Last week the Scottish Gamekeepers Association (SGA) responded to the REACH consultation on banning lead shot ammunition in the UK.
You can read the organisation's response in full, below.
We confine comments to the following.
There is a need for robust UK data and more testing on environmental impacts of alternatives to lead shot and their toxicity. Current data is inadequate. A risk exists that, by banning lead, we introduce other environmental hazards.
There is some evidence (referred to by REACH) of high leaching of copper into water which poses a risk to aquatic organisms. Copper ammunition is now widely used on land owned by Forest and Land Scotland (FLS) and testing of water courses could be independently conducted.
Similarly, little testing has been carried out on Tungsten toxicity, internationally and domestically, perhaps because it is used in military small arms.
Steel production (steel ammunition being viewed as a viable alternative) is energy intensive and environmentally polluting. Despite the ability to recycle steel, IEA stated in 2010 that steel production accounts for 6.5% of global carbon emissions.
Steel production leads to air emissions, wastewater contaminants and hazardous and solid wastes.
When corroding in the environment, steel changes physical and mechanical properties of soils and sediments, increasing surface run-off.
A 2021 Norwegian study in ‘Toxicology in Vitro’ assessed lung damage potential through exposure to gun fumes. The worst impacts were found to come from steel ammunition, of a magnitude greater than lead, with the ability to change DNA.
In assessing risk, these are also risks which need to be balanced. This will require detailed UK research, encompassing all proposed alternatives to lead.
There is a need for robust UK data on impacts to animal welfare of lead alternatives. Considerable differences of opinion exist within the professional wildlife management community on the relative merits of alternatives, particularly the ability of alternatives to shed weight which leads to humane, fast kills of the animal being controlled. A considerable percentage of our membership are professional wildlife managers. They don’t want to see animals dying lingering deaths, when avoidable.
Any ban on lead should be preceded by detailed, verifiable in-field testing by governments which should include wildlife managers. Much of the international data comes from modelling and cannot replicate local conditions.
Members have reported to us that copper bullets will not expand as much as lead. It is more likely than with lead that a copper bullet will pass through the animal, which would then require a second shot. In forestry, this is not always possible.
The animal may run on and will potentially not be found, increasing welfare concerns. Inappropriate phase-out timescales, if this remains a REACH priority, could mean wildlife managers having to shift quickly to alternatives they are not accustomed to. Members have reported to us that propensity for ricochet is generally greater in copper and steel than in lead. In Scotland, there are now high numbers of roe deer around urban and peri-urban areas. We do not want public safety concerns from shot ricochet or bullets passing through animals and rebounding unpredictably. Members have also reported unpredictability in ballistic flight behaviour with copper, compared to lead, and restricted range when using steel.
For these reasons, we recommend appropriate in-field testing, in all wildlife management conditions, before moves to ban lead.
Regardless of merits or otherwise, there is need to redraw the economic cost/benefit analysis for a lead ban. The world has changed since the consultation, which relies on re-modelled ECHA data for the UK, was published in May.
War in Ukraine, quite rightly, must have precedence on ammunition supply. Shortages of copper bullets, already up to 4 times more expensive than lead, are being reported in Scotland, with FLS supply being prioritised. Brexit had already increased ammunition supply issues in the UK and global shortages of some alternatives such as steel are being reported.
A cohort of cartridge makers described the voluntary phase-out timescale, espoused by some shooting organisations, as ‘impossible’. Covid-19, the rising cost of production, war and instability in global supply will not have made these timescales any easier to meet. Any changes proposed must have recourse to them and the considerable challenges they face, even to remain competitive today.
Higher energy costs and record inflation must be factored into the next stage of REACH’s work on economics, if it is to reflect the present impact on shooting of any proposed lead ban.
High costs of gun replacement to incorporate steel shot is well referenced. Justification for this consultation to use re-modelled ECHA data to represent UK costs because the UK data from BSSC seemed ‘too high’ is suspect at best.
REACH itself states that suitability of the options it presents is dependent upon availability, performance and price. All of these aspects are now much changed and subject to greater flux.
Assumptions were made that hunters would use the same amount of ammunition, despite the increased cost and that people will buy new guns. Is this realistic now, in a cost-of-living crisis and with Business Sentiment quarterly analysis in Scotland for November 2022 showing nearly half of Scottish firms planning to reduce operations in response to increased costs of production?
Whilst under consideration, we support the FSA’s suggestion game meat consumption be limited for vulnerable groups such as children and individuals during pregnancy. We feel this guidance is proportionate to the evidence of risk to human health in UK, given quantities consumed. We refer to Green and Pain (2015) which stated that availability of dietary lead would be lower than lead in the ‘general’ diet.
Potatoes, cereals, water, vegetables, salad and tea all contain lead.
In reversing their lead ban, we note that isotopic testing in Norway found that increasing lead toxicity in birds could not be linked to lead ammunition but was more likely caused by lead occurring due to latent industrial use.