On Friday 6 May the Health and Safety Executive (HSE), as part of the UK REACH process, has published its dossier or ‘report’ with recommendations on restricting the use of all lead ammunition over all types of landscape in England, Scotland and Wales.
WWT is glad to see the publication of this report. Although we need more time to fully digest the 230 page document we are happy to see the clear appraisal of the problems caused by lead ammunition and the recommendation to ban its use in most circumstances.
We particularly welcome that the report recognises that for all the uses of lead included in this dossier, the HSE concludes that the use of lead shot and bullets pose a risk to the environment and/or human health that is not currently adequately controlled and needs to be addressed at a GB level.
As such the report’s recommendations include
We support these recommendations.
We note that different transition periods are recommended away from lead shot, with a 5-year period if derogations for competitive sports shooting are approved. We believe that a shorter transition period is both desirable and achievable.
WWT submitted extensive scientific research about the problems caused by lead ammunition and the solutions to the poisoning it causes to wildlife and people to UK REACH as part as of the technical evidence gathering process to draft the report.
We will prepare a comprehensive assessment of the published report with comment on our website shortly and will be submitting our full response within the 6 month public consultation period. Our researchers are very familiar with the extensive scientific literature around lead ammunition and will want to ensure the report and the recommendations it makes is as robust as possible.
Our research includes findings that between 50,000 to 100,000 wildfowl die in the UK each year due to ingesting lead. A further 200,000 to 400,000 birds suffer welfare or health impacts, and animals that predate wildfowl can also suffer.
This formal risk assessment and management process under UK REACH is the greatest opportunity yet to ensure legislation to fully regulate the use of lead ammunition. We shall remain fully engaged with this process to ensure we make lead poisoning from ammunition a problem of the past.
Following Brexit, the UK has set up its own version of the EU regulation of chemicals, UK REACH.
In March 2021, Environment Minister Rebecca Pow announced that one of the first chemicals to be assessed under the new process would be lead in ammunition. The announcement recognised the important work undertaken by WWT in investigating the risks from lead ammunition.
Environment Minister Rebecca Pow said at the time:
Addressing the impacts of lead ammunition will mark a significant step forward in helping to protect wildlife, people, and the environment.
This is a welcome development for our new chemicals framework, and will help ensure a sustainable relationship between shooting and conservation.
Dr Julia Newth, Ecosystem Health & Social Dimensions Manager at the Wildfowl and Wetlands Trust (WWT), said:
Conservationists, including WWT, shooting organisations and game meat retailers have recognised the toxic risks from lead ammunition to people and the environment. Regulation of its use in all shooting, wherever this may happen, is very much needed as soon as possible to protect human and animal health and to enable us to move towards a greener and safer future.
Following a call for evidence last autumn, the HSE has now published this dossier which will be open to scrutiny during a 6 month public consultation by anyone with an interest in lead ammunition.
Like us, the shooting organisations want to see an end to many of the risks caused by lead shot though they want a voluntary approach. Unfortunately, this approach has not worked so far and we know from our research that even partial regulation doesn’t work. Full regulation of all lead ammunition, whether for hunting or sports shooting, is needed to protect wildlife, livestock, soils as well as human health.
WWT will be involved and following the process closely and would encourage anyone with information which could improve the dossier and fill the gaps identified to submit that to the
HSE before the 6 November deadline.
To submit a response to the dossier click here. Please follow us on social media @wwtworldwide for updates.