Letter from Chris Packham to M&S

Apologies to anyone for whom this post is not displaying perfectly – I’ve tried to fix it and that’s the best I can do. Sorry! Here’s the link to this letter on Chris Packham’s website.

Steve Rowe
Marks and Spencer Group plc
London W2 1NW

Dear Marks & Spencer

I have a few questions relating to the possibility that you may be selling Red Grouse in your stores this year.

You say ‘We’ve been working hard with estate managers and the Game & Wildlife Conservation Trust to further develop our industry leading responsible sourcing Code of Practice for game suppliers’.Q: Do you consider the GWCT to be a fully independent body and therefore best placed to help oversee the development of this code?You also state ‘We already make sure that the estates we source from, which are well-known to us and are across Northern England . . . and the Scottish Borders, protect and enhance natural habitats for a bio-diverse landscape’.Q: Please name the estates to which you refer, and what measures you have in place to ensure that the grouse will be supplied from an “approved estate” and not any other source.You write that these estates ‘All comply with legislation, of course they do. But for us that’s a bare minimum. We insist that they operate to the industry’s Code of Good Shooting Practice and the Defra Codes of Practice for the Welfare of Game Birds (www.defra.gov.uk). But to go one step further, we’ve developed and are implementing our own responsible sourcing code for the industry that is truly transformational’.Q: Please provide a copy of your sourcing code and explain what is meant by “transformational”.Further you state ‘It needs to provide a high level of protection for habitats in need of conservation and ensure that the estates that comply with the code are recognised as adding value to rural communities’, and ‘We know our estates are already doing well in these areas and our suppliers are therefore playing a huge role in developing the code’.

Q: Please confirm whether or not you are aware of the research recently published by Leeds University which implicates grouse moor management as a contributory factor in climate change. See https://www.leeds.ac.uk/news/article/3597/grouse_moor_burning_causes_widespread_environmental_changes

Q: Please confirm whether you are aware that management on the Walshaw Moor Estate in the South Pennine Moors is currently under investigation by the European Commission in relation to contravention of the Habitats Directive. See letter attached below.

Q: Please confirm whether you are aware that blanket bog burning at Walshaw Moor may have significantly impacted upon serious flooding issues in nearby communities? See https://www.theguardian.com/commentisfree/2015/dec/29/deluge-farmers-flood-grouse-moor-drain-land

Regarding the birds themselves you say ‘Last year we worked with independent industry experts and the Game and Wildlife Conservation Trust to introduce the game industry’s first ‘Codes of Practice’ to ensure all our game, including grouse, is sourced to the highest standards of game rearing and moorland management, from estates that we know and trust’

Q: Please identify the industry experts referred to.

Q: Please identify the estates referred to.

You also state that ‘Unfortunately, due to poor spring weather conditions last year, our red grouse single estate had insufficient quantities to meet our customer demand, so we were unable to sell grouse’.

Q: Please identify the estate referred to.

Q: Do you consider that this message may imply that further intensification is required (both in terms of habitat and predator control) to provide a shootable surplus in order that you can meet customer demand?

You say ‘We are currently working with our supplier to monitor numbers (of grouse) for this year’s season’.Q: Please confirm whether or not you monitor the populations of (i) breeding birds of prey and (ii) mountain hares on the estates from which you source grouse. In this regard I assume that you are aware of the critical state of the UK Hen Harrier population, particularly in England, and that it is a species being persecuted on grouse moors.In an email I have been forwarded you have said that the grouse you sell will be ‘hand inspected to minimise risk of excessive shot and any risk to our customers’.

Q: Please confirm what lead level you regard as acceptable in grouse meat sold to the public.

Q: Please confirm what is meant by “excessive shot”, by what criteria this will be measured, and whether or not your statement anticipates that birds sold will contain shot.

Q: Please confirm whether or not you will be labelling grouse meat to inform your customers of the actual or likely lead levels?

Q: Please confirm the process of hand examination that will be carried out and how you can be sure it is reliable.

I look forward to your replies concerning this issue as it is one currently concerning many conservationists in the UK and, if social media is anything to go by many of your customers too.


Chris Packham




17 Replies to “Letter from Chris Packham to M&S”

  1. Interesting first question. I’ll ask a similar one, how independent was Oxford lead symposium (WWT’s lead symposium)?

    1. Ed – easy to answer – a bunch of academics whose work was independently peer reviewed. And a difference is that you and anyone else can read the Oxford Lead Symposium – M&S is keeping its ‘industry-leading’ code of practice secret. It talks about it but doesn’t reveal it or allow it to be scrutinised by its potential customers who, presumably, are supposed to be reassured by it.

      There is another aspect to the Oxford Lead Symposium – many people from different view points were invited to it. I was invited but unable to attend. People from the shooting industry were invited but chose not to attend. Shooting appears to have decided never to work with others so that it is easier to criticise others. No-one from Moorland Association or GWCT memberships or staff would speak at Bird Fair, walk out of stakeholder non-scientists from LAG, failure to attend Oxford Lead Symposium – this appears to be an industry that won’t face its public in debate.

      1. Interesting, it appears Wwt slimbridge are behind theOLS! Quite a few staff wrote reports for it. Doesn’t appear very independent.

        1. Edward Coles – you seem to have skipped past the fact that this was independently refereed, again. Which bit of ‘independently refereed’ should I attempt to explain in more detail for you?

          You’ll notice that Prof Lord Krebs FRS does not work for the WWT, and he said ‘Lead ammunition may be traditional but
          it is doubtful whether future generations would perpetuate a tradition of knowingly adding lead to food or exposing wildlife to poisoning.’

