Yesterday’s response from the FSA on lead was very helpful.
Here is what they wrote (in blue) and comments from me:
There is no agreed safe level for lead intake. Independent scientific expert groups across the European Union advise that exposure to lead should be reduced as far as possible. You can’t get much clearer than that. Any retailer or restaurant or game dealer needs to take note of this and not of the nonsense pumped out by the shooting industry.
The EU maximum level of 0,10 mg/kg for lead in meat (excluding offal) of bovine animals, sheep, pig and poultry (Commission Regulation 1881/2006 as amended) does not apply for lead in grouse or other game meats. Yep – we knew that.
The Lead in Food Regulations 1979 did contain a maximum permitted limit for lead in game of 10 mg/kg (excluding discrete particles of shot), but these regulations were revoked by the Contaminants in Food (England) Regulations 2002. Ah – but I didn’t know that. I found this useful reference and this one too.
Maximum limits for lead in game have been considered in discussions at the EU Commission expert committee on industrial and environmental contaminants. It was agreed by all Member States and the Commission that due to the very variable nature of lead levels in game shot with lead, that consumer advice would be a more effective risk management measure. That’s interesting too – although it doesn’t make much sense to me. I wonder when these discussions took place – the next paragraph shows that they took place after 2012, so for 10 years nothing was done: no new limit was set, and no public education campaign was carried out. Why not?
Prior to these discussions, a FSA 2012 risk assessment identified that lead shot game is unlikely to be a significant source of exposure for the majority of consumers who never or only occasionally consume game; but it may be a significant, additional and avoidable contributor for frequent consumers. And during this period the shooting industry was promoting the healthiness of game meat while the FSA did nothing to counter the misinformation. I wonder whether any correspondence passed between the FSA and the Countryside Alliance or BASC on the fact that ‘exposure to lead should be reduced as far as possible’?
The Food Standards Agency subsequently published advice in 2012 stating that frequent consumers of lead-shot game should eat less of this type of meat. Eating lead-shot game on a frequent basis can expose consumers to potentially harmful levels of lead. The FSA should have been doing more, in my opinion.
To minimise the risk of lead intake, people who frequently eat lead-shot game, particularly small game, should cut down their consumption. This is especially important for vulnerable groups such as toddlers and children, pregnant women and women trying for a baby, as exposure to lead can harm the developing brain and nervous system. And for the game shooting community who were being misinformed, I believe, primarily by BASC, and the Countryside Alliance. Remember that a BASC survey showed that just under a quarter (23%) of BASC member households ate game meat (excluding venison and wild boar) once a week or more. Where was the FSA’s public education campaign?
The FSA risk assessment concluded that consumption of two game bird meals every week throughout the year would increase the dietary exposure to lead by up to 8 times for an adult and up to 5 times for a toddler. These are conservative estimates, assuming visible lead shot is not removed. So, as said often on this blog, a few game meals increases exposure to lead hugely.
The Lead Ammunition Group was set up to advise the Government on human health and environmental impacts of the use of lead ammunition and provided its final report to Government last year. The FSA is reviewing the report and as part of this has sought review from the Committee on Toxicity. As part of this review, the FSA is also considering the output of the Oxford Lead Symposium. Well, you aren’t moving very quickly are you?
We are aware that the EU Commission will ask the European Chemicals Agency (ECHA) to gather information in 2016 regarding the potential risks presented by lead ammunition. UK Government will be fully engaged in this process Good (probably)
The FSA is interested in the information presented on your blog identifying levels of lead in game on sale in a UK supermarket. The mean level as reported is higher than that used in our risk assessment of 2012 and higher than expected for red grouse when compared to other published data. We will be discussing with the British Retail Consortium and relevant supermarkets what controls they have in place to minimise lead in these products. We would ask that any new available data on the levels of lead in game be submitted to:
I’m glad that a member of the public is doing work that could have been done by the huge apparatus of government and that it is making a difference – but why aren’t FSA doing this themselves? And why hasn’t the Moorland Association or BASC or the Countryside Alliance done this work. Is it because they don’t care how much poison their hobby pumps into food on sale to the public or because they know that it would be difficult to justify a Game to Eat campaign?
The mean lead level in the Red Grouse flesh/meat analysed at my request is higher (it has to be either higher or lower) but it is not anywhere near statistically significantly higher than previous estimates. because of the statistical distribution of the results (I made this point in previous blogs). There is nothing surprising about these results, they are in line with those of Pain et al. 2010. However, they do treble the sample size for recently-analysed Red Grouse samples, taking it from 20 to 60.
It’s good to hear that the FSA will be having a chat with retailers about lead in their products – why hasn’t this happened already? Why the delay between 2012 and now? After all, the FSA was completely au fait with the progress of the Lead Ammunition Group. I’ll happily ask the laboratory which carried out the analysis to forward the data to the email address given.
This is a useful response from the FSA – I’m glad that I emailed them during their ‘live’ Board meeting, but it seems a very odd way for progress to be made on this issue. What on earth are Defra ministers doing all this time?
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A very very good article Mark – particularly informative – well done.
The article raised one further question for me. Are there any regulations covering the provision of consumer information at the point of sale such as “this product may contain lead”?
For any government agency (semi or otherwise) to allow parents to give their children toxic meat which can affect their development is simply scandalous.
Yet again i don’t understand why this isn’t front page news.
And yet again, thanks Mark for doing the job of the press, government and sleeping environmental/food watchdogs.
Even in Scotland we have an environmental minister and SNH promoting grouse as healthy.
Forgive my simplistic question, which has probably been answered previously somewhere, but who is actually responsible for the appointment?
Naively I’d assume that a role with such a level of remuneration would require Ministerial approval?
To consider the appointment of someone with such high levels of association to ‘interest’ is in itself a risk to Ministerial credibility as well as bringing into question FSA impartiality and objectivity? This does not appear to bode well for consumer / public confidence?
Having said that, as Chair designate, Ms Hancock is clearly the preferred Ministerial (?) candidate?
Ever an agnostic ….
Good article there. Some might say the beef, chicken, pork etc that consumers buy in supermarkets are all poison through all the chemicals that are added to preserve them but at least it is labelled and tested beforehand so the consumer can make a choice and/or reduce consumption. Plus the fact that lead kills thousands of birds and predators throughout the year. If game was to be tested for lead levels before reaching the dinner table I’m sure plenty of it would fail.
To me this argument on lead is so clear that anyone against the banning of lead is suspect!!
“Some might say”
Especially orthorexics who will enjoy a miserable life before they die anyway
As an aside isn’t it interesting that after leaded petrol was withdrawn from sale the number of violent assaults (GBH etc) decreased in city areas.
On topic, the idiots who are happy to use lead shot are welcome to eat it but it would appear that it will just make them more belligerent!
Well done Mark. Incredible lack of action by food production companies. Find it hard to believe people would leave the shot in the meat. Have you heard from Iceland yet?