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

Last 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

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

Susan Davies, Chief Executive

END

The 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.

Cryptosporidiosis

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).