My personal response to the HSE lead ammunition consultation

A live public consultation by the Health and Safety Executive on the future of lead ammunition is in play until 23:59 on Sunday 10 December.  This should see the end of the use, sale and availability of lead shot and lead bullets for shooting at live quarry – also known as live animals. Such regulation is long overdue but government, its agencies and to some extent the wildlife charities that should have pressed for action have delayed the inevitable for many years. Are we going to see the final successful resolution of this issue soon? I hope so, but the champagne will be kept on ice until we really know.

If you want to have your say then you will be hampered by the highly technical, and frankly abstruse, nature of the consultation. However, once you cut through the obfuscation it would probably only take you 15 minutes to make a difference – every person who responds will be making a difference. Every person who doesn’t respond will be risking a poor outcome.

If you want to respond then my advice is to read the Wild Justice blog which gives advice on how to spend a few minutes of your time most profitably in sending a response – click here. But you can go ahead and do it on your own if you like – here is the link.

This is some of my rather personal response to the consultation – it’s not suitable to be used as a model for your response (see the Wild Justice blog instead) – but then, I have had an involvement in this issue for getting on for 30 years.

Question: Due to the voluntary agreement to transition away from lead ammunition for use in live quarry shooting by 2025, the Agency is considering a shorter (e.g., 3-year) transition period for this use.

Please provide information you have regarding the viability, difficulties and benefits of a shorter transition period for the use of lead ammunition in live quarry shooting with shotguns

My answer: A short transition will not only reduce the input of a poison to the environment and food through future restrictions but will make it increasingly difficult for the c25 years of blatant disregard of existing laws on use of lead ammunition in wetlands and for shooting certain waterfowl species to continue. The shooting industry has a long and tawdry track record of ignoring laws and regulations (eg continued shooting and poisoning of protected wildlife and burning of protected blanket bogs) and compliance with existing legislation on use of lead ammunition has been very poor. The proposed measures can be seen not only as extra measures for new situations but also measures for providing much-needed extra certainty for compliance with existing laws. I support a 3-year transition but would prefer a 2-year transition.

For the avoidance of doubt, I would also support a 3-year (but better, 2-year) transition on the use of lead bullets in shooting live wild animals. You seem to have forgotten to ask me about that issue in this public consultation – my first opportunity to express a view on it.


Question: Monetised benefits associated with restricting lead bullets for live quarry shooting.

Do you have information regarding the monetary benefits associated with reducing the risk of secondary poisoning of raptors from the use of lead bullets e.g., from WTP-based evaluations or similar?

My answer: This is an issue that I understand but your question fails to meet the standards for a proper public consultation. You have not explained what this is all about, you have not explained ‘WTP’, ‘secondary poisoning’ or ‘monetised’ and you are therefore excluding many potential respondents in a public consultation.

However, I think you are getting at the benefits of restricting the use of lead bullets for the purpose of shooting live animals such as deer and wild boar.

For the avoidance of doubt, I would also support a 3-year (but better, 2-year) transition on the use of lead bullets in shooting live wild animals.

My reasons for that are varied but I’ll start with your issue of poisoning birds of prey:

  • there is a huge literature on the impacts of lead on wildlife including birds of prey and other predatory and scavenging birds and mammals when they ingest lead from ammunition shot into other animals through hunting. I don’t want that to happen because I like birds of prey (and other wildlife) and value it in social and economic terms very highly. There are non-toxic alternative ammunitions available which avoid this issue. I am firmly of the view that non-toxic ammunition should be the norm and I and large numbers of other people would be willing to pay, in theory, to see that achieved. But a much better alternative is simply to act like a proper regulator and restrict its use. That, to be clear, is what I want you to do as quickly as possible.
  • you are probably aware that in several range states of the California Condor the use of lead bullets for hunting, especially deer, has been banned on similar grounds. This has had no impact on hunting levels, indeed my understanding is that hunters are now proud of, and bragging about, the contribution they have made to conservation.
  • UK governments have an obligation to conserve threatened wildlife and  restricting the use of lead ammunition is a very simple way partly to  discharge those responsibilities. Failure to take the right measures would be a serious abrogation of responsibility. So please, just get on with it.
  • more broadly, and not touched upon by the questions in this public consultation, switching from lead to non-toxic bullets in shooting live quarry is simple and has been done by many already. The regulation is behind the curve and so you should act decisively.  As a personal example, 13 years ago I wrote this account, as RSPB Conservation Director, of how RSPB trialled using copper bullets instead of lead bullets (15 years ago) at four sites where deer were controlled (ie killed) for habitat protection reasons – click here. Our RSPB deer stalkers found no problems, were relieved that the venison that their families and others were then eating was lead-free and when given the option to return to lead turned it down.
  • my understanding is that practically all use of lead bullets ceased on Forestry England land in 2016 – click here.
  • my understanding is also that use of lead bullets for deer control in Scottish forests is now very low following the recommendation of this group in early 2020 – click here.
  • since there is no maximum allowed level for lead in game meat (a perverse situation when lead is shot into game) and no obligation for the high lead levels in game meat to be identified through labelling or health warnings,  restricting the use of lead ammunition, shot and bullets, is a necessary means to protect the public, including the most vulnerable sections such as expectant mothers and young children from eating high levels of lead. Wild Justice has carried out much of the testing of game meat for sale in supermarkets (see here for example) and shown that lead levels are very high, far far higher than in non-game meats, and far far higher than would be legal in non-game meats. You must be aware of the Food Standards Agency advice (click here) and NHS advice (click here) on consumption of lead but very few people walking into a butcher’s shop, game merchants or supermarket have any idea of the health risks of lead. The shooting industry still pushes game sales as healthy options. This consultation needs to lead to the removal of the danger of eating lead-contaminated food whether it be deer carcasses or grallochs by Golden Eagles on Scottish hillsides or Pheasant breasts on sale in London supermarkets

