BASC’s position on UK REACH lead ammunition restriction proposals

positions

Following publication of the UK REACH lead restriction dossier on 6 May by the Health and Safety Executive (HSE), BASC has reviewed the document and evidence presented within it in its entirety. The restriction proposals apply to England, Wales and Scotland.

BASC's overall position on UK REACH lead restriction proposals

We accept that in some settings lead ammunition poses an exposure risk that must be controlled. Managing proven risks is beneficial to the environment and the long-term future of shooting.

The sector has already committed to a voluntary transition away from lead shot and single-use plastics for live quarry shooting and has ambitions to source shot game from lead-free supply chains.

live-quarry-shooting
Discipline-specific positions

Lead shot for live quarry shooting

BASC’s position: Restrictions on the use of lead shot for live quarry shooting must be evidence-based and proportionate to the evidenced risk.

We encourage the Health and Safety Executive (HSE) to work closely with the sector to secure realistic transition periods that account for global supply chain issues.

We remain committed to the shooting organisations’ five-year transition away from lead shot for live quarry shooting with shotguns.

Lead shot for clay pigeon shooting

BASC’s position: We are opposed to the restriction proposals.

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

Lead rifle ammunition for live quarry shooting

BASC’s position: Restriction on the use of lead rifle ammunition for live quarry shooting must be evidence-based and proportionate to the risk.

We encourage the HSE to work closely with the sector to secure realistic transition periods that account for global supply chain issues.

If transition periods are to be defined by calibre, we believe that large calibre rifles should be any centrefire calibre of 6.5mm and above.

Small calibre rifles should apply to any centrefire calibre smaller than 6.5mm, as well as all rimfire calibres and any lead projectiles not defined as gunshot, but should exclude airgun ammunition.

The sector has existing ambitions to source game from lead-free supply chains.

Lead rifle ammunition for target shooting

BASC’s position: We are opposed to the 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.

Lead airgun ammunition for live quarry and target shooting

BASC’s position: We are opposed to the restriction proposals.

It is our view that lead airgun ammunition can continue to be used for live quarry and target shooting where risks are appropriately and proportionately controlled. This should be done through the application of existing directives, regulations, and best practice guidance.

airgun
Public consultation - have your say

BASC will be submitting evidence to the public consultation on the UK REACH proposals, including a critique of the HSE’s restriction dossier for lead ammunition.

We encourage all members to respond to the consultation and have their voice heard on this issue.

Make your voice heard

We have a good basis of data to respond to consultation questions, however, we are keen to encourage responses from key stakeholders.

Specifically, these are:

  • General comments from anyone who is involved in shooting on the restriction dossier and proposals under UK REACH; this includes live quarry shooting with lead shot and other lead ammunition, clay/target shooting with lead shot and lead ammunition and airgun shooting (live or target) with lead pellets.
  • Comments and evidence in relation to projectiles made from alternatives to lead. We would specifically encourage members to submit any evidence or studies they have conducted on the use of alternative forms of ammunition. We will also be encouraging manufacturers of ammunition to respond on the technical, economic, research and development issues related to alternative ammunition products.
  • We encourage members to give their opinion on how a potential ‘buy-back’ scheme for lead ammunition might operate, and how effective this could be.
  • We encourage all operators of outdoor shooting ranges to respond to questions around licensing of ranges and to give evidence on possible costs of adaptation to meet licensing requirements. We also encourage them to submit any information they might have on the costs of remediation for lead in soil.

Click here to respond to the HSE public consultation.

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