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

The evidence presented in the dossier of risk from lead gunshot 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 any further restrictions to be unnecessary and disproportionate.

Within proposals, HSE seeks to require containment and treatment of water run off on ranges where lead continues to be used, despite their report concluding that there is no risk within surface waters.

In addition, there are existing requirements in through the Water Framework Directive (Standards and Classification) Directions (England and Wales) 2015 and the Scotland River Basin District (Standards) Amendment Directions 2015.Further regulation that seeks to control this is not required.

There remains a risk of primary exposure to birds from consumption of spent lead gunshot. This risk would need to be managed; however, we argue that for many forms of clay pigeon/shotgun target shooting, this risk can be adequately controlled without the need for further legal restriction.

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