Tne justification for enforced "qualification" of Scottish stalkers (SNH FOI request)

caorach

Well-Known Member
As some may recall there was a thread a while back where, to my shock and dismay, even a small number of stalkers were treating calls for enforced training and qualification with some glee. While explanation for their personal position is beyond my talents or understanding I thought it might be possible to investigate the reasons underlying the government/SNH position that we need more paperwork.

My position with training and testing of any type is that it is first necessary to establish a need or a failing on the part of the target trainees. To do this you need evidence in a form that can be measured so you can establish the nature of the need, the means to correct the problem, the exact training to be given and then, most importantly, after the training you can measure the improvement.

With these points in mind I stated on the thread that I would contact SNH, who are pushing the calls for training, with a FOI request with a view to establishing the information they are using to support their demands for training. I asked questions about the areas which appear, on reading this forum, to be where most people consider stalkers present a risk. I asked only about fatalities as past experience has indicated that this is a very simple metric which is not prone to manipulation (i.e. it is easy to count dead people and there is no "wiggle" room to up the figures by making stuff up.)

The questions I asked are as follows, this is the exact text I sent to SNH so there is no room for ambiguity:

Please consider the following a request for information under the Freedom of Information Act (Scotland).


Please provide the information relating to the following for the period of the previous 5 years. Ideally I would like individual sets of figures for each year but a total for the last 5 years for which figures are available would be acceptable if producing detailed information would result in excessive cost:


1) The number of people killed by firearms while the firearms were actively being used by deer stalkers for the purpose of shooting deer.


2) The number of people killed by food poisoning, or other illness, contracted by eating wild venison which was shot in Scotland and where the source of the infection was shown to be as a result of mishandling of the meat by the deer stalker.


3) The total number of people killed by food poisoning, or other illness, contracted by eating wild venison which was shot in Scotland.


4) The number of CONFIRMED cases of animal welfare issues concerning deer that were shown to have been caused by stalking or stalkers.

The SNH reply will follow in the next post on the thread.
 
The SNH reply is as follows, I've quoted their answers exactly but removed all the info about appeals etc. as that doesn't add any information relating to our position:

1) We do hont hold data on the number of people killed by firearms while the firearms were actively being used by deer stalkers for the purpose of shooting deer. SNH are no aware of any deaths involving firearms used in deer management activities over the last five years in Scotland.

2) We do not hold data on the number of people killed by food poisoning, or other illness, contracted by eating wild venison which was shot in Scotland and where the source of infection was shown to be as a result of mishandling of the meat by the deer stalker. SNH are not aware of any people being killed by food poisining, or other illness, contracted by eating wild venison which was shot in Scotland and where the source of the infection was showing to be as a result of mishandling of the meat by the deer stalker.

3) We do not hold data on the total number of people killed by food poisoning, or other illness, contracted by eating wild venison which was shot in Scotland in the last five years. SNH do not know of any deaths associated with food poisoning, or other illness, contracted by eating wild venison which was shot in Scotland in the last five years.

4) We do not hold any data on the number of confirmed cases of animal welfare issues concerning deer that were shown to been caused by stalking or stalkers. SNH as part of the Best Practice steering group has produced a series of guides which aim to prevent or mitigate welfare issues arising from the management of wild deer in Scotland. The guides are available on-line at welcome to BPG
 
Probably containing a big fat zero! ........... (Hopefully)

I personally think it is much more interesting that they don't keep the information at all - how can you possibly justify introducing a whole new layer of expense, paperwork, regulation, law, civil servants and so on when you don't even bother to keep records? However, you are correct in the sense that they have also very helpfully detailed that they are not aware of any hygiene or firearms safety risks posed by stalkers.

Now, of course, is is possible that other organisation keep these records but it isn't the other organisations who are calling for further testing and regulation and, quite simply, I think the buck stops with SNH in this case. I'm not going to pay for your regulation, pay for you to have more staff, pay to take your training course, pay to sit your exam and probably pay to renew it every 5 years on the basis that some interfering busy body wants to have more say in what I do in my own time.

