Offensive Weapons Bill

Written evidence, Offensive Weapons Bill, submitted by Rupert Fitzsimmons on behalf of Cambridge University Small Bore Club and Cambridge University Rifle Association.

Dear Sir or Madam

Executive Summary:

- This submission is concerned solely with the aspects of the bill concerning firearms with specific reference to the contents of the document titled ‘Notices of Amendments: 4 September 2018’.

- Proposed Clause NC22 regarding the possession of component parts and manufacture of ammunition in the document titled ‘Notices of Amendments: 4 September 2018’ would criminalise a common practice amongst target shooters and mean the end of some shooting disciplines and the closure of many small businesses.

- Proposed Clause NC19 regarding miniature rifle clubs and ammunition in the document titled ‘Notices of Amendments: 4 September 2018’ risks making it very difficult for small bore clubs to function as it would make it hard for them to purchase ammunition.

- Due to the various issues with Clauses NC22 and NC19, they would be best excluded from the Offensive Weapons Bill and should be reassessed more carefully with the interests of target shooters taken into account by the Firearms Advisory Committee discussed in NC21.

- Proposed Clause NC21 regarding the establishment of a Firearms Advisory Committee is welcomed but the existing phrasing of the proposal does not ensure that appointed members would accurately represent or have experience in the recreational or sporting use of firearms.

Personal Introduction:

I am the captain of Cambridge University Small Bore Club and the Match Rifle captain of Cambridge University Rifle Association. I am also the former secretary and police liaison for Cambridge University Small Bore Club and a Firearm Certificate holder. In this submission I am representing the opinions and interests of over sixty club members as well as my own.


1. The points that this submission makes are primarily concerned with the contents of the document titled ‘Notices of Amendments: 4 September 2018’ and are found on this page in the document: I, and members of my clubs, believe that two of the proposed amendments in this document would severely affect target shooting in the United Kingdom. A further proposal in this document requires adjustment in order to ensure that the interests of target and other recreational and sporting shooters are fairly represented.

2. Dealing firstly with Clause NC22, the current phrasing of the proposed amendment would serve to criminalise what is currently a very common practice amongst target rifle shooters. For the benefit of both accuracy and cost a very large proportion of target shooters currently own the component parts of ammunition and manufacture their own ammunition.

3. This practice is known in the shooting community as either ‘handloading’ or ‘reloading’. It involves the employment of specialist equipment and specialist knowledge in order to produce ammunition that is often optimised for or usable in just one rifle. Once ammunition has been manufactured in this way it is then stored securely and written onto firearm certificates to ensure the ammunition is kept track of.

4. The target shooting disciplines of F Class and Match Rifle are both popular in the United Kingdom and we have had great success internationally competing in these disciplines. Both of these disciplines rely heavily ammunition being as accurate as possible. This is something that can only be achieved through the manufacture (handloading or reloading) of ammunition specifically for one rifle. To make it illegal to own components of ammunition and to manufacture ammunition, as Clause NC22 would do, would result in these disciplines becoming impossible to continue with in any meaningful way. Additionally, the discipline of Target Rifle (which is included as a discipline in the Commonwealth Games), while not requiring ammunition to be manufactured specifically to suit certain rifles, also benefits greatly from the ability to manufacture ammunition.

5. Aside from this measure negatively influencing the sport of target shooting, it would also impact many small businesses which specialise in selling the components of ammunition and precision tools required to produce ammunition. Currently also the sale of primers and powders, the ignition and fuel components of ammunition, takes place face to face and registered firearms dealers make records of the sales of these goods and ensure that they are selling them only to those with suitable firearm certificates.

6. Of course, the possession of ammunition components and the manufacture of ammunition with intent to commit crimes by individuals or groups of people not permitted to possess ammunition is a concern. The illegal weapons and ammunition manufacturing operation in Halisham that has come to light in recent weeks, for example, would have likely benefitted from a clause along these lines being added to the Firearms Act. Equally though, if someone were to manufacture ammunition that they were not permitted to possess they would already be committing the crime of possessing such ammunition without the authority to do so. If the inclusion of this clause is therefore to aid in the prosecution of those manufacturing or intending to manufacture ammunition that they are not allowed to possess, with criminal intent, then this clause requires redrafting so as to not criminalise target shooters engaging in legal ammunition manufacture.

