HSE publishes risk assessment opinion on lead in ammunition restriction proposals

[OlafUK]

Not sure how many people may have seen this yet, but the HSE have just published the following...

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HSE statement on “Lead in ammunition” UK REACH proposals​

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Here you will find the link to the Public Consultation that opens today and closes on the 10th December

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UK REACH - Public Consultation on Lead in Ammunition​

And attached is the HSE's "Lead in Ammunition Restriction Opinion Document - Draft SEA Opinion" all 104 pages of it...

 

[TRINITY]

looks like we are on borrowed time , 5 years grace suggested then we are done. That's how I read it.
Let's see how the industry adapts with steel cartridge alternatives and how much it could possibly cost us.
One thing is for sure the dealers will quickly want to offer very little for non lead proofed guns.

 

[westley]

looks like we are on borrowed time , 5 years grace suggested then we are done. That's how I read it.
Let's see how the industry adapts with steel cartridge alternatives and how much it could possibly cost us.
One thing is for sure the dealers will quickly want to offer very little for non lead proofed guns.

The 'Dealers' are already offering very little for none STEEL proofed guns and have been for some time. English 2 1/2" chambered guns have been practically worthless since this entire lead shot debacle kicked off. The ban on lead shot is easy to achieve and the cost is negible, except to shooters ? However it takes the pressure off the Utility Companies, to whom it would cost a fortune to get rid of all of the lead piping, still in use by them !

 

[MartynB]

There never was a consultation, it’s always been a ‘fait accompli ‘ . Some of the ‘ facts’ presented in the report are stunning in their ignorance. My favourite is “ Hunters” ( I always thought they were big horses , but he-ho “ causing lead poisoning in their companion animals ( dogs ) by feeding offcuts of lead shot game … Homer Simpson is alive and well and working for the HSE .

It just shows that divide and conquer is alive and well , lots of clay shooters thought it was a game shot only issue , The HSE claims clay shooters deposits approximately 3.5 times the lead per annum than the game shooters do , so that’s that scuppered . A particular well done to BASC and the CPSA for your marvellous work fighting this ….. not

 

[TRINITY]

There never was a consultation, it’s always been a ‘fait accompli ‘ . Some of the ‘ facts’ presented in the report are stunning in their ignorance. My favourite is “ Hunters” ( I always thought they were big horses , but he-ho “ causing lead poisoning in their companion animals ( dogs ) by feeding offcuts of lead shot game … Homer Simpson is alive and well and working for the HSE .

It just shows that divide and conquer is alive and well , lots of clay shooters thought it was a game shot only issue , The HSE claims clay shooters deposits approximately 3.5 times the lead per annum than the game shooters do , so that’s that scuppered . A particular well done to BASC and the CPSA for your marvellous work fighting this ….. not

Whatever you think about those organisations, the reality is they are powerless. The issue was already decided sometime back and the whole consultation process is just a sham to purport to show fairness.

 

[FESkent]

If (and it is a big IF) you accept the science that lead shot is harming flora and fauna and people then banning lead for live quarry shooting then requires they ban lead shot completely as you see and read on other forums comments recommending the use of 7.5 shot or smaller for live pigeon shooting.
Yet clay clubs and commercial grounds operate over a relatively very small and fixed area of land, where such risks are tiny and I would not recommend trying to eat a clay pigeon.

Statement in the proposal that they do not expect participants to give up shooting as a consequence I fear will be wrong as the current costs are already resulting in that and no mention as to if it will be a barrier to enter the sport.

Read the proposal carefully and the ban could be within two years not five.

I say this as an RFD and long standing clay Club secretary.

 

[vmax1010]

Once the hse was tasked with this it was pretty much a done deal to ban lead, whoud you expect a civil servant to stick his head over the paripit and say "carry on it's ok to use a poisonous substance"

 

[Paul120]

Umm, it's not going to be cheap.

and we all know how good these agencies are at forecasting costs

4.4.2.2.1 Shooter substitution costs As in 4.4.2.1.1, the Agency anticipates that, under a derogated restriction on TS with lead shot, a variety of costs would occur directly to shooters in substituting away from lead shot to alternative shot. These costs can be classified as either one-off or on-going costs. The same assumptions apply here as those outlined in section 4.4.2.1 of this opinion (explored in further detail in section 2.6.1.1.1 of the Background Document). In terms of one-off costs, shooters may face: • The cost of purchasing a new shotgun in order to shoot alternatives to lead shot. The Agency estimates this cost to total £241.1m in PV terms. • The cost of modifying their existing shotguns(s) in order to shoot alternatives to lead shot. The Agency estimates this cost to total £12.0m in PV terms. • Any re-proof that may be required after such modifications. The Agency estimates this cost to total £1.7m in PV terms. In terms of on-going costs, shooters may face: • Costs due to more expensive alternative ammunition. The Agency estimates this cost to total to £120.4m in PV terms. Section 2.6.1.3.1 of the Background Document contains full detail on the methodology and assumptions used to estimate the substitution costs to shooters. Totalled across the 20-year appraisal period, the Agency estimates these costs to amount to £375.2m in PV terms.

