Please respond to a public consultation on lead ammunition

Today we are asking you, please, to respond to a consultation by the Health and Safety Executive on the use of lead ammunition. This is an issue on which Wild Justice has been very active.

Below we have set out some background information on the issue, as well as some guidance on how you might want to fill out the consultation, step by step.

Background.

We believe that restrictions on the use of lead shot and lead bullets for shooting live quarry are long overdue. Lead is a poison and shooting it into the environment or into creatures that may enter the human food chain or be eaten by other wild animals is senseless. This consultation is important and it feels like getting change is possible. Honestly, it won’t take you very long to make your views known and the more people who respond, the better. 

Many of the respondents will be shooters who have been briefed by the shooting industry. This is an industry which has been dragging its feet on this matter for years and years and years.  Some shooters will respond in wildlife-friendly ways but this is your opportunity to speak up for wildlife (and for human health). The consultation applies to Great Britain (England, Wales and Scotland) but if you live in Northern Ireland or elsewhere there is no bar to you responding and there may well be implications of the decisions that apply to you.

The consultation has two attached papers – we’ve read them. They are both very long (100+ pages each), quite technical and would take you hours and hours to read properly. But filling in a public consultation is not an exam test and you’ll be able to answer the few questions without wading through all of the two papers although you may find them interesting and informative.

However, if you want more information then here are some comprehensible sources of information on the topic, we include them to show that we know our stuff on this subject and we regard it as important:

• Webpage of the Lead Ammunition Group – click here – which contains much information including their 2015 report (after five years of expert work), correspondence, updates and various other information
• Recent blog by John Swift, chair of LAG, calling for restrictions on use of lead shot and lead bullets for shooting live animals – click here – these are exactly the same measures that Wild Justice supports. It is striking that John is a former Chief Exec of the British Association for Shooting and Conservation and has been an active shooter.
• Oxford Lead Symposium – a 2015 compendium of accessible research papers on the impacts of lead ammunition on people, wildlife and the environment generally – click here.
• Wild Justice website has a variety of blog posts on tests of lead levels in supermarket game meat – click here for information on lead in dog food, lead in supermarket game meat and more.
• An RSPB blog post by one of us 13 years ago which describes the RSPB trialing copper bullets for deer control and deciding to make that change permanent – click here
• A letter from RSPB and Wildfowl and Wetlands Trust (2022) calling for an all-out removal of lead for shotgun pellets – click here.
• A blog post by the RSPB which calls for the end to the use of lead ammunition (shot and bullets) from 2022 – click here.
• The Food Standards Agency advice on not eating game meat shot with lead – click here
• NHS advice on not eating game meat shot with lead
• if pregnant, trying to get pregnant or for young children – click here

The consultation closes at midnight on Sunday 10 December so you have 6 days including today, and including the weekend, to respond. Here is the link to the consultation:

LINK TO THE CONSULTATION

We think that this is a very poorly worded and dense consultation. This is ‘the’ public consultation by a government agency on a matter of considerable public interest and yet the questions are off-putting and assume quite a lot of technical knowledge. It does look quite scary but please don’t be put off.  There aren’t many questions, you can skip lots of them and so with some explanation from us we think you can make a difference by expressing your views within a few minutes. Note that you don’t have to finish the answers all in one go, you can do a bit and then click the option for ‘save and come back later’ at any time and do just that. 

The good thing is that the draft Agency Opinion (ie what they propose to do) is heading in absolutely the right direction on lead shot but needs a bit of a kick up the backside as far as lead bullets are concerned.

Filling out the consultation:

Below, we refer to the 7 pages of the consultation (which contain 20 questions), although the pages aren’t numbered, because we think it will help you navigate the document.

OK, let’s get started.

Page 1:
There are 12 questions about you (eg what’s your name?) so they are relatively easy and because you are responding as an individual, not an organisation, you can skip a few of the questions anyway. That’s the first page done and only eight questions left.

Page 2:

This has one question about transition periods – otherwise known as delays.
Should the shooting industry be given three years or five before the use of lead shot for shooting live animals is banned?

We say, three years, and you may feel the same. Our reasons are that lead ammunition is already banned for use over wetlands and/or for shooting a list of waterbirds (details differ across the UK nations) and therefore many shooters have already had many years to transition. Despite being illegal for over 20 years, compliance with the lead shot ban in this form of shooting has been very poor, and so bringing in a short transition for the new measures will not only bring in new protection it will help to enforce the existing laws which have been flouted by shooters for decades.

OK, so you have now answered 13 out of 21 questions.

The next page, Page 3, is about ‘Humane Dispatch’ where we guess you won’t have any special knowledge so that you can almost certainly tick ‘no’ (14th question) and move on to Page 4 and a question (the 15th question) about monetising raptor deaths.

