few carcasses of birds poisoned by ingested lead are ever found because, it’s claimed, they’re eaten by predators. If that is so, why are numbers of avian scavengers such as kites, buzzards and crows increasing?

Some research has recently been carried out to look at the potential impact of lead ammunition on avian scavengers. In general terms, this modelling asserts that for bird species that are increasing, this is at a slower rate than should otherwise be the case due to the impact of lead ammunition; and for some bird species that are decreasing, this is at a faster rate than should otherwise be the case. Across Europe for the 10 raptor species studied it was estimated that the population was 6% smaller than otherwise expected due to the impact of lead ammunition.

However, these results have been inappropriately used by the scientists involved to call for a complete ban on lead ammunition across Europe. That leap from modelling research to policy recommendations by the authors of the study undermines the objectivity of the research.

Buzzard with prey

Studies claim populations of scavengers such as buzzards are impacted by lead shot

The evidence published with the UK REACH restriction proposals is not conclusive on the points of secondary exposure risk. While a potential exposure pathway exists, the ‘cause/effect’ relationship of lead ammunition to sub-lethal and lethal impacts on scavengers and birds of prey is not conclusive. This is because other sources of environmental lead could not be ruled out, even when lead isotope analysis is conducted.

However, while BASC will be fighting many of the restriction proposals, we do accept that in some settings lead ammunition poses an exposure risk that must be controlled because managing proven risks is beneficial to the environment and the long-term future of sustainable shooting.

Airgunning

BASC believes a ban on the outdoor use of lead pellets for airgunning is unjustified

The sector has already committed to a voluntary transition away from lead shot and single-use plastics for live quarry shooting and has ambitions to source small and large game from lead-free supply chains.

Are lead airgun pellets going to be banned? If so, why? Most quarry species are shot in the head when hunting with an airgun, so the lead does not come into contact with any edible meat.

Yes, a ban on the outdoor use of lead airgun pellets is proposed and BASC is fighting this because it is not justified. Lead airgun pellets should be allowed to continue to be used for live quarry and target shooting where risks are appropriately and proportionately controlled.

As per the example in the question, the risks to human health from eating game meat are nil to negligible from quarry killed with airgun pellets. The nature of use and construction of lead airgun pellets is that lead is highly unlikely to fragment in quarry and pellets would be detected and removed when preparing the game meat for consumption.

Also, the evidenced risks of secondary poisoning of birds from lead airgun pellets is nil or negligible. Moreover, there has been no research done evidencing any risks from airgun pellets contaminating the soil and the lead-contaminated soil or vegetation being eaten by livestock.

Lead shot buy-back schemes have been proposed. Will similar schemes be extended to owners of serviceable guns with damascus barrels who can’t afford bismuth cartridges? If not, why not?

No details have been given in the consultation about how a ‘buy-back’ scheme for lead ammunition might operate and how effective this could be. Readers could help by submitting their opinions on this in their responses to the consultation.

Throughout the process, BASC will hold firm to some overarching principles:

We will challenge restrictions 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.

We will fight for timelines that are realistic and guided by the sector to ensure that the range of lead-free products and their supply can meet market demands.

Working closely with other organisations, we will ensure that the needs of both live quarry and target shooting interests are considered, and we will continue to oppose one-size-fits-all restrictions.

Have your say

The online consultation response form can be completed before 6 November 2022 and you do not need to answer all the questions.

Many people are simply answering the ‘general comments’ question on the second page of the survey form.