BY MARK CRUDGINGTON

All UK shooters are eagerly waiting to hear what the Health & Safety Executive (HSE) decide to recommend to DEFRA with regard to the future of lead in ammunition.

The HSE is a government agency and this is how they described what guides them on their website:

“The fundamental principle of health and safety law is that those who create risks are best placed to control them. We take into account the impact on the economy, by ensuring any action we take is proportionate, targeted, consistent, transparent and accountable.”

However, when it comes to lead in ammunition they have been told, by the European Union it seems, that lead in ammunition MUST be banned and that they were to conduct a consultation to ensure that this happened. How can this be fair practice?

Despite the HSE stating its aims are to be ‘proportionate’ and ‘transparent’, in this case they have been the complete opposite. I have submitted to them various parts of the consultation on lead in ammunition and I have also asked them via e-mail what scientific evidence they are using that shows a direct link between lead ammunition and ‘poisoning’ of flora, fauna, humans and the environment in the UK. 

Now the HSE has published a massive document showing how lead could be a cause for concern but it is so muddled using scientific papers from a myriad of sources. None appear to be directly linked to lead ammunition here in the UK. The link to the 2023 analysis of risk on the HSE website no longer links to what was a 280 + page document that showed zero scientific evidence damning UK lead ammunition.

Instead now they have published a draft agency ‘opinion’:

That the main justifications for a GB-wide restriction are therefore:

• to ensure a harmonised high level of protection of the environment and human health to address the identified risks, which are common to England, Scotland and Wales
• to ensure free movement of goods within GB in line with the UK Internal Market through consistency of regulation; and
• to ensure a level playing field for everyone engaged in outdoor target shooting within GB.

A restriction under UK REACH would:

• allow effective control of both placing on the market and use of lead in ammunition in specified activities
• address risks to human health and/or the environment
• be applicable across GB through a single legislative change
• be subject to appropriate scrutiny throughout the legislative process and 59
• be subject to the REACH core principles of practicality, effectiveness, and enforceability

Well let’s just look at one of these justifications shall we?

• address risks to human health and/or the environment

So, what are the proven risks?

According to another Government agency, this time the Food Standards Agency , who state on their website “ it is impossible to avoid lead in food “  and the fact there is not one single report of anyone in the UK entering hospital suffering from lead poisoning as a result of using, ingesting or being exposed to lead ammunition, indeed according to the data held in the House of Commons Library from the NHS you have a .00001% chance of entering hospital in England suffering from lead poisoning (all those patients work in the lead industries ) yet you are 5x more likely to enter hospital having been struck by lightning and 10x as likely having been bitten by a poisonous snake (in England!).

So once again I ask the HSE what are the proven risks?

I am looking forward to reading the data they will display transparently showing the actual, not the possible, unproven, risks.

The whole malarkey smacks to me a bit of the Post Office /Horizon scandal. In that case it is alleged that 2 large organisations accused franchisees of the Post Office of something they were not guilty using assumption of data produced before the courts of which the 2 large organisations had complete control.  A cover-up that suited them ensued. The same could well be happening here.

Now the HSE are barging about using very expensive data gathered from all sorts of sources such as the Wildfowl and Wetlands Trust who claim that lead shot poisons over 100,000 ducks every year in the UK. They, the WWT, have never been able to produce any scientific evidence to substantiate this alarming statement. Indeed, when challenged, they finally admitted they have NO scientific proof that UK lead ammunition users poison wildfowl at all. One of their scientists , when challenged, stated to an 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”

Despite a slew of papers written by their scientists over the last 35 years it appears this is the sum total of actual scientific proof they have managed.  Hardly cast iron proof to back a ban on lead in ammunition.

Shooters are in desperate need of an Alan Bates to challenge what appear to be claims as non-sensical as the claims by Fujitsu and the Post Office.

As for the Environment, the now missing 2023 analysis of risks produced all sorts of dire warnings about lead ammunition in the environment, including papers on how metallic lead can be broken down by water (very, very slowly), how soluble lead compounds poison the environment etc etc , all the while pointing a huge fat finger directly at lead ammunition, no mention of any other source of lead in the environment.

They have completely ignored the billions of tons of metallic lead used in historical and current building construction, exposed to the same conversion effects as they so damningly describe for lead ammunition.

I am therefore led to conclude that if the HSE recommends the banning of lead ammunition for environmental reasons they will also recommend a ban of all metallic lead used in the building industry and the removal of existing building lead? 

Then, of course there are the dreaded soluble lead compounds  that can be produced from metallic lead . Well, the UK is “built on soluble lead compounds such as common Galena (Lead Sulphide , the main source of lead ore) as well as millions of tons of other common lead compounds both natural and man-made. Maybe the HSE will recommend the removal of all land from the UK to reduce the risk? Maybe we should all go and live in France instead?  

Steve Barclay MP, the present minister at DEFRA, can read. And no doubt he will see through this baloney.

I am astounded that despite this subject being expensively examined on a similar mandate by the Lead in Ammunition Group, which concluded in 2016, there is another examination ongoing now. The then Environment minister, the now much pilloried former PM Liz Truss MP, decided on studying the report (which also damned lead ammunition without scientific proof)

 “The Secretary of State has confirmed that the Food Standards Agency will not be changing its advice on the consumption of game shot with lead ammunition and notes that “the report does not provide evidence of causation linking possible impacts of lead ammunition with sizes of bird populations”. In relation to both human health and wildlife the Secretary of State is clear: “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”

So, what has changed in the last 8 years?

Nothing is the answer.

Just the rise in volume of small single issue focus groups opposed to shooting such as the now infamous and fading Wild Justice. And the rise of social media. It is interesting to note that many of the science papers produced by the HSE to back the desire to ban lead shot have been written by scientists described by Wild Justice, an organisation that wants the end to field sports in UK, as their ‘friends’!  

Let’s remember the HSE’s words again …

‘Integrity‘

Upholding the highest standards of honesty and ethical behaviour is essential in our mission to provide accurate, up-to-date, and reliable information on health and safety topics. We firmly believe in transparency and authenticity in all our content and interactions.

Shooters of the UK , we appear to be placed into a very similar situation to 2016. And unless, like Alan Bates, you are prepared to make your disquiet known, to challenge the accepted “truth” and seek evidence that proves your case, you too will suffer the removal of what for many is both a hobby, pastime and in some cases a vocation that gets them out and about.

Mr Barclay, please read all the documents yourself. Do not be hoodwinked or scared off by a Twitter pile-on. If you need a word on who are the propagandists you are facing, please do get in touch.  

Mark Crudgington is a 2nd generation gunmaker, at large in Wiltshire. His company George Gibbs Ltd is nearing its 200th birthday. A passionate shot, angler, deer stalker and natural sceptic. If you’d like to learn more about this subject, please have a look here.