HSE Report on Lead Ammunition

[Popsbengo]

The HSE have released their "opinion" document regarding lead in shot and bullets.

https://nra.org.uk/hse-publish-proposals-for-restrictions-on-lead-ammunition/

https://nra.org.uk/wp-content/uploads/Lead-in-Ammunition-Restriction-Opinion-Document-Draft-SEA-Opinion.pdf

On first reading it seems that for rifle shooting, provided controls can be made for containing and removing lead from an outdoor range it can be 'business as usual'.  It's proposed that there's formal registration of ranges required with some sort of audit/enforcement protocol.   What this could mean for field firing ranges with no practical method of containment and removal remains concerning.   The use of lead shot for shotguns is coming to an end for sure.  Indoor ranges appear to be outside of the scope of the report for some reason not explained.

Of course, as yet it's a proposal and will require legislation to implement.

[AJW7088]

With reference to indoor ranges, and their exclusion from further consideration, the HSE Proposal Document dated April 2022 included the following assessment as regards such ranges;

"the environmental and human health risks arising from lead exposure from lead ammunition are negligible if the appropriate risk management measures are applied."

(see page 153 as an example)

I believe that this conclusion was based on the assessment conducted by the European Chemicals Agency (ECHA). 

I realise it is not a full rationale, but I hope it helps, at least for now.

Adrian

[Roy W]

This sounds like it could have an impact on PRS type events then?

[AJW7088]

Potentially Roy. The derogation proposals for the continued use of lead bullets on outdoor ranges are summarised on page 9 of the HSE document. Whether outdoor range operators can meet the proposed arrangements would be be something they would each have to decide on I expect. There is/was a further issue of whether the land being used as a range or being shot over is also used for other purposes (e.g. agriculture or grazing). Whilst I think that this consideration was earlier applied to both the use of lead shot and lead bullets, it now appears restricted to the consideration of the use of lead shot alone (page 8).

As Popsbengo says, these are proposals. The NRA links also link on to the current HSE consultation. Whilst that consultation seeks responses to very specific questions it does have a general comments section which could be used to comment on the aspects above.

Adrian

[Popsbengo]

On 10/16/2023 at 8:00 PM, Roy W said:

This sounds like it could have an impact on PRS type events then?

I don't do PRS myself but would it be practical / cost-effective to build a containment butts/ canopy etc to capture bullets for stand-alone targets?

I would think the likes of Eskdalemuir ranges to also be a challenge to manage lead capture & recovery.

I also wonder if civvies using MoD field firing ranges will continue to be permitted ?