The recommendation was originally due in January, however HSE – which acts as the agency for the chemical regulation UK REACH – delayed its decision after receiving nearly 3,000 responses to a consultation.
In its opinion dossier published this week, HSE concluded that there are risks that are “not adequately controlled” to the environment for lead shot, lead bullets and airgun ammunition. It also found there were health risks that are “not adequately controlled” for people eating high volumes of game meat, and for vulnerable people such as young children.
Currently, lead shot is prohibited In England and Wales on all foreshores, in specified Sites of Special Scientific Interest (SSSIs), and for the shooting of all ducks, geese and swans, coots and moorhen. In Scotland it is banned for shooting over any wetland. These prohibitions apply to shot at a 1 % weight by weight (w/w) concentration limit.
However, the environment secretary previously called for further restrictions to be looked into by HSE – coming under Annex 15 of UK REACH – because evidence from testing water birds for sale at game dealers suggested there is low compliance with these regulations and further measures may be needed.
HSE has now recommended that lead shot is banned for sale and use both for outside use and live quarry shooting, with an exception – or derogation – for athletes involved in target shooting, as identified by the appropriate sporting body. It recommended a transition period of five years.
The regulatory body also put forward a restriction on the use of lead bullets for outdoor target shooting with a derogation for use at ranges with appropriate risk management measures in place, but is waiting for more information on what to do about this for live quarry shooting. For this, it recommended a transition period of two years.
It clarified that the proposed restrictions will apply to ammunition with a concentration of equal to or greater than 1 % w/w lead, which it described as “achievable by manufacturers, whilst still allowing alternatives to be used that might contain low levels of lead as an impurity”.
No actions were proposed for air gun ammunition as HSE could not identify any workable restriction options to consider in its socio-economic analysis.
HSE has opened a consultation on these proposals which closes in December, and said in its opinion document that the recommendations are subject to change depending on the outcome of this.