HSE asks for extension to timeline for lead ammunition review

There is plenty of good evidence linking lead to health problems.

Playing devil's advocate, I think there is quite a body of evidence that says it doesn't to any significant level.
We have all eaten plenty of lead over the years, on which of our health problems do we blame lead?
 
We have 150 plus years of household water delivered through lead pipes. Never did me any harm - wibble wibble.
 
Playing devil's advocate, I think there is quite a body of evidence that says it doesn't to any significant level.
We have all eaten plenty of lead over the years, on which of our health problems do we blame lead?
Have a read of a box of cartridges- it will tell you.

As stated elsewhere it has no been shown that with many of the aggressive cancers - leukaemia, small cell lung cancers, pancreatic etc there are elevated levels of lead, cadmium and other heavy metals in the blood. New treatments to reverse these levels have been very effective and the first has just been given FDA approval for orphan drug in the US.

A good summary but more focused on shotgun pellets. of Effects of lead on human health - Game and Wildlife Conservation Trust

In terms of lead in venison shot with lead bullets and how fragments spread and then ingested by pigs when they consume the venison (a good surrogate for man)


And finally summary of the new treatments for cancers


And


I know those who are developing the drugs. They were a client of ours (we provided advice on funding and corporate strategy), so we had plenty of conversations on consuming lead. It is really not a good idea at all. The thesis is that we all do have different threshold levels and once you go over that your body systems go haywire. In patients with Acute Myeloid Leukaemia the mean level of 25 nano mols of lead per litre of blood was observed, but for some it was as high as 300 nano mols. Still pretty small amounts though.

The real challenge in the UK is that the medical profession are not looking for heavy metals in routine health screening. They only look if there is an acute case of poisoning etc. And in UK NHS takes a very long time adopting new ideas etc. It is pretty much why most new drug companies are basing themselves in Europe or USA.
 
Last edited:
Have a read of a box of cartridges- it will tell you.

As stated elsewhere it has no been shown that with many of the aggressive cancers - leukaemia, small cell lung cancers, pancreatic etc there are elevated levels of lead, cadmium and other heavy metals in the blood. New treatments to reverse these levels have been very effective and the first has just been given FDA approval for orphan drug in the US.

A good summary but more focused on shotgun pellets. of Effects of lead on human health - Game and Wildlife Conservation Trust

In terms of lead in venison shot with lead bullets and how fragments spread and then ingested by pigs when they consume the venison (a good surrogate for man)


And finally summary of the new treatments for cancers


And


I know those who are developing the drugs. They were a client of ours (we provided advice on funding and corporate strategy), so we had plenty of conversations on consuming lead. It is really not a good idea at all. The thesis is that we all do have different threshold levels and once you go over that your body systems go haywire. In patients with Acute Myeloid Leukaemia the mean level of 25 nano mols of lead per litre of blood was observed, but for some it was as high as 300 nano mols. Still pretty small amounts though.

The real challenge in the UK is that the medical profession are not looking for heavy metals in routine health screening. They only look if there is an acute case of poisoning etc. And in UK NHS takes a very long time adopting new ideas etc. It is pretty much why most new drug companies are basing themselves in Europe or USA.
Everything you buy has that california warning.
 
As stated elsewhere it has no been shown that with many of the aggressive cancers - leukaemia, small cell lung cancers, pancreatic etc there are elevated levels of lead, cadmium and other heavy metals in the blood. New treatments to reverse these levels have been very effective and the first has just been given FDA approval for orphan drug in the US.
The self same heavy metals that are found in cigars and other smoking products?

Maybe there’s another source of lead ingestion that should be banned (or not) before the HSE moves on to lead ammunition?
 
The self same heavy metals that are found in cigars and other smoking products?

Maybe there’s another source of lead ingestion that should be banned (or not) before the HSE moves on to lead ammunition?
Absolutely- biggest concern with vapes is the level of heavy metals they contain, especially all the black market disposable ones.
 
Well it's not been an issue for the last 50 years as far as I am aware of.
That was until the shooting organisations that are supposed to represent us volunteered us all for a 5-year voluntary transition away from lead.
Unbelievable.
 
Looks like at least 60% of responses to consultation were via BASC. Dont know what that means re outcome but, putting the “voluntary” transition issue to one side, at least demonstrates some credibility for BASC.

I suspect the HSE and associated blob need more time to work things round to the pre agreed outcome : me a cynic ?
Thanks.

They have asked for more time to sort through relevant information and evidence, before they can propose recommendations to the Secretary of State for the Environment, Food and Rural Affairs. They were not expecting this volume of responses. The same happened in 2022. They expected a few hundred responses at most and received 2667 responses and requested an extra 6 months for that stage of review. To put that in context, for a similar consultation in EU, by the European Chemicals Agency that 2667 figure was way more responses than submitted by hunters from across the EU. And again for last year's consultation, they would have expected less than 2667 from the previous consultation - again based on EU process - but instead they got over 3 times as many responses.

