Respond to the HSE Lead Consultation

HSE LEAD CONSULTATION UKPSA GUIDE

RESPOND BEFORE 10TH DEC DEADLINE

Following the launch of the HSE’s UK REACH – Public Consultation on Lead in Ammunition on the 10th October 2023. The UKPSA has submitted a formal response highlighting the disproportionate harm that such a prohibition would create.

See the UKPSA’s response here – HSE Lead Consultation Response

In order to add further weight to the UKPSA’s submission, it is important that we ask all our members and the wider dynamic shooting community to respond the the HSE’s consultation, particularly as it is during this phase of the process that the agency is obligated to consider the socioeconomic effects of implementing their proposals.

But the HSE Consultation is only asking question sabout live game, does it really affect IPSC or dynamic shooters?

UKPSA members and any person who enjoys target shooting should be responding to the HSE consultation as it is highly likely that any new regulatory changes will extend beyond live game shooting and will impact all forms of shooting, affecting ammunition availability, costs and shooting practices.

A large response from the IPSC and/or dynamic shooting population will encourage the HSE to consult directly with the UKPSA on appropriate derogations to ensure the continuation of our sport. A poor response will leave us excluded from any future discussions and at the mercy of other organisations who have no interest in IPSC and/or dynamic target shooting disciplines.

But it's complicated and boring!

We don’t disagree, we’d much rather be out shooting too!

However, it is really important we make our individual voices heard. We can’t simply copy and paste the same response or the HSE will be able to discount the responses as duplications.

To help you respond we’ve provided some guidance on how to complete the specific questions, and then some themes that you might like to consider for your own response to the final general comment section.

HSE CONSULTATION FORM

RESPONSE GUIDE

This guide will provide a step by step format to filling in the HSE form. We recommend having the form ready on another web page or device whilst following this guide.

You can find a link to the HSE form here: UK REACH – Public Consultation on Lead in Ammunition

Fill in as much as you want of the first section of the form; providing personal details and general information about how you found out about the consultation. Then click on the continue button at the end of the page for the following sections.

Transition Periods

The Agency is considering a 5-year transition period before the entry into force of the proposed restriction on target shooting with shotguns. Due to the voluntary agreement to transition away from lead ammunition for use in live quarry shooting by 2025, the Agency is considering a shorter (e.g., 3-year) transition period for this use.

Please provide information you have regarding the viability, difficulties and benefits of a shorter transition period for the use of lead ammunition in live quarry shooting with shotguns.

UKPSA Suggested Response Themes

The so-called ‘voluntary agreement’ – Did you volunteer to give up lead ammunition?

The lack of any technical or economically viable alternatives to lead ammunition on the market – Rushing the transition period clearly demonstrates the HSE’s lack of concern for shooting sports and the economic and social harm a lead ban will cause.

The continued public scepticism around government scientific advice and the actual harm that has been inflicted upon the UK’s economic and social well-being via hurried and poorly implemented policy based on flawed scientific models.

The need to increase transition periods and only enforce a prohibition once it can be proved beyond all reasonable doubt that shooting sports will not be negatively affected by any prohibition.

Humane Dispatch Derogation

Do you possess information regarding the need for a derogation on the use of lead ammunition for humane dispatch (i.e. in instances where animals/livestock require humane dispatch, which may occur for example: on‐farm; in transit; in markets, lairages or collection centres; or as a result of accidents on the public highway, at racecourses, shows or exhibitions)?

Yes or No

UKPSA Suggested Response Themes

The UKPSA is only concerned with IPSC and target shooting so cannot comment on this subject. You as an individual may be involved with human dispatch activities so please feel free to respond accordingly.

Monetised benefits associated with restricting lead bullets for live quarry shooting

Do you have information regarding the monetary benefits associated with reducing the risk of secondary poisoning of raptors from the use of lead bullets e.g., from WTP-based evaluations or similar?

Yes or No

UKPSA Suggested Response Themes

Use of different bullet types for live quarry shooting and target shooting

Please describe any instances in which you use non-expanding ammunition for live quarry shooting in the box below, including an indication of relevant calibre and quarry.

UKPSA Suggested Response Themes

Please describe any instances in which you use expanding ammunition for any shooting other than live quarry in the box below, including an indication of relevant calibre and location.

UKPSA Suggested Response Themes

IPSC target shooting is made up of several distinct disciplines requiring the use of different firearms and ammunition which can contain ammunition that has been assembled using expanding bullets.

Those IPSC disciplines are;

IPSC Handgun – .22lr, 9mm, .38, .357, 40 S&W, .45ACP/GAP
IPSC Mini-Rifle – .22lr
IPSC Rifle – .223/5.56, .308/7.62
IPSC Pistol Calibre Carbine – 9mm, .38, .357, 40 S&W, .45ACP/GAP

Rifles and zeroing

How often do you zero your rifle for live quarry shooting?

UKPSA Suggested Response Themes

Whilst IPSC is target shooting, the principles of marksmanship remain the same. Rifle shooting often involves taking a shot over long distances so it is of the utmost importance you know the zero of your firearm. As such, IPSC shooters would check their zero every time they use their rifle and it should be the same for any serious hunter, particularly considering the jeopardy involved should an out of zero rifle be used over open ground and/or at live quarry.

In what locations do you zero your rifle for live quarry shooting? Please choose all that apply.

UKPSA Suggested Response Themes

(UKPSA recommends highlighting indoor, outdoor and other including adding the note as highlighted, but please tick all that apply to you)

– At an indoor shooting range
– At an outdoor shooting range
– On my own property
– At the location of a live quarry shoot
– Other private land with the permission of the landowner
– Other (specify below)

If you chose other, please specify

Over any land or shooting range approved for IPSC competition and/or practice.

General comments

Please provide your general comments in the box below

UKPSA Suggested Response Themes

Your significant reservations about the scientific basis for the proposal to ban lead in ammunition.

Your doubts regarding the necessity and effectiveness of any ban of lead in ammunition.
The legitimacy of the so-called ‘voluntary agreement’ to phase out lead. Did you volunteer to give up lead?

The lack of consideration of the broader shooting community’s needs and concerns.

The illogical nature of a proposed civilian lead ban with exemptions for military and law enforcement. Do the birds know not to eat the lead the army leaves behind?
The likelihood a lead ban would make your shooting unaffordable.

The likelihood a lead ban would result in a reduction of your shooting activity leading to;

– a reduction of your physical activity.

– a reduction in your social interaction with friends & family members.

– a reduction in your mental well-being

The likelihood a lead ban would result in the closure of local businesses.

The likelihood a lead ban would result in the closure of your gun club.

The importance of club shooting, you can’t have elite shooters without a strong grassroots community.

The proliferation of lead within the built environment. Do the birds not sit upon your lead flashings?

Writing not your thing? We got you covered!

If writing isn’t your thing, why not try using AI to help!

Follow this link https://chat.openai.com/

Its free and you can use it a bit like Google!

Type in a prompt such as, “Write a paragraph expressing my objection to the HSE Lead Ban on the basis that it will negatively affect me by (then add in those items that you feel need addressing)…”

You can then copy & paste AI crafted responses into the HSE’s consultation.

Once again, thank you for supporting our awesome sport and putting in the effort to respond to the HSE Lead Consultation. Your individual response can and will add weight to this consultation to ensure we can fight for the best possible outcome for IPSC in Great Britain.

DVC