General Licences –
Wild Justice continue to threaten legal actions, and there is concern that DEFRA are making bad policy decisions re general licences as a result.
Please continue to monitor the websites to ensure you comply, and member organisations of BSSC will continue to express their concerns to George Eustice Secretary of State.
Medical Reports for Licence Renewals and Applications
If you are having difficulty obtaining a medical report from your GP for your firearms/shotgun/explosive licence renewal or application, you may want to contact MedCert, a highly eminent group of medical professionals who are very supportive of shooting, to do the report for you.
The idea of MedCert was formed after a day of good shooting, followed by good food and drink, in good company, as many a good idea is. After consultation with all the Firearms Licensing Authorities and many chats with well-known FEO’s, MedCert launched their Website.
MedCert provide a service by doctors, GP’s and above, with a wide medical knowledge base, who will immediately on your application to them, request your medical records from your GP (can take upto 4 weeks to arrive), and within seven days of receiving your notes, write a medical report taking into consideration the licensing criteria. This will then be sent to yourself or to your licensing authority, depending on the individual licensing authorities’ procedures. If there are any further issues with regard to the medical report MedCert will stay with you until your licence is renewed/issued. All this for £50.
MedCert are fully GDPR compliant and no information is shared with anyone else. Each applicants’ medical notes are given a reference number, only the doctor writing the report will know who you are. The report will be entirely evidence based, nothing personal about it. MedCert can not place a medical marker on your records as they do not keep your records. Your licencing authority should ask your GP to place a medical marker on your records on completion of your grant/renewal.
MedCert can be contacted via www.medcert.co.uk , or for those without internet, at MedCert, Zinc Building, Great Stoney, Chipping Ongar, Essex, CM5 OAD
Tel. 020 8063 4503 – Discount for SA Members of 10% using code SA1996
EU Regulation – Lead in Gunshot In or Around Wetlands
By 15/7/2020 Member States of the EU will have confirmed, in a written vote, whether they agree to the proposed restrictions on lead shot over wetlands. FACE are urging member nations to reject the proposal due to serious legal and practical issues.
Banning possession/carrying of lead gunshot: The Commission proposes “anyone found in or around wetlands carrying lead gunshot while out shooting, or as part of going shooting, is presumed to be carrying that gunshot while out wetland shooting, or as part of going wetland shooting”. This establishes a legal presumption that hunters must prove they have not been shooting over wetlands if carrying lead shot. The presumption of innocence is an extremely important EU law in all member states, the burden of proof is on the prosecution to prove an offence. The Commission’s proposal is illegal. Fundamental principles of EU law must not be interfered with for lazy administrative convenience of enforcement.
Definition of Wetlands and Inclusion of Buffer Zones: The Commission propose to use the Ramsar definition of Wetlands, this includes peatlands, wet or dry, and that a 1m² of temporary water, say after rain, constitutes a wetland. Combined with 100m buffer zones, this makes wetland boundaries perpetually movable.
This does not fulfil the principle of legal certainty, making it unlawful and very impractical to administrate.
Transition Period: The EC propose a shorter period of 24 months, rather than the original proposal of 36 months. The transition period should be at least 36 months, and 60 months for countries that do not already have any restrictions in place.
Applicability of REACH to hunters: The original scope of REACH regulations was originally intended for industry. It is unclear whether the REACH regulations can legally apply to hunters as consumers.
The UK is no longer represented within the EU REACH committee. However, the UK Government says the UK will be bound by any Regulation adopted prior to Brexit on 31/12/2020.
If the proposed regulation gets majority support from the Member States it will then pass to the European Parliament and the European Council for scrutiny over three months. If not rejected by the Committee on the Environment, or Public Health and Food Safety it will pass into law.
Every effort is being made by FACE and Associations working with them to make sure the vote on 15/7/2020 does not carry the proposal forward.
More information is available on the following link: https://www.euractiv.com/section/energy-environment/opinion/restricting-lead-gunshot-over-wetlands-why-is-the-european-commission-proposal-so-problematic/
EU’s plans to further restrict the use of lead ammunition.
Further to the above proposal the EU has asked the European Chemicals Agency to “collect information for the assessment of the risk and socio-economic impact of a possible restriction for other uses of lead ammunition, including hunting in other terrains than wetlands and target shooting, as well as for the use of lead weights for fishing”. It is expected that the ECHA will propose a complete ban on lead ammunition because of risk to human health.
