According to guidance from the Environment Agency (EA), spent shotgun cartridges are classed as a ‘Directive Waste’. The phrase “Directive Waste” refers to European legislation called the Waste Framework Directive. Directive wastes include nearly all household, commercial and industrial wastes. Directive wastes have to be assessed as to whether they are classed as ‘Hazardous Waste’ or ‘Non-hazardous Waste’ according to a set of criteria under the Waste Framework Directive. Even though spent shotgun cartridges contain lead (hazardous substance) residues, lead is not present in the quantities required for it to be classed as a ‘Hazardous Waste’. Spent shotgun cartridges are therefore classed as a ‘Non-hazardous’ waste and are subject to the regulations governing non-hazardous waste.
Local authorities are responsible for the removal and management of domestic household waste. Based on guidance from the EA, small quantities of cartridges can be deposited in normal domestic household waste*. No official policy exists to define the limits of ‘small quantities’, however the EA suggests anything up to 100 cartridges is reasonable. Local authorities have a duty of care to remove non-hazardous, directive waste, which spent cartridges are. Any problems encountered by the removal of spent shotgun cartridges in your domestic waste needs to be addressed with the local authority responsible.
Disposal of large quantities of spent shotgun cartridges are subject to the new agricultural waste regulations (further details on the EA website). Under these regulations disposal of large quantities of spent shotgun cartridges by burning or burial is illegal. The EA recommends contacting a local waste recycling company to arrange removal.
Duty of care applies to everyone handling trade waste, which includes commercial shoots. If you break the duty you are liable to an unlimited fine.
Duty of care means that you have to take all reasonable steps to keep the waste safe. For example safe storage of spent cartridges might be in large bins or a skip. Duty of care also means that the waste must be properly disposed of. That means contacting a company authorised to dispose of it properly.
The easiest way to do this is by entering into a contract with the local authority to take the waste away. You can also give it to a registered waste carrier. There are a few companies who offer this service, for which there is a charge including Agricycle www.agri-cycle.uk.com and Solway Recycling Ltd www.solwayrecycling.co.uk. For further information contact them directly. It is the responsibility of the waste producer to check that their chosen recycling organisation is registered.
In addition waste producers need to sign a waste transfer notice, saying what the waste is and how it is stored.
Contact your local police firearms licensing authority who can collect live or misfired cartridges and dispose of them. The Health and Safety Executive also provides guidance on disposal of large quantities of live or misfired ammunition. DO NOT dispose of live or misfired cartridges through domestic waste, burial or burning – it is illegal and dangerous.
* No guidance has been issued by the Department of Environment Northern Ireland for disposal of domestic quantities of spent cartridges.
NB BASC does not accept responsibility for any misinterpretation of guidance. It is the responsibility of members to familiarise themselves with the regulations for each of the countries in the UK. For further information on waste regulations contact the Environment Agency (England and Wales), Scottish Environment Protection Agency (Scotland) or Department of Environment (Northern Ireland). BASC does not accept responsibility for the guidance given or services provided by any organisation listed in this document.
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