Page 4:

This page’s question is a stinker: ‘Monetised benefits associated with restricting lead bullets for live quarry shooting: Do you have information regarding the monetary benefits associated with reducing the risk of secondary poisoning of raptors from the use of lead bullets e.g., from WTP-based evaluations or similar?’

Your reaction may be ‘Wtf is WTP?’ but this extremely poorly posed question is about how much you care that birds of prey may ingest lead from the carcasses of injured animals that they kill or dead animals that they scavenge. You can answer that, so tick ‘Yes’ and then say why you care about birds of prey such as Golden Eagles, Red Kites and Buzzards that may be poisoned by ingestion of lead ammunition (and that you care about other carrion-eating birds and mammals).

You might want to say that nobody has ever asked you about your willingness to pay (WTP) to see poisoning of birds of prey from lead ammunition addressed but that if they had you would be willing to pay and you are sure that large numbers of wildlife lovers would do so too. However, you might want to point out that protecting threatened birds of prey is a responsibility of government and that you are already paying your taxes so that government, and bodies such as the HSE, do that job properly.

You might want to point out that taking the time to answer this badly-phrased question on this consultation is a proxy for willingness to pay. You could also say that since non-toxic alternatives to lead ammunition are readily available then this is very simply a question of sensible regulation where a less harmful ammunition is readily available. You might want to say that you care very much about rare birds of prey such as Golden Eagles and you don’t want them to suffer or be harmed by unnecessary contamination of their food by a poison.

You may want to end by saying that there are so many reasons why removing lead bullets from use on live ‘quarry’ is a good idea that your view is that they overwhelmingly outscore a small inconvenience to shooters and that you want restrictions on using lead bullets to be as strong as those in the draft Agency Opinion for lead shot.

Page 5:

Let’s move on to Page 5 where there are two questions (questions 16 and 17) about ‘Use of different bullet types for live quarry shooting and target shooting’. If you know anything about these issues then do answer the questions but we are confident that the vast majority of you can tick ‘no’ to both and move on.

That just leaves three questions and the good news is, on Page 6…

… we doubt whether many of you can or want to answer the two questions on ‘Rifles and Zeroing’ so that’s 19 of the 20 questions done. Which takes us very quickly on to Page 7.

Page 7:

This page is for General Comments and we would encourage you to go to town here.

You may want to start your general comments with these three points:

• I support the draft Agency Opinion that restrictions on sale and use of lead shot for shooting live animals should be brought in as a matter of urgency.
• I support those restrictions being brought in after a transition period which is less than five years; I would favour three years rather than five (see my response to that question above) but I would urge an even quicker transition because this simple and necessary measure has been delayed overlong.
• For the sake of clarity, since this question has not specifically been asked in this consultation, I support similar urgent restrictions being brought in for the use of lead bullets for shooting live animals

Then make some or all of these comments in your own words:

This is your first opportunity as a member of the public to comment and so there are issues not addressed by the consultation questions that you want to make.

• Lead is a poison and it is crazy to shoot a poison into wild animals destined for the human food chain. There is no mandatory labelling of game meat as containing lead (if it does) which is a poison so the only safe way for game consumers to avoid eating lead is if lead ammunition is removed from use. The FSA and NHS both draw attention to the human health aspects of lead ingestion. These concerns apply to game shot with shotgun pellets (eg Red Grouse, Pheasants, partridges and duck) but also to many species of deer shot with bullets and sold as venison.
• Environmental contamination and secondary poisoning of scavenging and predatory birds and mammals is an issue that needs addressing so restrictions should apply to lead bullets as well as lead shot.
• Strong, quick regulation is needed because existing regulations on shooting of waterfowl are flouted by shooters.
• The 2015 report of the Lead Ammunition Group recommended that such restrictions should be brought in and it is outrageous that UK governments are still consulting and delaying on this very simple issue.
• Other jurisdictions in Europe and North America have brought in similar restrictions – the UK would not be going out on a limb but would simply be following what is clearly going to become the norm.
• Removal of lead from petrol, water pipes, paints has been achieved years ago and removing lead ammunition from use is simply one more step based on lead’s known harmful impact on people and wildlife.

It is up to you how you respond but please do respond. We’re sorry that the consultation is so badly worded and framed but this is an important opportunity, your only opportunity, to make your views known. Please do have a go – thank you!

Wild Justice will respond as an organisation but we are asking you to accept the invitation from the HSE to respond to this consultation as an individual. Perhaps you know others who also might want to respond to it – feel free to bring this information to their attention.

CLICK HERE TO FILL OUT THE CONSULTATION

In this case, we would like to hear from you if you respond to this consultation. Please drop us an email (admin@wildjustice.org.uk) and tell us if you responded and any comments you have on the consultation and/or on the advice contained in this blog.