SNH responds to complaints about ‘Scotland’s Natural Larder’ campaign

Aim Click Collect June 2015Last month we blogged about SNH’s joint campaign (with BASC Scotland) called ‘Scotland’s Natural Larder’, which aims to promote ‘natural local produce that has been harvested sustainably’.

According to their campaign materials, lead-shot red grouse are to be considered ‘healthy’, ‘natural’ and ‘sustainable’.

We had a few problems with SNH’s promotion of Scotland’s pantry of dead wildlife, namely that lead-shot red grouse are not ‘healthy’, are not ‘natural’ and certainly haven’t been harvested ‘sustainably’ if they originated from a driven grouse moor (see here).

We (and many of you, thank you) wrote to SNH’s chief exec, Susan Davies, to ask some questions about this campaign and here is the generic response:

Thank-you for your recent email on the topic of Scotland’s Natural Larder’s (SNL) grouse banner which is one of a suite of banners we use under this initiative, others include seafood and foraging.  The SNL is a partnership project between SNH and the British Association for Shooting and Conservation (BASC) and is about reconnecting people with local and natural produce that has been sustainably harvested or hunted, encouraging best practice and responsible use of natural food resources.  The grouse banner is specifically used in support of the “Field to Fork” project which makes links between sport shooting, wildlife management and the food industry.  The goal is to secure long term behavioural change by working with students to help them understand and take responsibility for exemplary practice and good quality food.

One of SNH’s primary functions is to promote the sustainable use of nature’s assets. We work within the current legislative framework to secure multiple benefits, including those of an economic nature. Across the breadth of different land uses in Scotland there are a number of practices where changes in behaviour and raised standards would deliver greater benefits and improve environmental outcomes.

Our approach to moorland management is no different. We believe that when lawful moorland management for grouse is undertaken responsibly, and to assured standards that the ‘harvest’ of this wild game bird may be regarded as sustainable.   We are involved in a number of strands of work that seek to address the sustainability of moorland management; particularly the more intensive and single-minded approaches to managing some grouse moors as well as practices such as burning. These are highlighted in the report of our Scientific Advisory Committee’s Review of Sustainable Moorland Management, which we will be publishing shortly. They include working with the wide range of stakeholder groups represented on the Moorland Forum to agree and promote refreshed best practice standards, and with the Wildlife Estates Scotland initiative to provide independently assessed assurance of the extent to which they are being met. We need to use the full range of available tools to engage with all stakeholders, stimulate discussion, promote high standards, and seek solutions that work for all interests.

The Scottish Raptor Persecution blog site raised a number of specific issues and for completeness I have responded to each of these below.

Use of lead shot

The use and impact of lead in shooting is currently being discussed by the Westminster Government (DEFRA) Lead Advisory Group (LAG). This has considered evidence on lead ingestion both in humans and wildlife. SNH await the recommendations from the LAG. In the meantime the use of lead shot to kill quarry in sport shooting and wildlife management is standard but non-lead alternatives are being trialled.  As regards the use of food products killed in this way, Scotland’s Natural Larder promotes the skills needed to handle, inspect and prepare shot game to assure the quality of the final product and minimise health risks. SNL promotes best practice inspection which includes removal of visibly affected meat (i.e. bruised or containing shot / bullet tracking) which in turn will minimise risk from lead in game meat.

The Food Standards Agency are the statutory advisors on food safety and have undertaken research into game meat which informed advice to consumers. The advice suggests a reduction in the consumption by those who eat large quantities of game.  This is in line with advice proffered for red meat and oily fish.  According to FSA, the risk to infrequent consumers (less than once a week) is minimal, and for frequent consumers effective game meat handling can minimise the risk.

Use of medicated grit

Medicated grit is used under licence on many grouse moors and is administered by a vet. A four week withdrawal period (based on its use in comparable species) is recommended prior to treated birds going into the food chain.  Compliance with this withdrawal period has been facilitated by the development, promotion of best practice advice, and use of compartmentalised grit boxes to allow controlled access to medicated or non-medicated grit. SNL’s clear aim is to make sure that the people running the shoots and managing the species understand the responsibilities they have for the product entering the food chain.


Cryptosporidiosis has long been present in poultry and wild game and has not been reported as presenting a risk to human health. Under the inspection responsibilities that we promote as part of Scotland’s Natural Larder the shot game will be inspected by trained personnel and birds that are suspected of being infected, badly shot or otherwise contaminated will not enter the food chain.  The first inspection of this nature takes place at the estate larder and a secondary check would be made by the butcher or game dealer during processing.

It is clear that the deeply held and strongly divided opinions surrounding moorlands and grouse shooting present challenges but we believe that a twin track approach of development and promotion of good practice with strong enforcement of legislation is a proven approach in raising standards in wildlife management.   I hope that this background at least helps you better understand the basis for our approach even if you do not agree with it.

