HSE Lead ammunition proposals

[HE117]

HSE has just posted its report on the use of Lead in Ammunition..

UK REACH – Restriction Proposals 004 - Lead shot in ammunition - Health and Safety Executive - Citizen Space

Find and participate in consultations run by the Health and Safety Executive

consultations.hse.gov.uk

https://consultations.hse.gov.uk/crd-reach/restriction-proposals-004/supporting_documents/Annex%2015%20restriction%20dossier%20%20lead%20in%20ammunition.pdf

https://consultations.hse.gov.uk/crd-reach/restriction-proposals-004/supporting_documents/Annexes%20%20lead%20in%20ammunition.pdf

As can be imagined, the proposals, if adopted in full will pose a huge threat to the continuation of shooting in UK.
It had been trailed that target shooting, where the lead is practically all captured, would be subject to "derogation" however the HSE proposals for range management border on the impossible.

The consultation period ends in November.. I expect the National Shooting bodies to react before them

From an initial skim, thoughts are as follows:

1. This is a basic cut & paste from EU REACH.
2. The only serious evidence of damage by lead is to waterfowl as a result of ingestion. There is NO evidence of anyone suffering from the effects of lead from any other path from shooting (apart from the obvious one..!). The waterfowl issue is a recognised problem, and has been addressed by the shooting community for over a decade now.
3. The majority of the paper is based more on speculation than any documented facts. The paper admits it has no evidence of any harm arising from shooting activities, however reacts to lead as if it were a manufactured contaminent. Lead is a naturally occurring element and is endemic in the environment. Only when lead occurs in an easily absorbed compound such as the tetraethyl lead used in petrol is there a problem. To describe the distribution of lead as "contamination" is to grossley misrepresent the situation.

Be quite clear, this is an attempt to shut down shooting.. no more no less!

 

[Sam The Bam]

HSE has just posted its report on the use of Lead in Ammunition..

UK REACH – Restriction Proposals 004 - Lead shot in ammunition - Health and Safety Executive - Citizen Space

Find and participate in consultations run by the Health and Safety Executive

consultations.hse.gov.uk

https://consultations.hse.gov.uk/crd-reach/restriction-proposals-004/supporting_documents/Annex%2015%20restriction%20dossier%20%20lead%20in%20ammunition.pdf

https://consultations.hse.gov.uk/crd-reach/restriction-proposals-004/supporting_documents/Annexes%20%20lead%20in%20ammunition.pdf

As can be imagined, the proposals, if adopted in full will pose a huge threat to the continuation of shooting in UK.
It had been trailed that target shooting, where the lead is practically all captured, would be subject to "derogation" however the HSE proposals for range management border on the impossible.

The consultation period ends in November.. I expect the National Shooting bodies to react before them

From an initial skim, thoughts are as follows:

1. This is a basic cut & paste from EU REACH.
2. The only serious evidence of damage by lead is to waterfowl as a result of ingestion. There is NO evidence of anyone suffering from the effects of lead from any other path from shooting (apart from the obvious one..!). The waterfowl issue is a recognised problem, and has been addressed by the shooting community for over a decade now.
3. The majority of the paper is based more on speculation than any documented facts. The paper admits it has no evidence of any harm arising from shooting activities, however reacts to lead as if it were a manufactured contaminent. Lead is a naturally occurring element and is endemic in the environment. Only when lead occurs in an easily absorbed compound such as the tetraethyl lead used in petrol is there a problem. To describe the distribution of lead as "contamination" is to grossley misrepresent the situation.

Be quite clear, this is an attempt to shut down shooting.. no more no less!

Lead shot has been banned in Montana for quite some time now. Now it's steel ball only and occasionally (read always) the Conservation Officers will drop by and have you submit your ammunition for the magnet test. they'll pick a half dozen rounds at random.

Basically mate you're probably going to have to change the type of shot you use. I load my own shells and if I'm honest it costs me a couple of $ more a 5lb bag.

 

[instinct]

Lead shot has been banned in Montana for quite some time now. Now it's steel ball only and occasionally (read always) the Conservation Officers will drop by and have you submit your ammunition for the magnet test. they'll pick a half dozen rounds at random.

