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Last week we blogged about the deployment of gas guns on grouse moors and how we were still waiting for guidance on their use from SNH and Natural England; guidance that had been promised before the start of the 2016 breeding season (see here). We were/are concerned that these devices were/are being used to deter hen harrier breeding attempts. If they were/are, this would constitute an offence of causing reckless or intentional disturbance.

SNH has responded with the following statement:

Thank you for your email.

I note your concerns about the use of propane gas guns, which may have the potential for disturbance of protected bird species. We are not in receipt of specific evidence of an impact on breeding or nesting birds but we would welcome any information you may have regarding this or any related concerns of improper use of gas guns. This information should be forwarded to andy.turner@snh.gov.uk. Intentional or reckless disturbance of Schedule 1 nesting birds is an offence, and any suspected incidents of this through gas gun use should be reported directly to Police Scotland on 101.

Although we do not have specific information, we are working with Natural England to provide best practice guidance on the use of this equipment to minimise the likelihood or potential of disturbance in the vicinity of protected species. We currently expect to make this available later this month. The use of gas gun equipment is regulated by Local Authorities under the Environment Act and we are not currently considering separate licensing under the Wildlife & Countryside Act. We will, however, continue to assess on a case-by-case basis any licence application to disturb scheduled birds.

Thank you for your concern.

Andrew Bachell, Director of Policy & Advice, SNH

We found this statement to be contradictory and confusing. SNH says it doesn’t have any evidence of an impact on breeding or nesting birds. Has SNH investigated any of the previous reports it has received about these gas guns being used on grouse moors? If SNH hasn’t investigated, then of course no evidence will be available.

SNH says it wants to hear about any concerns but then says improper use could constitute an offence which should be reported to Police Scotland. Can anyone imagine Police Scotland investigating the use of a gas gun in the middle of a remote grouse moor? No, neither can we. And if the schedule 1 bird has already been ‘disturbed’ by the gas gun and has since cleared off, then if the police did miraculously attend, there’d be nothing to see anyway and therefore no evidence of an offence.

SNH says gas gun use is regulated by local authorities under the Environment Act. But this legislation relates to statutory nuisance, ‘noise emitted so as to be prejudicial to [human] health or a nuisance’. This legislation does not relate to the illegal disturbance of Schedule 1 birds.

SNH says it is working with Natural England to provide best practice guidance, but in a later response to one of our blog readers (see comment from blog reader Andrew here), SNH says ‘there is insufficient evidence to warrant the production of guidance’ and then admits that ‘SNH guidance is not enforceable by law should an individual decide not to adhere to it’.

SNH says it is not considering separate licensing under the Wildlife & Countryside Act ‘but will continue to assess on a case-by-case basis any licence application to disturb scheduled birds’. But if gas gun use is unlicensed, then nobody will be submitting a licence application for use because they don’t need to.

Confused? We are.

The best advice we can offer to anyone who finds a gas gun in use on a grouse moor in Scotland is to report it to RSPB Scotland. Email: _InvestigationsSHQ@rspb.org.uk [please note the underscore at beginning of email address] Tel: 0131-317-4100.

We’re still waiting for a response from Natural England about their gas gun ‘guidance’.

Following yesterday’s blog about pesticide legs bands being attached to female red grouse to deter ticks (see here), Countryman’s Weekly has been in touch:

“We’d like to point out that we printed a correction to the article above in our edition of April 20 (we are a weekly title), which stated that the shoot “does not use pesticides in their dosing process“”.

Ah, so it’s just the chemotherapy drug Levamisole hydrochloride that they’re using then? What a huge relief that will be to everyone considering eating red grouse from this estate.

However, just because Cabrach Estate isn’t using pesticides to dose their red grouse (if you believe Countryman’s Weekly), that doesn’t mean that other grouse moors are not using them. The author of the original article (Linda Mellor) clearly believes pesticide leg bands are commonly used as a grouse moor management technique, otherwise she wouldn’t have written:

‘There has been a marked increase in grouse survival rates through this type of tick prevention‘.

As we pointed out yesterday, Linda is a professional freelance writer specialising in the game-shooting industry – if anyone should know, it would be her.

And if pesticide leg bands are not commonly used, why would the GWCT include specific advice on their website about how to use them (even though they’re unlicensed for use), as recently as last month?!

The thing is, just like this industry’s use of super-strength medicated grit with added de-wormer drugs, their use of toxic & poisonous lead shot, and their use of chemotherapy drugs, who is monitoring their use of pesticides to dose red grouse?

Er, that’d be nobody.

To say the grouse shooting industry is unregulated would be the understatement of the century.

Sign the petition to ban driven grouse shooting HERE

Last year we wrote a blog called The red grouse and medicated grit scandal: it’s hard to swallow (here). The opening paragraph of that blog went like this:

‘Just when you thought that all the detrimental environmental and health hazards associated with driven grouse moor management had been exposed, and just when you thought you understood the extent of corruption and/or incompetence by the government agencies responsible for preventing the detrimental environmental and health hazards associated with driven grouse moor management, along comes something else to make your jaw drop. This time it’s medicated grit‘.

The blog was about the unregulated and unlicensed use by grouse moor managers of super-strength medicated grit (used to treat red grouse against infestations of the parasitic Strongyle worm) and how the Government agencies responsible for food safety were not testing to see whether the active drug (Flubendazole) was reaching the human food chain because those agencies ‘didn’t know where to find red grouse for testing’. Unbelievable, literally.

