HSE pushes back decision on restricting lead in ammunition

The Health and Safety Executive (HSE) has delayed its decision on whether to recommend a restriction on the use of lead in ammunition by six months after receiving nearly 3,000 responses to a consultation.

The use of lead ammunition for outdoor shooting over wetlands is already subject to regulation in Britain, but HSE launched a consultation in May 2021 under the new UK REACH regime to establish whether additional controls are needed for outdoor shooting.

According to HSE, the responses received included many detailed and technical submissions that it says need to be worked through.

Dr Richard Daniels, HSE’s director of Chemicals Regulation Division, said: “It has been really encouraging to see the level of interest received, underlining that it is important we get this exercise right for the benefit of affected groups, peoples’ health and the environment.

“Although we have more than tripled the number of people working on the consultation responses, our technical specialists will need more time to both consider responses and put forward our concluding opinions.

"The UK REACH legislation enabled us to make an extension if needed. We are making the necessary changes to the legal timetable, and keeping ministers updated.”

Daniels also noted that members of the REACH Independent Scientific Expert Panel (RISEP) will require accurate and comprehensive information for them to scrutinise and challenge the agency’s draft opinions.

According to HSE, an initial review of responses indicates that alternative risk management options may need to be considered. The original request to prepare a restriction report came in April 2021 from the then environment secretary, with the agreement of the Scottish and Welsh Governments.

Dr Julia Newth, ecosystem health & social dimensions manager at the Wildfowl & Wetlands Trust, said: “Any delay in tackling the removal of this toxic substance from our environment and lives is to be avoided especially considering that non-toxic alternatives are readily available.

“Pervasive resistance to change narratives have no doubt contributed to the high consultation response rate so although we are disappointed to have further setback and expense, we recognise that a robust process is critical and more time is needed on this occasion.”

British Association for Shooting and Conservation (BASC) East director, Terry Behan, commented: “The use of lead ammunition is huge and varied, and blanket restrictions as proposed are not as simple as some make out. The HSE has taken the right decision to utilise the six-month extension clause to fully evaluate the responses and avoid any unintended consequences.

“The suggestion from the HSE that alternative risk management options and derogations may need to be considered aligns with the conclusions of BASC’s technical reports and 180-page consultation response.

“While the HSE fully digests all the responses, it is expected the socio-economic impact assessment consultation will be delayed from its intended February start point.”

HSE said that it will send its final risk assessment and socio-economic opinions on the GB restriction proposals to the appropriate authorities (i.e. the DEFRA secretary of state and the Scottish and Welsh Governments) by August 2023 and November 2023 respectively. After receiving the final socio-economic opinion, the appropriate authorities will then have three months to make a decision on whether to accept the proposals.

The regulator also said that the restriction proposals for tattoo inks and permanent make-up, which were also published on 6 May 2022, will follow their original timescales.