Lead pellet ban: BASC to fight lead airgun pellet ban proposals

In May, a six-month public consultation launched on proposals to restrict or ban the use of lead ammunition for outdoor recreational shooting in England, Wales and Scotland. This impacts on airgunning and every shooting discipline for live quarry and target shooting.

The Health and Safety Executive (HSE) was tasked by the government to look at the evidenced risks posed by lead ammunition and to publish proposals to reduce or eliminate those risks. BASC has reviewed the 500 pages of so-called “evidence” and we will be fighting most of the proposals, including a ban on the use of lead airgun pellets for both live quarry and outdoor target shooting.

In its report, the HSE estimated that 14.5 tonnes of lead is “released into the environment” annually from all live quarry shooting using small calibre bullets and airgun pellets. There were no standalone figures for airgun pellets. To put that figure into perspective, the estimated amount of lead shot used for live quarry shooting was 6,357 tonnes annually. For outdoor target shooting with lead airgun pellets the HSE stated that it had no data.

The HSE referenced six reports of lead poisoning of birds through direct consumption of ammunition in the UK that were caused by either lead shot or airgun pellets, and having reviewed these reports it is almost certain that this was lead shot. However, on the basis of this scant evidence the HSE has recommended a ban on the use of lead airgun pellets within five years, lumped in with small calibre rifles.

The justification given for a ban on live quarry shooting with lead airgun pellets is to eliminate the risk of secondary poisoning of birds caused where prey or carrion containing lead is eaten, and to eliminate risk to humans via consumption of game meat containing lead.

Looking at the data presented by the HSE it’s clear that the evidenced risks of secondary poisoning of birds from lead airgun pellets is nil or negligible. As regards risks to humans, this is also nil or negligible as the nature of use and construction of lead airgun pellets is that lead is highly unlikely to fragment in live quarry, and pellets would be detected and removed when preparing shot game for consumption.

Dr Conor O’Gorman

So what about firing lead airgun pellets in your garden?

Well, if the proposals went through you could only do so if you had your garden formally licensed as an approved range and could comply with the environmental safeguarding measures proposed by the HSE. Alternatively, you could perhaps dig a tunnel and turn your plinking spot into a makeshift indoor range because indoor shooting is exempt from a ban, which just underlines how ridiculous the proposals are.

Let’s face it, securing an HSE licence to plink in your garden, or shooting in a makeshift tunnel is not viable and the only place you could legally fire lead airgun pellets in the event of a ban would be at licensed ranges with prescribed environmental protection measures in place. This would mean an uncertain future for Field Target and Hunter Field Target disciplines.

The justification given for such restrictions is because of the risk of airgun pellets contaminating the soil and the lead-contaminated soil or vegetation being eaten by livestock. However, no evidence has been given to back this up.

Whilst there are a range of non-lead pellets available, many of which have been reviewed in this magazine, there are many known and unknown limitations to their use relative to lead pellets, including performance in the 25-50m zone (and beyond) for target shooting and generally for live quarry shooting.

It is also highly unlikely that manufacturers can invent non-lead pellets that cover all scenarios fulfilled by lead pellets. Consideration has to be given to performance with spring-powered air rifles, pre-charged pneumatic and C02-powered rifles, and the 12 ft-lb muzzle energy limit for non-FAC air rifles.

As regards the economic impact of a ban, no financial estimates are given by the HSE for a lead pellet ban and it was not known if the proposals were proportionate or cost-effective.

The lead ammunition review will culminate in recommendations being submitted no later than April 2023 to the Secretary of State for Environment, Food and Rural Affairs for consideration. A legislative proposal will be likely thereafter, subject to parliamentary scrutiny and consultation with devolved administrations.

BASC has been approved as an accredited stakeholder by the HSE and we will ensure that the proposals are robustly scrutinised and that any future restrictions are based on evidence and proportionate to identified risks. We will not accept disproportionate restrictions that unfairly disadvantage airgunners or participants in any other shooting disciplines.

Please respond to the consultation. The online survey consultation response form is open to complete before 6 November and you do not need to answer all the questions.

Many people are simply answering the “general comments” question on the second page of the survey form. If you or your club have any evidence or studies on the use and performance of non-lead ammunition, and especially for airgun pellets, please submit it in your response. Visit the BASC website at basc.org.uk/ammunition for more information.

I would like to thank Airgun Shooter contributor Phil Hooper for getting in touch and offering his advice on the proposals and commenting on this article. If you have any queries on the restriction proposals or BASC’s position, please email me at conor.ogorman@basc.org.uk