Well, after an anxious wait, we finally received the two key reports to submit to the Government’s consultation on Lead in Ammunition.
Cranfield University’s School of Supply Chain Management and Blake International, specialist consultants, were asked to complete independent assessments on the time it would take our four major cartridge manufacturers to be able to switch their production to lead-free. As you will remember, the HSE has proposed an eighteen-month transition period after enactment – which is planned for next year.
As we have been reporting for some time, the impacts of the pandemic and the resulting global supply chain issues, together with the war in Ukraine, have meant that sourcing ammunition components is harder than ever. The double-based powders normally used in steel cartridges are the same as military propellants that are being diverted for the re-arming of NATO and beyond. Furthermore, I would never have known that the steel in cartridge heads used to come from the besieged Mariupol steel factory. Keeping up with the normal production of lead ammunition is currently a challenge too.
Both reports are clear. The 18-month transition period is unfeasible. The steel shot ammunition you have seen so far, has been loaded on traditional machines at slow rates – nothing that would facilitate full-scale production. For that we need machines, specially constructed to deal with the increased risk of loading steel. The order books for these rather niche machines are full and delivery can take years. Our companies are already investing and working towards increased production.
So – how long? Well, Cranfield University, a world-renowned source of expertise in business management say at least 4 ½ years. Dr Peter Hurley of Blake International, who has extensive experience in ammunition matters, reports potentially 6+ years.
The ball is now in the HSE court. We have made the clear point that they should always have been engaging with the industry to collect facts – not deal in speculation. The imposition of an unwarranted 18-month transition would affect us all. Nationally, we consume 260 million cartridges a year for both game and clay. The industry is working flat out but they won’t be able to provide what we need – and not for years. Actually, business survival is at risk.
We won’t be sleeping. The message now needs to get to politicians and we need to hold Therese Coffey to account. It’s her signature, as Secretary of State for DEFRA, that goes on the restriction. We cannot allow our world-leading manufacturers to suffer from the ignorance of officials.
I attend a series of meetings with the government on your behalf and I am picking up snippets about the replacement for the National Firearms Licensing Management System (NFLMS), that the police use to manage guns and certificate holders. It certainly needs it. The topic of concern is the Home Office seem to be planning to extend the system to RFDs to cover registers. This won’t happen quickly and will need changes to legislation but establishing a national firearms database that includes RFD holdings is a dramatic change to the way we currently work. It has a number of implications that require debate. A couple of years ago, when the replacement was suggested, I spoke to the IT project team and discussed various advantages and disadvantages of such a system.
Yes, it could simplify customer administration and the notification process but it would also facilitate more intrusive examination of stock levels by licensing departments, let alone disrupt the IT systems you might now be using. Your software solutions for your register may link to sales platforms, financial accounting etc. Those linkages are unlikely to be built into the new system.
I will be challenging the Home Office and Chief Constable Debra Tedds, the Chair of the Firearms and Explosives Licensing Working Group for more information at a meeting on 22 November. They appear to have ambitions that could radically affect our lives and have not yet properly included us in the process. I will make it clear that they have failed to consult and need to do so.
What I need now is your opinion. Some of you might delight in being provided with a free online register provided by the police. As the customer leaves the shop, the gun has already been transferred onto his certificate and tracking is automated. No longer would we have the problem of ‘lost’ guns that fall between the cracks. For others, this might feel like a step too far. The overzealous licensing officer might track your holdings on a daily basis and get excited about what he considers is ‘trading to a substantial extent’. If your register is integrated with other systems, that may be lost and you could find yourselves having to run parallel systems with massive additional administration. Benefits the police but an unnecessary toll on the life of the RFD.
Think about the idea now, talk about it and let me know what you think. I will get more details of their ambitions and keep you informed. With GTN, we will collect data from you with a survey of opinions. Our regulators may be keeping quiet on this because they’re frightened of our opinion.
No longer. This is now on the radar!