Basically mate you're probably going to have to change the type of shot you use. I load my own shells and if I'm honest it costs me a couple of $ more a 5lb bag.

Do they ban lead in centre fire rifle ammo for target shooting?

 

[Sam The Bam]

Do they ban lead in centre fire rifle ammo for target shooting?

Only on State/public land. Private ranges and clubs is a no but we do mine and clean up the backstops every two years.

 

[4(T)]

HSE has just posted its report on the use of Lead in Ammunition..

UK REACH – Restriction Proposals 004 - Lead shot in ammunition - Health and Safety Executive - Citizen Space

Find and participate in consultations run by the Health and Safety Executive

consultations.hse.gov.uk

https://consultations.hse.gov.uk/crd-reach/restriction-proposals-004/supporting_documents/Annex%2015%20restriction%20dossier%20%20lead%20in%20ammunition.pdf

https://consultations.hse.gov.uk/crd-reach/restriction-proposals-004/supporting_documents/Annexes%20%20lead%20in%20ammunition.pdf

As can be imagined, the proposals, if adopted in full will pose a huge threat to the continuation of shooting in UK.
It had been trailed that target shooting, where the lead is practically all captured, would be subject to "derogation" however the HSE proposals for range management border on the impossible.

The consultation period ends in November.. I expect the National Shooting bodies to react before them

From an initial skim, thoughts are as follows:

1. This is a basic cut & paste from EU REACH.
2. The only serious evidence of damage by lead is to waterfowl as a result of ingestion. There is NO evidence of anyone suffering from the effects of lead from any other path from shooting (apart from the obvious one..!). The waterfowl issue is a recognised problem, and has been addressed by the shooting community for over a decade now.
3. The majority of the paper is based more on speculation than any documented facts. The paper admits it has no evidence of any harm arising from shooting activities, however reacts to lead as if it were a manufactured contaminent. Lead is a naturally occurring element and is endemic in the environment. Only when lead occurs in an easily absorbed compound such as the tetraethyl lead used in petrol is there a problem. To describe the distribution of lead as "contamination" is to grossley misrepresent the situation.

Be quite clear, this is an attempt to shut down shooting.. no more no less!

Yes, another fake consultation, and then rubber-stamped into legislation. The Home Office will certainly grab this opportunity to further the agenda.

It does look like the end of shooting sports in all forms is drawing near.

I've been watching this coming for a couple of years, and trying to decide if and when I should sell off all my firearms and shooting kit. I don't want to be left holding thousands of pounds' worth of scrap, which is what it'll be when the majority of firearms in UK become unusable and unsaleable.

 

[instinct]

So genuinely what is the best way to start putting our representation forward?

 

[HE117]

So genuinely what is the best way to start putting our representation forward?

I hate to say it, but shooting needs to get political and start to play the "special interest" card.. I don't want it, and I don't think it is a good long term strategy, but I think we are getting past the point where playing the "nice guy" is not in our favour.

The main issue is however that we need to collapse all the shooting tribes into one body.

 

[terminal]

HSE has just posted its report on the use of Lead in Ammunition..

UK REACH – Restriction Proposals 004 - Lead shot in ammunition - Health and Safety Executive - Citizen Space

Find and participate in consultations run by the Health and Safety Executive

consultations.hse.gov.uk

https://consultations.hse.gov.uk/crd-reach/restriction-proposals-004/supporting_documents/Annex%2015%20restriction%20dossier%20%20lead%20in%20ammunition.pdf

https://consultations.hse.gov.uk/crd-reach/restriction-proposals-004/supporting_documents/Annexes%20%20lead%20in%20ammunition.pdf

As can be imagined, the proposals, if adopted in full will pose a huge threat to the continuation of shooting in UK.
It had been trailed that target shooting, where the lead is practically all captured, would be subject to "derogation" however the HSE proposals for range management border on the impossible.

