Reply on lead ammunition from Therese Coffey

I wrote to my MP on the subject of lead ammunition back in August.

I’m grateful to my MP, Tom Pursglove, for forwarding my letter to Defra and now for sending me the following reply from the Parliamentary Under Secretary, Therese Coffey, as follows;


My response to Mr Pursglove is already on its way through the ether as follows:


Dear Mr Pursglove

I am grateful to you for forwarding my letter on the subject of lead ammunition to Defra and for sending the reply by the Parliamentary Under Secretary, Therese Coffey, back to me. Her response, though, is pure sophistry so I would be grateful if you could please send this letter back to her for a proper, less evasive, response.

There are two matters here. The first is that the FSA’s advice on lead consumption, which presumably the government would like us to heed, is as useful as a road sign warning of a dangerous bend which is hidden behind a hedge – nobody sees it or reacts to it.  What steps, on this public health matter, is the government going to take to ensure that the FSA advice is heeded? To remind you and Dr Coffey (who as a scientist ought to know better), the FSA advice includes the words ‘…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 ‘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.‘.

Dr Coffey is strictly correct about what the former Secretary of State for Defra, Liz Truss, said in her letter to the Lead Ammunition Group about the content of their report but at the time she knew (or should have known), and Defra certainly knew that there is good scientific evidence for a population impact of ingested lead on waterfowl populations. This is the scientific paper which provides that evidence .

The government’s position on this matter is hopelessly adrift from the science – and we are talking about matters of public and environmental health.  That’s why I quoted, in my earlier letter, the remarks of Michael Gove as follows ‘environmental policy also needs to be rooted, always and everywhere, in science.’ and ‘But it is only by adherence to scientific method, through recognising the vital importance of testing and re-testing hypotheses in the face of new evidence, through scrupulous adherence to empirical reasoning, that we can be certain our policies are the best contemporary answer to the eternal questions of how we live well and honour the world we have inherited and must pass on to our children‘.

Mr Pursglove, I’m sure I won’t be able to tempt you into any comment on this matter but may I suggest that your covering note when you send this letter on to Defra ought to say something like this:

Dear Therese, I know that your former boss, Liz Truss got us all into this mess but she can’t get us out of it now. My constituent Dr Avery isn’t going to go away and nor will this issue. Your response makes you, Defra, the government and the Conservative Party look foolish and as an MP in a marginal constituency you aren’t doing my electability any good by taking this line on a subject which is of little interest to all but a few.  And that’s the trouble, how can our party pretend to represent the many when we are defending the use of toxic ammunition solely because a few of our own supporters shout loudly, and unscientifically, about it? Come off it, best wishes Tom.

Just an idea.

Thank you again,

Yours sincerely

Dr Mark Avery



29 Replies to “Reply on lead ammunition from Therese Coffey”

  1. Lead shot deposited on moorland catchments when shooting game bird is not harmful to the public via our drinking water so claims United Utilities. United Utilities Plc continues to allow the use of lead shot throughout their Forest of Bowland water catchment by several shooting syndicates despite any risks that lead may or may not pose to public health. Indeed lead shot has been used throughout this moorland region of Lancashire for over 100 years; water taken from this important water catchment is being used for consumption by hundreds of thousands of consumers in the N.W of England today, despite the fact that lead is highly toxic and cumulative.

    1. I am strongly in favour of a ban on lead ammunition but I do not think that it is helpful to the case for this to suggest that public drinking water supplies are at risk from the use of lead shot in catchment areas unless there is evidence that this is the case. Drinking water is subject to strict standards covering allowable concentrations of a wide range of chemicals and microorganisms that are imposed through European (the Drinking Water Directive) and national law (The Water Supply (Water Quality) Regulations). The limit for lead concentration in drinking water was 25 microgammes per litre until 2013 when it was reduced to 10 microgrammes/litre. Water supplies are subject to regular testing against these standards and United Facilities makes the results of water quality testing available via its web-site. The results I have looked at indicate that water supplies in various parts of the UU region have lead levels that are well inside the legal limits.
      I agree that on a precautionary principle basis one could argue that if there is no good reason to disperse a toxic element over a water catchment area then we should not do it even if, so far, there is no evidence of it affecting water supply quality. However, I fear that if we seek to make claims for a significant public health risk that cannot be supported by the evidence, all we risk doing is to allow the shooting organisations to label us as hysterical fear-mongers and divert attention away from more well-founded arguments.

