Sent the below to my MP - section 4.7 is the kicker where they basically admit they have very little actual evidence supporting the restrictions they are pushing …
I write to you in regard to the recent publication by HSE on the usage of lead ammunition in Great Britain – the report is available here:
Statement on HSE proposals to restrict use of lead ammunition in Great Britain – HSE Media Centre
Despite a lengthy consultation process, the HSE seems to have jumped to a series of foregone conclusions and recommendations that do not seem to be backed up by any clear scientific evidence.
The introduction to the report notes that back in 2010 the Lead Ammunition Group (LAG) concluded that the only way to address the perceived risks to wildlife and human health was to phase out lead ammunition entirely, and that a number of shooting organisations left LAG as they did not agree with the conclusions LAG was putting forward. From what I have seen and read it was widely perceived at the time that LAG had very little scientific evidence backing up their claims, and to be frank was simply an anti-shooting body, yet this report also states in its introduction that the HSE has “extensively referenced the work down by LAG” as a basis for this proposal despite these being seemingly discredited and discounted at the time.
The summary of the HSE’s recommendations are below:
I would like to draw your attention to Section 4.7 of the above linked report titled “Assumptions, uncertainties and sensitivities” wherein I found a number of assumptions that seemed to me to render the HSE’s findings and recommendations null and void, and at the very least should attract some thorough questioning before any legislation is considered.
In terms of the environmental assessment the HSE’s assumptions are in standard text, and my queries are in italics in the bullet points underneath:
- A number of estimates were provided for the tonnages of each ammunition type for each use, each with uncertainties depending on the estimation method used. In particular, estimates of airgun ammunition are very uncertain. Tonnage values selected for use in this assessment should not be seen as definitive but are sufficient for the purposes of this assessment for the reasons described in the Background Document.
- I find it hard to understand how the HSE can make a recommendation proposing that lead ammunition be largely banned when they are unable to determine how much of it has been put (back) into the environment by lawful shooting activities. I also see no differentiation between civilian shooters and the military, who presumably discharge far more ammunition than we do.
- Although a risk has been identified for primary and secondary poisoning of birds, estimates of the numbers of birds at risk are uncertain (N.B., the number of organisms at risk has not been a factor in any environment focussed restriction of other substances under REACH).
- The HSE has no idea how many birds have been poisoned either primarily or secondarily as a result of the usage of lead ammunition. How can they propose a ban when there is no clear evidence one is needed?
- No GB data on primary ingestion by grazing mammals have been identified, although it is assumed to be a possibility based on evidence from other countries.
- As above, this is an assumption only with no clear evidence, even anecdotal, that a ban is needed in order to address an issue.
- No GB data on secondary poisoning of predatory or scavenging non-avian species have been identified
- Likewise, the HSE admits there is no data available in the UK indicating that predatory or scavenging wildlife is impacted by lead shot.
- GB data on lead concentrations in surface or groundwater associated with the use of lead ammunition are not available.
- As above, there is no data or clear evidence requiring a ban as a result of lead contaminating surface or groundwater.
- A single study reports ingestion of airgun pellets by birds. It is unclear whether this exposure pathway is significant in GB.
- Whilst the HSE has been able to present a single study indicating ingestion of bird pellets, I would argue a single study should not necessitate a nationwide ban on anything, and besides this airgun pellets are one of the items the HSE is NOT including in its proposed ban (not that I am advocating they should).
- Throughout the dossier the risks posed have been considered for all uses of lead ammunition combined. Where the same risk is identified for different uses we have considered whether the relative risks can be determined qualitatively, but this assessment is uncertain. Tonnage used annually is used as a general indicator of relative risk. However, for secondary 105 poisoning of birds in particular, the use of annual tonnage is not considered a suitable proxy to determine the relative partitioning of risks from lead derived from shot and lead derived from bullets.
- The HSE admits its assessments are uncertain, and is simply basing their recommendations on “tonnage = risk” despite scant other evidence of any risk or impact at all.
