The Lead Ammunition Group

What is the Lead Ammunition Group (LAG)?
The Lead Ammunition Group was set up in 2010 at the invitation of the Department for Environment, Food and Rural Affairs (Defra) and the Food Standards Agency (FSA). The group was chaired by John Swift (BASC Chief Executive until 2013) and included a range of stakeholders such as the RSPB, Wildfowl & Wetlands Trust, Countryside Alliance, Gun Trade Association, Game Dealers Association and GWCT, as well as other professionals and academics. On the government side, the Food Standards Agency and Defra, were present; the latter initially provided the secretariat. The group submitted reports to government in 20151.

What was the aim of the LAG?
Defra requested that the LAG evaluate the published scientific evidence of the impact of lead ammunition on human health (for people eating shot game), on wildlife and the environment generally, and on livestock grazing on shot-over land. The Group was asked to focus on the likely impact in England, pay attention to population-level effects, to examine mitigation strategies, and to bring forward consensus recommendations.

Did the Group deliver a consensus on the future use of lead in ammunition?
No. Instead, the 2015 report recognised that viewpoints diverged. Some stakeholders believed that the risks from lead ammunition were not sufficiently proven to justify further restrictions. Others believed that, as the body of scientific evidence globally is compelling, and since replacements for lead ammunition are available and have been successfully used in other countries, it would be prudent to phase out lead ammunition.

Furthermore, as some members resigned from the group and were not replaced, a consensus outcome was not reached. This meant that the report did not fulfil the group’s terms of reference.

Why did some members of the group resign?
They were unhappy with the structure and workings of the Group. As a result, there was a dispute over the evidence used and the process followed to produce it. Documents published after a Freedom of Information request supported the view that some members of the group were working to eliminate all risk rather than establish strategies to mitigate risk.

What was the conclusion of the final report submitted to Defra?
The report concluded that “it is a matter of political judgment whether the actual and potential risks to wildlife and human health described in the report and associated risk assessments merit further mitigation effort in addition to the regulations for wetlands already in place. If it is decided that the risks to wildlife and human health need to be better addressed, there is no convincing evidence, yet available, that anything other than an eventual phase-out of lead ammunition and phase-in of the non-toxic ammunition alternatives will do it.”

What was the response of the Secretary of State to the report?
The Defra Secretary of State Liz Truss MP wrote a letter to John Swift in July 2016 which said:

“…it was disappointing that a number of Group members resigned and that a whole group consensus could not therefore be reached on this important issue. However, I fully appreciate the challenges the divergence of opinions within the Group presented you with.

Following receipt of your report, the Food Standards Agency (FSA) sought independent scientific advice from the Committee on Toxicity about the human health risk assessment within it. This has led the FSA to conclude that the evidence provided in your report does not affect their current advice. This advice, which has been in place since 2012 […]

With regard to the impact of lead ammunition on wildlife, we note that the report does not provide evidence of causation linking possible impacts of lead ammunition with sizes of bird populations in England.

In both instances – human health and wildlife – the report did not show that the impacts of lead ammunition were significant enough to justify changing current policy; we therefore do not accept your recommendation to ban the use of lead ammunition.

The use of lead ammunition is already banned on all foreshores, certain SSSIs and for the shooting of all ducks, geese, coot and moorhen. I do, however, recognise that there appears to be an issue with poor compliance with the Lead Shot Regulations and I can confirm that Defra will look at how the existing Regulations on wildfowling can be better implemented. We also understand that the FSA will be considering if action is required to raise awareness of their advice amongst the at-risk population.

As you know the European Chemicals Agency (ECHA) has been asked by the European Commission to gather information on the potential risks presented by metallic lead, to establish if there is a case for regulating its use within the European Union; we will keep the evidence presented by the ECHA under review.[….]”

Did the Secretary of State seek further clarification of any aspects of the recommendations from the remaining members of the LAG?
No. The letter stated that “… this marks the end of the Group which the Government established in 2010, I have no doubt that the evidence you have gathered together will form a useful input to the exercise the ECHA is taking forward. I would like to thank you again for your efforts.”

What is the current status of the LAG?
LAG was stood down as an official body after the 2015 report but continues to operate independently.  However, the government is considering whether any changes to current regulations are required following an Update Report produced by LAG in April 2018 and the findings of the ECHA review.

What additional evidence does the LAG update report present?
The 2018 update provides further evidence of the effects of lead ammunition on wildlife, expanding previous evidence to include non-wetland bird species, an additional pathway of exposure resulting in higher estimates of the number of birds suffering welfare effects and population-level effects (an area of weakness in the 2015 report identified by the Secretary of State – see letter above), and human health. It also reviews recent developments in international policy and practice. It concludes “that the numerous peer-reviewed papers and other information published since production of the LAG report both support and strengthen its conclusions.”

Does the new evidence demonstrate population scale effects occurring in species in the UK?
No, none of the new evidence, except a paper based on computer models, relates to studies in the UK, although a number of species that occur in the UK are shown to be affected.

What did the ECHA report to the European Commission conclude?
In September 2018 the ECHA reported that its investigation into non-wetland uses of lead in ammunition (gunshot and bullets) and in fishing weights had found sufficient evidence of risk to justify regulating the use of lead ammunition in terrestrial environments as well as those proposed for wetlands. The report was issued in November 20182. The Commission is expected to take a decision mandating ECHA to take forward the restriction in terrestrial environments, most likely when a new Commission is appointed following the June 2019 European elections.

The proposed restriction on the use of lead shot over wetlands is currently being taken forward by the Commission according to REACH process.

References

  1. Lead Ammunition Group. (2015). Lead Ammunition, Wildlife and Human Health.
  2. European Chemicals Agency. (2018). A review of the available information on lead in shot used in terrestrial environments, in ammunition and in fishing tackle. Helsinki.

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