 

[Luke_(NL)]

Umm, it's not going to be cheap.

and we all know how good these agencies are at forecasting costs

4.4.2.2.1 Shooter substitution costs As in 4.4.2.1.1, the Agency anticipates that, under a derogated restriction on TS with lead shot, a variety of costs would occur directly to shooters in substituting away from lead shot to alternative shot. These costs can be classified as either one-off or on-going costs. The same assumptions apply here as those outlined in section 4.4.2.1 of this opinion (explored in further detail in section 2.6.1.1.1 of the Background Document). In terms of one-off costs, shooters may face: • The cost of purchasing a new shotgun in order to shoot alternatives to lead shot. The Agency estimates this cost to total £241.1m in PV terms. • The cost of modifying their existing shotguns(s) in order to shoot alternatives to lead shot. The Agency estimates this cost to total £12.0m in PV terms. • Any re-proof that may be required after such modifications. The Agency estimates this cost to total £1.7m in PV terms. In terms of on-going costs, shooters may face: • Costs due to more expensive alternative ammunition. The Agency estimates this cost to total to £120.4m in PV terms. Section 2.6.1.3.1 of the Background Document contains full detail on the methodology and assumptions used to estimate the substitution costs to shooters. Totalled across the 20-year appraisal period, the Agency estimates these costs to amount to £375.2m in PV terms.

Among how many hunters and clay enthusiasts in the UK is that 375M GBP divided? Seems a stiff bill to foot per shooter. Class action claim could stand a chance, if your associations could initiate such steps.

In NL we can only shoot steel and have done so for years with no ill effects to hunting and clay shooting (afaik). Prevalence of ancient damascus Purdeys is lower here of course, but steel shot cartridges here seem cheaper than your lead shot cartridges judging by the Catridge Prices topic.

 

[jasper]

As previously stated. The cpsa misguided attempt to do a deal regarding clay shooters was absolute folly. As is proven by this document. Getting in bed with the enemy rarely works out well.

 

[Paul120]

Among how many hunters and clay enthusiasts in the UK is that 375M GBP divided? Seems a stiff bill to foot per shooter. Class action claim could stand a chance, if your associations could initiate such steps.

Not sure TBH.assuming there are in the order of 350,000- 500,000 licence holders ( could be way out, though) this would work out at around £750- £1k per licence holder. This is for the participants. I guess there will be some cost to the trade. How did the grounds go about preparing for steel in the NL? A lot of grounds here currently don't allow it due to the risk of Richochet off concrete etc. How did that get addressed over there? I guess there will be a cost for this and the risk assessments, etc, as well.
I'm happy to get 2 of my guns multichoked for steel (£700 + each) and go up a couple of shot sizes to make up for the ballistic difference. I don't just want them opened up though as I use it abroad to shoot OT so will still want to shoot lead with tighter chokes.

 

[FESkent]

Among how many hunters and clay enthusiasts in the UK is that 375M GBP divided? Seems a stiff bill to foot per shooter. Class action claim could stand a chance, if your associations could initiate such steps.

In NL we can only shoot steel and have done so for years with no ill effects to hunting and clay shooting (afaik). Prevalence of ancient damascus Purdeys is lower here of course, but steel shot cartridges here seem cheaper than your lead shot cartridges judging by the Catridge Prices topic.

Hi Luke,

Do you have steel shot cartridges in .410 and 28gauge ?
Small gauges are quite popular in the U.K. what’s the situation in NL

 

[Luke_(NL)]

How did the grounds go about preparing for steel in the NL? A lot of grounds here currently don't allow it due to the risk of Richochet off concrete etc. How did that get addressed over there? I guess there will be a cost for this and the risk assessments, etc, as well.
I'm happy to get 2 of my guns multichoked for steel (£700 + each) and go up a couple of shot sizes to make up for the ballistic difference. I don't just want them opened up though as I use it abroad to shoot OT so will still want to shoot lead with tighter chokes.

We tend not to shoot at concrete, really. In terms of grounds lay-out and risk assesment, there is not much difference to lead than steel. Angles of possible (mis-)fire are accounted for, shot sizes on courses are limited to 'not bigger than 6' in most places, and it is obviously critical to not shoot outside of a box or stand at anything, much less at anything that isnt a clay. Given that steel carries less far than lead (allegedly) you could even argue that the "unsafe area template" meaning the area where shot could possibly land, is smaller after the change, making life a little easier for ground owners.

Do you have steel shot cartridges in .410 and 28gauge ?
Small gauges are quite popular in the U.K. what’s the situation in NL

Hardly. We can't shoot 410 and 28 gauge I believe: For hunting purposes 16 Gauge is the smallest allowed and for sporting we get to use what's officially allowed under ISSF rules. You see 20 Gauge every so often, but I'd venture that's about it. I'll have to check the specific rules for sporting permits on that one, but if allowed, few and far between (which has an effect on the price of those cartridges if you could find them).

 

[Paul120]

It's also interesting that the proposals make an allowance for identified olympic shooters ,so they are not disadvantaged. But what about the other GB teams. DTL, ABT, UT and Fitasc and English sporting that all have European. World Championships and as NI according to the proposal comes under EU legislation and it only covers GB, Home Internationals.

To me, if it's the right way to go on
proven grounds of safety, then fine. But these questions need asking so we know where we stand and also things aren't kicked down the road to be sorted later on. They never are or end up being a complete mess.

 

[FESkent]

But how do future shooters become olympic shooters if they cannot practice on equal terms? so when the 50 individuals give up nobody is available to replace them.

 

[Luke_(NL)]

Hi Luke,

Do you have steel shot cartridges in .410 and 28gauge ?
Small gauges are quite popular in the U.K. what’s the situation in NL

I looked it up. We can't go smaller than 24 gauge, apparently and that's on hunting permits only. On the claygrounds I don't think I've seen anyone shoot 24 gauge, and finding steel shot for it would be hard indeed from a quick glance on the web. Our rules are stricter for what's allowed under a sport permit. 12 & 20 probably make up 99% of the guns here, if not more.

I used to think the steel thing was an EU rule, but on some German grounds it is mandatory to shoot lead only. I've been told they hoover up the lead pellets and sell them as lead scrap, but get far less money it is 'contaminated' with steel pellets. The grounds I've seen this are fenced in with webbing though, and you can actually hear the pellets striking the perimeter and trickling down.