COUNTRYSIDE ALLIANCE

This Countryside Alliance briefing has been prepared in response to correspondence from Dr Debbie Pain from the Wildlife and Wetlands Trust (WWT) regarding risks associated with lead ammunition. This is a brief on the issues which gives some balance to the points raised. It is important to understand that due to the very nature of shooting in the UK, issues surrounding lead ammunition are very complicated and cannot be easily solved with an outright ban. Such a move would have serious ramifications for the whole shooting industry, estimated to be worth £1.6billion to the economy. Attached is a brief on lead ammunition which explains these issues. We hope you find this brief, which has been sent to Parliamentarians, useful. 

This latest communication appears to be part of a concerted campaign by individuals at two wildlife charities, the WWT and the RSPB against the shooting community. This campaign, details of which were leaked publically earlier this year, not only plans to raise concerns about lead ammunition in the environment, but also sees creating a food scare around human health implications as a means of progressing this campaign both in the UK and Europe. In the process, they are subverting the work of the Lead Ammunition Group (LAG) which has a clearly established process and is currently assessing the issues surrounding lead ammunition. This working group was established by DEFRA and the FSA at the request of the WWT and RSPB and is due to report shortly.

Lead Shot in Wetlands – The Facts

• Due to the unique way that certain waterbirds feed, some species are susceptible to ingesting lead if it is deposited in their feeding area. This was highlighted as a source of poisoning for some wildfowl species, including several migratory birds. To address this, the African-Eurasian Waterbird Agreement (AEWA) aimed to reduce the amount of lead ammunition used it wetland areas where such wildfowl feed. The feeding habits of non-wetland birds are very different, and are not affected by lead in silt layers of wetlands.

• The UK, in order to comply with the AEWA, has prohibited the use of ammunition containing lead for the killing of certain species or specific areas as follows:

England and Wales
In England and Wales, the use of lead shot is prohibited below the High Water Mark of Ordinary Spring Tides, over specified SSSIs, and for the shooting of the following species, regardless of where they occur:

Duck (Mallard, Wigeon, Gadwall, Shoveler, Teal, Pochard, Pintail, Tufted duck, Goldeneye)
Geese (Greylag, Pink-footed, White-fronted, Canada)
Waders (Golden Plover)
Coot and Moorhen

Scotland and Northern Ireland
In Scotland and Northern Ireland, the use of lead shot is prohibited over wetlands. Wetlands are defined as any areas of foreshore, marsh, fen, peatland with standing water, regularly or seasonally flooded fields, and other water sources whether they be natural or man-made, static or flowing, fresh, brackish or salt.

• The recent study produced by the WWT shows nothing that we do not already know, and legislation currently exists to protect water birds from this very threat. Reading through the report however, there appear to be many inconsistencies and inferences are made which amount to one very low numbers of birds tested.

• Many of the wildfowl tested in the study are migratory species, and as such have travelled many miles from various different locations. Although the WWT provide assurances that these birds obtained the lead in the UK, there is simply no way of proving this. Moreover, sources of lead poisoning can come from many sources, as previous research has shown that birds from urban have higher levels of lead in their blood. This is not acknowledged.

• For those species that are non migratory, questions must be asked how these birds, which were only tested from WWT reserves, are obtained this lead shot whilst resident on these reserves. As these reserves are not shot over, the most probable explanation is that lead that was dropped in these areas prior to any legislation. Indeed, Sir Peter Scott, the founder of the WWT was keen wildfowler and would have used lead ammunition in his day. This is further evidenced by the fact that no evidence any other form of shot type found in the bird’s gizzards. Given that these alternatives have been widely used for over ten years, this would be expected and which further confirms the birds obtained the shot from the reserves.

• The suggestion of this paper is that restrictions on lead ammunition are made across all forms of shooting, not just wetlands. Legislation exists in the United Kingdom to prevent such poisoning of waterfowl. There is however inconsistent national regulations across the migratory routes of many birds. The Countryside Alliance along with all other shooting organisations supports these regulations to protect our wildlife. We will continue to ensure that those who shoot comply with these regulations, but seen no evidence to suggest that a wider lead ban needs to be implemented.

Lead and Human Health – The Facts

• This week, the FSA (Scotland) were due publish a report into the human health aspects of lead ammunition. It was decided instead that the report was to be presented to Lead Ammunition Group before being made public. Although we do not know the contents of the report, it is assumed that it would suggest a maximum amount of game that could be consumed in a given period. There appears to have been a certain amount of preparation prior to publication, with many media outlets being contacted alerting them to expect the report. Some confusion therefore occurred when the decision was made not to publish the report.

• We welcome any precautionary approach to food safety, but we must always remain practical. It is important to note that lead, along with many other substances classified as toxic, exist in small quantities in virtually all food that is consumed including potatoes and greens. No one risk should be viewed in isolation, potential risks from lead ingestion therefore exist with all types of food types if eaten to excess.

• The fact is that virtually every food contains lead and its consumption is unavoidable. According to a recent study by the European Food Safety Agency (attached), venison meat contains half that of garlic and pheasant meat a third of that found in certain mushrooms. Weight for weight, there is more lead in some forms of chocolate than any game meat found in the UK. The EFSA further identify bread, tea, water and potatoes as the foods which contribute the most lead to the average adult diet.

• In addition, data from the NHS Hospital Episode Statistics illustrates the very low number of lead poisoning cases when comp-ared to poisoning caused by other toxic substances. Between 1998 and 2011, 19.6 people a year on average are admitted for treatment for the toxic effects of lead. By comparison, 125 a year on average are admitted for the toxic effect of soap and detergent, 982 for the toxic effect of ethanol, 69 for the toxic effect of ingested mushrooms and 40 for the toxic effect of snake venom. Of these lead poisoning cases, the vast majority of those admitted to hospital for treatment for the toxic effect of lead were male and in their late 20s and early 30s, suggesting that occupational hazards when dealing with lead are the greatest risk factor in UK poisonings.

• Investigations must also take into account butchery and cookery methods involved in processing any game meat shot with lead ammunition. It is usual for wound channels to be removed when processing meat and forms of best practice may mitigate and potential risk to levels consistent with conventional meats. There is also serious concern that alternatives to lead ammunition, especially tungsten, could also have serious implications for human (and, for that matter, environmental health) which have not been thoroughly explored or studied. Such studies must be completed before any widespread move is made to any alternative form of ammunition.
The Lead Ammunition Group

• The Countryside Alliance is committed to the process of the Lead Ammunition Group, which was formed at the request of the RSPB and WWT. This group is currently investigating the potential issues which surround the use of lead ammunition in a thorough risk based approach. The group, of which we are a part, is expected to report their conclusions and recommendation in the near future. No pre-emptive decisions should be made until this group, set up jointly by DEFRA and the FSA, has reported its findings.

• It is important to note that the LAG was created at the request of Mark Avery (RSPB) and Debbie Pain (WWT). Details of the request can be found here. It now appears that these organisations are undermining the process of the Group, by publishing papers and research publically and not referring their work to the group.