Dear Secretary of State

Photo: Policy exchange via wikimedia commons
Photo: Policy exchange via wikimedia commons

Dear Ms Truss

It is six months since you received the report of the Lead Ammunition Group and your department has, so far, not commented on it.

Given that the findings of the report demonstrate human health impacts and wildlife health and conservation impacts your idleness is unacceptable. Each day you delay you are complicit in allowing more avoidable harm to be done.

Let’s just recap, for your benefit, the findings of the group (I’ve highlighted some areas in red):

Lead is a highly toxic hazard and presents risk at all levels of exposure. It is especially dangerous as a neurotoxin for both young people and for wild animals.

Some 6,000 tonnes of lead from ammunition used in shotgun and rifle shooting are being discharged every year. At least 2,000 tonnes of shot used for game and pest shooting are irretrievably and unevenly deposited on or close to the soil surface where it is available for ingestion by birds. It probably becomes unavailable to them quite quickly, though it remains in the soil and substrates for a long time with as yet unknown consequences. Some 3,000 tonnes are deposited on clay target shooting grounds.

Lead from ammunition can (and does) get into wildlife by several routes, mainly by ingestion by many species of bird in mistake for grit or food items, or in scavenged dead animals, or as the prey of some raptors. In areas of intensive shooting lead is taken up by some plants and soil microfauna getting into the food chain, but the research studies that have been done on this latter route are limited.

Lead from ammunition causes harm to wildlife and certainly kills some birds. Numbers are hard to be certain about, but almost certainly at least tens of thousands to hundreds of thousands annually in UK. The welfare effects in these animals, and the larger numbers that ingest sub-lethal doses, are sufficient to cause illness and can be very severe and prolonged for them.

Lead shot and bullet fragments can be present in game meat at levels sufficient to cause significant health risks to children and adult consumers, depending on the amount of game they consume.

Almost certainly some 10,000 children are growing up in households where they could regularly be eating sufficient game shot with lead ammunition to cause them neurodevelopmental harm and other health impairments. Tens of thousands of adults are also exposed to additional lead by eating game as part of their normal diet, and this could cause a range of low level but harmful health effects, of which they will not be aware.

Current regulations restricting the use of lead shot in wetlands and for shooting wildfowl are apparently not achieving their aim and are insufficient for dealing with the wider risks because it is now known not to be just a wetland problem; and moreover, compliance with current regulations appears in any case to be low in England, as well as far from complete, as yet, in other countries along the flyways of wildfowl. Publicity has so far had little or no measurable effect on compliance with existing regulations.
For human health there is no evidence that existing advice from FSA and other stakeholders has so far reached target groups or affected game eating habits.
There is currently no evidence to suggest that the will, funding or resources exist, or are being planned, to develop measures that will ensure that game and venison containing lead levels above those permissible for red meat and poultry do not enter public markets as food.
For small game, no proposals have been made to the Group for any measure, short of lead shot replacement, that would ensure that small game entering the food chain do not have elevated lead concentrations.

Safer alternatives to lead ammunition are now available and being improved and adapted all the time for use in different shooting disciplines. There is considerable experience from other countries where change has already been undertaken.

There is no evidence to suggest that a phase out of lead ammunition and the use of alternatives would have significant drawbacks for wildlife or human health or, at least, none that carry the same scale of risks as continuing use of lead; though there are procedural, technical and R&D issues still to work on and resolve.
There is no convincing evidence on which to conclude that other options, short of replacement of lead ammunition, will address known risks to human health, especially child health.
To get this report, your predecessors assembled a bunch of experts on science and some representatives from game shooters. The group was dominated by those vocally opposed to any change in the status quo – vested shooting interests – and was chaired by the then chief executive of a major shooting organisation. As a former member of this group it felt to me at the beginning as though the chances of progress were rather slim. However, the weight of scientific evidence, carefully reviewed by the expert group assembled, has led to a very clear finding that lead ammunition needs to be banned.
The group took a long time to sift the evidence and reach its conclusions and in the mean time the evidence for harmful impacts of lead have grown, more countries and US states have moved to ban lead ammunition use and the UK, as part of an EU delegation, has voted for a phasing out of lead ammunition in three years (less than two years left).
In addition, last week a symposium was published which added further academic weight to the calls for lead ammunition to be phased out very quickly which was supported by three Fellows of the Royal Society, no less.
It is time for you to stir yourself and say something. Your delay is unacceptable and shameful.  It’s a no-brainer. It is time, in fact it is past time, for lead ammunition to be banned and you should state that that is your plan for England and that you are talking to devolved administrations about a co-ordinated response but in any case you will make sure that lead ammunition is phased out with alacrity in England.
Your delay is used as an excuse by others to delay too.
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7 Replies to “Dear Secretary of State”

  1. "not achieving their aim", Mark, you have no idea if that is the case. Think about what the evidence shows and where those mallard came from. Good luck.

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  2. You have to use language people can understand to make your arguments. The SoS for Pork likes to impress her bosses - the proportionate increase in VAT on more expensive ammunition would be very persuasive. They understand that. Try green ink, too

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  3. The Lead Ammunition Group was set up under the auspices of Defra. It was not a self appointed pressure group that has sprung its report on Defra out of the blue. It is unconscionable that Defra has not responded in any way fully six months after receiving the report.

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  4. Lead weights have been banned in angling for years, below I believe 2 oz. Split shot commonly used by anglers are even given their shot name e.g BB, AA,swan shot. So if this is banned in angling and lets face it an angler wouldn't lose the amount of lead in a life time of fishing that is discharged by a shoot. It is beyond believe that shooting has no such ban. The only reason I can see is coarse angling is deemed a working man's sport.

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    1. I don't think there was a classist agenda. As far as I understand it, there was an acute and evident problem of lead poisoning in mute swans, which in the 1970s and 1980s was the major cause of mortality in that species. The ban on lead shot for anglers was brought in for that reason in 1987 after an initial voluntary ban had failed to work. Awareness of the extent of the problem more widely has developed since then.
      I daresay there are quite a few people who enjoy a bit of rough shooting or clay pigeon shooting who would not consider themselves especially high-born, even if they may be thinner on the ground up on the grouse moors.

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