7. Moving on to the second Clause that has caused concern, Clause NC19, there are further worries. This proposal is intended to 'amend the Firearms Act 1968 to prevent persons being able to acquire an unlimited number of .22 rifles and ammunition without background checks or making the police aware’. This is an attempt to tackle the existing miniature rifle club exemption, the operation of which is outlined in some detail by the National Small-bore Rifle Association here:

8. Currently many small-bore clubs use this exemption in order to purchase ammunition for their clubs. In the case of Cambridge University Small Bore Club this is especially useful because it allows senior committee members to acquire ammunition for the club without having to produce the club’s firearm certificate which is held by an alumnus of the club who cannot, for valid work reasons, always be present for the purchase of ammunition. It is important to note here though that while the intention of the amendment is to ‘prevent persons being able to acquire … ammunition without background checks or making the police aware’, following this method, background checks are capable of being made and the police are aware of purchases. As part of the requirements for a rifle club to gain Home Office approval the police force under which the club falls must be informed of the details of the club’s members. As such, those who may be exercising the exemption in order to acquire ammunition and rifles are, in fact, known to police forces already. (See points E, G, H, and I of the Home Office Criteria For Approval: ).

9. Furthermore, the sales of firearms and ammunition by registered firearms dealers are recorded and the police are made aware of firearm transactions. This means that the only way in which ammunition or firearms could be acquired by a Home Office approved club without the police either being aware of the transaction or being able to see evidence recorded of it would be if the transactions were done between clubs, rather than dealers, already holding the firearms or ammunition under the miniature rifle club exemption. This is not something which my clubs engage in and is something that is unlikely to really occur in any legitimate target shooting club. This is because, as described in the link above to the NSRA’s website, firearms acquired in this manner can only be used at a range being conducted by the club’s committee. In their words, ‘You could not bring the guns to Bisley and shoot in our Championship Meetings because we are ‘conducting’ the range’. This limitation to the use of the firearms, presuming their owners are obeying the law, renders them undesirable.

10. As is clear then, the existence of this exemption is not a security issue for clubs that are already Home Office approved for transactions involving registered firearms dealers. By virtue of being Home Office approved, transactions that utilise this exemption will be traceable and the individuals involved in them are already known to police forces. Losing this exemption would be extremely frustrating for many rifle clubs that currently use it, Cambridge University Small Bore Club included. Fundamentally, it would severely hamper many University small bore clubs and school rifle clubs that currently use the exemption for legitimate reasons. As a sport that already faces many restrictions, this further restriction would serve to make it even harder for people to compete, practice and enjoy.

11. Where the issue with this exemption lies is for those clubs that are not Home Office approved and in transactions taking place between clubs rather than registered firearms dealers. It is only in these quite specific and, to our knowledge unheard of, circumstances where the sales of firearms and ammunition may not be traceable or the police may not be aware of them. With this in mind, therefore, if the miniature rifle club exemption is to be amended it is perhaps best done so in order to make this sort of scenario impossible rather than to infringe upon the actions of Home Office approved clubs.

12. Given that both proposals NC22 and NC19 exhibit problems for lawful target shooters it is my belief, the belief of Cambridge University Small Bore Club and also of Cambridge University Rifle Association that neither proposal in their current formats should be included in the Offensive Weapons Bill. Both clauses contain points that are worthy of pursuing as well as honourable sentiments, but the information and time required to make decisions on them is far greater than there is scope for in this present Bill. As such, it would likely make more sense if they were issues that were dealt with more carefully and with the interests of target shooters in mind by the proposed committee outlined under NC21.

13. The Firearms Advisory Committee proposed in NC21 seems like a positive step towards tidying up the firearms legislation of the United Kingdom. Such a committee, made up of knowledgeable individuals, would be a fantastic way to develop, improve, and manage existing firearms law and it would likely be better qualified to deal with the balance of issues raised by the clauses discussed above than the Offensive Weapons Bill committee.

14. As things stand, however, the outline of the committee in NC21 states that members shall be appointed by the Secretary of State on account of their knowledge in the following fields: ‘(a) the possession, use or keeping of, or transactions in, firearms; (b) weapon technology; and (c) the administration or enforcement of the provisions of the Firearms Acts 1968 to 1997’. Omitted from the requirements is any reference to the specific knowledge of recreational or sporting use of firearms. This means, with current phrasing, that no form of legal civilian shooting (including those types of shooting sports competed in the Olympic and Commonwealth Games) is required to be represented in this committee.

15. Submissions to the Offensive Weapons Bill committee have been rife with statistics regarding the numbers of legal registered firearms owners in the United Kingdom. This document shows, for example, that in the financial year ending on the 31st of March 2018 there were 586,583 people possessing firearm or shotgun certificates.

16. What is clear from these statistics is that there are a sufficient number of legal registered firearm and shotgun owners to make it obvious that any committee designed with the sole purpose of making recommendations regarding firearms to the Secretary of State ought to include significant representation for these people. An addition to this proposed amendment along these lines would therefore be most welcome.


It is hoped that these points will be considered by the Offensive Weapons Bill committee in good faith and that the sport of target shooting is taken into consideration when firearms legislation is being discussed.

Yours sincerely

Rupert Fitzsimmons

On behalf of Cambridge University Small Bore Club and Cambridge University Rifle Association

September 2018


Prepared 10th September 2018