UK REACH - Public Consultation on Lead in Ammunition

Overview

On 29 April 2021, the Health and Safety Executive (HSE) as the Agency for UK REACH received a request under Article 69(1) of UK REACH from the Defra Secretary of State, with the agreement of the Scottish Government and the Welsh Government, to prepare an Annex 15 restriction dossier assessing the risks to the environment and human health from lead in ammunition (projectiles). The Annex 15 dossier prepared by HSE (working with the Environment Agency) was to examine if further risk management action is needed to control the use or placing on the market of lead in ammunition for shooting outdoors into Great Britain (GB; England, Scotland and Wales)

Article 69(6) of UK REACH requires HSE to publish proposals for restrictions on its website and undertake a 6-month consultation. This consultation took place between May and November 2022 with the Annex 15 dossier being published as part of this consultation. Due to the high response rate (2,759 responses) the restriction process was extended by 6-months in line with the provisions in Article 72(1).

Article 70 of UK REACH requires HSE to formulate an opinion on risk assessment, this has been published.

This opinion was developed after considering the responses from last year’s consultation and using advice from the REACH Independent Scientific Expert Pool (RISEP). HSE have identified risks from lead in ammunition, primarily to the environment, that are not adequately controlled at present. Measures have been proposed to address these risks by restricting certain (but not all) uses of ammunition containing lead. A derogation is proposed for a small number of specified athletes who compete internationally to enable them to train and compete.

The socioeconomic consultation

Article 71(1) of UK REACH requires HSE to publish the draft socioeconomic opinion on the restriction and invite interested parties to submit comments on the draft opinion no later than 60-days from the publication of that draft opinion. This consultation fulfils this requirement.

Please note that this consultation seeks information on socioeconomic factors that need to be taken into account. We are not seeking comments on aspects of the risk assessment (in particular sections 4.1 and 4.7.1). The draft Background Document, an updated version of the Annex 15 dossier previously consulted on, is also being made available for reference.

People wishing to submit information during this public consultation are encouraged to submit information as early as possible.

The following documents are attached to this consultation:

• The draft Agency Opinion
• The draft Background Document

UK REACH came into force at the end of the EU exit transition period (31^st December 2020) and regulates the access of chemicals to the GB market. Under the Northern Ireland Protocol, EU REACH continues to regulate the Northern Ireland market.

Please support your contribution with references and reliable data (facts and figures).

HSE’s Confidentiality and GDPR statements

HSE tries to make its public consultations as thorough and open as possible.

Information provided in response to this public consultation may be subject to publication or disclosure in accordance with the access to information regimes (these are primarily the Freedom of Information Act 2000 (FOIA), the General Data Protection Regulations (GDPR) and the Environmental Information Regulations 2004 (EIR)). Statutory Codes of Practice under the FOIA and EIR also deal with confidentiality obligations, among other things.

If you would like us to treat any of the information you provide as confidential, please make this clear in your response. If we receive a request under FOIA or EIR for the information you have provided, we will take full account of your explanation, but we cannot give an assurance that confidentiality can be maintained in all circumstances.

An automatic confidentiality disclaimer generated by your IT system will be disregarded for these purposes. Requests for confidentiality should be made explicit within the body of the response.

HSE will process all personal data in accordance with the GDPR. This means that personal data will not normally be disclosed to third parties and any such disclosures will only be made in accordance with the Regulations.

How to submit comments

Basic information can be provided in the survey below. More detailed information should be provided in document(s) which can be submitted as attachments at the end of this survey.

The restriction opinion will take into account all comments which apply to the  socioeconomic information presented in the draft opinion. After the end of the restriction process HSE will publish lists of the comments that stakeholders submitted during the first and second public consultations, together with responses to those comments.  It will be helpful if you can provide a “public” non-confidential version of your information to make it clear which of your information we can publish in the response to comments documents. If you also want to provide confidential information in your submission, please additionally complete a “confidential version” and submit both versions as attachments. We will take account of both non-confidential and confidential information in the restriction opinion.

When responding to this survey, please provide as much information and evidence as you can.

If you need assistance to complete this survey, please use the general comments section to indicate what information you are willing to share and tick that you are willing to be contacted by HSE.

By submitting information as part of this public consultation, you agree that any data provided (excluding your personal details) can be shared with the Environment Agency under obligations under Article 2B, our independent scientific advisers and the appropriate authorities (i.e., Defra, the Welsh and Scottish Governments).

The public consultation lasts for 60 days and closes at 23:59 London time (BST) on 10 December 2023.