BASC response to UK REACH lead ammunition consultation

Clay pigeon and target shooting

The evidence presented by the HSE on secondary exposure to birds, plus lead exposure pathways to livestock and other animals, soil, soil organisms, plants, and surface waters, is not conclusive.

We believe that the HSE has failed to address uncertainty in the evidence as is required by regulatory guidance. As a result, restrictions based on these risks are unnecessary and disproportionate.

BASC believes that lead shot could continue to be used for clay pigeon / target shooting at venues where risks of primary exposure to birds is managed. We also advocate that lead rifle ammunition (non-expanding) can continue to be used on ranges. We believe that current legal and regulatory frameworks are effective and further regulation risks the unnecessary ‘gold plating’ of environmental directives.

Our requests

In our detailed response, BASC is also making the following requests of the HSE:

1. Re-assess the use and risk of lead ammunition in the UK context.
2. Uphold the transparency requirements of the European Chemicals Agency (ECHA) for Annex XV restriction dossier preparation.
3. Reassess their estimate of lead shotgun ammunition use. 
4. Reassess their estimate of rifle ammunition use.
5. Review their assessment of environmental and human health impacts and benefits of restrictions.
6. Ensure accurate costs are applied during the forthcoming socio-economic impact assessment.
7. Thoroughly explore the uncertainty in the evidence in relation to secondary poisoning of birds from lead ammunition.
8. Thoroughly explore the uncertainty in the evidence in relation to impacts on ‘other’ animals from lead ammunition.
9. Thoroughly explore the uncertainty in the evidence in relation to impacts on soil, soil organisms and vegetation from lead ammunition.
10. Exclude surface and ground waters from its proposals.
11. Move the boundary for defining ‘large calibre’ centrefire ammunition to ≥6.5mm.
12. Ensure that any restriction and transition period for rimfire ammunition is reviewed before implementation.
13. Drop proposals for restricting the use of lead airgun ammunition.
14. Consider providing extended transition periods for small gauge shotgun calibres of 28 bore and smaller.
15. Revise restriction proposals, ensuring that they are proportionate to the evidenced risk, make best use of existing legal and regulatory frameworks and avoid ‘gold plating’ existing environmental directives.
16. Implement a buy-back scheme to: a. Fairly compensate material loss resulting from restrictions; b. Incentivise the transition to lead free alternatives; c. Ensure that the restrictions do not create a ‘false’ or ‘early’ cliff-  edge for sales of lead products that undermines manufacturers’ ability to invest in development and production of lead-free alternatives.