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.


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