The consultation period ends in November.. I expect the National Shooting bodies to react before them

From an initial skim, thoughts are as follows:

1. This is a basic cut & paste from EU REACH.
2. The only serious evidence of damage by lead is to waterfowl as a result of ingestion. There is NO evidence of anyone suffering from the effects of lead from any other path from shooting (apart from the obvious one..!). The waterfowl issue is a recognised problem, and has been addressed by the shooting community for over a decade now.
3. The majority of the paper is based more on speculation than any documented facts. The paper admits it has no evidence of any harm arising from shooting activities, however reacts to lead as if it were a manufactured contaminent. Lead is a naturally occurring element and is endemic in the environment. Only when lead occurs in an easily absorbed compound such as the tetraethyl lead used in petrol is there a problem. To describe the distribution of lead as "contamination" is to grossley misrepresent the situation.

Be quite clear, this is an attempt to shut down shooting.. no more no less!

I am not disputing that you have a concern, but what precisely are the main problems with respect to lead-free ammunition in target shooting? This is not a problem area that I am familiar with.

 

[4(T)]

I am not disputing that you have a concern, but what precisely are the main problems with respect to lead-free ammunition in target shooting? This is not a problem area that I am familiar with.

- lack of alternative bullets in many/most calibres

- excessive cost of monolithic bullets (copper, bronze, etc)

- many/most ranges cannot accommodate monolithic bullets (increased ricochet distances)

- lack of safe lead substitutes for historic arms, including muzzle loaders

- potential loss of millions of rounds of legacy ammunition (@ c.£1 per round in many cases)

- unknown reproofing requirements - in a duopolistic proof system that is both extremely expensive and already log-jammed with the fallout from previous waves of legislation (shotguns, de-acts, etc)

- as yet unknown costs attached


and so on and so forth.

 

[HE117]

I am not disputing that you have a concern, but what precisely are the main problems with respect to lead-free ammunition in target shooting? This is not a problem area that I am familiar with.

There are a host of issues, however the main ones is that lead free bullets have significantly greater ricochet characteristics than lead ones. Lead at normal temperatures has almost no elastic properties. All our target ranges are designed to capture lead based projectiles. This is why monometal bullets are not allowed on MOD ranges.

The other main issue is that most historic firearms cannot be used with non lead ammunition. Most pre war shotguns, particularly those with Damascus barrels cannot be used with steel shot and have to use Bismuth, at prohibitive cost. Lead shot is about £4 per Kg, Bismuth is £56 per Kg. It is not possible to use historic black powder rifles and muskets with non lead projectiles as the designs require the plastic characteristics of lead.

All the projectiles in target shooting are captured in a stop butt or within a few hundred meters in the case of shot. There is minimal escape of metallic lead into the environment, and what does escape is invariably below the "background" level in nature.

Edited to add.. the military are exempt the proposals, which is a bit rich as they fire more lead than civvie shooters.

 

[4(T)]

AFAIK, chaps using copper or bronze bullets for hunting find that the drastically reduced density means that the energy at range for a given bullet length/shape drops off rapidly - copper rounds at c.200 yards having the same residual energy as lead at c.600yds.

Hence copper/bronze might be suitable for deer stalking at close range, but would be entirely useless for target shooting at medium and long ranges.

 

[Rapierman]

At the end of the day we all know that the gun laws in the UK are mental, for a country that has pretty much brassed up most of the map?
I know it is always quoted but is true "guns don't kill people, people do"
So am I to believe that my little tin of .22 Spitfires are going to be illegal?
This country seriously needs a shake up, I think personally it is on it's way. There is no trust in power or decision anymore and dare I say Monarchy or Government.
Too many liberal beliefs have been adopted and taken as mainstream ideology. This is not the case and why we are the laughing stock on the world stage,

 

[terminal]

There are a host of issues, however the main ones is that lead free bullets have significantly greater ricochet characteristics than lead ones. Lead at normal temperatures has almost no elastic properties. All our target ranges are designed to capture lead based projectiles. This is why monometal bullets are not allowed on MOD ranges.

