The Countryside Alliance response to the HSE lead shot in ammunition consultation

On 6 May, the Health and Safety Executive (HSE) published its restriction dossier for the use of lead in ammunition. It also opened a 6-month consultation based on its findings, that the Countryside Alliance has responded to. A summary of our response to the key issues can be found below, and our full response 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.

In February 2020, the Countryside Alliance and eight other rural organisations issued a joint statement on future shotgun ammunition for live quarry shooting, stating that in consideration of wildlife, the environment and to ensure a market for the healthiest game products, at home and abroad, we wished to see an end to both lead and single-use plastics in ammunition used by those taking all live quarry with shotguns within five years. The shooting community must maintain its place at the forefront of wildlife conservation and protection, and sustainability in our practices is of the utmost importance.

Shooters spend in excess of £2.5billion each year on goods and services, and shooting is worth £2 billion to the UK economy. It is a major lifeline for those employed by shoots, both full and part time, 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 is given to transition away from lead in ammunition this would cause adverse effects to the UK shooting industry, as detailed below.

Transition periods:

Proposed

• 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)

Response

We remain committed to the voluntary transition from both lead and single-use plastics in ammunition used by those taking all live quarry with shotguns, however, since that voluntary transition was announced in 2020, there have been global logistical supply chain issues as a direct result of the Covid-19 pandemic which have caused unavoidable delays in the development of and transition to non-lead ammunition.

The transition periods must be realistic, and allow time for viable alternatives to be developed and manufactured en-masse. The Restriction Report has not considered the global logistical 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 ammunition. More recently, the Russian invasion of Ukraine has seen ammunition manufacturers shift their focus onto military, rather than sporting ammunition, further exacerbating supply issues. An 18-month transition period will give the gun and ammunition manufacturers little time to ensure a secure supply of non-lead ammunition, putting the shootingindustry at risk in the UK.

The impacts of too short a transition period, as proposed, would lead to a decrease in shooting in the UK. As well as the negative economic impact people who shoot also put in 3.9 million work days on conservation every year – the equivalent of 16,000 full-time conservation jobs. Any decrease in activity level will be detrimental to conservation efforts in the UK. The majority of the £2.4b that shooters spend in the UK on shooting every year contributes to the rural economy and many communities rely on that income during winter months outside the main tourist season. The social and mental health benefits that hunting shooting brings to the estimated 1,000,000 people that are involved in the UK are also a major concern should a disproportionately short period be imposed.

Regarding large calibre rifle ammunition, the Restriction Report has not considered the pressing government cull targets for deer with the increase in tree planting across the UK. The Department for Environment, Food and Rural Affairs (Defra) recently consulted on key proposals to ensure the sustainable management of the English deer population, and a reduction in the impacts of deer on the natural environment. Severe damage will be inflicted on new crops if deer managers and hunters are unable to purchase sufficient ammunition. The increase in pest species such as foxes and rabbits will have severe detrimental effects on conservation of ground-nesting birds and others in the UK.

Airgun Ammunition

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 airguns both for 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 (We defer to the British Shooting Sports Councils research as submitted on this issue) 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.

Buy-back scheme

We consider it possible that a buy-back scheme for lead ammunition could incentivise the transition from lead to non-lead shot and ammunition. Any such scheme would, however, have to fairly compensate shooters for any loss which they incur as a result of restrictions, and on a market value basis.

Alternatively, we would see value in a scheme which enables shooters to exchange lead shot and ammunition which they are no longer able to use for comparable non-lead ammunition.

Any Government-funded scheme should also give consideration to retailers holding stocks of lead ammunition which would no longer be saleable, and to manufacturers with machinery and equipment which could no longer be used for the production of lead ammunition, and which was not suitable for conversion to the production of non-lead loads.

Conclusion

The Countryside Alliance is of the view that given the clear issues the proposed 18-month transition period will have on the UK shooting industry as set out in the Annex 15 restriction dossier, both in reference to shotgun and rifle ammunition, all calibres and shot, excluding air rifle pellets, should be subject to a transition period of no less than 5 years. We look forward to contributing to the socio-economic impact consultation due to be launched in February 2023.