Public health

The Food Standards Agency (FSA) in 2012 conducted a risk assessment on lead exposure from game meat consumption, based on a consumption survey of high-level consumers of lead-shot wild-game meat in Scotland and pre-existing data on lead levels in these types of food in the UK. The risk assessment concluded that regular consumption of game meat could increase exposure to lead, and that this increased exposure would be a concern in the case of toddlers, young children and pregnant women, because of the neurotoxicity of lead to the developing brain.

The report highlighted that lead levels were higher in smaller game (birds) than larger game (venison)

In response to growing concerns about the effect of poisoning on humans and wildlife from lead ammunition, the DEFRA and the Food Standards Agency-commissioned Lead Ammunition Group was formed in 2010 with a remit to identify and assess key risks (Lead Ammunition Group 2018a).

The Group’s findings were published in 2015 (Lead Ammunition Group, 2015) and include the following conclusions, as detailed in a summary letter to DEFRA from John Swift, the Chair of the Lead Ammunition Group (Swift, 2015):

•  Lead is a highly toxic hazard and presents risk at all levels of exposure. It is especially dangerous as a neurotoxin for both young people and for wild animals.
• Some 6,000 tonnes of lead from ammunition used in shotgun and rifle shooting are being discharged every year. At least 2,000 tonnes of shot used for game and pest shooting are irretrievably and unevenly deposited on or close to the soil surface where it is available for ingestion by birds. It probably becomes unavailable to them quite quickly, though it remains in the soil and substrates for a long time with as yet unknown consequences.
• Lead from ammunition can (and does) get into wildlife by several routes, mainly by ingestion by many species of bird in mistake for grit or food items, or in scavenged dead animals, or as the prey of some raptors. In areas of intensive shooting lead is taken up by some plants and soil microfauna getting into the food chain, but the research studies that have been done on this latter route are limited.
• Lead from ammunition causes harm to wildlife and certainly kills some birds. Numbers are hard to be certain about, but almost certainly at least tens of thousands to hundreds of thousands annually in UK. The welfare effects in these animals, and the larger numbers that ingest sub-lethal doses, are sufficient to cause illness and can be very severe and prolonged for them.
• Lead shot and bullet fragments can be present in game meat at levels sufficient to cause significant health risks to children and adult consumers, depending on the amount of game they consume.
• Almost certainly some 10,000 children are growing up in households where they could regularly be eating sufficient game shot with lead ammunition to cause them neurodevelopmental harm and other health impairments. Tens of thousands of adults are also exposed to additional lead by eating game as part of their normal diet, and this could cause a range of low level but harmful health effects, of which they will not be aware.
• For human health there is no evidence that existing advice from FSA and other stakeholders has so far reached target groups or affected game eating habits.
• There is currently no evidence to suggest that the will, funding or resources exist, or are being planned, to develop measures that will ensure that game and venison containing lead levels above those permissible for red meat and poultry do not enter public markets as food.
• For small game, no proposals have been made to the Group for any measure, short of lead shot replacement, that would ensure that small game entering the food chain do not have elevated lead concentrations.
• Safer alternatives to lead ammunition are now available and being improved and adapted all the time for use in different shooting disciplines. There is considerable experience from other countries where change has already been undertaken.
• There is no evidence to suggest that a phase out of lead ammunition and the use of alternatives would have significant drawbacks for wildlife or human health or, at least, none that carry the same scale of risks as continuing use of lead; though there are procedural, technical and R&D issues still to work on and resolve.
• There is no convincing evidence on which to conclude that other options, short of replacement of lead ammunition, will address known risks to human health, especially child health.

As this is a devolved issue the Scottish Government is entitled to draw its own conclusions and adapt policy in favour of the Lead Ammunition Group’s recommendation.

The Revive Coalition calls for a complete ban on the use of lead ammunition on all peatland

Currently in Scotland, the use of lead ammunition is prohibited over wetlands under the terms of the African-Eurasian Waterbird Agreement (AEWA). For the purposes of the AEWA, ‘wetlands’ are defined by reference to Article 1(1) of the 1971 Ramsar Convention which state:

“For the purposes of this Convention wetlands are areas of marsh, fen, peatland or water, whether natural or artificial, permanent or temporary, with water that is static or flowing, fresh, brackish or salt, including areas of marine water the depth of which at low tide does not exceed six metres.”

The inclusion of ‘peatland’ in the Ramsar definition of ‘wetland’ would include many upland areas managed for driven grouse shooting. However, the Environmental Protection (Restriction on Use of Lead Shot) (Scotland) (No.2) Regulations 2004 deliberately exclude many driven grouse moors from regulation as ‘peatland’ is specifically defined in this Scottish legislation (Para. 3(2)(b)) as, “only peatlands with visible water”.

However, in September 2018 the European Chemicals Agency identified further risks to the environment from lead ammunition and submitted recommendations to the European Commission to regulate the use of lead ammunition in terrestrial as well as wetland environments (European Chemicals Agency, 2018). If implemented, this may prohibit the use of lead ammunition on all peatland areas including land managed for driven grouse shooting.

Revive believes that peatland should be included in this definition to protect our people and our wildlife from the unnecessary risk that comes from lead shot.