Is UK REACH compliance mandatory?

If the proposals were to come into law next year they would be mandatory in England, Wales and Scotland. However, there is a lengthy scrutiny process ahead before any laws are drafted.

The proposals and consultation are taking place under the UK’s post-Brexit chemical regulations, referred to as UK REACH, which covers England, Wales and Scotland (but not Northern Ireland due to the NI Protocol).

The Health and Safety Executive (HSE) has been tasked as the agency under UK REACH to produce a report that outlines the risks posed by lead ammunition. Where it believes those risks to be unacceptable, it has also been asked to propose restrictions to reduce those risks.

Under UK REACH, a two-year lead ammunition review was launched in March 2021 and this was followed by a call for evidence from August to October 2021. The proposals published on 6 May are subject to a six-month consultation, and BASC and the other shooting organisations are reviewing more than 500 pages of findings and firming up agreed positions.

In summary, many of the proposals are not evidence-based and go too far, and will be challenged. This is especially the case for restrictions on the use of lead ammunition for target shooting.

We will challenge proposed restrictions where there are no viable alternatives to lead, where socio-economic factors mean a transition isn’t appropriate, and where lead can continue to be used in settings that present negligible or no risk.

We have significant concerns about the short timeframes outlined in the dossier for transition away from the use of lead ammunition, which could be as short as 18 months. This is particularly alarming in light of current global supply chain issues. We will fight for timelines that are realistic and guided by the sector, to ensure that the range of lead-free products and their supply can meet market demands.

Working closely with other organisations, we will ensure that the needs of both live quarry and target shooting interests are considered, and we will continue to oppose one-size-fits-all restrictions.

Over the coming months, there will be scientific scrutiny of the HSE findings and proposals through an independent panel of experts.

BASC has been approved as an accredited stakeholder by HSE and we will ensure that the proposals are robustly scrutinised and that any future restrictions are based on evidence and are proportionate to identified risks. We will not accept disproportionate restrictions that unfairly disadvantage shooting activities.

A draft socio-economic opinion on the impact of the HSE proposals will follow later this year or early in 2023, which will also be open to public consultation. The review will culminate in recommendations being submitted no later than April 2023 to the Secretary of State for Environment, Food and Rural Affairs for consideration.

A legislative proposal will be likely thereafter subject to parliamentary scrutiny and consultation with devolved administrations. If we have concerns that the resulting legislative proposals are disproportionate and will damage shooting, we will lobby for them to be revised.

 

 

How do the RSPB and the Wildfowl and Wetlands Trust (WWT) arrive at the statistic of 100,000 birds dying annually in the UK from ingested spent lead shot?

If they can be so precise on this cause of death, maybe they can tell us how many wildfowl die from outbreaks of botulism, bird flu, other diseases, or flying into overhead power cables on their own wetland reserves?

The WWT and RSPB are quoting research that has used data from various sources to estimate that up to 400,000 wildfowl suffer from lead poisoning every winter in the UK, of which 50,000 to 100,000 die.

WWT research found that nearly half of live whooper swans they tested had worrying lead levels in their blood with 10% of the birds in measurably poor body condition as a result. Lead poisoning is estimated by scientists to kill a million wildfowl a year in Europe and cause sub-lethal poisoning in a further three million birds. Further modelling research indicates population-level effects of lead poisoning in wildfowl, terrestrial birds, raptors and scavengers.

In its findings, the HSE has outlined the evidence on the impacts of lead shot on birds and they mirror the findings of scientists from the Game and Wildlife Conservation Trust (GWCT).

Based on evidence submitted to the HSE last year, more than 6,000 tonnes of lead shot is fired into the British countryside annually as a result of live quarry shooting – that’s billions of individual pieces of lead shot lying on the ground available to birds, much of which is from game shooting.

Unfortunately, many species of birds pick up this lead shot mistaking it as grit. The lead shot grinds in their acidic gizzards and toxic lead salts are absorbed into the bloodstream and find their way into the tissues of vital organs. Death occurs in a few days or weeks, depending on how much lead shot a bird eats. For those that survive, their behaviour, resistance to diseases, mobility and ability to breed are affected.

 

Has anyone actually died of lead poisoning by eating meat shot with lead?

We are not aware of any cases of people dying from swallowing pieces of lead shot or eating lots of lead-contaminated game meat. The evidenced impacts are more subtle than that and are now better understood by scientists and can unfortunately cause underlying health issues for some of us.

When we eat game meat contaminated with lead ammunition, we absorb some of that lead in our blood, tissue and bone.

X-ray and chemical studies of large and small game shot with lead ammunition reveal that lead contamination is much more extensive than only the wound channel and most of it cannot be detected by eye. Due to hormonal changes during pregnancy, lead that has been stored in the skeleton is released into the blood, exposing both mother and foetus. As a result, high levels of lead in mothers’ bones have been identified as a risk factor for impaired mental development in infants.

Developing brains exposed to low levels of lead are at risk for attention-related behavioural problems, decreased cognitive performance and increased incidence of problem behaviours.

This is why the Food Standards Agency advises against frequent consumption of lead-shot game by toddlers, children, pregnant women and women trying for a baby. For adults, there is growing evidence around lead exposure and associated increased risk of leukaemia, lung, stomach, and urinary-bladder cancer.

 

Lead shot ban – have your say

How can we, the shooting community, make our voice heard on this matter?

• Visit BASC’s website, basc.org.uk/lead, for the latest advice and FAQs on the proposals.

• Then visit the HSE website at consultations.hse.gov.uk/crd-reach/restriction-proposals-004/ and complete the online survey.

• It is imperative that every shooter gets involved and has their say, and we have until 6 November to do so