BASC exposes process failures in lead ban proposals
Conor O'Gorman
BASC has written to the government’s Environment Audit Committee to hold the Health and Safety Executive to account for significant process failures in its recent review of lead ammunition. Dr Conor O’Gorman explains…
BASC has submitted evidence to the House of Commons Environment Audit Committee, highlighting concerns about the way in which the Health and Safety Executive (HSE) has developed its lead ban proposals.
It’s bad enough that the HSE’s findings are based on hundreds of pages of inaccuracies and assumptions based on poor data, but it gets worse.
The HSE has appointed Professors Debbie Pain and Rhys Green to its Independent Scientific Expert Pool and the agency only published this information in October 2022. This is very concerning because both individuals have been quoted in the media calling for a ban on lead ammunition since the HSE review began.
That clear conflict of interest is magnified when one considers that a dozen and more research papers that the HSE is relying on in its restriction dossier are authored by the very same lead ban campaigners.
Furthermore, Pain and Green are being asked to advise on and critique the HSE’s use of that evidence for its proposals to ban lead ammunition.
The HSE is in effect marking its own homework.
The background
In March 2021, the UK government announced a two-year review of lead ammunition under the UK’s new post-Brexit chemical regulations referred to as UK REACH and the HSE was tasked with carrying this out.
Over the last 20 months the HSE has had ample opportunity to consider the evidence and objectively identify proven exposure risks in a UK context and then to propose workable solutions.
Firearms and ammunition manufacturers, shooting organisations, gun shops, clay grounds, rifle ranges, clubs and syndicates and individual shooters have all shown a willingness to engage constructively in last year’s two-month call for evidence.
However, given the contents of the HSE proposals published in May, our collective feedback was clearly not listened to because the HSE ploughed on regardless with a lead ban proposal, largely cut and pasted from proposals published by the European Chemicals Agency a year earlier.
Voluntary transition
So, what happens next?
Will the HSE take stock of the consultation responses it has received over the last six months from the shooting community and change tack?
In our consultation response we told the HSE that we are opposed to restrictions on lead rifle ammunition and lead shot for target shooting; and that we are opposed to restrictions on lead airgun pellets for live quarry and target shooting.
When it comes to the use of lead shot there is clear evidence that this poses a risk for birds where it is available for them to pick up – much of that coming from game shooting but also simulated game and standard clay shoots taking place in open countryside.
There is also clear evidence that the use of lead shot and expanding rifle ammunition poses risks for human health due to the game meat containing traces of lead ammunition.
The only feasible way of reducing these risks for birds and human health is basically for us to stop shooting live quarry with lead shot and expanding rifle ammunition and a voluntary transition away from lead shot for live quarry shooting is being encouraged by the shooting organisations.
However, the HSE wants legal restrictions brought in and in the context of the voluntary transition, we have told the HSE that further regulations are not required.
Fighting shooting's corner
When the lead ammunition review was announced last year BASC made a promise to the shooting community – if we have concerns that the resulting legislative proposals are disproportionate and will damage shooting, we will lobby for them to be revised.
If the HSE continues down its current path there will be a political battle ahead and BASC will fight our corner.
However, the wolf is not at the door yet. There is another consultation due in February 2023 and final recommendations to be submitted to Defra thereafter. It will then be for the government to decide whether to act on those recommendations.
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