      1. Lead – among others – is termed a “potentially” toxic element in soil contamination jargon despite the fact that there is no doubt about its toxicity. I guess this reflects the fact that it is quite difficult for animals or humans to ingest PTEs when wastes are spread on soil except by direct ingestion which is possible for grazing animals but not all that common in humans. The catchments from which UU collects water lie over some of the highest lead-content geology and soils in the UK, that also have a history of lead mining and where the landscapes are littered with mine tailings and spoil. So – even without the extra burden of lead shot that missed its target – if there was ever a region where chronic lead poisoning could be endemic, it’s in the Pennines (and the Lakes, Mendips, Flint & Denbigh, and parts of South Wales). But it doesn’t seem to be an issue. Nevertheless the study referred to by Mairi below may reveal otherwise, if we all live long enough to see it published …

    2. How convenient of Terry Pickford to forget to mention anything about the old lead workings!

  2. For balance: Dr Coffey is more than strictly correct. Your referenced ‘good scientific evidence’ paper is entitled:

    ‘Possible effects of ingested lead gunshot on populations of ducks wintering in the UK’

    and only provides findings that ‘…….support the hypothesis that ingested lead gunshot might affect population trend.’

    Returning to the good intentions paving company, the affordable alternative to lead shot is steel shot.

    Steel shot is ‘…substantially less dense than lead so pellets at least two sizes larger than lead are normally needed to achieve similar penetration energy levels.’


    Once you increase the shot size, the pattern density falls to levels where wounding is increased at longer ranges.

    The solution is to change equipment to larger, heavier shotguns capable of accepting larger loads.

    As usual, that penalises those who can least afford it.

    The net result of banning lead shot is, in practice, more birds wounded by the irresponsible and, in many cases, the forced giving up of their hobby, provision of nutritious, healthy food, for some of the poorest, hardest working people in the country

    1. But is it “nutritious healthy food” if it is contaminated with lead particles as Dr.Avery’s previous laboratory results showed in grouse? Especially if being fed to women of child-bearing age and children.
      I believe the main thrust of Dr.Avery’s campaign here is to ban driven grouse shooting and that is hardly carried out by the “poorest, hardest working people in the country”. Or are we talking about gamekeepers here? If they are the poorest, then they are being exploited by the rich grouse-moor owners and should do something about it.

      1. Thank you for your response and very interesting question.

        My concern is that the evidence offered is weak and needs to be much stronger to justify any change in the law, particularly one that will particularly disadvantage the less prosperous.

        The risk of ingesting tiny quantities of lead from the occasional treat of lean wild meat, with a lower content of pro-inflammatory omega-6 fatty acids and a higher content of anti-inflammatory omega-3 fatty acids compared to farmed meat, is certainly acceptable to me, combined, as it is, with plenty of exercise and fresh air.

        But you are absolutely correct. Some health agencies do recommend that pregnant women and children avoid consumption of game meat harvested with lead bullets.

        The idea of banning grouse shooting in England, based, as it is, on anecdotal evidence, only, from outside England, will, I think, prove to be politically challenging and, once again, expensive for the long suffering taxpayer

    2. The experience in Denmark, a country where all use of lead shot has been banned since the 1990s, does not support your predictions. Fears of increased wounding did not materialize and likewise the number of people participating in hunting did not decline.
      With respect to your comment about “more wounding by the irresponsible”, I would suggest that the answer to that would be to eliminate irresponsible shooting/shooters rather than persisting in spraying lead all over the countryside. Many European countries operate a hunting license system and shooters are required to undergo some training and/or pass tests before they can get a license to shoot. The introduction of such a system here might be a very good way to address the irresponsibility that so concerns you.