General comments

My comments: for the sake of absolute clarity:

  • I support the draft Agency Opinion that restrictions on sale and use of lead shot for shooting live animals should be brought in as a matter of urgency
  • I support those restrictions being brought in after a transition period which is less than five years; I would favour three years rather than five (see my response to that question above) but I would urge an even quicker transition because this simple and necessary measure has been delayed overlong
  • and particularly, since this question has not specifically been asked in this consultation, I support similar urgent restrictions being brought in for the use of lead bullets for shooting live animals

Further general comments:

  • I was RSPB Conservation Director back in the late 1990s when a Labour government secured a partial ban on the use of lead shot – just for wetlands – in the Environmental Protection (Restriction on Use of Lead Shot) (England) Regulations – click here – (and similar regulations followed  in Wales and Scotland).  It is a pity that more widespread restrictions on use of shot for shooting Pheasants, Grey Partridges, Red Grouse, Woodcock etc weren’t introduced then but it is scandalous that this matter has not been brought to a conclusion in the intervening 25 years.
  • I wrote (as RSPB) with Debbie Pain (as WWT) in 2009 asking government to set up the Lead Ammunition Group – click here – and that was what kicked off the next round of cogitation.
  • the case for quick and decisive action was made in the 2015 Lead Ammunition report – click here – and everything since then has simply been an unnecessary waste of time. Liz Truss’s stated reasons for not accepting the findings of that group were a mixture of a lie (there was evidence for population-level impacts and she and her Department knew that) and callous disregard for the proven health impacts of eating lead contaminated meat – click here, here and here. 
  • I do hope that this process will now throttle off use of lead shot and lead bullets for shooting wild animals throughout Great Britain, just about completely, and in short time. It is shocking that it has taken so long, if it takes any longer it will be even more disgraceful. It appears that those who should be regulated for the public good have been able to persuade decision makers to act slowly if act at all for the last 13+ years. Restricting use of lead ammunition for environmental and human health reasons is not a brave decision – it is a very simple one. Let it be done!  Sometimes difficult decisions take time to be made but it is a damning indictment of both Whitehall and Westminster that such easy decisions have taken so long to be made.

5 Replies to “My personal response to the HSE lead ammunition consultation”

  1. I have sent a response to the consultation, expressing support for restrictions on sale and use of lead ammunition to be introduced as soon as possible.
    Hopefully many others have too.
    Let’s hope that this time round the issue doesn’t get booted into the long grass. It’s hard to see how they can avoid acting now but with the present shower in government I am not counting any chickens – particularly since Rishi seems to have got it into his head that being anti-environmental is his pathway to electoral redemption.

  2. I replied to the consultation before I received suggestions as to how to reply. I did find some of the questions obscure and did not seem to cover areas which I thought important. I’d have liked to receive advice much earlier. Thanks for your copy of your response. It explains some of the areas where I was confused.

    1. Alex – if you were subscribed to the Wild Justice newsletter you would get regular advice on petitions to sign and on a few consultations a year.

      1. I do subscribe but I had replied to the consultation before the newsletter arrived. I should have awaited hoping that I could receive help nearer the due date. Your blog item was most revealing.

  3. The questions are obscure because this is not a neutral consultation – it is designed to allow the Minister to delay the ban as long as possible and to exclude comment from outside the shooting community. The question about monetising secondary poisoning is simply ridiculous, especially as there will be no cost to shooting or shooters once the transition is made the only reason non-lead shot is more expensive is because there’s little demand.

    The only reason the Government might shift on this – and this is something to watch on a much broader scale -is to embarrass a future Government – we’ll see more of this as the election approaches and be in no doubt that were the conservatives re-elected they would renege on their own commitments without batting an eyelid – as they are doing constantly on environmental policy they are failing to deliver.

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