No logic to lead ban
BASC’s Dr Conor O’Gorman wonders whether the Health and Safety Executive will see common sense and drop its lead ban proposals.
Following a call for evidence and two public consultations, the Health and Safety Executive (HSE) will soon complete its review of lead ammunition and make its recommendations to the Defra secretary for consideration.
However, before doing so the HSE needs to take account of an estimated 5,000 responses to its recently closed consultation. There is unquestionably a lot at stake.
In October 2023 the HSE confirmed in consultation documents that it would not be recommending a ban on lead airgun pellets for either live quarry or target shooting, and that lead rifle ammunition could continue at approved ranges. However, in that final consultation the HSE was still considering a ban on nearly every other outdoor recreational use of lead ammunition in England, Wales and Scotland.
BASC pulled no punches in its consultation response, which considered the impacts on every shooting discipline, both live quarry and target, and the documents we submitted can be downloaded from the ammunition section of the BASC website.
In our response to the HSE we made it clear that BASC was opposed to further regulation on the use of lead ammunition in the UK for the following reasons:
Regulations are already in place to mitigate risks to wildfowl from the use of lead shot in wetlands.
There is clear evidence that lead shot poses a risk to a wide range of bird species in terrestrial habitats and a voluntary move away from lead shot for shooting live quarry with shotguns is reducing those risks.
The shooting sector must be allowed time to develop non-lead shotgun ammunition, due to a world shortage of components and the need for manufacturers and assemblers to source new machinery to produce lead shot alternatives and biodegradable wads for all shotgun calibres.
Lead in game meat is a potential risk to human health through secondary exposure and government guidance and market forces are managing risks via best practice.
Lead exposure pathways are not conclusive for livestock, soil, soil organisms, plants and surface waters, and current legal and regulatory frameworks are in place to manage risks.
BASC critiqued every assertion presented by the HSE on the exposure risks from lead ammunition and in most cases found the evidence to be either inconclusive or theoretical in nature. As a result, BASC found many of the restriction proposals to be over-precautionary.
We outlined the significant progress that was being made with the voluntary transition away from lead shot and single-use plastics in shotgun cartridges for shooting live quarry, but outlined the various challenges that still needed to be addressed.
BASC detailed these challenges, including lack of lead alternatives for smaller shotgun gauges (20-bore and smaller), which account for 22.9 per cent of cartridges used in live-quarry shooting, a shortage of components including powder, and a production bottleneck for steel shot.
As a result of the above — and much more — BASC has called for amendments from the HSE (see panel, left). Will it now do the right thing and further revise its restriction proposals before finalising its recommendations? We hope so, but if it does not we will keep fighting for a proportionate approach based on the evidenced risks