      1. Well said! Thank you very much for your response. The Danish studies that I have read have studied non toxic alternatives to lead, rather than exclusively concerning themselves with steel shot. There are excellent non toxic alternatives to lead shot, but these are expensive compared to either lead or steel. The Danish recommended maximum range for shooting quarry is 25 metres, very nearly half that considered acceptable with lead shot.

        May I sympathise with the sentiment of eliminating irresponsible shooters whilst timorously witholding full hearted endorsement of such a draconian tariff?

        As I mentioned, the use of more powerful shotguns, heavier loads, at shorter ranges will solve the problem of thinner patterns and less penetration, the causes of increased levels of wounding.

        Legislation to ban lead shot will price many out of their hobby and so comes with a political cost difficult to justify in the absence of definitive evidence of the harm caused by lead shot to wildlife.

        However the Danish experience shows that hunting benefits from an improved image as a consequence of the change over to non toxic shot and I, certainly, would be delighted by such a move in this country, provided steel shot is also banned.

        I have used steel shot, and seen it used, and I will never use it again.

    3. “As usual, that penalises those who can least afford it.”

      Those who can least afford it have already pawned their shotguns. Perhaps to help pay for a phonecall to the Universal Credit hotline.

      Sorry to widen the politics here, but you did bring out faux concern on the matters of social equity.

    4. Liz Truss, after long delay but somewhat hastily on the day she was being sacked and cleared her desk, took the narrow view (which was politically convenient for her) that our Lead Ammunition Group report “did not provide ‘evidence of proof of causation’ linking possible impacts of lead ammunition with sizes of bird population in England”. This would be a good text for A level students to analyse and write about in not more than 250 words!

      As I read it, Mark simply said that there is indeed good scientific evidence for population level impacts on waterfowl populations, which is unquestionably true; and on the basis of the precautionary principle I say it must be taken seriously. (It could well be that there are population impacts for raptors and scavenger species too. But that’s another story.) Tim contends that the evidence only supports “the hypothesis that ingested lead gunshot might affect population trend”. I see goal posts moving around the pitch but believe Mark is correct. Liz Truss was being blatantly political. Tim is kidding himself.

      Tim’s assumptions about the performance of steel shot are just that – assumptions – not supported by evidence apart from much comment by users who may have tried a box or two – and contradicted by some serious ballistic and field trials – and moreover conflict with my experience over the past 40 years (let alone the Danes’). I grant you that the performance of steel, having looked at the ballistics, probably tails off faster than lead above 40 yards – but (elephant in room) nobody should be trying to shoot live quarry at such ranges…should they? And if you must you can try Bismuth. In any case it’s not the 30 gms going up the barrel but the 50<100 kilos pointing it that counts.

      Many wildfowlers have been using steel satisfactorily for over 15 years in UK and many of them are far from wealthy. I am not aware of anybody who has 'given up' for this reason. There has been no evidence of more wounded birds. The health risks are precisely as stated in numerous authoritative reports. They should not be overstated but are certainly not insignificant especially for vulnerable groups who we know for certain eat lead-shot game regularly. The shooting and game food worlds should not be complacent about that either – especially with solutions available.

      1. ‘Tim contends that the evidence only supports “the hypothesis that ingested lead gunshot might affect population trend” is a misrepresentation.

        That is not my contention. It is the contention of the report on which Dr Avery relies for ‘good scientific evidence for a population impact of ingested lead on waterfowl populations.’

        The full quote from the report, entitled ‘Possible effects of ingested lead gunshot on populations of ducks wintering in the UK’, is:

        ‘These findings support the hypothesis that ingested lead gunshot might affect population trend.’

