Lead in Ammunition: Industry’s Struggle and Government’s Transition Period

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.

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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!

HSE’s Extended Consideration Period for Lead Ammunition: Understanding the Impact

Following the 2,700 responses to the consultation on restrictions on lead in ammunition, the HSE justifiably added six months to their consideration period to assess the huge amount of data they received.  The timeline will now see them make their recommendation to Ministers towards the end of the year.  The restriction proposals cover everything from lead shot to air pellets and, as we in the industry know, the technical, performance and suitability of lead and alternatives is a hugely complex area.   I am reassured that the HSE and Environment Agency teams are studying the evidence in detail.  They have asked supplementary questions to shooting organisations and have started visits to ranges and shooting grounds to understand the factors.  The GTA is conducting further trials to provide more detail on the performance characteristics of lead alternatives in a number of small rifle calibres.

On shotgun ammunition, we will continue to fight for longer transition periods.  The 18 months originally proposed is completely unworkable.  Even with our manufacturers embracing change, the long lead times for sourcing machines that are optimised for loading steel cartridges and the worldwide shortage of components will require years, not months.  The two academic studies we submitted to the consultation indicate about five years is required to be able to provide consumers with the quantities of alternatives required.  Any less than that and shooting will be forced to stop through shortages of ammunition.  Indeed, the situation could be worse in that, without products to sell, our UK manufacturing sector could collapse.

There is a sad irony in the current proposed restriction timeline.  Nowhere else in the world are a group of companies investing so much in developing effective, lead-free shotgun ammunition with the entirely voluntary additional benefit of bio-degradable wads.  The game shooting community in the UK have long demanded ammunition that does not litter the countryside with polypropylene wads.  The technical challenge of providing cup wads that protect barrels from steel shot and then bio-degrade in the field is no easy battle, but our manufacturers are well on the way to success.  Let us hope that the HSE and EA recognise the achievements being made and allow our cartridge loaders in the UK time to be able to meet the needs of all.  On behalf of the manufacturers, importers, retailers and shooters themselves, the GTA will continue to push for reasonable and proportionate transition times.

This last weekend has seen the delivery of another great Stalking Show in Staffordshire.  From humble beginnings, this show has rapidly grown to attract stalkers and the trade alike.  Our congratulations and thanks to David Freer and the team.  Central to the show’s success appears to be the delivery of educational and inspirational content and not just a retail opportunity.  Jose Souto and Rachel Green will always pull in the crowds; experts like Frederic Hannah and the deer trackers will extend knowledge and introduce new skills; Charlie Jacoby will reassure and stiffen the sinews and the national treasure that is the Ole Hedge Creeper will reveal another set of magical sounds to lure in the wildlife.

Keep up the great work.

As the weather warms, there are plenty more shows on the horizon.  The national events are key to keep drawing in newcomers to our sports but so too are the regional and local events where shooting is less well represented.  If you can find opportunities to support shooting at these shows, please engage.  Retail is of course an opportunity but so is helping out our organisations and clubs that might be encouraged to recruit youngsters or represent the value shooting has to offer.

I don’t need to remind you that shooting is under attack.  Discussion of Plymouth and other high-profile tragic events has now reached the political phase.  We have seen the police and coroner’s reports and we are now in conversations at a national level on what might be reasonable and proportionate in our shared interests of maintaining public safety.  I know where attention is needed and it’s across the licensing system – not a knee-jerk change in legislation.  All too quickly there were police call for changes in controls on shotguns.  We all know there were plenty of opportunities to restrict Jake Davison from his murderous campaign through existing controls.

I would expect a Government consultation on these matters later in the year; I hope to know more shortly.  We must be ready to ensure attention is paid to the areas of greatest concern.  And at the same time, we must be ready to celebrate shooting and all it represents.  Shooting provides us with our jobs, businesses, and pastimes.  It provides us with a meaningful connection with the countryside.  We don’t need to convert everyone to shooting but we do need to tell our story and spread knowledge and understanding of what we do and live for.

Our partners at Medcert have advised us to put out a reminder for everyone using third party medical checks to thoroughly check their medical proformas before passing them onto the police.

Medcert have been informed of a situation where a diagnosis was given by a third party medical professional (not associated with Medcert) based purely on the client’s notes and history and not on a face to face meeting, resulting in a contradiction of what the client’s own doctor had ruled. This culminated in a lengthy issue between the client, the licensing department, and the medical professional in question, all of which was entirely unnecessary.

With that in mind, if you need to have a medical check and you are planning to use a third party organisation, first of all, we encourage you to use Medcert as they are Official GTA Partners, but also make sure to double, triple, and quadruple check you medical proforma for any inaccuracies before sending it off to your FEO.

Action required before 22 September 2021

Did you know that the law on antique firearms has changed? Some firearms that could previously be possessed without a firearm certificate as an antique are now subject to licensing. Owners of such firearms have until 22 September 2021 to apply to the police for a firearms certificate if they wish to keep them. Alternatively, they can surrender, sell or otherwise dispose of their firearm before 22 September 2021.Further information about the antique firearms affected by the Antique Firearms Regulations 2021, and the options for owners, can be found on gov.uk.