Rifle

We are opposed to current restriction proposals.

It is our view that lead ammunition can continue to be used for most forms of target shooting where risks are appropriately and proportionately controlled through the application of existing directives and regulations.

We do not believe that the evidence presented by the HSE justifies the restriction proposals as they stand.

The evidence presented in the dossier of risk from lead ammunition 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.

BASC will be making the case that the proposed restrictions are not justified by the evidence presented and are therefore not required through scrutiny and challenge panels, and the ongoing public consultation.

We will be seeking to avoid any unjustified restriction and providing alternative proposals for how evidenced risks can be controlled without banning the use of lead ammunition for target shooting.

We accept that there is an evidenced risk to human health. This, alongside consumer demand, is part of the reasoning behind a move to all game meat being sourced from lead-free supply chains.

We consider elements of HSE’s justification of restricting the use of lead ammunition for live quarry shooting as valid.

However, as with the use of lead shot for live quarry shooting, we will seek to influence any restriction proposals so that they are balanced against the identified risk and come with realistic transition periods. This will be done through scrutiny and challenge panels and the ongoing public consultation.

The restriction dossier is prepared on the assumption that legislation will come into effect in 2024.

Yes. The proposals are for an 18-month transition period for large calibre rifle ammunition. That would allow the continued use of lead bullets for 18 months from the date any new law came into effect.

No. The proposals provide no exemptions for using lead ammunition for live quarry shooting.

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 proposals call for a ban on the use of lead bullets.

There is a body of evidence presented in the restriction dossier about the impacts of lead on human health. Sub-lethal effects include neurotoxicity, kidney effects including renal disease and cardiovascular effects. Although the evidence does not directly or solely attribute lead ammunition as a cause, either through primary or secondary exposure. Lead is a ‘zero-threshold’ neurotoxin, which evidence show has impacts on the IQ of children and ‘in-utero’ impacts on the developing foetus.

Dietary exposure to lead in game meat is an exposure pathway for humans, and it is clear from the evidence presented by HSE that existing meat processing practices cannot eliminate all lead contamination from game meat. It is for these evidenced reasons that HSE are seeking to eliminate the risk of lead contamination in game meat reaching the human food chain.

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 potential exposure pathway to be necessary or proportionate.

No. The proposals provide no exemptions for using lead ammunition for live quarry shooting.

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.

A derogation (exemption) is proposed that would allow the continued use of lead bullets for target shooting 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.

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. 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.