          You’ll notice that Prof Chris Perrins FRS does not work for the WWT, and he said ‘Then, as now, the stakeholders involved appeared to have some sort of blind-spot when it came to seeing lead as a poison.’ and ‘Nowadays, no one can be oblivious to the issues of lead because of the damage to human health, particularly children’s health due to impacts on their developing brains. Eating food with lead purposefully shot into it, of course, now seems like a bad idea.’

          You’ll notice that Prof Ian Newton FRS does not work for the WWT, and he said ‘My own view is that a legislative ban is needed on the use of lead in all ammunition used for hunting. At one stroke this would alleviate the problems created for people (especially the hunters themselves), for wildlife and for domestic livestock by this unnecessary but highly toxic material.’

          And yes, there are some WWT scientists who are featured in the symposium (and some shooters by the way) – that’s probably because they have done science on the subject – don’t you think?

      2. Mark, While the GWCT non-scientist (though the only member of the group with experience of public health risk assessment) did indeed resign from LAG, a highly respected scientist from the Trust, Dr Alastair Leake, remained as a member of the Primary Evidence and Risk Assessment Subgroup. His co-authored paper on Lead Ammunition and Wildlife, Appendix 3 of the substantive report (pp 181-261 [sic]), concluded that there was insufficient evidence that spent lead shot had a population-level impact on wildlife to justify a ban on its use. In rejecting LAG’s recommendations, the former Secretary of State clearly attached considerable weight to that conclusion, as she was of course entitled to do.

        I have seen no suggestion – in John Swift’s guest blog or elsewhere – that her decision is being challenged by way of Judicial Review.

        1. lazywell

          Hi! And thank you for some good points – as usual. You are such a rarity amongst shooters.

          Judicial review – interesting idea. I haven’t heard any talk of it. It ought to be WWT and/or RSPB who took that step if it were warranted – but we know how cautious and timid they can be. Your knowledge of the subject is likely to be far better than mine, but my memory is that JR looks at the process of the decision-making rather than its merits. In other words, a JR will fail if Defra can show they have gone through the correct process even if they have, just for the sake of argument, made a palpably wrong decision. So it feels to me as if there is little scope. What do you think?

          I had forgotten Dr Leake – you are right. I would certainly agree he is a scientist and would be happy to describe him as a respected one. I’d slightly withdraw from ‘highly respected’ as a description of Dr Leake only because it would mean that others on the group would then have to be called very highly respected, very very highly respected and very, very, very highly respected when it came to this particular subject.

          Of course, Dr Leake will know that absence of evidence for something is not the same as evidence for absence of something, and we now know, as did Miss Trust, that there is evidence for a population impact of ingested lead on wildfowl.

          But thank you for your thoughtful comment and I’m sorry that it looks unlikely that we will be able to meet up in the near future to joust further over a glass of claret.

          1. Thanks for your gracious comments. Though I’m confident that I’m not quite the rarity amongst shooters as you suggest.

            As regards JR, the Court can indeed review the decision as well as the procedure, but would have to be satisfied that the decision is so unreasonable (or irrational) that no reasonable person acting reasonably could have made it. It’s a strict test, but not far off your “palpably wrong decision”. But I don’t think even you are saying that Ms Truss crossed that threshold. Or are you?

            I acknowledge, of course, that the sub-group included some eminent scientists besides Dr Leake. However, I couldn’t help noticing that one of his fellow members, for all her purported expertise in this field, was criticised for shortcomings in some of her previous papers: undue reliance, for example, on ‘secondary literature, opinion and unverifiable information from questionnaire surveys’; and referencing ‘non-peer reviewed studies, reports and books, magazine articles and conference proceedings, and “personal communication”, among the otherwise peer-reviewed material’. Just the sort of criticism you have been dishing out against GWCT science in recent years.

            Have fun at Bird Fair. I will be thinking of you as I raise my gun. Sorry, that came out wrong. But yes, I look forward to toasting what we do agree on later in the year – if only the quality of the claret.

          2. Lazywell – don’t think of me as you raise your gun – think that it might be one of the last times that you raise your gun.

            Ah well, we do have a problem identifying the good guys in shooting don’t we – because they seem silent and invisible – I haven’t seen or heard any to match your wit so far.

            Ah, I see, criticised by your Dr Leake! No wonder you said he was so highly respected… Not ‘just the sort’ of criticism I have dished out – my criticism was based on analysis of citations which shows GWCT scientific standing falling (though, to be fair, the data are now a little out of date – maybe time to repeat to see if the decline has been arrested? What would you think?).

  2. Reasonable questions, should be straightforward to answer. I look forward to Mr Rowe’s reply.

  3. The M & S AGM was held last week.
    Is it possible to find out if the issue was raised?

    1. I don’t think so as I discovered too late somebody I know who went to the agm. I had never got round to asking him before to sign the petition which he has done. He did say that at the AGM of M and S the new CEO ? would listen to its customers which seems to be at odds as they are not listening to us. If only I had asked before he would have asked a question he said.

  4. “You also state that ‘Unfortunately, due to poor spring weather conditions last year, our red grouse single estate had insufficient quantities to meet our customer demand, so we were unable to sell grouse’…….Q: Do you consider that this message may imply that further intensification is required (both in terms of habitat and predator control) to provide a shootable surplus in order that you can meet customer demand?'”

    Brilliant, i had missed that gem amongst all the spin/hype/bullshit.

  5. It wasn’t displaying properly at the time of my earlier post but it’s back to normal now.

  6. Please publicise this far and wide. Right on, Chris Packham! Please could we have a mention on Autumnwatch or don’t they let you say anything hard-hitting at all? (I remember your mumbling over predator cats, but we know you don’t like ’em).
    I am quite disappointed that a “trusted” retailer like M&S won’t enter a full and frank discussion about this. We customers need to know.

Comments are closed.