Have your say on banning lead ammunition

Whooper Swan Ben Andrew (rspb-images.com)

This special blog is written by Imogen Taylor, Senior Policy Officer to highlight the opportunity to have your say on the latest consultation on banning lead ammunition. 

We have been talking about the long-overdue need for a ban on the use of lead ammunition for many years, and the UK REACH consultation looking at restricting lead ammunition since the process started in 2021. We are now at the final public consultation stage and we are asking for help in achieving a ban by having your say on why we don’t want lead poison polluting our environment.

Why should lead ammunition be banned?

We have written blogs on this here, here, here or here, where you can get a bit more information on lead but the gist is that it is toxic and a poison that is very harmful to people and nature. It has been banned from most of the products we use that used to contain it like petrol and paint, but lead ammunition is still in use, and from ammunition, lead gets into the environment contaminating habitats and the animals that are shot which can go on to be consumed by people, pets and wildlife.

In the UK it is estimated that 75,000 waterbirds, plus predatory and scavenging birds such as White-tailed Eagles, Red Kites and Marsh Harriers die each year as a direct result of lead poisoning and many more are impacted by the other effects including reduced fertility and weakened immune systems.

This is not a call for an end to shooting. Non-lead ammunition alternatives are available and are already being used many shooters. It is a call to stop putting toxic lead into the environment and food-chain.

What can you do?

In this final stage of the UK REACH consultation, the Health and Safety Executive is asking the public for comments on the draft socioeconomic opinion they published along with the consultation. We need people to voice their concerns, and experiences with the use of lead ammunition. The consultation is open until 10 December 2023, and we will submitting our own response including general comments on lead ammunition and the economics around restrictions.

The opinion document is thorough and detailed, but we believe some of the conclusions have led to proposals that are not strong enough. The proposed restrictions are

Proposal 1: Lead shot would be banned for target shooting and live quarry shooting with a derogation for nominated sports shooters and a 5-year transition period.

What we think: We welcome a ban being proposed on lead shot, but think 5-years is too long a transition period and it should be shortened to 18-months.  This would align with a commitment by shooting organisations to the voluntarily phase out of lead ammunition by 2025. 

Proposal 2: Lead bullets for target shooting would be banned with a derogation for certain sites which would be required to demonstrate appropriate risk management measures such as clean up. Lead bullets for live quarry shooting have no restriction proposed.

What we think: We are really disappointed that no restriction is proposed for live quarry shooting with lead bullets since there are risks to people and wildlife. The value this ban would have for secondary poisoning of birds of prey has not been recognised.

Proposal 3: Lead airgun pellets – no restriction proposed

What we think: There is more limited information relating to airgun pellets, but we are concerned that no restriction is proposed, as airgun pellets are another source of lead in our environment and alternatives are available.

 How to respond

To submit a response to the consultation, visit the website here by 10 December 2023 and at the bottom of the page is a link to the online survey.

Please feel free to answer the questions they have provided depending on your experience with lead ammunition, but if you just want to submit general comments, the last section provides a space for this.

The first page will ask for your details and then clicking continue will take you to the questions.

 There is no expectation to answer all or any of the specific questions they ask, but two questions you may want to respond to are:

• The first question on transition periods – we believe the proposed 5-year transition period for lead shot is too long and this should be shortened to 18-months align with a commitment by shooting organisations to the voluntarily phase out of lead ammunition by 2025.
• The third question on the monetised benefits around secondary poisoning of raptors from lead bullets, you may want to select “yes” and include in your comments that that there is value in birds of prey not being poisoned by lead.

 If you continue through, you will come to a page for general comments.

• Here you can include your views on the continued use of lead ammunition and why it should be banned and comment of the proposed restrictions.
• If you have experience with lead ammunition, or positive experiences of lead alternatives that would be great to include. Our blogs linked above have further background information on lead, or visit the WWT page which provides a great summary.
• Some suggested points you may want to mention about the proposals include:
• Lead shot - We welcome a ban being proposed on lead shot, but think 5-years is too long a transition period and it should be shortened to 18-months align with a commitment by shooting organisations to the voluntarily phase out of lead ammunition by 2025. We would also want further clarification on the process for identifying athletes eligible for the derogation and what measures will stop lead shot getting into the environment this way.
• Lead bullets - We are really disappointed to see that no restriction is proposed for live quarry shooting with lead bullets since there are risks to people and wildlife. The value this ban would have for secondary poisoning of birds of prey has not been recognised. We would also like clarity around what would be required for sites to be eligible for the derogation for target shooting with lead bullets.

Airgun pellets - We are concerned that there is no restriction proposal for lead airgun pellets when it is still a pathway for lead getting into the environment

•  We recommend personalising your response as it can help to strengthen it.
•  Then you can continue through to submit your response.

 This is our chance to get a comprehensive ban on lead ammunition and we need to make our voices heard and stop the toll this poison is taking on our wildlife! Thank you for taking action.