The other main issue is that most historic firearms cannot be used with non lead ammunition. Most pre war shotguns, particularly those with Damascus barrels cannot be used with steel shot and have to use Bismuth, at prohibitive cost. Lead shot is about £4 per Kg, Bismuth is £56 per Kg. It is not possible to use historic black powder rifles and muskets with non lead projectiles as the designs require the plastic characteristics of lead.

All the projectiles in target shooting are captured in a stop butt or within a few hundred meters in the case of shot. There is minimal escape of metallic lead into the environment, and what does escape is invariably below the "background" level in nature.

Edited to add.. the military are exempt the proposals, which is a bit rich as they fire more lead than civvie shooters.

I did some googling to find some material to read up on this. As I said, I'm not familiar with the issue but I do find it interesting. I thought I would share a couple of the most interesting documents that I found in case they are of any use to anyone else.

This document is from Public Health Ontario and it discusses lead exposure in indoor ranges. It sounds like there are major problems with this and I'm not sure there is a good answer to them on most indoor ranges without lead-free ammunition. The issues on outdoor ranges are entirely different and are not discussed in this document.
Lead Exposures Among Recreational Shooters

This is a report on the problems with lead restrictions with respect to black powder firearms. It makes for quite interesting reading. It appears to have been written by the Hungarian CIP Proof House, and so should be considered to be an authoritative source on this issue.
Report on lead restrictions on black powder firearms


I don't live in the UK and I am not familiar enough with the issues there to offer any prescriptions. However, I see the issue has having several different aspects, each of which may need a different approach. These are indoor ranges, outdoor ranges, waterfowl hunting, and other (non waterfowl) hunting. If you are going to argue for a compromise on the lead ammunition issue, then I suspect you would need to argue the details of these with respect to the effects of a blanket ban on society (e.g. the cultural aspects of things such as antique firearms, target shooting, and hunting in rural communities) and to divide the issue up instead of lumping all of lead ammunition together into one big mass of metal.

 

[terminal]

AFAIK, chaps using copper or bronze bullets for hunting find that the drastically reduced density means that the energy at range for a given bullet length/shape drops off rapidly - copper rounds at c.200 yards having the same residual energy as lead at c.600yds.

Hence copper/bronze might be suitable for deer stalking at close range, but would be entirely useless for target shooting at medium and long ranges.

Do you have a particular category of ammunition in mind in this respect, or are you talking about copper or copper alloy bullets in general? Because French 8mm balle D was bronze and extensively used by the French in the early part of the 20th century and I don't recall reading about there being any issues with it lacking in punch at range.

 

[HE117]

Do you have a particular category of ammunition in mind in this respect, or are you talking about copper or copper alloy bullets in general? Because French 8mm balle D was bronze and extensively used by the French in the early part of the 20th century and I don't recall reading about there being any issues with it lacking in punch at range.

The Balle D was one of the first examples of smokeless small calibre rounds. The energy profile of this round, although better than the black powder ammunition it replaced, is not really comparable with the rounds that followed it. Balle D was fairly quickly replaced with a jacketed lead bullet.

Bullet energy and momentum is down to cross sectional density. Although you can compensate for reduced density with increased velocity, this has a significant effect on bore erosion.

The issue of lead in indoor ranges is reasonably well understood, and modern ranges are built with air conditioning and bullet trap designs to address this. The Canadian paper is again questionable regarding the risk associated with lead. There is widespread misrepresentation regarding the toxic effects of lead in its various forms. Metallic lead is not that toxic in itself, it is only some lead compounds that are able to have a physiological effect. There is some seriously dodgy science in play here.. just because you can detect something does not mean that it is a problem. Our ability to detect small quantities of material has not been matched with the study of the effects of such materials. Lead is an element and exists as a result of the breakdown of natural uranium and other dense elements.

 

[Blogg]

Lead ammunition restriction proposals: what happens next? - The British Association for Shooting and Conservation

Read our overview of the Health and Safety Executive's proposed lead ammunition restrictions in England, Wales and Scotland.

basc.org.uk

 

[QRK2]

I did some googling to find some material to read up on this. As I said, I'm not familiar with the issue but I do find it interesting. I thought I would share a couple of the most interesting documents that I found in case they are of any use to anyone else.