Then moving on to uncertainties in human health:
- Some estimates of the numbers of people in the UK that consume game birds were based on data that did not differentiate between wild-shot birds (potentially contaminated with lead) and farmed birds (not killed with lead ammunition).
- There has been no clear differentiation between people who eat farmed game (IE not potentially shot with lead) and wild game that has been hunted. This could potentially be inflating the size of the perceived risk and inflating the perception of the need for a ban.
- There is a lack of information on consumption of game meat by children and pregnant women.
- I would suggest that the first step should be for the HSE to get the data and see if there is a problem, rather than presenting a conclusion and a recommendation without a robust piece of data led analysis backing it up.
- Large variations in lead concentrations in different game meat samples and cuts of meat, particularly for large game killed with bullets, because lead contamination from the ammunition is not evenly distributed throughout the animal; some samples might have highly elevated lead levels (for example, close to bullet wound channels), whereas in other samples levels might not be elevated.
- There could potentially be some form of recommendation here (EG, disposing of an area of X inches of meat around the wound channel) which could help address this issue, however the counter argument here is that the amount of lead contamination is extremely variable and as such I would argue the risk can be managed and mitigated with far less intrusive and draconian measures.
- The relative contributions of game hunted with lead shot and game hunted with lead bullets to game meat consumption in GB, and the annual tonnage of the latter.
- There is no clear evidence or delineation between perceived impacts from lead bullets vs lead shot. How the HSE is able to form recommendations banning one form or the other, or both, is beyond me given they have no evidence clearly supporting either approach.
- The relative partitioning of human-health risks from lead derived from shot and lead derived from bullets, considering the impacts of released lead quantities, shot-to-kill ratios, lead distribution in the animals, proportion of hunted animals destined for human consumption, butchery practices and cuts of meat consumed.
- Related to the above, there is therefore no clear linkage between lead shot vs lead bullets when it comes to the potential for lead exposure via shot game. Again, I find it hard to see how the HSE has recommended a ban on either form of lead ammunition given the lack of evidence supporting it.
- Uncertainty about the proportion of ammunition-derived lead that is absorbed or how much BLLs are increased per unit of dietary lead ingested.
- Again, I cannot see how we can be talking about wholesale bans when the HSE is not clear on how much of an already unclear amount of lead ingested is actually absorbed into the body.
- Very limited information on how game meat consumption affects BLL in hunter families.
- Related to the above, it is also unclear as to how much of the uncertain amount of lead ingested impacts people who hunt, who typically eat more game than the average person.
- A lack of reliable measurements of BLL in children of high game meat consuming (hunter) families.
- And again, it is unclear how much this might impact the children of such people.
- Impacts on human health of possibly different exposure patterns from the consumption of small game hunted with lead shot and large game hunted with lead bullets.
- Again, this points to a series of assumptions that are shaky at best and unfounded at worst, yet are being used as a basis for an extremely heavy handed proposal.
Related to all of the above, I would like to draw your attention to the below graph from the European Food Safety Agency, showing the percentage contribution of total exposure of lead in food. You will note that lead from game meat ranks below cephalopods (the likes of calamari and octopus) and only slightly above algae as a food source. This does not paint a picture supporting any sort of a ban or restriction given ones Friday night pint and our own tap water contribute far more highly than lead shot game.
I am not ideologically wedded to lead as an ammunition type and were there clear evidence of harm being caused by its use I would be far more inclined to be accepting of the HSE’s recommendations. Given the above this seems like an incredibly heavy handed and draconian approach being taken on the basis of scant evidence and broad sweeping assumptions, with little in the way of data led research backing up the assumptions.
Can I please ask you to raise this at your earliest convenience with the HSE and in Parliament, and can I please ask for your support in rejecting the HSE’s recommendations on the basis of the lack of supporting evidence?
I look forward to hearing from you.
unless for wildfowl.
basc.org.uk
