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NRA Response – UK REACH Restriction Dossier on Lead Ammunition

Lead is a known toxin and exposure is harmful to human health and the environment; it is reasonable to review its use in ammunition.

We have worked closely with other major shooting organisations to conclude the NRA’s response to the Health and Safety Executive (“HSE”) consultation on proposals to ban all forms of lead ammunition used outdoors, with limited derogations.

Our response has focused on the proposed derogation to allow the use of lead ammunition on GB outdoor ranges.

The April 2022 HSE report stated “[outdoor] shooting ranges would need to demonstrate that the necessary operational conditions and risk management measures are in place to ensure a minimum of 90% recovery of deposited lead”.

Lead projectiles fired on outdoor shooting ranges are managed in the following manner:-

  1. Well established safety protocols are designed to ensure 100% of all fired projectiles are captured by bullet catchers on outdoor shooting ranges;
  2. Lead projectiles captured in bullet catchers are effectively inert and, when undisturbed, pose no risk to human health or the environment;
  3. Bullet catchers are routinely inspected to ensure range safety is maintained, including testing for accumulation of projectiles;
  4. Projectiles are removed, before accumulations reach levels that could compromise range safety, by screening by licensed contractors or range personnel in accordance with The Control of Lead at Work Regulations 2002 (“CLAW”) and licensed waste handling processes; and
  5. Screened projectiles are sold to licensed waste handlers or recycled by range personnel

After careful consideration and helpful discussion with Environment Agency (“EA”) and HSE staff, and consultation with regional range operators, the NRA and NSRA propose the following:-

  1. NRA / NSRA assist EA / HSE in drafting protocols and procedures to define the operational conditions and risk management measures required to manage lead in bullet catchers;
  2. NRA / NSRA publish these protocols and procedures to affiliated and non-affiliated shooting range operators;
  3. Affiliated and non-affiliated shooting range operators complete an annual Registration confirming adherence with the published protocols and procedures;
  4. NRA / NRSA maintain a publicly available online Register of ranges approved for the use of lead projectiles; and
  5. Registered ranges are subject to inspection by EA personnel to ensure compliance.

Points to note:-

  1. The above proposals relate to outdoor ranges only and cover all types of lead projectiles;
  2. No restriction on agricultural activity on Registered ranges is necessary as they are designed to ensure 100% of projectiles are captured by the bullet catchers;
  3. Recovered lead has a resale value of £1,000 to £1,300 per tonne;
  4. We have highlighted that civilian target shooting with lead projectiles takes place on military ranges;
  5. Most major live quarry shooting organisations accept that restrictions on the sale and use of lead shot and expanding lead rifle ammunition will reduce the risk posed by lead to human health and the wider environment; and
  6. Clay target shooting organisations contend that exposure to lead shot on clay ranges can be managed effectively.

 

The HSE Consultation can be found https://consultations.hse.gov.uk/crd-reach/restriction-proposals-004/ ; the deadline for responses is 6 November 2022.

 

We understand the EA will:-

  • Finalise their opinion and summary and launch a second public consultation on socioeconomic impact in February 2023 for 3 months; and
  • Make their final submission to DEFRA in summer 2023

DEFRA will thereafter determine the scope of the legislation.

 

Andrew Mercer

NRA Secretary General

28 October 2022

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