Have your say on HSE’s public consultation on banning lead ammunition (lead shot & lead bullets)

The Health & Safety Executive (HSE) is running a public consultation on the use of lead ammunition in England, Wales and Scotland.

This is the final phase of a long-running (and delayed) process to consider the risks posed by lead ammunition to human health and the environment. The HSE has come up with proposed restrictions on the use of lead ammunition – this public consultation is asking for our views on those proposals, prior to the DEFRA Secretary of State making a decision.

The proposals fall far short of what is needed, no doubt heavily influenced by the game-shooting lobby which has stood in the way of progress on this issue for years. It’s current and much-heralded claim of a voluntary transition away from lead shot is not well supported as lead-contaminated gamebird meat still dominates the market, three years into the five-year phase out period (see here). The shooting industry’s response to these results was a disgraceful attempt to slur the research as ‘pseudoscience’ (see here).

Of most concern for those of us wanting to protect raptors is the HSE’s opinion that there’s no need to ban lead rifle bullets. Instead, the HSE has argued that because the tonnage of lead emitted as shotgun pellets is larger than that emitted as rifle bullets, they can safely ignore benefits of a ban of lead rifle bullets in their benefit/cost calculations. This is clearly bonkers given the hunting habits of certain raptor species, especially golden and white-tailed eagles, which are massively vulnerable to lead poisoning, either directly or indirectly by sublethal effects, when they scavenge on rifle-shot deer gralloch that has been left on the hill.

The HSE’s consultation closes just before midnight tomorrow (Sunday 10 December 2023). It would be brilliant if you could take 15 minutes this weekend to complete it, to show the HSE (and DEFRA) that the banning of ALL lead ammunition (shot and bullets) is long overdue and is a matter of widespread concern, not just for the benefits to human health but also for our environment.

Conservation campaign group Wild Justice has provided a step-by-step guide to responding to the consultation – please click here for details.

Thank you.

17 thoughts on “Have your say on HSE’s public consultation on banning lead ammunition (lead shot & lead bullets)”

  1. Just filled in the HSE public consultation. Thank you for bringing it to my attention and for providing assistance. I’m sure these things are deliberately bewildering to put the average person off.

  2. Even considering allowing this debacle to continue is outrageous when there are alternatives that are not poisonous . Coarse anglers got no consideration when it came to poisoning the rivers so why give these people who are not happy unless they can kill something they would not even consider eating the right to spread poisonous lead all over the country permission to carry on .

  3. Just come back from one very big estate (not for the shooting, I must add) where the keeper tells me that both lead shot and plastic wads are prohibited. So some are making the right steps. Need everyone to follow voluntarily making the need for yet more legislation pointless; faint hope I fear.

  4. Let’s be honest, there’s no lead in deer grolloch on the hill. Your encouraging people to take part in a consultation on a subject they have zero knowledge on.
    You and your followers are simply anti fieldsports.
    You really need to get a life

    1. it’s not just about Deer shooting, I would buy game meat if I knew it wasn’t shot with lead, we aren’t all anti fieldsports. for gods sake take your head out of the sand and evolve

  5. I agree with Iain that there isn’t any lead in gralloch. When culling deer stalkers usually take what is known as a body shot, aiming for the chest cavity to achieve a quick kill when the bullet penetrates the heart or lungs. Gralloch is the stomach and intestines which shouldn’t be contaminated with lead. Organisations such as Land and Forestry Scotland are undertaking trials with copper bullets to assess their effectiveness in giving a quick humane kill. Until the results of this are known I don’t fully support a ban on lead rifle bullets.
    If there’s a problem with sub-lethal levels of lead in raptors this is far more likely to be caused by them eating game birds or other wildlife that was shot with lead shot and the bodies weren’t collected or the animal was only wounded and died elsewhere from it’s wounds. Therefore a ban on lead shot will have positive benefits for raptors, and other wildlife, and should definitely be supported.

    1. Matt, can I suggest you read the Report of the Deer Working Group (Management of Wild Deer in Scotland) which states explicitly:

      ‘The Group notes that lead contaminated gralloch could be consumed by carrion eaters including, for example, golden eagles in some situations’.

    2. I would say that rabbits shot by keepers with the .22LR Rimfire (a typical estate firearm) as part of the systematic culls across the many Estates that have constant high rabbit numbers will pose a big risk to any scavenging species that pick them up. The sub-sonic bullets tend to zigzag about in the rabbit until they lose their power – if a body shot, and the lead bullet will often remain lodged in the flesh / against a bone. I know of Estates that cull thousands of rabbits per year with this method shooting at night from the Hilux or quad, and most rabbits are left where they lie – with only a minority of (the cleanly headshot ones) picked up and sold to game dealer if prices make it worth the effort. But I doubt there will be any research-worthy data to be gleaned from those Estates, as the scavenging species tend to die of lead related causes but in a much quicker way!

    3. Matt,

      Further to your claim that “there isn’t any lead in gralloch”, a blog reader has forwarded the following paper which demonstrates the risk of lead in the viscera of UK rifle-shot deer:

      https://www.sciencedirect.com/science/article/abs/pii/S0048969710009149?via%3Dihub

      The blog reader also suggests you read the many papers on lead bullet fragmentation from the US (where the intenstines/gralloch are called ‘gutpiles’), specifically in relation to studies on lead poisoning in the California Condor. There’s also a lot of research on this issue in WTEs by Oliver Krone.

  6. Anglers dsicontinued using lead shot in the 1980s. Lead ammunition should have been banned then if the shooters would not follow suit.

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