UPDATE – UK REACH – Public consultation on lead in ammunition

Published on:
Nov 30, 2023

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UPDATE – UK REACH – Public consultation on lead in ammunition

We have been working closely with other shooting organisations to coordinate our responses to the consultation.

The questions, numbered for convenience, posed on the online consultation are found here

The key points for the target shooting community and the NRA’s responses are as follows:-

Question 1 Transition Periods (prohibition of the sale or use of lead shot)

Any transition must take account of the need to allow time for the cartridge trade to import and install manufacturing machinery suitable for loading steel shot cartridges. Furthermore, the transition period must allow sufficient time for the development of robust supply lines for components. There is a serious risk to the viability of the commercial infrastructure which supports GB shotgun shooting, namely the shooting grounds and game shoots, in the event of a ‘cliff edge’ in which future supply of ammunition is uncertain.

We recommend that a 5 year transition should be reviewed in year 4, at which point 80% of required ammunition should be available, measurement of availability to include both importers and UK manufacturers and to be assessed by a disinterested agency or contractor. If 80% of required ammunition is not available at this point, then an extension to the transition period should be triggered.

Question 4  (Use of different bullet types for live quarry shooting and target shooting)

The principal use of expanding ammunition in target shooting is that of .22 rimfire, in which a standard soft nosed lead bullet is universally used both for target shooting and for the shooting of pest species and small ground game. The same round is marketed both for target shooting and for live quarry.

All non-jacketed ammunition is by its very nature expanding and is used extensively in target shooting. Other types of target shooting in which solid lead projectiles are used Include:-

• Muzzle-loading shooting, with original and replica arms including muskets, rifles, pistols and revolvers;
• Breech loading historic arms (and modern reproductions) designed for such projectiles;
• Shooting with classic arms (e.g. the WW1 Enfield SMLE) using ammunition produced to fall within the limits of small ranges as operated by many clubs;
• Gallery rifle (GR) shooting. “Gallery rifles” are lightweight rifles designed to fire low-powered ammunition, usually in a calibre originally intended for pistols.  The archetypal gallery rifle is the Winchester saddle rifle originally produced in the 1870s to 1890s in various designs, with rifles to the same designs but built to modern standards used for short-range competition by thousands of participants;
• Cowboy action shooting using very low-powered cartridges with soft lead projectiles; and
• Heritage Pistols held under S7(3) Firearms Act 1997 which is intended to enable the preservation of pistols of particular rarity, historic interest, technical interest or aesthetic merit. These are often in obsolete calibres for which mass-produced commercial projectiles are unobtainable; owners of such use solid lead projectiles which can be cast in small batches and combined with small charges of propellant to minimise stress on these preserved firearms.

Question 6 (General Comments)

1. Target Shooting on Military Ranges

It is noted that the HSE’s proposed derogation for the use of lead ammunition on outdoor target shooting ranges with rifles as drafted would not permit target shooting by civilian shooters on military or police ranges. These ranges provide shooting for thousands of target shooters. This oversight should be corrected; we suggest the following amendment to

Page 15 Table 2 – Proposed Text of the Restriction – at item 6:

This restriction on lead in ammunition shall not apply to the following applications: indoor target shooting; police, security services, military, including target shooting on outdoor ranges under the control of those agencies by users authorised by the operator; technical testing and/or proofing; testing and development of materials and products; forensic analysis; historical and other technical research or investigation.

1. Publication of Addresses of Ranges

The NRA is concerned about the proposed publication of lists of ranges or shooting clubs which may be approved for target shooting with lead bullets, since this would potentially compromise the safety and security of the ranges, the range operators and the users of such ranges. We would be content with the publication of lists of contractors designated as competent to remove lead from stop butts.

Members may wish to refer to these points when responding, in their own words, to the consultation.

The deadline to the online consultation https://consultations.hse.gov.uk/crd-reach/lead-in-ammunition/consultation/subpage.2023-07-27.8019028924/ is Monday 10^th December.

Andrew Mercer

Secretary General