        Furthermore, the weak contention of that report relies on another report:

        ‘Poisoning of birds and other wildlife from ammunition-derived lead in the UK’

        which concludes

        ‘All birds that ingest lead gunshot may suffer some welfare effect’

        and then states ‘In the UK, we can broadly estimate the numbers of birds
        from certain avian taxa that are likely to die.’

        These are uncertain foundations indeed for sensible legislation.

        Regarding steel shot, I do not make assumptions. Others, far better qualified than I, have done it for me:

        ‘Steel….Substantially less dense than lead so pellets at least two sizes larger than lead are normally needed to achieve similar penetration energy levels.’


        Regarding effective shooting range in Denmark since lead shot banned:

        ‘For goose hunting, recommendations are that geese should not be shot at when
        the distance from the hunter to the quarry exceeds 25 m’

        I am in favour of legislation against lead shot precisely as a consequence of the Danish experience:

        ‘… is believed, though never investigated, that the public image value of hunting not being connected to a pollutant such as lead is of paramount importance for the perception and long-term political sustainability of hunting.’

        always, however, provided that steel shot (though not other more effective non toxic alternatives) is also banned.

      2. I’ve sat around many working group tables when policy makers take everyone’s opinion of equal value with no regard to weighting these opinions based on the experience of those concerned. This is a major failing in UK democracy as we saw in the ban driven grouse shooting (non) debate. Government ministers and CEOs of shooting organisations should listen to and heed John’s wise words

  3. It amazes me that the shooting community is so resistant to replacing lead given the known impacts on birds, even if there is debate about whether or not there are population level effects. Shooters are always so keen to stress the respect they have for their quarry and the environment in general – just think of the name change to insert the word ‘conservation’ into BASC. But that argument loses all credibility if you are pumping a known toxin into the environment and trying to argue that its ok because it might not impact on populations. Yes, a few tens of thousand birds may die (no-one questions that fact) but that’s ok because the population wont be adversely affected. Where is the respect? When will they realise that they are shooting themselves in the foot by fighting to delay the inevitable?

    1. They don’t care , they are so arrogant, they think they are untouchable , and in England they probably are.

    2. They refuse because they don’t like the proles and plebs getting to tell the gentry what to do, plus they’d have to give up their antique purdeys for modern shotguns and that would put them on the same level as the common shooters in America or France. It is all about status, power, and kicking the poors in the face.

  4. Curious … if lead shot is having such a damaging impact on wildlife, why is there no pressure on MOD using lead ammunition at their firing ranges (some of which, coincidentally, are also wildlife havens).

      1. Errr, no they don’t. They use 5.56 Nato round in the SA80 which is a copper jacketed lead core – also known as a full metal jacket. For obvious reasons steel bullets and steel barrels wouldn’t make good bedfellows. All military ammunition is FMJ (copper jacket – lead core).

    1. Perhaps the answer to your question is that military ammunition is not sprayed indiscriminately across the whole countryside but restricted to a relatively small number of places. Also, of course, the military do not on the whole use shot-guns (I am not an expert on military arms so do correct me if I am wrong) which spread small pellets of lead over the soil surface where they can be mistakenly ingested by birds seeking grit. As far as I can see a tank shell or a rifle bullet is much less likely to leave particles of lead of the right size and in the right place for this to occur (though of course the probability is not zero).
      So, yes, it would be desirable to eliminate this as a source of lead being released into the environment but it is much less of a priority than the lead used by pleasure shooters in their shot guns.