Well, it doesn’t end there. We’ve now uncovered another potential health hazard associated with eating driven red grouse and this time it’s pesticides.

Last month a blog reader (thank you) sent us this clipping from the April 2016 edition of Countryman’s Weekly:

This young lad works on the Cabrach Estate in NE Scotland. In the article he talks about how busy he’d been in April, catching up red grouse at night to force a tube down their throats to administer a powerful veterinary drug (Levamisole hydrochloride) to kill the parasitic strongyle worm.

Amazingly, catching up grouse at night to administer medication is legal in Scotland throughout the year (except between 16 April – 31 July) under an SNH General Licence. Interestingly, it is only permissible in England during the grouse-shooting season (12 August – 10 December), although this raises serious concerns about the high probability of the drug entering the human food chain via shot birds (see here). It is NOT permissible to catch up red grouse to administer medication during the closed season in England, according to recent advice from Natural England. This is important – we’ll come back to it.

Now, back to the article. What we’re particularly interested in is the last three sentences. These are not direct quotes from the young trainee gamekeeper, but have been inserted by the article’s author who we believe was someone called Linda Mellor. Linda Mellor is a professional freelance writer, specialising in writing articles for the game-shooting industry, so we might expect her to know what’s going on on the ground:

‘Two go out on a quad at night; the passenger uses a net to catch up the grouse, typically females first, and ties a pesticide leg band onto the bird. This protects her directly and indirectly protects her chicks as they acquire some pesticide while brooding. There has been a marked increase in grouse survival rates through this type of tick prevention‘.

Eh? Leg bands impregnated with pesticides are being attached to the legs of female red grouse (in Scotland) to protect them and their chicks from ticks which can transmit Louping Ill Virus (and thus enhancing grouse productivity)? Really? That’s astonishing!

What type of pesticide is being used? What strength of pesticide is being used? For how long does the pesticide last? What is the effect on predators that may ingest a pesticide-treated red grouse? Is the pesticide licensed for use on wild birds that will later enter the human food chain? What about the statutory 28-day withdrawal period of all veterinary drugs prior to an animal entering the human food chain? Remember, the General Licence in Scotland does not permit the catching-up of red grouse until after 31st July, but the grouse-shooting season opens on 12th August. That means that these pesticide leg bands will not be removed in time to comply with the statutory 28-day withdrawal period. That makes the use of these pesticide leg bands illegal.

We’d not heard of this particular aspect of grouse moor management (perhaps it’s one of those that the GWCT is so keen to ‘keep under the radar‘) so we did a bit of digging. It turns out that several years ago various trials took place (in Scotland) to test the efficacy of this technique, some by independent researchers (e.g. see: Mougeot et al 2008 acarcide leg bands) and some by the GWCT.

There’s a useful article in the GWCT’s 2008 Annual Review (here – see pages 48-49), that concluded these pesticide leg bands did appear to reduce the tick burden of grouse chicks but that further research was required to confirm the findings.

There’s also a fascinating published thesis on the subject, that explains, among other things, how the active drug (in this case Permethrin, commonly used as an insect repellent and also used to treat scabies and pubic lice!) circulates through the body of the grouse via the bloodstream and how Permethrin-impregnated wing tags have also been trialled. It concludes that further research is required to test the effectiveness of these pesticide leg bands on the productivity of large scale grouse populations: Thesis 2011 acaricidal treatment red grouse

Now, all this research took place several years ago so we were interested in what ‘advice’ the GWCT may be giving out about the use of pesticide leg bands in 2016. Here’s what we found (downloaded from the GWCT website on 14th April 2016):

So, GWCT acknowledges that pesticide leg bands are not currently licensed for use on red grouse, but they suggest that grouse moor managers can adapt ‘existing products which require an off-label prescription from a veterinary surgeon’. In other words, find yourself a tame vet and do what you like, in exactly the same way grouse moor managers get around the licensing restrictions of using super-strength medicated grit (see here).

What’s also interesting about this GWCT advice is that it doesn’t make any reference to the restrictions of catching up grouse in England outside of the shooting season. Therefore their advice implies that it’s ok to do this in England, despite clear warning from Natural England that catching up grouse to administer medication between 11 Dec – 11 August is illegal (see here).

So, on the day when Marks and Spencer announced they’re preparing to sell red grouse in their stores this year (see here and here), on the advice of the GWCT(!), here are some of the ‘healthy’ things M&S can tell their customers they’ll be consuming as they tuck in to their ‘healthy and natural’ M&S red grouse:

• Excessive amounts of toxic poisonous lead (over 100 times the lead levels that would be legal for other meat – see here)
• Unknown quantities of the veterinary drug Flubendazole (see here)
• Unknown quantities of the veterinary drug Levamisole hydrochloride (also used in chemotherapy treatment for humans with colon cancer – see here)
• Unknown quantities of the pesticide Permethrin (used topically to treat scabies and pubic lice; probably not that great to ingest)
• They should also know that their red grouse may also be diseased with Cryptosporidiosis (see here).

Yum!

And then there’s all the environmentally-damaging effects of driven grouse moor management, as well as all the associated wildlife slaughter, both legal and illegal, but this blog is long enough already.

Ban driven grouse shooting: please sign the petition HERE

UPDATE 13 May 2016: Update on pesticide leg bands being attached to red grouse here