The other key point to bear in mind that that they have very carefully answered the questions I've asked and this may indicate that they are calling for competence testing for reasons other that the areas I asked about. However, I believe I've asked about the main areas of public concern and accountability and, therefore, other reasons could only be minor or politically motivated rather than related to the actual competence of the stalker. Once more I think we are looking at someone wishing to interfere in the private lives of others just because these private lives are unregulated rather than because there is any evidence of risk to the public.
 
The level of competence has been set and by 2014 SNH will decide that we are to continue to use the private sector to reach the competence lev or if SNH will take over and make there own training available. SNH will not have the money to set up a full competency system and for the reasons you point out will not get them past government. So we will be left with BASC BDS SGA etc setting the standards and SNH will say it was voluntary.
Great post caorach.
May i ask what the minister for the environment said about the questions and answers and his feelings on this after all it will be him that puts the final seal on things.
 
Neck out time!

I personally feel that stalkers need to have some form of formal training and have demonstrated competence before being let loose with a firearm, level 1 or otherwise. In the services you have to complete appropriate training before you handle a weapon and obviously there is a very strict set of protocols for RCO's and the training soldiers on the range. The idea that a person can get a hunting rifle or shotgun and attempt to hunt animals without first having demonstrated the necessary competence to do so is quite frankly disturbing and unwise. Would you allow a person who has just got a shotgun or firearm of limited skills and experience to take your child out in the field for 'a bit of fun'?

I do not claim in any way the DSC1 is in any a designed standard to demonstrate a person is competent in every area of sporting shooting but it is the best we have at the moment that requires a candidate to pass safety related elements that are fundamental to proper field practice and conduct with firearms capable of hunting large game.

I expect that in the future, people applying for firearms licenses followed later by shotgun licenses will be required to qualify to a recognised standard before they can use their guns freely. This is only something that brings us in line with other countries in Europe that have strong and more accepted hunting traditions.

Perhaps by raising the standards a person has to achieve to first own their guns and then hunt game, the general public might then greater respect the hunting community. Who knows? Fighting in and moaning about it will at best delay the process and your efforts might be better applied preparing for the changes ahead because they will come.
 
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I think you are on a slightly different tack though Paul in the sense that there is no one denying that stalkers need to be competent however, as SNH have indicated, there is no evidence that those currently stalking are in any way lacking in competence. We don't need more regulation quite simply because the situation is already self regulating. The police are checking that we are fit to hold firearms and stalkers themselves are ensuring that they are competent to use them and to deal with the hygiene and animal welfare aspects of the sport. SNH quite simply can provide no evidence of any lack of competence or any need for further regulation.

Given this, and that SNH will probably be the competent authority in terms of guiding ministers, there is no need to prepare for changes because there is absolutely no reason for changes to be implemented - stalking is safe, presents no risk to the public, provides a valuable management service with no known risk to animal welfare and the only reason to regulate it further would be if there was political pressure, and politicians are elected and work for us, or if some interfering do-gooder with nothing else to do with his time happened to have a personal dislike of our sport and to find himself in a position to interfere to the detriment of the sport.

Now I appreciate that you provide training but not having training forced upon us does not mean that stalkers will not be undertaking training of their own accord. Remember the information provided indicates that stalkers are competent and they are getting this way themselves, which is to say that many are undertaking training of their own free will when they identify a weakness or lack of knowledge on their own part. I think it is much more desirable to provide training to someone eager to learn and on subjects that they, often as experts in their field, feel they are lacking than in having groups of people forced to sit through a training programme which is forced upon them and, therefore, for which they begrudge handing out the cash. I am also fairly certain that if the "government" get a hand in training then they will want more and more control until it turns into a nightmare for those involved who actually know something about deer and deer management. Given all of this I might suggest that the situation as it is currently is not only better for stalkers but also, potentially, for training providers.
 
Caorach, was the reply as written verbatim their reply? If so I'm disgusted that someone working for a government department, in a public facing role, has such a poor standard of English. Some of the replies are barely decipherable!

