British shooting organisations may not unanimously agree on a future for lead ammunition – but they all want shooters to respond to the Health & Safety Executive’s report on banning it.
The HSE has brought out a report (and vast annex to that report, together totalling 467 pages) proposing a ban on most lead bullets for outdoor target shooting and hunting plus a ban on the sale and use of lead shot. The six-month public consultation closes on 6 November 2022. It proposes allowances for ‘authorised athletes’ and ‘licensed ranges’ but offers little wriggle room for the bulk of shooting sports that take place in England.
The wide-ranging proposed restrictions, which are similar to the EU’s REACH proposals, would apply to shotgun, rifle, and airgun ammunition. They will change the way Britain’s 650,000 shotgun and firearm certificate holders and estimated 12 million airgun owners go shooting.
Shooting umbrella body Aim to Sustain, which includes BASC, prefers a self-regulating model to the government regulation which the HSE wants to impose. In a letter to its critics at the RSPB and Wildfowl & Wetlands Trust, Aim to Sustain chiefs write: ‘Our organisations do not support further regulatory constraint, nor do we judge it necessary. If, however, Government feels it necessary to bring forward further legal restrictions on the use of lead ammunition, we are committed to ensuring that any such proposals are robustly scrutinised, evidenceled and, most importantly, proportionate to any identified risk with appropriate transition periods to allow manufacturers the time to scaleup production of viable alternatives to lead.”
Shooters widely regard lead as the best quality and best-value material for the shot in shotshells, the bullets in rifle cartridges, and the pellets that airgunners shoot. The HSE cites science which says there is ‘no safe level of lead’ in human consumption. However, it does not cite science about safe levels of lead shot alternatives: bismuth, tungsten and steel. Shooters are already pointing to restaurant operator McDonald’s alleged self-imposed ban on steel grinders for meat in its burgers because of the risk that tiny quantities of that steel shed by the grinders into food could contribute to liver cancer. Shooters fear that the HSE report is produced by people who want to ban shooting, not just shooting with lead ammunition.
The new fast-track approach by the government overtakes the shooting organisations’ own attempts to phase out lead. It comes after DEFRA minister Rebecca Pow warned she would ban all lead by statutory instrument if shooters did not come to heel.
In 2019, BASC and the Countryside Alliance led a group of shooting organisations that called for a five-year phase-out of lead shot. That produced a backlash from members and the gun trade that both organisations are still feeling. Two years later, cartridge manufacturer Lyalvale Express (now owned by Fiocchi) still has a statement on its website criticising the shooting organisations’ plan.
Now, BASC’s view is that the writing is on the wall. It wants to work with the regulator to make sure it acknowledges the huge challenge that the possible changes will bring to the shooting community. BASC is working with the Gun Trade Association, the British Shooting Sports Council and, it says, UK manufacturers to examine the report. BASC says it will play a ‘full role’ in scrutinising the proposals and will challenge the proposed restrictions ‘where there are no viable alternatives to lead’.
Other organisations plan a stronger fightback. Andrew Mercer, secretary general of the National Rifle Association in the UK, says: “These proposals pose a real threat to the future of target shooting. We are reviewing the document and will publish our response to the proposals by 1st July 2022. It is essential that the target shooting community respond in large numbers to the consultation in a coordinated, measured and rational manner.”
BASC England director Dan Reynolds agrees the shooting sector has issues with component parts, raw materials, machining and tooling. He says: “Those are all challenges which need to be reflected in the consultation process. It very difficult to say where we would be in the future but I do think that what we’ve got to do now over the period of consultation is to engage, is to be robust, be challenging, be credible and try and get to the end of this. If we do have restrictions that it is on that basis of necessity, and proportionality to the risk that has been identified.”
The stakes are high. Shooting is worth £2 billion to the UK economy and employs more than 74,000 people. Dan says it is vital that BASC collects evidence to go back to the regulator. He wants to explain the specific circumstances if there is no viable alternative to lead. He says: “For example, if they are saying there’s an 18-month transition period for a given element and we go back with evidence to say that is just technically not possible – it’s economically not viable to do – then, hopefully, if the regulators are working on an evidence base and proportionality they would offer some form of exemption or derogation for to allow that to continue. Or, additionally, look at a transition period which reflects the fact that the manufacturers can say what is technically and economically viable and how quickly or how long is that going to take.”
Aim to Sustain is calling for the HSE and UK REACH to work with manufacturers and assemblers to plan a ‘routemap’ for ‘adequate supplies of sustainable ammunition’.
Dan says BASC wants to protect sectors where there aren’t viable alternatives to lead. He admits that, though there may be areas where it is technically possible to make the change, it may be too costly. He says: “Technically, it might be viable to make bullets out of gold, but nobody’s going to be able to afford to that.”
Dan says BASC and other organisations have to take the lead in the process. He acknowledges that many members objected to the voluntary transition but he believes they now realise it is important. He says: “I think it’s about the mindset: if we are going to continue as a community, as a sector, as people who shoot, where do we need to be in five years’ time? ten years’ time? to make sure that my kids, their kids and everybody in between are able to continue to go shooting.”
Dan says the issue of lead has hung over the sector for a long time. He believes that, in light of the UK Reach announcement, shooters accept that the voluntary transition has given the sector for shotgun ammunition a head start on changes he believes are inevitable. He says: “I think whilst at the moment some people may see it as pandering to the antis, it’s very much not. It’s actually about the shooting sector putting a marker down and saying, ‘This is where we want to get to because this is how we see that we as a community are going to be able to survive’.”
BASC wants a proactive shooting community that sets the agenda with lead ammunition. Dan says: “I think people are proud of that and I think all people pleased to see that.”
He admits: “There are always going to people who don’t agree with the direction.”
BASC detailed examination of the HSE’s 500-page report will include regular updates. Dan says: “It’s going to take us time, but we will keep members and the wider community updated. The information’s going to be limited to the outset because it’s just such a volume of stuff to consider.”
BASC says it remains fully committed to the five-year voluntary transition away from using lead shot for quarry shooting. It now adds the rider that, if any resulting legislation could damage shooting, it will lobby for the legislation to be revised.
Click here to download the report and take part in the consultation.
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