The UK, Australia, Japan and Germany have all taken measures to reduce gun homicides. Can the US learn anything from them?

Four countries with gun control – and what America could learn from them

Thirty people will be shot dead in America today. On average. It could be more. If it’s less, then more will die tomorrow. Or the next day.

The United States’s gun homicide rate is 25 times higher than other high-income countries, according to a recent study.

It took one massacre: how Australia embraced gun control after Port Arthur Read more

Americans are divided on whether the country’s gun deaths could be reduced through tougher laws on gun ownership. Liberals argue that legal restrictions on gun ownership could save lives. Conservatives say that tougher gun laws would do nothing to change the behaviour of violent criminals.

Even the 2012 Sandy Hook school shooting that left 20 first-graders dead was not enough to convince American lawmakers to pass new gun control laws, with many people seeing the ownership of guns as a crucial check on government tyranny. The country’s highest court has ruled that outright bans on civilian ownership of handguns are unconstitutional.

After similar mass shootings, other countries have taken more dramatic steps to regulate gun ownership. A look at four countries show that tougher gun laws have been central to these efforts, but that enforcement and culture may also play important roles in preventing violence.

UK

From the moment 43-year-old Thomas Hamilton unloaded his legally held arsenal of handguns on children and staff at Dunblane primary school on 13 March 1996, gun control was on the cards.



Nothing like Dunblane – a massacre of 16 five- and six-year-olds, along with the teacher who tried to protect them – had taken place before in Britain. The shock and collective grief of the whole nation resonated from the northernmost point of Scotland to the tip of Cornwall. This was not the United States, where by 1996, classroom shootings had occurred in many places including Nashville, San Diego and South Carolina.

Facebook Twitter Pinterest Gwen Mayor died with 16 of her young pupils at the school in Dunblane, Scotland. Photograph: PNR/PA

As grief turned to a national anger, public debate focused on how someone like Hamilton, a former Scout leader who had been ostracised because of his suspicious behaviour with young boys, had been allowed to own such lethal weapons.

Public petitions, most notably by the Snowdrop Campaign, founded by friends of the bereaved families, called for a total ban on the private ownership and use of handguns in the UK. Signed by 750,000 people it was symbolic of the weight of public opinion.

Nine years before Dunblane, there had been Hungerford, where Michael Ryan went on a rampage through the Berkshire town, killing 16 people in a series of random shootings before turning the gun on himself. He had been carrying a handgun and two semi automatic rifles, for which he had firearms certificates.

The aftermath of Hungerford brought to an end the right to own semi-automatic firearms in Britain; they were banned along with pump action weapons, and registration became mandatory for shotgun owners.

With Dunblane the focus turned to handguns – held by tens of thousands who took part in pistol shooting across the country. The Conservative then prime minister, John Major, passed the Firearms (Amendment) Act 1997 after the Cullen inquiry into the massacre. It banned all cartridge ammunition handguns, except 22 calibre single-shot weapons.

But with the landslide election of Labour and Tony Blair the same year, the law was tightened further, and the remaining .22 cartridge handguns were also banned. The decision, supported by a majority of the public, all but wiped out target shooting as a sport in the UK.

Dave Thompson, chief constable of the West Midlands, and the lead on gun crime for the National Association of Chief Constables, said: “The legislation coincided very well with a culture.”

Overnight, however, about 200,000 owners of handguns, most of whom kept them for pistol shooting, found their weapon banned and their pastime wiped out. All small-bore pistols and rifles used by target shooters were included in the ban. Penalties for anyone in possession of an illegal firearm were tough - from heavy fines to prison terms of 10 years.

The hostility of those involved in the sport to what they term the draconian legislation is still strong, 20 years after Dunblane. Mike Wells, secretary of the Sportsman’s Association of Great Britain and Northern Ireland, set up in 1996 to counter public pressure for a ban on handguns, said politicians had been driven by a need to show they were doing something but their actions did nothing to stop the criminal use of guns. “It never, never has any effect. The criminal underworld in England, the drug dealers … have all got guns, but they are illegal guns,” he said.

