Just found this on another site!
The relevant bits....
The continued wide availability of airgun ammunition for indoor use (the large
majority of total use) would highly likely undermine any practical enforcement of the
placing on the market of airgun ammunition for outdoor use.
Alternatives to ammunition for airguns also provide unique challenges because of
the regulations governing airgun ownership. It is possible that the use of one viable
non-lead alternative in one airgun would work well, whereas its use in a different
airgun would result in exceedance of the legislative muzzle energy threshold - which
would then mean a Firearms Certificate would be required. Such effects could result
in widespread, unintended criminal offences being committed.
For these reasons, including significant practical difficulties in the ability to monitor or
enforce such a restriction, the Agency does not consider any restriction options to be
monitorable or enforceable.
Target shooting with lead airgun ammunition
The only option that could reduce risks to the environment would be a prohibition on
the use of lead airgun ammunition for target shooting. However, there are no viable
alternatives for many airguns and ammunition would still be available for sale for
indoor use. Therefore, a prohibition on use would not be practical, monitorable, or
enforceable.
The Agency was therefore unable to identify a risk management option to be taken
forward to the SEA for this use.
4.2.2 Rationale for modifying restriction options
A long-list of potential options was listed and included for consideration during
development of the Annex 15 dossier resulting in the initial restriction proposal (HSE,
2022). Based on information supplied to us during the public consultation and
comments received from the REACH Independent Scientific Expert Pool (RISEP), a
shortlist of options was developed by selecting only those that the Agency
considered were the most feasible and impactful. The options included in the short
list are only those that have the potential to eliminate or reduce the risks identified for
both the environment and human health (where relevant) for each use. Fiscal
measures which were identified as options in HSE (2022) but not fully assessed at
that time were included in the short list. An analysis of each of the options on the
short list was undertaken for each use and is described in the Background
Document, underpinned by information on uses, releases and availability of
alternatives.
Since the publication of the Annex 15 dossier, receipt of information from the first
public consultation, scrutiny by RISEP, and further stakeholder engagement, some
of the options previously proposed have been modified.
Lead shot for target shooting
The option that would provide a fully effective removal of risks is a complete
prohibition on the placing on the market and use of lead shot for target shooting. This
was not considered practical as it would prevent a small number of athletes who
perform at the highest level from training and competing with the lead shot that is
required by the rules of the sport. In the Annex 15 dossier the Agency had included a
proposal to derogate licensed sites for target shooting with lead shot where risk
management was in place, in addition to licensing the placing on the market of lead
shot and use by athletes.
In meeting with the relevant bodies that oversee outdoor target shooting and
competitive shotgun shooting in GB, the Agency established that:
- approximately 50 shooters at any time may be required to continue shooting
lead
- the total amount of lead used by these athletes annually is approximately 37
tonnes (0.6% of the amount of lead used for target shooting with lead shot)
- the locations used to shoot are spread across GB, depending on the needs of
the individual athlete
- risk management measures suitable for capturing and collecting spent lead
shot are not feasible at the vast majority of shooting sites, often because of
the types of land over which shooting occurs.
It also became clear that a licensing scheme for sites and athletes was not required,
and something much simpler could be established, relying on the vastly decreased
use only by identified athletes, dispersed over a variety of sites, and the clear
identification and management of athletes by competitive shooting governing bodies.
The proposal to license the sites has therefore been removed from the proposed
restriction option for use of lead shot in outdoor target shooting as it is not
considered practical. However, the proposed restriction still includes the sport’s
governing bodies specifying only certain athletes that are required to continue to
shoot lead shot, to reduce the tonnages used and therefore the risk.
Lead in airgun ammunition
In the Annex 15 dossier, the use of airgun ammunition in live quarry shooting was
incorporated within the use of small calibre bullets. Although identified as a separate
use, the Agency did not have sufficient information to assess the options for use of
airgun ammunition for target shooting. Instead, the options considered for target
shooting with small calibre bullets were also considered to be appropriate for this
use. In the Background Document the options to mitigate against risks from uses of
lead airgun ammunition are now considered separately.
Lead airgun ammunition is used for live quarry and indoor and outdoor target
shooting. A prohibition on the placing on the market of lead airgun ammunition per
se cannot be considered as this would prevent sales for the indoor uses that are
formally out of scope for consideration of a restriction. The only options therefore
need to be focussed on the use, not the supply, of this ammunition. The Agency
considers that any prohibition on the use of lead airgun ammunition in outdoor
settings will be both unmonitorable and unenforceable, as the use takes place not
only in formal shooting settings, such as ranges or field target sites, but also on
private land, such as farmland and back gardens.
4.2.5 Further information about the proposed restriction
The Agency is not proposing to include additional labelling requirements for lead
ammunition or to make the provision of information about the restriction compulsory
at the point of sale. The Agency considers that other methods to promote the phaseout of lead ammunition and the use of alternatives would be more effective. This
58
could include, for example, direct engagement with shooting organisations, suppliers
and users.