As for the requirement for training, I totally agree Caorach. If there is no evidence of a risk that is to be mitigated by implementing compulsory training, then how do you justify imposing such requirements? The fact that someone feels that something is dangerous doesn't justify imposing layer upon layer of red tape and expensive bureaucracy absent evidence of there being an actual risk.
 
Don't worry about the spelling etc. Matt as the typos were probably introduced by my transcription - they sent me a letter so I had to type it all out again and couldn't just cut and paste. I should go through it and correct it now. However, apart from my finger trouble the wording is as they sent me.
 
May i ask what the minister for the environment said about the questions and answers and his feelings on this after all it will be him that puts the final seal on things.

Sorry, I didn't reply to this yesterday. Bear in mind that this was one FOI request which came out of a recent thread and so I was looking information to address the issues raised on the thread. For want of a better term my "remit" didn't extend any further.

However, I suspect that SNH will be considered the competent authority and so the minister will take his position from the one they indicate appropriate. Of course there could be political horse trading which might move the final position away from that recommended by SNH but I was interested in the bottom line - are stalkers a threat to the public, the deer or each other? The answer is clearly "no." If at any other point in this process we see other answers being presented then we know that someone is manipulating the situation either for political reasons or because of their own personal feelings about our sport and gun ownership.

I suspect that the politics of the matter are probably best addressed by BASC (or the others, I just happen to be a BASC member) and it is my intention to forward a copy of the SNH reply to BASC for their information and in the hope that they will take a similar position to mine - i.e. no evidence of a problem means no need for a solution.
 
The questions I asked are as follows, this is the exact text I sent to SNH so there is no room for ambiguity:

Please consider the following a request for information under the Freedom of Information Act (Scotland).


Please provide the information relating to the following for the period of the previous 5 years. Ideally I would like individual sets of figures for each year but a total for the last 5 years for which figures are available would be acceptable if producing detailed information would result in excessive cost:


1) The number of people killed by firearms while the firearms were actively being used by deer stalkers for the purpose of shooting deer.


2) The number of people killed by food poisoning, or other illness, contracted by eating wild venison which was shot in Scotland and where the source of the infection was shown to be as a result of mishandling of the meat by the deer stalker.


3) The total number of people killed by food poisoning, or other illness, contracted by eating wild venison which was shot in Scotland.


4) The number of CONFIRMED cases of animal welfare issues concerning deer that were shown to have been caused by stalking or stalkers.

The SNH reply will follow in the next post on the thread.

I think SNH were quite restrained in their reply to you. I don't think your questions were relevant. An FOI request has to be directed to the right department. None of these topics fall within the role of SNH except possibly 4).

SNH have already adopted the "Best Practice Guidance" initiated by the former DCS.

Under the Wildlife and Natural Environment (Scotland) Act 2011, SNH have been given the statutory responsibility of ensuring that (very broadly speaking) deer control is carried out in a proper manner according to accepted standards of animal welfare. If SNH decides at the end of the consultation period in April 2014 that DMQ1 Certification (which embodies BPG principles) is necessary to get on the 'Fitness and Competence Register', and the Scottish government enact this then ultimately no-one will be able to stalk unaccompanied in Scotland without it. Alternatively, they will have to be accompanied by a DMQ1 holder.

SNH have to decide by this date whether the current numbers of voluntarily qualified DMQ1 stalkers is enough to avoid statutory enforcement .... but you have to wonder how that step can be avoided. Having recommended a 'Standard' how would SNH know what proportion of stalkers (amateur or professional) are actually qualified to meet it without the SG making it a legal requirement?

Obviously there will have to be a period of a year or two to allow everyone who wants to go on the FCR to get trained before this becomes mandatory... so a couple of year's grace will have to be given..... so 2016 seems inevitable for all this.

The train has already left the station. Please look at the relevant sections of the WANE Act below:-

http://www.legislation.gov.uk/asp/2011/6/section/30/enacted
 
I've been quite vocal on this subject but have different motives. My problem with all this rumour and heresay is that 'DSC level one has been deemed the standard' this is absolute tosh.
It has been deemed the standard but only by the people who created it.

