Airgun

We do not believe that the evidence presented by the HSE justifies their restriction proposals.

For lead ammunition used in target shooting, the evidence presented in the dossier of risk to soil, soil organisms, plants and livestock is not conclusive. Furthermore, there are existing regulations and directives that are retained in UK law which address these factors, including:

• Regulation 1881/2006 that limits lead in food for human consumption (agricultural production),
• Regulation 1275/2013 that limits lead in animal feed, and
• DIRECTIVE 2002/32/EC on undesirable substances in animal feed

We therefore consider further restriction unnecessary and disproportionate to the risk.

For live quarry shooting, while there is potential for lead exposure for humans from consumption of game shot with lead airgun pellets, the nature of use and construction of airgun pellets means the risk is minimal.

With an airgun, lead is highly unlikely to fragment from the shot site and wound channel and as such, the risk can be controlled through existing game meat handling practices.

The size of ammunition used means that HSE do not consider primary exposure of lead rifle ammunition to birds to be a risk.

We do not consider the evidence presented by HSE in the restriction dossier of secondary exposure to birds from lead ammunition to be conclusive. Based on the presented evidence, we do not consider restrictions related to this route of exposure to be required.

We consider the promotion of guidance on best practice for game meat handling the most appropriate way to deal with the small risk to human health posed by lead airgun ammunition.

This approach minimises the already small risk and avoids an unnecessary restriction which would otherwise be almost impossible to monitor and enforce.

BASC will be making the case for this alteration through scrutiny and challenge panels, and through the ongoing public consultation.

A derogation (exemption) is proposed that would allow the continued use of small calibre lead bullets, airgun pellets and any other lead projectile not defined as gunshot at licensed ranges.

To obtain a licence, the proposal is that ranges would have to regularly recover over 90% of spent lead bullets, and would be required to ban any agricultural uses within the site boundary.

The proposals call for a ban on the use of lead bullets, including those of small calibre rifles (i.e. with a bullet diameter less than 5.6mm). The ban is only for use outdoors and does not affect the use of lead ammunition on indoor ranges.

Based on the proposals, there would be at least 18 months in which to use up shotgun and large calibre rifle lead ammunition even after any law is passed. There would be five years in which to use up small calibre rifle bullets, airgun pellets and other lead projectiles not defined as lead shot after any law is passed.

The proposals also mention a buy-back scheme for lead ammunition, but there are no details of how this would operate at this time. The HSE suggests that such a scheme will be considered during the consultation process.

Yes. Lead airgun pellets are covered under restriction proposals for ‘small calibre rifle ammunition’.

Yes. The proposals are for a five-year transition period for small calibre rifle ammunition. That would allow the continued use of lead bullets with a diameter below 5.6mm, lead airgun pellets and other lead projectiles not defined as gunshot for five years from the date any new law came in.