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HSE report on lead ammo will be in autumn

The public consultation on lead ammunition has been pushed back again, largely thanks to the concerted efforts of BASC members.

The Health and Safety Executive is allowing more time to review the 8,159 responses to its consultation last year before finalising its restriction proposals by September. In March 2021, the Government tasked the Health and Safety Executive (HSE) with a two-year review into the outdoor recreational use of lead ammunition, which was expected to conclude in recommendations last year to the Defra Secretary and the Scottish and Welsh governments. 

Lead in ammunition, and some substances in tattoo inks and permanent makeup, were the first areas to be reviewed under post-Brexit legislation called UK REACH on the control of hazardous chemicals. This mirrored similar reviews in the EU by the European Chemicals Agency under EU REACH rules. 

Since 2021, many more substances have been subject to HSE reviews, again mirroring similar reviews for those substances in the EU. All of this is to ensure continued trade in chemicals with the EU post-Brexit. 

No new laws 

In June last year the HSE published its final opinion on restrictions for hazardous substances in tattoo inks and permanent makeup. This was the first HSE restriction proposal under UK REACH and, almost one year later, the Government has yet to respond. There are no new laws in place. 

The HSE had originally timetabled its final opinion on restrictions for lead ammunition for last year. However, things have not gone to plan, thanks largely to BASC campaigns underpinned by evidence and supported by 10,918 responses to two consultations. 

The October 2022 HSE consultation on proposals to ban lead ammunition for nearly all outdoor recreational shooting activities resulted in 2,759 responses. This was a tiny response relative to the circa 600,000 people with shotgun and firearm certificates, let alone the estimated two million active airgunners. 

But it was a much bigger response than that received to a similar consultation last year on banning lead ammunition in the EU. So relative to the circa seven million hunters in the EU, who only managed a few hundred responses, we did quite well at that stage of the review process. 

Congratulations if you were among those 2,759 responders, because your evidence won major concessions, with the HSE requiring an extra six months to review it all (News, 14 February). 

Having completed its analysis to that consultation, the HSE announced it had dropped its original proposals to ban lead airgun pellets for lack of conclusive evidence. It also conceded that target shooting with lead rifle ammunition should be allowed to continue at approved ranges. 

However, the HSE’s final public consultation, launched in October 2023, still sought restrictions on nearly every other outdoor recreational use of lead ammunition in England, Wales and Scotland. That consultation received 8,159 responses (thank you all), and in January 2024 the HSE announced it would need more time than expected to go through all the responses and would publish a new timeline in due course. 


Things went quiet until last month, when the HSE sent an email to stakeholders explaining that it was working towards September 2024 to formulate its final opinion on its restriction proposals. It said “this extension will enable HSE to process, analyse and where appropriate take account of the information received in the final restriction proposals”. 

It is good that HSE is dedicating the necessary staff resource and time to properly go through the responses, many of which were well thought out and evidenced arguments against the remaining restriction proposals. 

BASC’s Terry Behan, who is leading on this policy area, said: “We can expect the HSE’s final recommendations on lead ammunition to be published this autumn. Meanwhile, as an accredited stakeholder with the HSE, BASC will continue to have oversight of the final scrutiny process, as we will be invited to attend meetings of the HSE’s independent scientific expert panel. 

“If BASC has concerns that any resulting legislative proposals are unevidenced and will damage shooting, we will lobby for them to be revised.”