Yours sincerely,


Susan Davies, Chief Executive


Field-to-Fork RHShow 2015_BASCThe first three paragraphs are a bit contradictory to SNH’s previous statements about the sustainability of red grouse, in as much as they say red grouse ‘may be regarded as sustainable if the moorland management has been lawful and undertaken responsibly’. Er, that’s the whole point – we are arguing that moorland management (on driven grouse moors) is rarely undertaken responsibly and quite often involves unlawful activity, as SNH knows all too well. SNH also acknowledges the need ‘to secure long term behavioural change, and that changes in behaviour and raised standards would improve environmental outcomes’. In which case, SNH is admitting that current practices are not up to standard and therefore red grouse cannot currently be considered as a sustainably harvested product. So why promote it as such?

Turning to the specific responses made about the use of lead shot, use of medicated grit, and Cryptosporidiosis:

Use of lead shot

SNH is waiting for the recommendations of DEFRA’s Lead Advisory Group. Aren’t we all. Meanwhile, SNH is blatantly ignoring the multiple scientific studies that have demonstrated the significant health risks from lead to humans, wildlife and the environment – e.g. see here and note the number of cited references. Removing visible lead shot from the meat may ‘minimise risk’ [of lead poisoning] but it definitely doesn’t remove the risk – see this paper, published five years ago, which shows the level of lead contamination in gamebird flesh even after visible shot has been removed. A high proportion of birds still contained lead concentrations that exceeded the European Union Maximum Level by several orders of magnitude. It’s absurd that SNH is still trying to pass off lead-shot red grouse as ‘healthy’. Massive fail, SNH.

Use of medicated grit

The statement, ‘Medicated grit is used under licence on many grouse moors and is administered by a vet’ is wholly misleading. Medicated grit (containing the drug Flubendazole, banned for human consumption) is purchased from a vet but it certainly isn’t administered by a vet. It’s administered by gamekeepers, who, as far as we are aware, are not qualified members of the veterinary medicine profession. In addition to the provision of medicated grit, where worm burdens are high gamekeepers are also catching up wild grouse in the dead of night and direct dosing them by shoving a tube down their throats to administer the drug as a liquid. (This practice raises other interesting questions about whether those gamekeepers are qualified and licensed to catch wild birds, let alone administer a veterinary drug – we’ll return to this issue another time).

SNH suggests that compliance with the requirement to remove medicated grit 28 days prior to the onset of the shooting season has been ‘facilitated by the promotion of best practice advice’. The provision of ‘best practice advice’ is useful, of course, but it in no way ensures compliance. And let’s face it, many of those involved with the management of driven grouse moors are not best known for their compliance with the law, let alone ‘best practice advice’. So, who does ensure compliance? Well, according to our research, the Food Standards Agency is responsible for monitoring compliance, by testing shot birds prior to their entry in to the human food chain, and also by making random visits to grouse moors during the shooting season to examine the contents of medicated grit boxes. We’ve made an FoI request to the Food Standards Agency to find out a bit more about how much testing has been going on and we’ll report on that in due course.


SNH claims that infected red grouse will not enter the food chain. The problem is, some infected birds ‘may not have any apparent symptoms’ such as a swollen eye or discharge from the nasal orifices, according to ‘guru’ Mark Osborne (see here). So how can SNH be so sure that diseased birds will not enter the food chain? Another massive fail, SNH.

In summary then, nothing in SNH’s response leads us to change our position that lead-shot red grouse are unhealthy, unnatural and unsustainably harvested. On the contrary, they may contain excessive concentrations of poison (lead), Flubendazole and be infected with Cryptosporidiosis. In addition, the evidence of the environmental damage caused by intensive moorland management just keeps growing (e.g. see here for the latest).

16 thoughts on “SNH responds to complaints about ‘Scotland’s Natural Larder’ campaign”

  1. Well done – this is an exceptional article which answers many questions that I had regarding the human consumption of game – I now feel able to gainsay those in favour of it. I look forward to seeing the response to your FoI request!

  2. ‘but we believe that a twin track approach of development and promotion of good practice with strong enforcement of legislation is a proven approach in raising standards in wildlife management.’

    Belief is the correct word here. No evidence whatever. I peeked at the bottom of the reply concentrating instead on the usual excellent RPS response. I have already responded to the e-mails i got from them which, basically admitted that Red Grouse is neither healthy, natural nor sustainable. But in true political fashion it doesn’t seem to matter to them. They are pursuing a political agenda come what may.
    I feel sick just reading their spin.
    Just finished Mark Avery’s book and it isn’t uplifting at all. Mark is an optimist, i’m not. Hopefully 2014 was the turning point, as he thinks but when you read guff like the SNH reply above it seems like a long way off.

    1. I should add that if promoting an industry which claims to be healthy, natural nor sustainable but which the NHS itself admits is neither is doing the exact opposite of the ‘promotion of good practice’ in fact it lowering the bar so low it could be a challenge for a limbo dancing competition.

  3. Yes I got that reply too,but have not received one from Dr Aileen Mcleod that was sent at the same time.Has anyome?

  4. If you’ll forgive the expression, SNH’s response is all ‘piss and wind’. They are trying to normalize and make acceptable the morally repugnant practice of raising thousands of birds in the spring so that people with no empathy for other living things can stand and blast them out of the sky six months later, purely for human pleasure. not to mention all the environmental collateral damage.