Mark Mastaglio, an expert on firearms who worked for the Forensic Science Service for 20 years, said there was no evidence that the ban on handguns after Dunblane had done anything to cut the criminal use of firearms. “It was very rare that there was ever leakage from the licensed gun owners to the criminal fraternity. Most guns used by criminal are either illegally imported or converted weapons. And that remains the case today,” said Mastaglio.

Crime statistics in the years after the ban was introduced appear to support the theory that it had little impact. Gun crime rose sharply, to peak at 24,094 offences in 2003/4. After that the number of crimes in which a firearm was involved fell consistently, to 4,779 offences in 2013. In the year ending September 2015 there was a small rise of 4% to 4,994 offences.

Thompson said the legislation was only part of it: law enforcement agencies had to prove they would carry through on the tough penalties and there was also poor policing of gang areas, and poor ballistics records and analysis. Both were addressed in the early 2000s, when there was a huge decline in gun crime, he said.

But there has been only one mass shooting in the UK – in Whitehaven, Cumbria, in 2010, during which Derrick Bird killed 12 people – since Dunblane.

Mastaglio said: “Dunblane was certainly a turning point. It was a huge piece of legislation, and had a huge impact on registered gun owners in the UK. We now have one of the most stringent set of firearms legislation in the world – only Japan has tougher laws.”

Japan

Japan has what may be the closest any country comes to “zero-tolerance” of gun ownership – a policy that experts say contribute its enviously low rates of gun crime. As of 2011, legal gun ownership stood at 271,000, according to police records, in a country of 127 million people.

There were six reported gun deaths in Japan in 2014, according to the National Police Agency. In 2006 just two people were killed in gun attacks; when the number rose to 22 in 2007 it prompted a bout of national soul-searching.

In his seminal 1993 paper for the Asia Pacific Law Review, whose conclusions still hold true more than 20 years later, David Kopel described Japanese gun control laws as “the most stringent in the democratic world”.

The 1958 law on the possession of swords and firearms states: “No one shall possess a firearm or firearms or a sword or swords.” Among the few exceptions are shotguns, but here too, the restrictions would cause outrage among American gun owners.

Before they can even lay hands on a shotgun for hunting and sport shooting, prospective owners must attend classes and pass written and practical exams. They must then undergo psychological assessments to determine they are fit to own a firearm. Police background checks are exhaustive and even extend to the gun owners’ relatives.

The aim, according to Kopel, is to make possession of a shotgun so complex and drawn out that few people believe it worthwhile applying for one.

Civilian ownership of handguns is banned. The few violations reported in the media usually involve members of the country’s many crime syndicates who have managed to smuggle them in from abroad.

But Japan was not always a low-crime, gun-intolerant nation. Guns quickly became the weapon of choice for feuding warlords after Portuguese traders introduced them to the country’s south-west in the early 1500s. Over time, Japan improved the design and performance of firearms and began mass producing them.

The beginning of the end of widespread gun ownership came when the feudal warlord Toyotomi Hideyoshi (1537-1598) unified Japan, then disarmed the peasant population by banning civilians from owning swords and firearms in 1588.

Facebook Twitter Pinterest Seized plastic handguns which were created using 3D printing technology are displayed by police in Yokohama, south of Tokyo. Photograph: Kyodo/Reuters

“The shogunate banned them because they were fearful of the consequences of having guns in hands of an angry populace,” said Robert Whiting, author of Tokyo Underworld. The quid pro quo, Whiting added, was that the general population’s safety would be assured provided they paid their taxes.

The notion that gun ownership should be limited to the authorities survived Japanese militarism and carried through to the postwar period. Japanese police officers did not begin carrying pistols until 1946, with the permission of the US-led occupation authorities.

Despite sporadic outbreaks of gun violence, Japan’s yakuza crime syndicates are reluctant to build up caches of firearms. Threatening a rival with a gun is often seen as an “unmanly” departure from the yakuza’s traditional code of honour, to which even modern-day mobsters try to adhere, according to Whiting.

Kopel says Japan’s gun laws do not necessarily prevent criminals – especially the yakuza – from acquiring guns. But, he added, even gangsters “see themselves as within the social system, in a broad sense. Even when breaking the law, they still play by certain rules of society.”

