Proposals to Ban Lead in Ammunition - HSE Report

So interesting post on NRA website.

HSE has published their report Lead in Ammunition proposing restrictions on the:

  1. use of lead bullets for outdoor target shooting, with a derogation for shooting at licensed ranges with appropriate environmental protection measures;
  2. use of lead bullets for hunting; and
  3. sale and use of lead shot, with a derogation for authorised athletes on licensed ranges.

and launched a 6-month public consultation.

Appreciate that it talks about outdoor ranges but what would the implications for cadets target shooting be and what would the alternatives be.

Within the cadet forces, no alternative (presumably) until available through stores?

More generally, within shotgun shooting it’s steel shot that replacing lead. I assume the same is true for rifles?

It is an interesting thought though. I wonder how much lead contamination there is across DTE ranges due to lead bullets?

Ah. Well now let’s ban all shooting.

Despite fisherman countrywide lobbing huge amounts of lead into the rivers and sea everyday.

Despite my compostable tea bag being sent from China by diesel ocean liner in a handy plastic pouch.

Unpopular opinion alert. It’ll make no difference to anything!


The main document with the proposals is here

HSE propose lead in ammunition

People can respond to the consultation here.

HSE consultation send response

Reading the document it seams that the main concern is livestock eating the lead.

Is there any part of the regularly military still using .22rf? Otherwise I can see it being phased out completely.

Flashbacks to CSI season 2, episode 15: burden of proof.

Ice bullets. It’s the way forwards. Ish.

Editted to add… Mythbusters episode 1: Ice bullets - myth.


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Has the ex-OC 2FTS got a new job at the HSE perchance?


Most military ranges are de-leaded on a regular basis, every 100,000 rounds or so per lane.

Field firing ranges may be a problem but the collection of lead in particular places is usually managed with backwash and cleaning like a normal range.

For target rifle shooting the bigger impact will be where the RAFAC use civillian ranges and they bring in a no lead rule or similar.

Clay target has been anti lead and anti plastic wadding for some time and will continue in that direction I suspect.

Be interesting to see what it does for things like air rifle pellets and whether they become more or less expensive.

I’d say that military ranges, with the existing measures, would be eligible for such derogation.
I can’t see it affecting us in that regard.

Though, a move away from lead would be good and probably cheaper in the long run too… How much money must be spent on managing lead on ranges? But it’s bound to take time.

I can see more use of simunition - not in itself a bad thing.

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Fishing weights haven’t been made of lead for years, apart from the biggest weights that wildlife don’t eat.

Simulation is great and all but still not 100% real, as if I trained non stop on a computer sim and then tried to do it in real life, I reckon I wouldn’t be as good as I was in the sim

Simunition is different from simulation:


That makes sense, I read it wrong, but I read it and it’s great

It’s disappointing how little interest this topic has generated and how few have actually read the consultation in any detail whatsoever. I accept that it’s daunting at 226pp and not in a particularly digestible format but it is important and anyone with an interest in shooting should make the effort to try and properly comprehend its contents and the potential outcomes.

The first item of importance is pp13, para 1, last 3 lines:

Military, police and non-civilian uses
are excluded from the scope of this request, as are indoor uses (such as at indoor
firing ranges) and lead-containing propellants

Whether cadet force shooting falls under this exemption (not derogation) is open to discussion and might require justification.

The unreality of the proposals starts to become apparent on pp21:

The Agency is aware that the use of lead shot is required for national and
international competitions in some outdoor sports shooting disciplines. Therefore, an
optional derogation could be considered, involving a licensing system to allow the
relevant athletes to continue training, and suppliers to continue sales to these
authorised athletes. This derogation would also include a licensing system for the
shooting ranges where this training takes place to ensure that lead collection
systems are in place to minimise the risks to the environment from this activity. This
optional derogation requires further consideration to ensure it is practical and
proportionate, noting that it would not be fully effective at removing all the
environmental risks identified.

A complete bureacratic nightmare, plainly dreamt up by someone with no knowledge of shooting sports.

The unreality of continues with the table on pp25-26. This predicts a total reduction in lead release over 20 years of 110,000 tons by banning the use of lead shot and lead bullets for hunting. Tucked away at the bottom of the table is the statement that extending a similar ban to target shooting may only result in a reduction of as little as 390 tons over 20 years. Given that this lead would be fired in a highly controlled situation where the majority of the lead would be recovered one has to question whether additional regulation is justified?

Bear in mind when considering the above figures, they do not include any data on non-civilian use.

I could go on almost indefinitely; pp59 data for Ocular Lesions in Bald Eagles, haven’t seen any of those round here lately; pp65 data relating to death of cattle near a shooting range in Calcutta, India, I’m sure their environmental standards exceed those in the UK. I hope that you get the picture, this apparently comprehensive paper is as full of dodgy data as the Iraq Intelligence Report.

I would urge everyone to make the effort to read the proposal and try to understand why it should be challenged.

Having done that you can then respond to the consultation with some knowledge to support your submission.


I think I’m on board with this, really, however impractical it is.

Maybe if you’re old enough to remember the days when cars were just pumping it into the air lead pollution doesn’t bother you as much, but it’s really nasty stuff and firing it directly into the environment is probably to be avoided.

To be honest, my perspective thus far is:

‘Proposal to reduce the use of lead’ - In principal, that’s a good thing. There would have to be something pretty horrific in their proposal for me to want to challenge it. I’m not sure I have the time nor the interest to trawl through the whole thing, perhaps only to find that the outcome is ‘might be bad for hunting’.

All I’m getting so far is that you’re not convinced by the figures. Since you are obviously keen to garner support against the proposal, perhaps you could offer a précis of the potential damage?

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Very early days - the UK NRA will be preparing a response in due course (that can be used a a basis for individuals / other organisations), probably will take a month or 2.

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The NSRA realised the threat this posed to target shooting and published a paper in September 2021.. It is only since then that the NRA have realised that exemption or derogation is by no means a “done deal” and that they’re going to have to argue a case.

The underlying issue is that even if a derogation is granted it might be accompanied with so many regulations and restraints as to make it unworkable in practical terms.

i have no interest in “hunting” but a significant number of people are very opposed to it. They have no interest in the collateral damage they may inflict in their campaign to achieve their aims.


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