The WANE act has made it so that SNH need to assess deer welfare issues and stalker training levels in 2014. While the WANE act includes provision of a register. They aren't suggesting that it WILL be implemented. Simply that they need to know the levels
BASC , BDS et al have decided for themselves that they must promote DSC level one as 'the acceptable level' to get more 'voluntary' uptake so that SNH don't need to make it law.

Thats what I have learned/ascertained about the subject through contact with SNH. The whole thing smacks of BASC scaremongering to up the numbers of candidates on DSC1 courses in my opinion.

I don't have a problem with mandatory training to hold a firearm, I just don't want these boys to profit from it.
 
I think SNH were quite restrained in their reply to you. I don't think your questions were relevant. An FOI request has to be directed to the right department. None of these topics fall within the role of SNH except possibly 4).

When a government organisation suggests further infringements of freedom, one expects these infringements to have
a) a purpose related to the safety of the public, or some similar benefit proprotionate to the proposed restriction
b) supporting evidence that they will in fact serve the purpose a); rather than simply being what appears to a bunch of jacks-in-office a good idea

I'm sure you're right that SNH are not the right people to ask for these figures.

However, I suspect Caorach asked SNH these questions not to find out the figures, but to find out whether SNH knew the figures; thereby to establish whether there was purpose or supporting evidence to the proposed meddling.
 
The reply that got when I emailed them about all of these rumours. Doesn't look to me that mandatory training is definitely happening. Puts a massive cloud of doubt (in my mind anyway) over the suggestion that DSC1 is the course to have too.



The reply



Dear Craig,

Thank you for your e-mail regarding the review of levels of competence of those who shoot deer in Scotland.

The Wildlife and Natural Environment Act 2011 introduced a requirement for SNH to carry out a review of the levels of competence among those who shoot deer in Scotland, and the effect of such levels of competence on deer welfare. *The Act also gave Scottish Ministers the ability to establish a register of persons competent to shoot deer in Scotland. The review will be undertaken in 2014.

The voluntary uptake of competence is being promoted by an industry working group membership of which includes BASC, BDS, SGA and SLE. This working group have decided that DSC level 1 or equivalent is adequate to demonstrate competence.

SNH will carry out a review in 2014 that will look at the number of people stalking unsupervised and what effect this is having on deer welfare. *

Whilst the new legislation allows for the establishment and operation of a register of persons competent to shoot deer in Scotland any implementation of such a measure would require the legislation to be enacted by Scottish Ministers. If post 2014 this was the intention of Ministers it would follow a period of consultation.

I hope that this is helpful.

Kind Regards
 
Not Europe, Scandinavia. ;)

Paul's post referred specifically to Europe. (Scandinavia is merely a part of Europe) There was a serious point to my post; if your principal reason for doing something is that other people are doing it then you've fallen victim to the Baaaa Baaaa Syndrome.
 
Paul's post referred specifically to Europe. (Scandinavia is merely a part of Europe) There was a serious point to my post; if your principal reason for doing something is that other people are doing it then you've fallen victim to the Baaaa Baaaa Syndrome.

I don't think Paul meant europe the continent. I think he meant the European union. We're a part of it (for the moment) and have to obey the rules. That's why we can't have too bent bananas etc.
 
However, I suspect Caorach asked SNH these questions not to find out the figures, but to find out whether SNH knew the figures; thereby to establish whether there was purpose or supporting evidence to the proposed meddling.

Absolutely, I think it very significant that the competent authority doesn't have the figures, has seen no reason to gather them and in as far as they are aware there has never been any incidents involving a threat to the public. So, while they have been tasked with establishing the level of competence within the stalking community based on current information the only conclusion they can reach is that the stalking community is extremely competent. I suspect that is why they are pushing the uptake of DSC1 - because they intend to announce that there has been significant uptake of training and that all the evidence says we are competent and so there is no need for further regulation. The training uptake will be the sweetner for the politicians so they can feel that something is being done. The simple truth is that nothing needs done.
 
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