Australia

Eerily, Australia’s moment of truth also occurred almost exactly 20 years ago, when a shooting spree in a gift shop in Port Arthur, Tasmania, resulted in 35 people dying in about half an hour. It was the worst mass shooting by one person in Australia’s history. The killer, Martin Bryant, received a sentence of 35 terms of life imprisonment.

Less than two weeks later, Australia’s then prime minister, John Howard, announced a sweeping package of gun reforms in a country where guns had long been considered an essential prop in the national mythology of life in the bush.

“Port Arthur we acted on,” said Tim Fischer, then Howard’s deputy prime minister. “The USA is not prepared to act on their tragedies.”

Before Port Arthur, most states had a weak licensing system and no requirement to register guns. Howard proposed each state and territory should introduce and enforce a firearm licensing and registration system which required people to have a “genuine reason” for having a firearm, such as sport or target shooting, recreational hunting or being a farmer.

Howard also introduced a national gun buyback policy for all weapons that did not comply, which led to the buying and melting down of more than 650,000 firearms at a cost of A$350m (now £185m). One study said the buyback cut the rate of firearm suicides by 74% in the first 10 years.

There have been no mass shootings in the 20 years since Port Arthur; in the 20 years before the massacre there had been 13.

However, since the 1996 National Firearms Agreement, four states have moved to wind back the mandatory 28 days “cooling off” period between applying for and buying a gun, a trend Howard has described as disturbing.

One of those states was Tasmania.

Germany

Germany’s relationship with firearms is intriguing: while there are a lot of guns in the country, they don’t seem to kill a lot of people.



Germany has one of the highest weapons-per-head rates in the world. In 2014, 5.5m legal weapons were registered as being in the hands of 1.45 million private individuals. The country’s police union estimates the number of illegal weapons in the country to be considerably higher, around 20m. According to GunPolicy.org, this puts Germany at 15th place out of 175 nations in terms of guns per capita.

Gun ownership is more widespread in the west of the country than in the former East Germany, where private gun ownership was illegal before the fall of the Berlin Wall. Recent reports suggest that gun ownership is rapidly increasing still: between November 2015 and February 2016 alone, 20,000 applications were filed for new gun licences.

Yet in Germany gun homicide rate is one of the lowest in Europe: a death rate of 0.05 per 1,000 people, compared with 3.34 in the US. In fact, incidents of gun crime, including both weapons being fired and used to threaten people, have declined by almost a quarter since 2010 (pdf).

Experts put this trend down to a number of tweaks to gun law in the wake of high-profile shootings.

In 2002, a 19-year-old student in the Thuringian state capital, Erfurt, shot dead 16 people at the school that had recently expelled him, using weapons he had obtained from his gun club.



Within a year, the law regulating access to guns had been changed: Germany is the only country in the world where anyone under the age of 25 who applies for their first firearms licence must undergo a psychiatric evaluation with a trained counsellor, involving personality and anger management tests.

Experienced hunters or sports shooters over the age of 25 may be called in for psychiatric tests if they display certain kinds of behaviour, such as being caught drink-driving.

A further tweak to the gun law in 2008 means that inherited guns have to be fitted with a state-of-the-art blocking mechanism, making them unusable.

Facebook Twitter Pinterest A tribute to the victim of the school shooting in Winnenden, near Stuttgart, by 17-year-old Tim Kretschmer. Photograph: Alex Grimm/Getty Images

There were calls for even more stringent laws after 17-year-old Tim Kretschmer shot dead 15 at a school in Winnenden near Stuttgart in March 2009. Kretschmer had obtained his weapons from an arsenal of 15 guns kept by his father, who was a member of a shooting club.



Under the newly amended weapons act, it is now harder for individuals to own multiple weapons. A national gun register was established for the first time in 2013 – previously, records of gun ownership were kept only at regional level.

Police officers can now also visit registered gun owners’ home for spot checks without warning. Guns in private possessions have to be locked away in a safe, with the security code or location of the key known only to the owner of the gun.

A number of politicians went even further in the wake of the Winnenden massacre, calling for a complete ban on the storage of firearms in private homes. Even hunters or sportsmen, they argued, should have to deposit their arms at centralised depots.

The proposal was rejected after protests from hunters, who argued that they frequently need access to weapons at short notice, such as when wildlife was involved in traffic accidents.