The BSSC was approached by the European Chemicals Agency (ECHA) which was researching the practice of lead capture and recycling on outdoor rifle and clay pigeon shooting ranges in preparation for its dossier on the prohibition of lead in ammunition. The Secretary has sought data from member associations that are involved in target shooting, but with many venues being closed due to covid-19 restrictions the data gathered is incomplete.
As a generalisation, all rifle and pistol ranges that responded, trap, recover and recycle their lead with the income from recycling the lead covering most of the costs involved. There was little water run-off, if any, reported on any of the ranges. Removal of lead is vital for safety reasons not just environmental ones, so we have been doing this for years.
For shotgun ranges/grounds, the shot falls in known areas, but very few venues recover and recycle the lead, mostly because of economic viability, although more venues are addressing the issue and will be recovering and recycling in the future.
SECURITY AND CARTRIDGE RETENTION
At renewal/grant some people who fall into the level 2 security category are being asked to install monitored alarm systems and video cameras based on the 2019 Firearms Security Handbook, this can be a little excessive. The BSSC secretary will meet with the National Police Chiefs Council once Covid-19 restrictions are no-longer in place to resolve several areas of concern within the guidance.
Hampshire Licensing Authority have introduced a voluntary cartridge retention policy. That is on renewal/grant they will ask you to keep one fired cartridge from each of your firearms, for comparison should you lose or have stolen said firearm/s, which might then be used in a crime. Other forces are copying this initiative. However, your participation is VOLUNTARY.
In the Queens speech (October 2019) the government announced their intention to ban imports from trophy hunting. A consultation on the import and export of hunting trophies then ensued, and evidence was called for.
The BSSC responded with “no change” please. They argued that there are considerable economic benefits, cultural, social and food benefits, to local communities where large game hunting takes place overseas. Also, that there are currently sufficient levels of control to address the conservation of endangered species without further restrictions on imports.
Both the impact on the rural economy, particularly in the Highlands, and on the management of wild deer throughout the UK were stated, should the government ban all hunting trophies leaving the UK, resulting in reduced overseas hunters visiting sporting estates across the country.
Channel 4 recently showed a programme supporting those who want a complete ban on all trophy hunting, and the Independent ran an article supporting the same. Minister for Department for Environment and Rural Affairs (DEFRA), Victoria Prentis has told MP’s “The outcome of the consultation, and accompanying call for evidence, will inform our next steps”.
Perhaps, more promisingly, a DEFRA spokesperson stated in both the Chanel 4 programme and the Independent article that “There is a clear manifesto commitment to ban the import of hunting trophies from endangered animals and we continue to work to end this shocking trade.”
THE CONTROVERSIAL TOPIC OF LEAD V NON-LEAD AMMUNITION.
Several shooting organisations recently proposed a voluntary ban on the use of lead shot for the shooting of all live quarry by 2024. “In consideration of wildlife, the environment and to ensure a market for the healthiest game products, at home and abroad, we wish to see an end to both lead and single-use plastics in ammunition used by those taking all live quarry with shotguns within five years.” The manufacturers of shotgun cartridges have responded by saying this is unlikely to happen in such a short timeframe, and had the shooting organisations consulted with the industry, they could have advised the associations of the various problems to be overcome.
Many conservationists are calling for an outright ban on the use of lead shot. Lead is a neuro toxin which can cause poisoning in many birds, scavengers, and ultimately humans who consume game on a regular basis. Some retailers are beginning to state that they will not stock game where lead ammunition has been used. Defra has so far said they do not intend to impose an immediate ban when shooting organisations are regulating themselves.
Lead shot is currently banned on all wetlands in Scotland and Northern Ireland. In England and Wales, there is a ban on using lead shot to shoot wildfowl and for shooting on foreshores and on sites of special scientific interest. An EU regulation banning lead shot on wetlands, plus a 300m buffer zone, is expected to come into effect by the end of 2020, with a phase out period of 24-36 months.
Further to that the EU has asked the European Chemicals Agency to “collect information for the assessment of the risk and socio-economic impact of a possible restriction for other uses of lead ammunition, including hunting in other terrains than wetlands and target shooting, as well as for the use of lead weights for fishing”. It is expected that the ECHA will propose a complete ban on lead ammunition because of risk to human health.
Defra has confirmed that the UK is bound by EU legislation during Brexit transition and must adopt it into UK law if it is passed before the end of 2020. It is unclear what position the UK Government will take on REACH (Registration, Evaluation, Authorisation & Restriction of CH chemicals) after transition, especially in the face of the present voluntary initiative to phase out lead shot. FACE UK are trying to find out.