As regards pre-agreed outcomes, yes, I think that was perhaps where things stood at the start of the review in 2021. But they have shifted based on responses from BASC and others, namely dropping plans to ban lead airgun pellets and conceded that target shooting with lead rifle ammunition should be allowed to continue at approved ranges.

In BASC's latest response (see BASC response to HSE lead ammunition consultation ) we continued to push back against all the remaining restriction proposals and hopefully we will see more of them dropped for the final recommendations going to the Minister. Once that happens its then a political issue.
 
So lead ammunition, just at the moment, isn't really an issue, yes?
Lead ammo provided it goes into a sand trap is good. But I wouldn’t want to be the one having to sift the sand unless you are wearing a good dust mask.

Lead going into anything that will end up in human or natures food chain I do not think is a good idea at all. Its not good for anyones health, nor do we want to have any accusation that we are harming wildlife.
 
Well it's not been an issue for the last 50 years as far as I am aware of.
That was until the shooting organisations that are supposed to represent us volunteered us all for a 5-year voluntary transition away from lead.
Unbelievable.
To be fair I find your comments unbelievable. Here are a few questions that spring to mind. Have you read the GWCT advice? Have you googled the research worldwide. Have you read anything on this forum on the dozens of lead ammunition policy updates for over a decade? Do you think the issues with some uses of lead ammunition (namely lead shot for live quarry shooting) being researched and recognised in the UK and worldwide, and various policy developments worldwide on lead ammunition worldwide, are because the shooting organisations in the UK announcing a voluntary transition away from lead shot for live quarry shooting in 2020? If you are looking for a reason for the HSE lead ammunition review kicking off in 2021 then perhaps blame Brexit.
 
To be fair I find your comments unbelievable. Here are a few questions that spring to mind. Have you read the GWCT advice? Have you googled the research worldwide. Have you read anything on this forum on the dozens of lead ammunition policy updates for over a decade? Do you think the issues with some uses of lead ammunition (namely lead shot for live quarry shooting) being researched and recognised in the UK and worldwide, and various policy developments worldwide on lead ammunition worldwide, are because the shooting organisations in the UK announcing a voluntary transition away from lead shot for live quarry shooting in 2020? If you are looking for a reason for the HSE lead ammunition review kicking off in 2021 then perhaps blame Brexit.
But @Conor O'Gorman, you are forgetting that many on SD believe that the UK, along with all its people, flora and fauna all behave very differently biologically to flora and fauna elsewhere in the world.

And just because scientists in the state of California have demonstrated that lead is very harmful to condors, and scientists in Houston Texas have shown clear links between lead and leukaemia, there are plenty on SD that believe none of such findings can apply to the UK.

Even worse is any research that has been done in Europe.

The only things they believe are whats shown on GB News, comes out of the mouth Boris, Trump or Farage, or written in the Telegraph.

Otherwise it’s all just left wing propaganda.

Oh the earth is still of course flat, and Bonacons and Unicorns are real. :)
 
I think one of the key points for me in the preamble to the latest doc to come from HSE on this issue was the very high proportion of ducks going through the trade which had been shot with lead. Despite this being illegal for many years. So can the shooting community be trusted to self regulate ? Any impartial outside observer would conclude clearly not.

We reap what we sow !
 
But @Conor O'Gorman, you are forgetting that many on SD believe that the UK, along with all its people, flora and fauna all behave very differently biologically to flora and fauna elsewhere in the world.

And just because scientists in the state of California have demonstrated that lead is very harmful to condors, and scientists in Houston Texas have shown clear links between lead and leukaemia, there are plenty on SD that believe none of such findings can apply to the UK.

Even worse is any research that has been done in Europe.

The only things they believe are whats shown on GB News, comes out of the mouth Boris, Trump or Farage, or written in the Telegraph.

Otherwise it’s all just left wing propaganda.

Oh the earth is still of course flat, and Bonacons and Unicorns are real. :)
What I find interesting is that people have no issue with the GWCT advice on positive benefits of shoot related land management for environment and pest and predator control for songbirds etc, but the same scientists are not to be believed or trusted when it comes to their equally expert and objective review of the science around the impact of lead shot on some bird species.

On the other hand we do expect the HSE to rely on relevant evidence for its review of lead ammunition and to take into account controllable risks before any regulatory recommendations. I don't think the condor example has any relevance for UK situation but there are other studies within and outside UK for other birds of prey that could have relevance - but one has to also consider that these risks are controllable. In other words best practice means live quarry shooting with rifle ammunition should continue. And as regards fragments of lead rifle ammunition in game meat, best practice and FSA advice are in place and market forces are leading to a move away from lead rifle ammunition for deer stalking, for example. The following section from BASC's response may be of interest.

