BY MARK CRUDGINGTON

Rt Hon Steve Barclay MP, DEFRA

Dear Mr Barclay ,

I am a master gun maker who has for the last 18 months been communicating with your predecessor concerning the proposed ban of lead in rifle and shotgun ammunition against which I am totally opposed.

I have also communicated with DEFRA, the HSE, my MP, The Prime Minister and various organisations.

In most of my communications I have asked for scientifically proven answers to simple questions concerning metallic lead as used in ammunition as well as metallic iron, which is proposed as the main replacement, should a ban on lead in ammunition be sanctioned. These questions should all be on record with your department as well as at the HSE.

In summary, metallic lead is a relatively inert metal, much more so than iron. To become a danger to the environment, fauna, flora and humans, metallic lead has to be turned into an organic / inorganic compound / ion. The same is true for iron.

Lead compounds can be highly dangerous, as can compounds of iron. Tetraethyl lead that was added as an anti-knocking agent to petrol for over 80 years and burned by the millions of tons (producing more harmful compounds) could kill you if it came into contact with your skin yet metallic lead cannot be absorbed through your skin. Metallic iron cannot be absorbed through your skin yet Ferric Chloride (Iron Chloride) can be absorbed and is highly dangerous, usually fatal.

Metallic lead is so inert that it is present, in billions of tons, on the vast majority of buildings in the UK, it is exposed to the erosive effects of wind, rain and sunshine as well as abrasion yet is not considered a danger. However metallic lead in relatively small amounts present in the sand traps of rifle shooting ranges exposed to the same forces, is considered so dangerous by HSE (without scientific comparison or explanation) that it is proposed it must be removed from those sand traps on a regular basis because of the dangers to human and animal life as well as the environment.

Acids do not react easily with metallic lead. Hydrochloric acid, present in our digestive system, does not dissolve easily if at all, nor does it react with blood or plasma, as shown by bullets and pellets left in victims, as surgery is viewed as sometimes more harmful to remove those objects. There are still veterans of WW2, the Korean, Vietnamese and Northern Irish conflicts carrying metallic lead “souvenirs” – some for more than 80 years with no reported ill effects.

Please look at the questions I have asked (copied below), which DEFRA and HSE have refused to or are incapable of answering. Without using available scientific tests such as lead isotope mass spectrometry data research, which pinpoints the type and source of lead in the environment, plants, animals and humans very accurately, to actually prove that metallic lead in ammunition is a danger, I and many, many others can see no valid reason for banning what is the only effective and humane projectile to harvest and dispatch through legitimate Field Sports, Culling operations etc.

The proposal to ban lead in ammunition has been put forward by scientists who are all described by the organisation “Wild Justice” as their “friends”.  Wild Justice led by Chris Packham are dedicated to banning all Field Sports and can hardly be viewed as an impartial arbiter of scientific research. They are infamous propagandists.

The Wildfowl and Wetlands Trust, who also want a ban, when they were challenged about the exact scientific evidence they had to prove that wildfowl could be poisoned by ingesting spent lead pellets, this after 40 years of claiming they had scientific evidence to show that was the case, replied to my question, copied to Danny Kruger MP:

“We and many other scientists believe that it is reasonable to suggest that lead shot is the most likely source of poisoning when poisoned birds have lead shot (usually multiple in our experience) in their digestive tracts, particularly when there is no other obvious source of lead exposure to birds in the environment that they occupy.”

When challenged about lead isotope mass spectrometry data research, they confirmed they had not used any and when I offered to pay for them to engage in it they replied that it “would be a waste of our charitable time”.

They have no proof, RSPB have no proof, DEFRA have no proof and HSE have no proof to give reason to ban lead in ammunition.

If you decide to implement such a ban you may only confirm in the mind of the common man that politicians are nothing more than a group of people easily corrupted through a lack of effort in using independent means of assessing the truth and administering their great offices of state with “fairness”, impartiality and professionalism.

The current faith in politics is rapidly being dismantled, I have many friends and customers, many dedicated Conservative voters, who, over this debacle over lead in ammunition, will either not vote at all in the next election or spoil their ballot papers as they feel there is no one in Government who actually represents Truth, Honour or Fair Play.

Let us hope that You, Sir, do.

Yours,

Most sincerely,

Mark Crudgington

LIST OF QUESTIONS ASKED:

Following a Health and Safety Executive (HSE) consultation in 2022, the revised restriction proposals for the outdoor recreational use of lead ammunition in England, Wales and Scotland are as follows:

• Lead airgun pellets – no restrictions proposed.
• Lead shot for live quarry and target shooting – proposed ban within five years or less, depending on consultation outcome.
• Rifle ammunition for live quarry shooting – no restrictions proposed, but this could change depending on consultation outcome.
• Rifle ammunition for target shooting – can continue on approved ranges where mitigation measures for lead removal are in place, with a  two-year grace period.

1   Lead shot for live quarry and target shooting – proposed ban within five years or less, depending on consultation outcome.

What lead isotope mass spectrometry data does the HSE have that can prove that metallic lead shot is a proven threat to wildlife, the environment or humans ?  

What proven scientific facts does HSE have that shows if lead shotgun pellets are soluble ?

What proven scientific facts does HSE have that shows how lead shotgun pellets if ingested by wildlife or humans can be converted into a soluble form ?

Considering that Dr Julia Newth of the Wildfowl and Wetlands Trust stated in an e-mail to me and Danny Kruger MP that “We and many other scientists believe that it is reasonable to suggest that lead shot is the most likely source of poisoning when poisoned birds have lead shot (usually multiple in our experience) in their digestive tracts, particularly when there is no other obvious source of lead exposure to birds in the environment that they occupy.”

What proven scientific facts does HSE have that shows how lead shotgun pellets if ingested by wildlife  can cause lead poisoning ?

The Food Standards Agency state, (I have highlighted an important sentence): “Lead is a naturally occurring chemical contaminant that is present in soil, water and the atmosphere, including as the result of human activities in the past. Due to its presence in the environment, lead is likely to occur at low levels in a wide range of foods including tea. Plants including tea plants can uptake lead via their roots and by deposition on foliage. This is not a new risk and people are exposed to lead in their diet from many sources. It is not possible to avoid exposure to lead from food.”

What scientific evidence, proven by the use of such tests as lead isotope mass spectrometry that shows lead shotgun pellets pose a greater threat to food supply than the normal levels of lead found in all foods and drinks?(this does not include the highly biased report made by Messrs Pain & Green about “game meat” which has not been independently verified).

2 Rifle ammunition for target shooting – can continue on approved ranges where mitigation measures for lead removal are in place, with a two-year grace period.

What scientific evidence does HSE have that proves scientifically that firearms ranges prove more of a threat to the environment that other sources of metallic lead such as lead roofing and lead roof flashings of which there are billions of tons in the UK ? 

What evidence does HSE have that will ensure we don’t have to remove ALL lead from exposed sites on buildings if small levels of lead rifle bullets cause a threat to the environment ?

What evidence does the HSE have that shows naturally occurring ” Galena ” ( Lead Sulphide ) which occurs in huge amounts in most parts of the UK is less of a threat to the environment and wildlife than lead rifle ammunition on rifle ranges and if it is the same or more so , how will the HSE remove all Lead Sulphide from the UK ?