Mark writes: John Swift is the former boss of the British Association for Shooting and Conservation and from 2010 chaired the Lead Ammunition Group set up by the last Labour government which reported to government in 2015 and which was treated so shabbily by the outgoing Secretary of State for Environment, a certain Liz Truss, in 2016.
LAG has continued its work and has regularly updated the information on science.
Matters are reaching an important stage as a public consultation is currently ‘live’ and will close at midnight on 10 December. Things are moving, but very very slowly because the shooting and ammunition industries are very good at keeping any issue in the long grass. Here John writes of his hopes for the future.
Replacing lead ammunition in Great Britain is at last now under serious consideration. Lead shot and bullets have been integral to shooting for hundreds of years. Something that is integral will, by definition, be very important or necessary to those involved. Shifting that mindset has been far reaching and challenging.
This is a strictly personal reflection on steps on a very long road.
In 2008 following a truly ground-breaking Peregrine Fund conference in Boise, Idaho, USA, entitled The ingestion of spent lead ammunition and the implications for wildlife and humans, I and many others realised that the problem was much bigger than “lead shot in wetlands”, which had been our preoccupation for 20 years. Replacing lead ammunition was looking like a fundamental challenge to shooting as a whole.
The Lead Ammunition Group (LAG) was established by Government in 2010 as a consequence. It is a body of independent stakeholder representatives, including shooting interests, to advise what should be done about the problems caused by lead ammunition. We reported to Defra in 2015. And thanks are due to all those who have been contributing at no cost to LAG.
After five years of work all of which is recorded on our website, we started to draw conclusions and prepare a final report in mid-June 2014. All members of the team agreed in principle to hold a consultative forum as part of our wider stakeholder communication, but shooting stakeholders regrettably demurred when faced with the reality that a convincing “pro-lead case” was not about to balance the agenda.
Even so, the Oxford Lead Symposium: Lead ammunition, understanding and minimising the risks to human and environmental health, went ahead in December 2014, thanks to Professor Chris Perrins LVO FRS, at the Edward Grey Institute, University of Oxford.
As I continued writing the final report it became inevitable, after discussion with Defra, that the report should be concluded even if some of our stakeholders were unhappy about doing so. The Report was duly submitted in June 2015 and it has certainly stood the test of time. Stakeholders who disagreed then resigned.
Our conclusion had to be that the only way to get rid of all the many problems that lead ammunition does to our environment, wildlife and human health is replacement of lead with the known alternatives.
We also recommended, which the then Defra Secretary, Liz Truss ignored, the creation of an action plan requiring further discussion among all stakeholders, to bring about:
· Either industry-led self-regulation by shooting sports, or
· A clear directive from Defra and FSA requiring such self-regulation, or
· Defra developing statutory and regulatory measures.
That is where we are now.
A year later in July 2016, on the afternoon of the resignation of prime minister Cameron, as a last act before being reshuffled, Truss sent an email to say that she thought “the impacts were not significant enough to change current policy”.
That was her opinion, but LAG remained actively reviewing the evidence about the conservation and health problems caused by lead ammunition as it continued to mount. These emerging insights are summarised in LAG’s update report in 2018. The report referenced 81 more peer-reviewed papers covering many aspects of the problem, and owed much to Professor Debbie Pain’s scholarship.
In 2019 attention turned to the risks to consumers posed by the lead levels in game food products sold on supermarket shelves. I have heard friends say, “I’m as fit as a flea it can’t be that bad”. But two things: food policy must first and foremost protect the vulnerable; and secondly, low-level exposure to lead has long been known to cause both expected and unsuspected harms to some extent whether you know it or not. Hence Waitrose pledged that by the season 2020/21 all their game would be brought to bag without the use of lead shot. We admire their leadership but it was a pledge they were not able to keep despite assurances from their suppliers.
With an increasingly untenable position of defending lead ammunition, pressures mounting from international agreements, and EU processes afoot to restrict lead ammunition, in February 2020 “the Earth moved”. The shooting organisations issued a joint statement declaring their intention to phase out the use of lead ammunition for live quarry shooting with shotguns within 5 years.
LAG’s interest was whether game shoots would adopt this phase out. There are several people to thank for investigating this question, not least Professor Rhys Green at Cambridge. First, it was found that the lead content of game meat products going onto supermarket shelves grossly exceeded the legal levels for beef, sheep, chicken and other farmed products. Second, the proportion of retailed pheasants shot with non-lead remained stubbornly small. The phase out appeared not to be working – laudable though it was.
In March 2021 the Earth moved a bit more. Defra announced that the Government itself was considering a ban of lead ammunition throughout England, Wales and Scotland. The Health and Safety Executive (HSE) assisted by the Environment Agency (EA) would do the preparatory work.
I do not labour the painstaking process, public consultation and scientific oversight through which this initiative has gone. HSE, assisted by EA, has produced a large formal background document updated to October 2023 following 6 months public consultation, assessing what action is needed. This is supplemented by the HSE’s Opinion dated 11 October 2023 proposing necessary restrictions on lead ammunition and is itself subject to public consultation that closes on 10 December. As things stand the restriction proposal is for:
While the restrictions on lead shot are supported, it remains to be seen whether shooting live quarry with lead bullets remains unrestricted. There is no reason why this should remain unchanged. In LAG’s opinion all lead ammunition used for deer and boar management should be restricted. The risks lead bullet fragments pose to raptors – as well as in the human food chain – are quite clear. Being unable to monetise the benefits of not poisoning these important constituents of our natural heritage within the HSE documentation is disappointing. No doubt the public consultation will shed more light.
Thereafter, within 3 months, the Defra Secretary of State with the consent of Scottish and Welsh Ministers will publish the draft restriction – with a negative statutory instrument then made and laid in the UK parliament, again with the consent of Scottish and Welsh Ministers.
This HSE restriction process is unlikely to be re-visited anytime soon and if this matter of restricting lead bullets is not dealt with now, it would be a disgrace.[registration_form]