Health and Safety Executive launch new consultation on lead ammunition

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In April 2021, the Health and Safety Executive (HSE) were requested by the Defra Secretary of State to prepare a dossier assessing the risks to the environment and human health from lead in ammunition.  

The dossier was to examine whether further risk management is needed to control the use or sale of lead in ammunition for outdoor shooting in the UK.

The HSE conducted a consultation on restricting the use of lead in ammunition, which closed in November 2022. The results were delayed due to an unprecedented number of responses (2,759), meaning the the draft Agency Opinion was only published this month.

The draft Opinion from HSE concluded that:

♦for the environment there are risks that are not adequately controlled for lead shot (primary and secondary exposure), lead bullets (secondary exposure) and airgun ammunition (primary and secondary exposure)
♦amongst consumers of high volumes of game meat that has been shot with lead ammunition (shot or bullets), there is a risk to the health of vulnerable people (young children and women of child-bearing age) that is not adequately controlled.

Therefore, the HSE is recommending measures to restrict the use and placing on the market of some types of lead ammunition. The revised restriction proposals for the outdoor use of lead ammunition in England, Wales and Scotland are as follows:

♦Lead airgun pellets – no restrictions proposed.
♦Lead shot for live quarry and target shooting – proposed ban within five years or less, depending on consultation outcome.
♦Rifle ammunition for live quarry shooting – no restrictions proposed, but this could change depending on consultation outcome.
♦Rifle ammunition for target shooting – can continue on approved ranges where mitigation measures for lead removal are in place, with a two-year grace period.

With regards to shotgun ammunition the HSE’s proposal is that lead ammunition is not to be used or sold in the UK within five years. The NGO feels that with a voluntary move away from lead ammunition underway, there is no need for a legislative ban.

We have urged the HSE to take into account the fact that there is currently a worldwide shortage of components for making non-lead shot shells. We have also pointed out that the manufacturers will need time to reconfigure production lines, invest in new machines and train the workforce, all of which takes time.

The above proposals are subject to a HSE public consultation which opened in October and will run for 60 days, closing on 10 December 2023. The NGO will be submitting a response.

The consultation document can be found here: A4template-online (hse.gov.uk)