This document is from Public Health Ontario and it discusses lead exposure in indoor ranges. It sounds like there are major problems with this and I'm not sure there is a good answer to them on most indoor ranges without lead-free ammunition. The issues on outdoor ranges are entirely different and are not discussed in this document.
Lead Exposures Among Recreational Shooters

This is a report on the problems with lead restrictions with respect to black powder firearms. It makes for quite interesting reading. It appears to have been written by the Hungarian CIP Proof House, and so should be considered to be an authoritative source on this issue.
Report on lead restrictions on black powder firearms


I don't live in the UK and I am not familiar enough with the issues there to offer any prescriptions. However, I see the issue has having several different aspects, each of which may need a different approach. These are indoor ranges, outdoor ranges, waterfowl hunting, and other (non waterfowl) hunting. If you are going to argue for a compromise on the lead ammunition issue, then I suspect you would need to argue the details of these with respect to the effects of a blanket ban on society (e.g. the cultural aspects of things such as antique firearms, target shooting, and hunting in rural communities) and to divide the issue up instead of lumping all of lead ammunition together into one big mass of metal.

The indoor range issue is rather different to the more general outdoor one, in the civilian (including cadets) world compounded by the nature of the 22LR unjacketed round that is commonly in use, range standing orders should where necessary include restrictions in the exposure that individuals may have over time. The indoor ranges that we use for LFTT have substantial (read massive) air extraction systems.

 

[aardvark64]

So genuinely what is the best way to start putting our representation forward?

Get our nearest and dearest to glue themselves to the pavement outside Parliament or across numerous slip roads to the M25. That'll have the legislators quaking into their lattes.

 

[4(T)]

I don't live in the UK and I am not familiar enough with the issues there to offer any prescriptions. However, I see the issue has having several different aspects, each of which may need a different approach. These are indoor ranges, outdoor ranges, waterfowl hunting, and other (non waterfowl) hunting. If you are going to argue for a compromise on the lead ammunition issue, then I suspect you would need to argue the details of these with respect to the effects of a blanket ban on society (e.g. the cultural aspects of things such as antique firearms, target shooting, and hunting in rural communities) and to divide the issue up instead of lumping all of lead ammunition together into one big mass of metal.

This is exactly what happens when new firearms restrictions are proposed. We do have shooting associations and SMEs who do put together expertly evidenced arguments that differentiate the various types of shooting, and which do rebut the claims against those sectors most affected by the proposals.

This expert defence is then generally ignored, and the bulk of the proposals take effect anyway.

Firearms licensing in UK is highly adversarial, and deliberately so. An issue identified with one aspect of shooting sports is usually amplified and extended, and then used to target the whole community.

E.g. the forthcoming lead ban (and it will be introduced) arose initially out of wildfowl injuries from lead weights (and predominantly the attached line) used in recreational fishing. This was swiftly extended to shot from shotguns (in the bird through shooting or ingestion), then extended to game hunting, and now to indoor and outdoor target ranges.

A common tactic is for multiple government agencies and pressure groups to leap on the bandwagon and thus smother the shooting community in a blanket of box-ticking requirements and costs that it cannot defend against. For example the lead ban campaign might involve the Home Office, Defra, HSE, MoD, LandMarc, the EU (still), multiple environmental and political activist groups - and a salacious media.

The common feature of these organisations is that they are all generally anti civilian shooting sports. Against this, shooters have no political defence or representation. The nature of UK party politics means that there is no real debate or examination of legislation affecting groups that are not in favour, but instead a tendency to strike out at those groups to score political points - vide Mercer's recent attempt to demonise and ban pump action shotguns (2 rnd mags here, of course).

Shooting sports are really a sort of canary in the coalmine in terms of the loss of civil liberties and the creep of bureaucratic authoritarianism, but no-one seems to pay much notice.

 

[ugly]

I’m going to use all lead until it’s sale is banned and I run out, to me the biggest issue is REACH banning certain propellants from import, bastards they are!