The relevant bits....
The continued wide availability of airgun ammunition for indoor use (the large
majority of total use) would highly likely undermine any practical enforcement of the
placing on the market of airgun ammunition for outdoor use.
Alternatives to ammunition for airguns also provide unique challenges because of
the regulations governing airgun ownership. It is possible that the use of one viable
non-lead alternative in one airgun would work well, whereas its use in a different
airgun would result in exceedance of the legislative muzzle energy threshold - which
would then mean a Firearms Certificate would be required. Such effects could result
in widespread, unintended criminal offences being committed.
For these reasons, including significant practical difficulties in the ability to monitor or
enforce such a restriction, the Agency does not consider any restriction options to be
monitorable or enforceable.
Target shooting with lead airgun ammunition
The only option that could reduce risks to the environment would be a prohibition on
the use of lead airgun ammunition for target shooting. However, there are no viable
alternatives for many airguns and ammunition would still be available for sale for
indoor use. Therefore, a prohibition on use would not be practical, monitorable, or
enforceable.
The Agency was therefore unable to identify a risk management option to be taken
forward to the SEA for this use.
4.2.2 Rationale for modifying restriction options
A long-list of potential options was listed and included for consideration during
development of the Annex 15 dossier resulting in the initial restriction proposal (HSE,
2022). Based on information supplied to us during the public consultation and
comments received from the REACH Independent Scientific Expert Pool (RISEP), a
shortlist of options was developed by selecting only those that the Agency
considered were the most feasible and impactful. The options included in the short
list are only those that have the potential to eliminate or reduce the risks identified for
both the environment and human health (where relevant) for each use. Fiscal
measures which were identified as options in HSE (2022) but not fully assessed at
that time were included in the short list. An analysis of each of the options on the
short list was undertaken for each use and is described in the Background
Document, underpinned by information on uses, releases and availability of
alternatives.
Since the publication of the Annex 15 dossier, receipt of information from the first
public consultation, scrutiny by RISEP, and further stakeholder engagement, some
of the options previously proposed have been modified.
Lead shot for target shooting
The option that would provide a fully effective removal of risks is a complete
prohibition on the placing on the market and use of lead shot for target shooting. This
was not considered practical as it would prevent a small number of athletes who
perform at the highest level from training and competing with the lead shot that is
required by the rules of the sport. In the Annex 15 dossier the Agency had included a
proposal to derogate licensed sites for target shooting with lead shot where risk
management was in place, in addition to licensing the placing on the market of lead
shot and use by athletes.
In meeting with the relevant bodies that oversee outdoor target shooting and
competitive shotgun shooting in GB, the Agency established that:
- approximately 50 shooters at any time may be required to continue shooting
lead
- the total amount of lead used by these athletes annually is approximately 37
tonnes (0.6% of the amount of lead used for target shooting with lead shot)
- the locations used to shoot are spread across GB, depending on the needs of
the individual athlete
- risk management measures suitable for capturing and collecting spent lead
shot are not feasible at the vast majority of shooting sites, often because of
the types of land over which shooting occurs.
It also became clear that a licensing scheme for sites and athletes was not required,
and something much simpler could be established, relying on the vastly decreased
use only by identified athletes, dispersed over a variety of sites, and the clear
identification and management of athletes by competitive shooting governing bodies.
The proposal to license the sites has therefore been removed from the proposed
restriction option for use of lead shot in outdoor target shooting as it is not
considered practical. However, the proposed restriction still includes the sport’s
governing bodies specifying only certain athletes that are required to continue to
shoot lead shot, to reduce the tonnages used and therefore the risk.
Lead in airgun ammunition
In the Annex 15 dossier, the use of airgun ammunition in live quarry shooting was
incorporated within the use of small calibre bullets. Although identified as a separate
use, the Agency did not have sufficient information to assess the options for use of
airgun ammunition for target shooting. Instead, the options considered for target
shooting with small calibre bullets were also considered to be appropriate for this
use. In the Background Document the options to mitigate against risks from uses of
lead airgun ammunition are now considered separately.
Lead airgun ammunition is used for live quarry and indoor and outdoor target
shooting. A prohibition on the placing on the market of lead airgun ammunition per
se cannot be considered as this would prevent sales for the indoor uses that are
formally out of scope for consideration of a restriction. The only options therefore
need to be focussed on the use, not the supply, of this ammunition. The Agency
considers that any prohibition on the use of lead airgun ammunition in outdoor
settings will be both unmonitorable and unenforceable, as the use takes place not
only in formal shooting settings, such as ranges or field target sites, but also on
private land, such as farmland and back gardens.
4.2.5 Further information about the proposed restriction
The Agency is not proposing to include additional labelling requirements for lead
ammunition or to make the provision of information about the restriction compulsory
at the point of sale. The Agency considers that other methods to promote the phaseout of lead ammunition and the use of alternatives would be more effective. This
58
could include, for example, direct engagement with shooting organisations, suppliers
and users.
