Consultation on the Removal of Lead from Ammunition

Removal of lead from ammunition, a Guest Blog by Clovis Pagewood.

DEFRA have asked the UK chemicals agency REACH to provide a consultation document focussed on the removal of lead from ammunition. This consultation ends its public phase on November 6th. The Consultation document is huge, some 500+ pages, containing virtually no supporting scientific evidence. This is despite the total focus being on removing all lead from ammunition.

Sure, there are many scientific papers cited, these in the main involve, it seems, modelling and assumption. Hard scientific fact would be backed by the likes of Mass spectrum lead isotope marker data, for instance. The other potential problem is that many of the papers shown are written or partly written by a small group of wildlife scientists attached to the Wildfowl and Wetlands Trust and RSPB.

The majority of these scientists are listed by the ” militant eco’ ” organisation Wild Justice, as “Friends”. One has to remember that WJ and W&WT want an end to shooting. Indeed, Chris Packham is heavily involved in both organisations and is an avid supporter of the Hunt Saboteurs Association. The reality of this suggests the work of these scientists must be viewed with some suspicion as to its impartiality.

Opinion vs Science

I extracted this confession from one of those scientists when I asked for detailed scientific proof that backed their claims.

“We and many other scientists believe that it is reasonable to suggest that lead shot is the most likely source of poisoning when poisoned birds have lead shot (usually multiple in our experience) in their digestive tracts, particularly when there is no other obvious source of lead exposure to birds in the environment that they occupy.” Hardly a ringing endorsement of detailed, provable scientific study? Indeed, one could question if they have any provable link between spent lead shot and lead poisoning in Wildfowl?

As for the threat to Humans, read the FSA or NHS warnings about lead shot game. You would be led to an assumption that you take your life in your hands tucking into a partridge. My MP provided this table of lead poisoning admissions to hospitals in England over a 10-year period.

These figures average out at 16 .5 people per year out of 17 + million hospital admissions. The average for people admitted having been struck by Lightning is 48 and being bitten by poisonous snakes 92!!!!

Lead vs Alcohol

Lead is a neurotoxin with no known safe level of exposure. This is the same position as held by alcohol, yet the figures for alcohol, for 1 year are these. There were 280,185 alcohol-related hospital admissions under the Narrow definition in England in 2019 to 2020. That’s an increase in the rate to 519 (per 100,000). This represents the second consecutive increase in the rate since 2017 to 2018. Alcohol-related admissions (Narrow): A measure of hospital admissions where the primary diagnosis (main reason for admission) is an alcohol-related condition. If one looks at deaths then it is even more worrying. There were 19,190 alcohol-related deaths in England in 2019, a minor reduction in the rate to 35.7 (per 100,000). The rate shows no significant change since 2016.

Lead is almost impossible to avoid

Most perplexing when considering these two highly “dangerous neurotoxins” is the fact that the FSA state that “it is impossible to avoid lead in food”. Alcohol consumption, however, is a conscious decision to ingest and can be avoided by choice. One could conclude that REACH and DEFRA could be using this consultation as a stalking horse to introduce prohibition of alcohol in UK. It seems there is a far stronger case for this than banning Lead ammunition!?!

As for the environment, there is virtually nowhere in UK that does not have at least traces of lead ore in the rocks and soil. Indeed the FSA confirm it is “impossible to avoid lead in food”. In fact, many root vegetables contain much in the way of lead ions within their skins and flesh. The same can apply to domestic stock and poultry.

However, reading the REACH consultation, which admittedly is focussed on lead in ammunition, this is the primary source of “deadly lead” in UK. There is no science produced to back it up! In conclusion, to any reasonable person it would seem there is no substantive evidence or reason to even consider banning lead in ammunition. In fact, it is questionable if lead shot should be banned for wildfowling. That same reasonable person might, to use the words of the Wildfowl and Wetlands Trust scientists, find it “reasonable to assume that the evidence so far presented is purely assumption”. The actual aim of those presenters is to ban all shooting which may actually be their reason for instigating such reports on a purely emotional level driven by “counterfeit virtue “.

Blatant Discrimination

If DEFRA on behalf of the government acts on this, then they are surely guilty of an act of blatant discrimination. Discrimination against a substantial minority of the UK population. Governments in the last 40 years have managed to reduce and, in some cases, remove discrimination. Particularly with regard to sexual orientation, race, colour and gender. Would it not be paradoxical if, led by emotion only, it decided to discriminate against up to 1 million citizens who participate in Fieldsports in the UK?

One has to remember that similar evidence was presented to the then Environment Minister Liz Truss MP in 2016 by the Lead in Ammunition Group (LAG). LAG wanted lead in ammunition removed. Liz Truss viewed what was presented and rejected the recommendation stating, in both instances – human health and wildlife – the report did not show that the impacts of lead ammunition were not significant. Certainly not enough to justify changing current policy. We therefore do not accept your recommendation the removal of lead from ammunition. The reality in 2022 is the situation has not changed at all!

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