It is if you want it to be.
Given the lack of ammunition, and the overall design, I find it hard to believe that there's a way to play it on which a significant amount of time would be spent shooting.
SS2 lets you use projectile weapons as your preferred way of disposing of enemies. In my mind, if you choose that path, it could be described as a shooter. That isn't all it is, but it is one word that describes a particular way you can choose to play the game.
Side note: SS2 is probably my favourite game so I certainly don't mean to "degrade" it by implying it is "just" a shooter.
It's a stealthy horror FPS, not a bulletstorm.
unlimited ammo!