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Terry Behan takes stock of BASC’s response to the Health and Safety Executive’s UK REACH consultation on proposals to restrict the use of lead ammunition outdoors in England, Scotland and Wales, and outlines what is to come.
Sporting firearms have changed a lot since the first flintlocks were designed to take live quarry in the 1680s.
Likewise, shooting practices have evolved since then. Some changes have occurred through natural progression and innovation, such as the move to sidelock and boxlock shotguns, or in more recent memory, the growth in the popularity of over and unders.
More revolution than evolution, change has been imposed on shooting through legislation. So, when staring down the barrel of a change in the law (if you pardon the pun), and mounting evidence of the environmental and health risks of lead, is it better to fight stubbornly until forced to budge or get ahead of the curve?
That was the tough decision faced by nine shooting organisations when together we called for a voluntary transition away from lead shot and single use plastics for live quarry shooting in shotguns.
BASC remains wholly committed to this voluntary transition and believes it remains a far more favourable route than legislation. It was a move taken in consideration of wildlife, the environment and to ensure a market for the healthiest game products, at home and abroad.
There’s no denying that the transition is making solid progress. Thousands have already made the move to non-lead products, with BASC’s Try Sustainable Ammunition days proving a marked success. Key to this has been investment from cartridge manufacturers to produce a range of ammunition suitable for varying shooting disciplines.
We have learned an awful lot on this journey, and we are not finished yet.
As it stands, we’re still two years away from an aspirational transition date. With more shoots going lead-free this year, an increasing choice of cartridges available and more being developed regularly, the voluntary transition is achieving its overriding objectives.
Fast forward to 6 May 2022, the Health and Safety Executive (HSE) released its Annex XV dossier on the restriction of lead ammunition under the guise of UK REACH.
The dossier went significantly further than the voluntary transition by proposing an outright ban on the use of lead gunshot and lead rifle ammunition (including for use in historic arms and all airguns). It contained only a limited number of derogations for the continued use of lead in licensed circumstances.
The dossier was an HSE sledgehammer in their objective to eliminate all risks posed by lead ammunition.
In November 2022, BASC submitted and a comprehensive response to the UK REACH consultation setting out several errors in the data supplied by the HSE. We also included four detailed technical reports outlining our findings regarding contentious issues such as lead-free ammunition for .243, .22 and airguns.
In the coming weeks, BASC will publish several articles giving an overview of each technical report and our subsequent proposal to the HSE.
Ahead of that I would like to set out BASC’s position.
We will continue to push forward in the five-year voluntary transition away from lead shot for live quarry shooting. We stand firm on our position that any restrictions imposed by the HSE on any form of lead ammunition must be evidenced and proportionate to the risks.
The HSE’s role is to eliminate risk associated with lead ammunition. However, if the shooting community does not agree with the proposals made under UK REACH, then we must present our own counter proposals to ensure the right outcome.
BASC set out counter-proposals in our submission to the HSE. The technical reports submitted within this response opposed restrictions to lead ammunition where it is either unnecessary compared to the known risks or unfeasible due to inadequate lead-free alternatives.
Our response to the consultation included the following:
We will publish each of the technical reports setting out our positions in due course; keep an eye on our website for each one. You can read more on our full UK REACH consultation response here.
Head to our Offbeat pages here.