        1. I proposed a reason why buckshot is the priority. Ideally we would not be dumping any lead into the countryside but for the reasons I outlined I believe lead from shooting game represents a much more significant problem for wildlife than military ammunition. Bullets used for shooting deer or boar should not in principle leave significant quantities of lead in the environment, assuming competent shooting and recovery of dead animals but evidence from N America indicates that Californian Condors suffer dangerously high levels of Pb in their blood from ingesting meat from un-recovered shot carcasses and I guess that will include animal shot with bullets and buckshot. That is certainly a potential route for intoxication of various carrion eating species here in the UK too so I would argue that all ammunition used for sport shooting and hunting should be lead free.
          Mark has also highlighted the concern relating to the amount of lead ingested by frequent eaters of game meat. As far as I can see the type of material used in military ammunition has no bearing on that.
          So, yes, it might be nice if the army were to adopt ‘environmentally friendly’ ammunition but it really does seem to be much less of a priority than for a change in the ammunition used by pleasure shooters. It might also be said that the armed force can always (and probably would) mount a ‘required in the defence of national security’ argument to justify the continued use of lead (indeed, in a wholly different context, the Restrictions on Hazardous Substances Directive – applicable to electronic goods and which generally outlaws use of lead in such products – does not apply to “Equipment which is necessary for the protection of the essential interest of the security of member states, including arms, munitions and war material intended for specifically military purposes;”) so there is little likelihood of forcing such a change anyway. Given this difficulty of affecting a change and the relatively low risk to wildlife or humans* from this source it would seem hard to justify much campaigning effort on getting the armed forces to change its ammunition. In contrast the shooting of birds and other game is a purely recreational activity and there is a clear and widespread benefit to be achieved from switching to non-toxic ammunition hence the campaign for change.

          * For the avoidance of doubt I am referring to the risk of ingesting lead originating from ammunition used in training exercises. Clearly when the ammunition is fired at people during an armed conflict the risk to humans is not low albeit not associated with dietary ingestion.

        2. No, Alfie. The main concern with lead bullets is that they fragment (micronise) when fired into an animal. This lead content may be then in certain circumstances be ingested by scavengers e.g. buzzards, kites, eagles and (of current concern elsewhere in Europe) vultures causing them harm if not to die. It can also get into game (venison) products for human consumption and cause additional dietary lead exposure, the consequences of which can be predicted.

  5. Some fair and well constructed points Jonathan. Thanks for taking the time to reply.

    I suppose my own personal opinion is, providing the risks are publicised the it should be left to the individual to make their choice. Let’s face it, as a nation the biggest impacts to long term health aren’t associated with lead from game consumption. National obesity levels (amongst adults and children) are one of the worst in the developed world – should we limit/control the diet of those who’re overweight ‘for their own welfare’? The risks associated with excessive alcohol consumption are also well documented – should we ban alcohol? Don’t even get me started on tobacco! Sorry, but on a generally anti-shooing blog it’s extremely difficult for me to accept there’s any form of sincerity for the long term welfare of people who consume game. The ‘save them from themselves’ message sounds slightly hollow, when viewed in the wider context of the nation’s health.

    Just my opinion, of course, and understand it may differ from yours.

    1. Alfie – it can’t be anti-shooting to support the use of non-toxic ammunition. It is antisocial of shooters to campaign to keep lead ammunition. The dangers of lead ammunition are publicised in a place where nobody sees them!

    2. The personal choice argument would be fine if that was all it amounted to in the case of lead ammunition but I am afraid it doesn’t. Choice implies that you understand the alternatives and the different risks associated with them – that clearly doesn’t apply to the use of lead ammunition:

      1) birds clearly are not making an informed choice when they ingest shot when seeking grit;
      2) children being fed game meat containing lead-shot are clearly not making an informed choice and
      3) adults eating game containing lead shot or feeding to their children may well be not making an informed choice – the FSA warnings about risks associated with lead in game are not exactly prominent and all the information emerging from the shooting industry, game dealers etc focuses only on how healthy the game meat is.

      Very few people indeed will be unaware of the plethora of warnings about the health consequences of smoking, drinking, over-eating or under-exercising so it is fair enough to say that people that do those things anyway are exercising personal choice. If the risks associated with using lead ammunition were entirely restricted to the person choosing what kind of ammo he is going to put into his gun then it might be fair enough to say it just a matter of personal choice bit I don’t think that is the case.

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