    To anybody reading this please don’t assume that I’m a ‘towny’ or ‘dogooder’ who has no understanding of the countryside. I was born and grew up on a farm in a shooting environment and have worked and lived in same. The issue here is not about countryside economics and whether something is safe for human consumption, it’s about respect for the environment and having empathy, compassion and understanding for other living things; and driven shooting is non of those. People who take part in this kind of ‘sporting’ activity are in my opinion either ignorant, stupid or plain nasty. If they weren’t then they wouldn’t get pleasure from taking life for their own self indulgence.

    For SNH to stand with this and justify it on economic grounds is a travesty of the position they hold and they should be ashamed of themselves.

  5. Thanks for all you’re doing. Perhaps SNH would like to look into what happens to lead shot in thin acid soils? One would assume it will dissolve quite quickly, and then there’s a risk of it being taken up by plants.

  6. When and by whom was flubendazole “banned for human consumption”? I am under the impression that this anthelmintic is in fact used to treat humans for parasites. It might therefore be a good idea to cite your source (if I am wrong) or to correct your statement (if I am right).

    1. Thanks, Robert. The source was a report published by Ethical Consumer. Will do some more checking, especially about the concentration levels of the active ingredient. Nevertheless, whether banned for human consumption or not, there’s still a statutory requirement to remove medicated grit from grouse moors 28 days prior to the start of the shooting season so that it doesn’t enter the human food chain.

  7. One minute they are saying eat more grouse they are full of natural goodness, then the next they are saying, don’t eat a lot of grouse cause that would be bad for you….. aye they cleared that one up!
    Anyone one want a bet that their scientific review concludes that black is indeed white?

    See SNH and reasoned scientific opinion…. nope, they apply the same rigour as the Countryside Alliance- any old anecdote will do. They will only say what the Scottish Government tell them to say. Its the politicians that count, is Aileen still having tea with the SGA? Has she been invited to the Hen Harrier day events?

  8. Excellent work, RPS. Keep it up. I’ve heard that this PR disaster of a banner has caused ructions within SNH itself, with many staff sending complaints up the line, and we mustn’t tar them all with the same brush.

  9. I beleive the FSA are no longer the stautory body for Food Safety in Scotland, from 1st april that falls to Food Standards Scotland.

  10. Maybe its time Susan Davies read the act which sets out what SNH is supposed to do… They seem to have pushed well beyond the spirit of the act. Where does it say… “promote the sustainable use of natures assets”

    Establishment of SNH

    1.—(l) There shall be established a body to be known as “Scottish Natural
    Natural Heritage” (in this Part of this Act referred to as “SNH”) whose Heritage.
    general aims and purposes shall be—

    (a) to secure the conservation and enhancement of and

    (b) to foster understanding and facilitate the enjoyment of, the natural heritage of Scotland; and SNH shall have regard to the desirability of securing that anything done, whether by SNH or any other peron, in relation to the natural heritage of Scotland is undertaken in a manner which is sustainable.

  11. I’m not going to add anything to what has been said already, except to say that the development of “new SNH” is utterly appalling. Ron Bury has already eloquently echoed my feelings. I’d have been more than happy to be proved wrong, but I’ve been predicting this trend for some years now, to no avail. There are various clues in the language used in the CEO’s statement, which will be obvious proof to some but cryptic to others, such as the use of the term “wildlife management.” Basically, this is a neologism for gamekeepering. I hesitate to state the following, not for fear of reprisal or professional vanity, but because anything that smacks of conspiracy theory is prone not to be taken seriously. However those who really know what has been happening to SNH in recent years, which includes most of their employees, know with certainty and beyond all reasonable doubt that the agency has been infiltrated by some particularly unsavoury but clever pro-hunting individuals. Many of these came in a package courtesy of the Scottish Government in the form of the Deer Commission (Scotland). Anyone who attended the deer seminar organised by SNH just a few years ago, who witnessed a delegate who also happened to be a hired killer heckling members of the audience with cries of “just shoot the buggers” when anyone spoke in defence of roe deer, knows first hand what has been happening. I might be breaking professional etiquette by revealing this, but I’m so disgusted by SNH’s new attitude towards our wildlife that I don’t care any more. So many professional ecologists in Scotland are aware of it, but why does everyone stay so silent? If we don’t resist this attempt to overwhelm our governmental nature conservation advisory body with pro-hunting sympathisers and their thinly hidden agendas, matters will become far worse. I feel sorry for the caring professional officers who are caught up in this mess.

  12. “we believe that a twin track approach of development and promotion of good practice with strong enforcement of legislation is a proven approach in raising standards in wildlife management..”..I laughed out loud when I read that!..Would someone give me a single example of where that has helped a predatory species in Scotland?…If the strong enforcement actually took place it probably would actually work…but it doesnt and “standards” [no criminal activity would be a start] are as bad as ever, despite some pretty large amounts of education, leafletting an general waffle from the likes of SNH over the last decades….

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