In the last 30 years many countries have phased out the use of lead shot over wetlands (this is before the EU regulation expected to come in later this year). Denmark and Sweden, hailed by some as leading the way, have a complete ban on the use of lead shot ammunition, as did Norway. However, in 2015 Norway repealed this ban except for over wetlands.
Why would Norway do this? Despite all the popular pressure to ban all lead shot ammunition they felt there was no conclusive scientific evidence that an outright ban was beneficial to the environment and wildlife. Or that the available alternatives were effective enough, let alone the lack of evidence about the effect such substitute materials will have on health or the environment.
So, what are the alternatives to lead ammunition, Steel, Plastic, Copper, Copper-Zinc alloy, Bismuth, Tungsten, a variety of alloys yet to be learnt about? There is no straightforward swap to suit all ammunition.
Non lead shotgun cartridges generally use steel or bismuth shot with plastic wads, a few have biodegradable wads. There is a shortage of steel shot in Europe, increasing demand will only inflate prices. There is also the question of suitability of steel shot for older shotgun barrels, and whether you will need to re-barrel more frequently, even with a modern shotgun. Let alone the laws in this country on performance of steel ammunition for civilians. The move by the military away from lead to steel is for better penetration, any positive environmental impact is just a nice secondary effect. Bismuth behaves similarly to lead but like steel has limited availability. However, Bismuth is medically proven to be a neurotoxin, and some Canadians are calling for toxic impact of Bismuth on the environment and in game to be re-assessed.
In short, the shotgun industry applauds the aim to have more environmentally friendly, less toxic but still effective and humane cartridges for all shotgun use. But it will take time to develop and test new materials, to secure continuous supply of said materials and to tool up for production. For the moment the industry is saying “At present the only commercially available options are lead shot with fibre wads, steel with plastic wads or unaffordable premium non-lead shot. Shooters and land owners will need to consider these options and then decide which option is preferable going forward. Right now, we need to decide which to eliminate– lead or plastic? We cannot avoid using both.”
It is an imperfect world, so let’s give our support to the aim of achieving the above, but accept that whilst we will all strive to do this as quickly as possible, we accept that it will only happen in a time that is practicable. Especially as we have to give consideration not just to shotgun ammunition, but to all ammunition for all guns of all ages.
As of 2017 the “Police and Crime Act 2017” prohibited the sale, loan or transfer of any firearms that had not been deactivated to the 2016 EU standard or any subsequent standard as published by the Secretary of State.
This does not affect OWNERSHIP of pre 2016 deactivated firearms, but does prohibit their TRANSFER, whether by sale, swap, gift or inheritance.
The only exception to the transfer of a pre 8/4/2016 deactivated firearm is when it is transferred to a museum which holds a “museum firearms licence”.
Firearms deactivated to standards which pre-date 8/4/2016, or any subsequently published specification by the Secretary of State, are considered to be “defectively deactivated weapons” (DDW).
Firearms Regulations 2019
With respect to firearms deactivated from 8/4/2016 and acquired since 14/9/18
As of 12/12/2019 it becomes a criminal offence to TRANSFER or LEND, for more than 14 days, a deactivated firearm to another person without registering the transfer with the Home Office. The person making the transfer must notify to whom they are transferring the deactivated firearm, with the make, caliber and serial number by registered post, recorded delivery or email before, or on the day of transfer or as soon after as is practicable.
Persons in POSSESION of a deactivated firearm commit an offence if they have not notified the Home Office of possession unless notice of the transfer has already been given by the person who previously owned it.
Deactivated firearms acquired between 8/4/2016 and 14/9/2018 which are unaltered do not have to be notified until 14/3/2021, unless transferred in the meantime.
The forms are available on GOV.UK and should be sent to firstname.lastname@example.org or by post to:
Deactivated Firearms Notification
Serious Violence Unit
5th Floor, Fry Building
2 Marsham Street
This was brought in as a Statutory Instrument 1420 on 31/10/2019 as a direct result of EU directive 2017/853.
Layman’s Guide to Registration and Notification of Transfer of De-activated Firearms
As per Firearms Regulations 2019
Letter to Gillian Keegan regarding
Proposal to Prohibit .50 calibre ‘materiel destruction’ rifles and rapid firing rifles under section 5 of the Firearms Act 1968. England, Wales and Scotland
2014-11-12 Letter from ACPO Firearms & Explosives Licensing Working Group Chair, Andy Marsh, dated 11 nov 2014