Two-year lead ammunition review - call for evidence
Conor O'Gorman
In his latest blog, Conor expands on the news of the Health and Safety Executive’s call for evidence on lead ammunition in England, Scotland and Wales.
In March, Defra announced that it has tasked the Environment Agency, together with the Health and Safety Executive (HSE), to start a two-year review of lead ammunition.
The review was to take place under the UK’s new post-Brexit chemical regulations referred to as ‘UK REACH’ and would result in proposals to restrict lead ammunition for England, Wales and Scotland. It was explained that Northern Ireland would be exempt from the review and any resulting proposals under the Northern Ireland Protocol.
Then things went quiet and it seemed like the review had been kicked into the long grass.
HSE work programme
However, the HSE has been busy behind the scenes and in June it published its 2021/2022 work programme. This featured timetable on the development of restriction proposals for the use and/or sale of lead ammunition and for substances in tattoo inks and permanent make up.
HSE staff have been recruited and independent experts appointed and on 23 August an eight-week call for evidence on lead ammunition was published with little fanfare, attracting no media interest nor any third sector response.
First stage in a series of reviews
The call for evidence is the first stage in a series of reviews and consultations over the next 18 months.
The draft restriction dossier is likely to be published in March/April 2022 for public consultation. A draft socio-economic opinion will follow in early 2023, which will also be open to public consultation.
The review will culminate in restriction proposals being submitted no later than April 2023 to the Secretary of State for Environment, Food and Rural Affairs for consideration.
A legislative proposal will be likely thereafter subject to parliamentary scrutiny and consultation with devolved administrations.
Call for evidence
So, what’s in the call for evidence and what happens next?
The scope of the review is to gather information and evidence to support the development of a report (called a UK REACH restriction dossier) on the risks to the environment and human health of the use of lead in ammunition in all habitats in England, Scotland and Wales. This includes both live quarry and target shooting. Indoor shooting activities are excluded.
Also excluded from the review is Northern Ireland and any military and non-civilian use of ammunition.
The call for evidence stage is not an opinion survey on whether there should be a ban on lead ammunition or when such a ban should take effect. Anyone attempting to use the questions in the survey form to submit opinions ‘for or against’ lead ammunition will soon find that this is a futile effort.
The call for evidence questions seek information pertaining to shooting ranges, hunting, game meat, and manufacture and supply. It also includes home-loading, lead ammunition alternatives, the impact of the voluntary transition, the impact of lead ammunition on wildlife; and the effect of restrictions on businesses and shooters.
This is a technical information gathering process and it is important that shooting organisations, shooting businesses and firearms and ammunition manufacturers provide as much information as possible.
Taking part will help ensure that the HSE is fully informed on the uses of lead ammunition. This is particularly important in assessing the socio-economic impacts of proposed restrictions to reduce the risks associated with some uses of some types of lead ammunition.
Assessing the risks
The outcome of the two-year review is unlikely to recommend a total ban on the use of lead ammunition for recreational shooting activities. This is about assessing the risks and looking to reduce those risks whilst taking into account socio-economic factors.
BASC will ensure that the HSE objectively evaluates the evidence and that restriction proposals consider the complex mix of socio-economics, technical factors and attitudes.
If we have concerns that the resulting legislative proposals are disproportionate and will damage shooting, we will lobby for them to be revised.
There will of course be others that will be satisfied with nothing short of a complete ban on lead ammunition and they will be lobbying to that end. The political stage of the process will no doubt be challenging.
challenging times for ammunition manufacturers
A key principle we must not lose sight of is that further restrictions must not be imposed until effective and affordable types of sustainable ammunition are available in sufficient volumes to meet demand.
Ammunition manufacturers in the UK and abroad are developing new products, which is a significant financial investment. It’s fair to say that the amount of non-lead ammunition required for the UK and world-wide markets with current production facilities is going to be very challenging.
Restrictions on lead ammunition should not result in a reduction in people participating in shooting due to a lack of ammunition for their guns and shooting disciplines.
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