What are the Rules?

Last autumn I visited Rules restaurant in London with a couple of friends on a reconnaissance mission. The visit is briefly described in Inglorious: conflict in the uplands.

Rules is London’s oldest restaurant and has a lot of game on its menu. On the day that we visited we could have had grouse but none of us did. Rules gets its grouse largely, I read, from its own grouse moor (which I glanced across one day last autumn).

I have sent the following email to Rules:


Dear Rules

I visited Rules with two friends last autumn and we had a good time with you. I had oysters and steak – both of which were excellent, thank you.

Red Grouse were on the menu, but seemed rather pricey, and I note that some of your grouse come from your own grouse moor at Lartington. I’m not a great fan of grouse shooting, in fact I am trying to get it banned, so I didn’t go for the grouse. I would be interested to hear whether all your grouse are sourced on your own estate and also what measures you take in your own land management to ensure that protected birds of prey are protected, blanket bogs are not damaged by too frequent burning etc.

But the main point of this correspondence is to ask you about the lead levels in the game meat that you supply your customers at Rules. Do you take any steps to ensure that non-toxic ammunition is used to kill the game that you serve up to your customers?

You may be aware that the delicious steak which I ate could not be sold if it had lead levels above 100ppb wet weight. Rather bizarrely, game meat, which may have been shot with lead bullets or shot, is not subject to any regulation on its lead level.

In recent scientific studies, it has been shown that game meat (including pigeon, partridge, pheasant, grouse and venison) all of which I believe you sell to your customers, bought in game dealers and supermarkets, and cooked in normal ways (with visible fragments of lead removed before testing) often has lead levels that would be illegal in beef, chicken, pork, lamb etc.

What do I mean by ‘often’? Actually about 50% of meals are likely to have lead levels that are higher than would be legal for other meats. For grouse, partridge and pheasant, the lead levels were often ten times higher than would be legal in non-game meat. There were some meals that contained over a hundred times the legal lead levels for non-game meat. Were you aware of that? Here is the link to the rather technical scientific paper but Table 3 is a good place to start.

The Food Standards Agency updated its advice to consumers on eating game meat shot with lead in autumn 2012 and stated that:  ‘The Food Standards Agency is advising people that eating lead-shot game on a frequent basis can expose them to potentially harmful levels of lead. The FSA’s advice is that frequent consumers of lead-shot game should eat less of this type of meat.‘  I wonder whether you have taken any steps to bring this advice to the notice of your customers? And do you have any plans to do so?

At an international meeting in Quito last autumn,  countries voted for the cessation of use of lead ammunition on wildlife and human health grounds (this included the EU, and the UK as part of the EU delegation) and for a rapid move to non-toxic ammunition (which has already been adopted in some countries, Denmark being a notable one where game shooting is still a widespread activity – but not with toxic ammunition.

As a business which appears to depend to a large extent on sales of game food, I’d be interested in your comments on these matters. I would be very happy to come and discuss them with you in much more detail to bring you fully up to speed on the matter and I am sure that I could bring other experts on the subject along with me.

I will post this letter on my blog (www.markavery.info/blog/) on Monday morning and I will be happy to post any response you make (or any lack of response) there subsequently.

The oysters and steak really were good.


Yours sincerely


Dr Mark Avery




12 Replies to “What are the Rules?”

  1. Great letter Mark. Their reply or lack of it will be very interesting. You may have already done so but I would have thought this letter of yours should be copied to the Food Standards Agency and Defra as a minimum

  2. Mark, good email and will be interested to see how Rules respond. Have you or will you send a similar email to more food retailers, hotels and restaurants? And how about covering some of the foodie industry publications?


  3. i am surprised that you give establishments dealing in game your patronage . The ecological damage caused by both pheasants and grouse management should dictate that you keep well away from these businesses

    1. Well of course Mark could have eaten somewhere else but I am pretty certain that that would have had no impact whatsoever on the use of lead shot, how grouse moors are (mis)managed or on the impacts of pheasant shoots on the countryside. By visiting Rules he gave himself an opportunity to carry the debate into another part of the game industry and the chance to have more impact than simply avoiding the place could have had. Having raised the issues with them as a customer, he can publicly declare his lack of satisfaction in their response and perhaps persuade other potential diners to avoid them as a result, putting further pressure on the shooting industry to change.

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