7.5 Mortality and sub-lethal effects from secondary exposure – birds.

As per BASC’s 2022 consultation response to the HSE, there is no GB evidence which provides a causal link between lead shot and lead poisoning resulting in mortality or sub-lethal effects on predatory or scavenging species. BASC considers that the HSE has not appropriately addressed the uncertainties in the evidence base from which it has drawn conclusions to justify restrictions.

The study by Pain et al. (1995) found a range of liver lead concentrations in 16 species of raptors in the UK. The study did not attempt to demonstrate analytically that lead shot was the cause of elevated liver lead concentrations.

Pain et al. (2007) analysis of food pellets from Red Kite roosts provided no confirmatory evidence of lead shot being present in samples. “Radiographs showed that 29 of 264 (11%) contained radio-dense material, not verified but presumed to be mainly shot or shot fragments. Sixteen pellets were dissected, six of which (37.2%) contained 1 to 3 objects regarded as lead shot”. The lack of confirmatory evidence renders the study speculatory.

Of the further studies referenced by the HSE covering 16 species of raptors, none offer a definitive causal link between mortality or acute poisoning from lead shot. Of the 22 studies of raptors cited by the HSE, only five studies offer any suggestion of the source of lead where elevated levels were detected. The source is described by the HSE as “suggested ingestion of ammunition” The HSE does not go on to address this uncertainty.

Of the 16 raptor species studied, only three species - Common Buzzard, Peregrine Falcon and Red Kite - were found to exhibit lead levels above clinical thresholds. Six other species were recorded with liver concentrations of lead above sub-clinical thresholds, but in any sample <10% exhibited such concentrations.

The HSE suggests that a secondary exposure pathway exists to predatory and scavenging birds from lead shot and rifle ammunition used for ‘live quarry shooting’.

The evidence supports the likelihood of lead shot being dispersed in carcasses or discarded offal. Given that 97% of game meat goes into the food chain (PACEC, 2014) there is limited scope for predatory and scavenging species to be exposed via this potential exposure pathway.

Best practice guidance for pest mammal and pest bird species which are not placed into the human food chain (e.g., fox, carrion crow) is to dispose via a certified waste carrier, incinerate or leave in a discrete location away from view of the public. Again, this often means disposal in locations of dense cover that would be unavailable to raptor species or other scavenging birds further reducing any potential secondary pathway.

There is no conclusive evidence which links lead ammunition as a cause of lead poisoning via secondary exposure, despite a theoretical pathway existing.

Even where isotope analysis of detected lead is undertaken (Walker et al., 2012 and Taggart et al., 2020) it is inconclusive as to the source of the lead. This is due to overlaps with lead isotopes from coal in the Walker et al. (2012) study which reports: “There was no clear evidence that birds with the higher residues (those with the top 25 percentile of total liver Pb concentrations) in either species had isotope signatures that particularly resembled that of shot or ammunition” and “There was also some overlap with the isotope signature for coal and for Pb shot, but the signatures in the birds were distinct from that of petrol”

Whilst the Taggart et al. (2020) study is most comprehensive UK study of lead exposure to raptors, it is not conclusive of the source of elevated lead levels in liver and bone. Only a small percentage of studied birds had elevated levels of lead (2.7% in liver and 4% in bone). The abstract of the study states: “Hence, most of the Pb acquired by Eurasian buzzards which have liver concentrations likely to be associated with lethal and sublethal effects is probably obtained when they prey upon or scavenge gamebirds and mammals shot using Pb shotgun pellets.”

Therefore, the HSE has not provided any analytical or observational evidence to link reports of birds with levels of lead above background concentrations to lead in ammunition.

The submissions of the ‘International Shooting Federation of Hunting Sport Weapons' (FITASC) to the European Chemicals Agency (ECHA) review of lead ammunition (Palinkas, 2020) discusses the behaviour of lead in soil and its relative stability, evidencing limited mobility of lead in soils where pH is >6.5. This report offers evidence that lead shot, even at sites with high use, can be adequately managed.
Some conclusions reached by the HSE are supported by evidence provided from modelling studies (Green et al., 2022 and Meyer et al., 2016). Such studies are modelled on a series of assumptions, and whilst they demonstrate a theoretical impact of lead poisoning, they do not identify the source of lead as being from gunshot. BASC considers that such models are unsafe to support proposals for regulatory action.

Finally, the HSE has not provided any empirical evidence in Great Britain to suggest negative impacts on individual terrestrial birds or at species population level.

BASC has concluded that highly restrictive regulation, based on the theoretical likelihood of secondary exposure to lead ammunition, is disproportionate to the risk. The HSE has identified significant uncertainty in its conclusion around secondary poisoning of birds but has not addressed this within its Annex 15 opinion document.

Currently, the proposed restrictions appear to be based on the existence of theoretical pathways of exposure rather than the actual impact because of the exposure. BASC contends that any restriction on this basis is currently not justified and is therefore unnecessary and disproportionate. If restrictions underpinned by secondary poisoning risk are to be implemented, this would be deemed an over-precautionary measure.
 
Back
Top