Government proposes ban on lead ammunition for all live quarry

On Friday 6th May the Health and Safety Executive published a dossier by UK REACH which contains far-reaching proposals for the legal ban of the use of lead shotgun and rifle ammunition for a wide range of activities, including the shooting of live quarry and inanimate objects such as clays and target shooting. Crucially, the ban on lead loads for live quarry shooting could come into force before 2025, the date originally targeted by the shooting organisation's voluntary phase-out of lead ammunition.

The publication of the dossier marks the beginning of a six month consultation period.

The 227 page document states that DEFRA requested that HSE assess

the risks from lead ammunition on the basis that the use of lead in ammunition raises concerns related to both human health and the environment. The harm of lead ammunition to wildfowl is of particular concern – poisoning from ingesting lead ammunition causes long-term suffering and slow painful deaths for animals. The health of humans, particularly children, may also be adversely affected from eating meat killed using lead ammunition.

Risk to the environment

With regard to the risk to the environment, the report highlights the dangers to wildlife, either through the primary ingestion of lead from the environment, or the secondary ingestion of lead through the feeding of predators or scavengers upon prey or carrion contaminated with lead, or by herbivores feeding on plants containing lead. As well as noting the risk of death the dossier notes that “sub-lethal and welfare effects can occur at exposure concentrations lower than those at which mortality occurs.”

Where previous such reports have focussed on the effects of lead on waterfowl and wetland habitats, this dossier goes further, suggesting that tens or even hundreds of thousands of terrestrial birds in the breeding population are at risk of lead poisoning.

Risk to human health

The main risk to human health, states the dossier, arises from the consumption of game that has been shot with lead. The report notes that among the wide ranging effects of lead exposure are “toxicity to the blood system, nervous system, kidneys, cardiovascular system and reproductive systems,” and goes on to highlight that in developing foetuses and young children the critical effect is “developmental neurotoxicity; even at low levels of lead exposure, cognitive development and IQ are reduced.”

The report acknowledges that those most at risk are members of the shooting and hunting community, and their families, as this group consumes the most game. The report estimates that 4,000 to 48,000 children in the UK are at a potential risk of incurring one point or more reduction in IQ from exposure to ammunition-derived lead.

According to the report:

The Agency considers that for all identified uses there is a risk to the environment that is not adequately controlled. In addition, there is a risk to human health from consumption of game shot with lead ammunition that is not adequately controlled.

Mitigating the risks of lead ammunition

When it comes to the risks posed to the environment and human health by the use of lead ammunition for live quarry shooting activities, the report evaluates a range of potential mitigation measures that could be implemented:

• Voluntary measures (such as the voluntary phase-out of lead ammunition)
• Applying a ‘polluter pays’ approach and taxing the sale of lead ammunition 
• Mandating the use of particular construction of lead ammunition (eg copper or nickel coating)
• Applying maximum permitted levels of lead in game meat sold for consumption
• Advice to cut away lead-contaminated meat when preparing game killed with lead shot
• Training programmes for hunters and pest controllers
• Labelling of ammunition boxes and the ammo itself
• A buy-back scheme for lead ammunition
• A ban on the sale and use of lead ammunition for hunting live quarry

Ban on lead ammunition recommended

Of all of these measures, the report concludes that only the last one - a legal ban on the sale and use of lead ammunition for the shooting of live quarry - would be effective, practical, monitorable and enforceable. Importantly, the voluntary phase out of lead ammunition for live quarry shooting is deemed to be only partially effective and not enforcable, and so is rejected as an option.

When it comes to the shooting of live quarry, the report concludes:

No risk management measures were identified that would adequately address the risks to either the environment or human health to allow continued use [of lead ammunition].

Banning the use of all forms of lead ammunition for hunting will remove the risks from this source of lead posed to humans via the consumption of game meat. Banning lead shot would prevent the primary poisoning of many bird species via ingestion of lead shot, and together with a ban on the use of lead bullets for hunting, raptor and scavenging species would also be protected from secondary poisoning.

Compliance with the existing lead shot bans over wetlands is thought to be low, so a total ban on the sale and use of lead shot would also tackle this issue.

Clay grounds and rifle ranges would also be impacted

Shooting organisations respond to the proposals

While the report will no-doubt be seen in some circles as a vindication of the shooting organisations' joint commitment to phase out lead ammunition, since it has galvanised ammunition manufacturers into pushing forward R&D on non-lead alternatives faster than would otherwise have been the case, nevertheless the news is likely to dismay many in the shooting community.

In particular, the short time frames mentioned in the document are likely to cause alarm. A statement from BASC said:

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.

The Gun Trade Association also expressed their concern in a statement, writing:

It is disappointing that HSE have been selective in their use of the evidence we submitted last November, especially on the open and honest data we provided on timelines and technology. Their statement that “Alternative ammunition is readily available’ for shotguns, completely fails to recognise the challenges we face.  While we have some candidate technologies, production in quantity in the timelines described is utterly impossible.  This will be raised at the political level.

The GTA will be making the strongest response on all fronts.  We will also be working with the shooting organisations to ensure we have a clear, unified voice.  We have already seen what harm can be caused by some going their own way on transition.  We must now mitigate the damage that could be caused and find ways to ensure that shooting can continue - and keep our businesses protected.

Aim to Sustain, the umbrella organisation representing nine of the biggest shooting organisations, had this to say:

Aim to Sustain will subject the dossier to a high level of scrutiny before making further significant comment. Using the combined expertise of our partner organisations, we will provide a substantive response to the consultation.

However, when our partner organisations signed up to a five-year voluntary transition away from the use of lead ammunition for live quarry shooting two years ago, we did so in the knowledge that such change needs time. We remain fully committed to that transition.

Aim to Sustain is committed to ensuring that HSE proposals around the use of lead ammunition for live quarry shooting are robustly scrutinised, evidence-­led and, most importantly, proportionate to any identified risk with appropriate transition periods to allow manufacturers the time to scale­ up production of viable alternatives to lead. 

The priority is to ensure sufficient supplies of non-­lead ammunition and to ensure that risks to land, food and fauna are adequately controlled. The HSE says it will continue to engage with UK REACH during the next stage of the process. Aim to Sustain is calling for the HSE and UK REACH to work with manufacturers and assemblers to plan a route­map for adequate supplies of sustainable ammunition.