On 6 May, the Health and Safety Executive (HSE) published its restriction dossier for the use of lead in ammunition. It has also opened a 6-month consultation based on its findings, which can be found here.
HSE have proposed the following restrictions for England, Scotland, and Wales:
- ban on the sale of lead shot
- ban on the use of all types of lead ammunition for live quarry shooting including lead shot, shotgun slugs, lead bullets and airgun pellets
- ban on the use of lead shot for outdoor target shooting with possible exemptions for licensed athletes at licensed ranges with appropriate environmental protection measures
- ban on the use of lead bullets for outdoor target shooting with possible exemptions for shooting at licensed ranges with appropriate environmental protection measures
- mandatory labelling of the packaging of lead ammunition regarding the hazards and risks of lead.
Buy-back schemes for lead shot cartridges and rifle ammunition have been proposed.
In 2020, the Countryside Alliance and eight other rural organisations issued a joint statement calling for the voluntary phase out of lead shot in live quarry shooting by 2025. Had we not made that decision, it was clear that it would have been taken for us, however we have always been clear that any restrictions must be based on science and evidence, and where this evidence does not exist there should be no restriction.
(PASEC) Shooters spend in excess of £2.4b in the UK on shooting every year. It is a major lifeline for those employed part time by shoots, as well as for rural businesses, especially hospitality, throughout the winter, and increasingly in the summer months with the rise of simulated days. If insufficient time to is given to transition away from lead in ammunition then this could discourage shooters from participating in the sport and spend will decrease in the rural economy.
- 18 months for shotgun cartridges and large calibre bullets (shotguns & rifles) – possible derogation for athletic shooting and shooting ranges that can collect >90% of shot. If derogation is accepted this would lead to 5-year transition for all lead cartridges.
- 5 years for small calibre (air gun)
The transition periods should be realistic and should allow time for viable alternatives to be developed and manufactured en masse. HSE has not taken into account the global logistic supply chain issues caused by the COVID-19 pandemic that is having a profound impact on the manufacture of steel and other non-lead cartridges, and more recently the Russian invasion of Ukraine has seen ammunition manufacturers shift their focus onto military, rather than sporting ammunition, further exacerbating supply issues.
HSE have proposed an 18-month transition period with a possible derogation for sporting ranges that would lead to a 5-year transition period for all shotgun cartridges. This derogation would be for sporting ranges that can recover > 90% of shot from their ranges. The Countryside Alliance is supportive of this derogation. If this derogation is adopted, it would give all shotgun shooters until 2029 to fully transition; an additional 4 years on top of the voluntary transition period of 2025. We expect that the majority of shoots and shooters will have transitioned over to alternative shot by 2025, however the resulting 4-year leeway will ensure manufacturers have sufficient time to produce alternatives in sufficient quantities to ensure they are viable.
If the derogation is not agreed, the Countryside Alliance is against the proposed 18-month transition period. Our main concern is that without sufficient time to increase supply, prices will remain high for alternative shot leading to less people being able to afford to shoot. The knock-on effects of this would be devastating for the UK rural economy. Even a 10% drop in usage would cost the UK economy an estimated £240million per annum. This will also lead to an increase in pest species, such as Wood Pigeon, causing avoidable damage to crops and a rise in mental health issues in farmers and agricultural workers.
HSE have split rifle ammunition by calibre.
The Countryside Alliance is against the 18-month transition period being proposed, and believe it should be 5 years for both large and small calibre in live quarry and target. This is to allow time for the sector to adapt, and for manufacturers to produce sufficient quantities of viable alternatives to meet demand. As with shotgun cartridges, HSE have not considered ongoing global supply chain issues caused by the COVID-19 pandemic. Specific to rifle usage, HSE have not considered the pressing government cull targets for deer with the increase in tree planting across the UK. Severe damage will be inflicted on new crops if deer managers cannot buy bullets from suppliers. An unintended consequence could also see many local communities suffer financially as visiting deer stalker numbers diminish. Hotels, shops and restaurants will all suffer as a consequence.
We are opposed to the current proposal to ban lead in airgun pellets as we believe that lead can viably continue to be used in both live quarry and target shooting. There are currently no viable alternatives on the market, as the accuracy and lethality of existing alternatives have been shown to be less efficient than lead potentially causing extended periods of suffering. Pellets rarely fragment so lead loss in quarry is negligible. Pellet-catchers are generally used in target shooting so 100% of the lead can be recovered and recycled. We believe the risks can be controlled through existing measures.