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Gun Trade Association: Simon West
THE CAT IS FINALLY OUT OF THE BAG
As the first draft of the HSE’s proposed lead ban is published, Simon West takes a look at what has been won and lost on the process.
THE HSE have published their long-awaited Socio-Economic Consultation on the restriction of lead in ammunition. This includes their current ‘opinion’ on where they think restrictions will lie. Some of it is inked in, but also there is additional scrutiny being conducted on certain topics. For those of you who want the detail—and there’s lots of it—google ‘HSE lead in ammunition’ and you will find the draft Agency Opinion and the draft Background Document. While these restrictions will have a significant effect on British shooting, they are far less punitive than those that were originally proposed. Their proposals now show that they have accepted the extensive evidence that the GTA and others have submitted over the last two years. I am somewhat encouraged that the combination of technical facts and industrial realities have been recognised as an important part of the debate. The timelines have been stretched twice, first to deal with the wealth of submissions to the consultation, and again to allow more time for the socioeconomic consultation to clear publication. We would not now expect final opinion and enactment (Secretary of State at DEFRA’s signature) before early 2024.
The headlines
• The use of lead shot for live quarry shooting would be prohibited (five-year transition from enactment to deal with industrial realities), as the GTA requested because of the industrial realities of re-machining and supply chain issues. • The use of lead shot for target shooting (clays) would be prohibited. However, a derogation will allow for a small number of athletes, as identified by the appropriate sporting body (for example, British Shooting), that are required to continue
shooting lead shot for the purposes of international competition and training. (Again, a five-year transition.) • The sale or trade of lead shot (for a price or otherwise) would be prohibited. However, a derogation will allow for those athletes referenced above to continue to source the lead shot required for international competition and training. (Again, a fiveyear transition.) • The sale or trade of lead bullets (for a price or otherwise) would not be prohibited, since these
ranges could continue to operate and allow the use of lead bullets. • The use of lead ammunition in air weapons would not be prohibited. (A major GTA objective, based on the current technical absence of effective alternatives.) • The sale or trade of lead ammunition for air weapons (for a price or otherwise) would not be prohibited. These are not final proposals; some are open to further scrutiny. The five-year transition for shot and the
“ The consultation is described on
the HSE website and the deadline for comment is 10 December ”
would continue to be available for indoor shooting, which is out of scope of this restriction. • The use of lead bullets for live quarry shooting would not be prohibited. (Part of our representation, particularly for small calibre rifles—quoting small calibre technical challenges and large calibre change is already occurring in the marketplace, led by consumer demand.) • The use of lead bullets for outdoor target shooting would be prohibited. However, a derogation would allow for this use to continue at sites that have controls in place to reduce the identified risks to the environment, and documentation indicating why these controls are appropriate. In practice, these controls, which include de-leading of ranges, are broadly expected to be in place by the majority of existing outdoor shooting ranges. This means that the majority of outdoor shooting
use of lead bullets for hunting is still subject to further scrutiny. The GTA will continue to put forward strong justification to maintain the current position. We will refresh the core data that related to remachining and supply chains. Steel shot cartridges cannot be produced at economic rates on old machines. The industry is investing in new machinery but with lead times of over two years. This is not a quick process. The supply chain issues arose out of the pandemic and war in Ukraine. There is some progress on a few components but you will all be aware of the global shortage of propellants. With the war in Ukraine far from over and new instability in the Middle East, this is not going to improve any time soon. In Europe, ammunition manufacturers have asked for a ten-year delay to any restrictions to allow for the prioritisation of military production.
These international factors will play a major part in the timelines for shot cartridge manufacturing change and also the availability of non-lead large calibre rifle ammunition, where much of our supply comes from Europe. The consultation is described on the HSE website and the deadline for comment is 10 December. We will now review the document in detail, collect further information where required, and then provide an appropriate response. The GTA shares evidence with the other members of the British Shooting Sports Council to ensure that valid and coherent comment is made. The original proposals from the HSE would have seen lead shot, large calibre bullets being banned in 18 months, and small calibre bullets, including airgun pellets, being banned within five years. These timelines would have been devastating to UK shooting because of the lack of alternatives. The GTA and its Cartridge Group invested time and resources in collecting data with Cranfield University and Blake International to be able to present technical and industrial realities. That representation has been vital in protecting shooting and the trade from excessive and unreasonable penalties. The GTA will continue to defend your interests. GTN
