Food Standards Agency suppresses publication of lead in ‘game’ meat warning

Posted on the 5th October 2012

After more than two years of meetings and examination of scientific reports, the Food Standards Agency (FSA), taking advice from the Lead Ammunition Group (LAG), was expected on 3 October 2012 to publish guidance to the public on the risks of consuming ‘game’ shot with lead ammunition. It declined to do so and gave no reason why.

The LAG’s key purpose is to inform government policy development. It is composed of stakeholders from the game shooting industry, animal welfare and environmental organisations. Its Chairman is John Swift, who is also the Chief Executive of the British Association for Shooting and Conservation (BASC). In setting up the LAG, DEFRA and the FSA demanded balanced, fair investigations and findings, an obligation that rested uneasily on the Chairman’s shoulders. Here is the BASC attitude to the use of lead ammunition and shot:

‘BASC will vigorously oppose any unwarranted restrictions on the use of lead ammunition. Discussions and decisions about possible restriction must fully involve shooting interests to ensure that social, environmental and economic consequences are taken fully into account by decision makers. The justification for any proposed restriction must be clear, substantial and science-based.’

In the meeting room of the LAG, detailed scientific evidence was heard that levels of lead in shot game, such as deer, grouse, pheasant and boar are a risk to human health.

  1. Lead shot cannot always be removed and disintegrates into powdered form that permeates muscle and tissue.
  2. There is no safe minimum dose of lead in food.
  3. Some game on sale in Britain has levels of lead that would be illegal in other meats.
  4. Children eating only one game meal per fortnight may lose one IQ point. This increases the risk of failure between High School and University of nearly 5 per cent and reduces worker productivity by 2 per cent.
  5. There is a risk of spontaneous abortion in pregnant women and an impact upon blood pressure and kidney function.
  6. Communities and individuals that consume large quantities of game are at greater risk.

Animal Aid believes that game shooting celebrity chefs, the shooting magazines, BASC and the Countryside Alliance, who promote the consumption of game by way of seeking to justify a cruel bloodsport, must all bear responsibility for the consequent damage to human health.

So why has the FSA suppressed the LAG advice? The answer lies in the small print of LAG’s terms of reference (see below) – but, ultimately, we believe it resides in a pro-hunting and shooting coalition government’s reluctance to damage the gun lobby. In setting up LAG, DEFRA and the FSA reserved the right to decide on the timing of publication of any advice to the public. It also gagged members of the LAG.

Animal Aid calls upon the government to publish the findings of the LAG with regard to human health and the consumption of shot game with immediate effect.

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Read the Terms of Reference for the LAG


The purpose of the Lead Ammunition Group (the Group) is to bring together relevant stakeholders and experts to advise Defra and the FSA on:
(a) the key risks to wildlife from lead ammunition, the respective levels of those risks and to explore possible solutions to any significant risks;
(b) possible options for managing the risk to human health from the increased exposure to lead as a result of using lead ammunition.

The scope will be limited to England* (though relevant research and evidence may be drawn from anywhere) and focused on safety aspects for human food, impacts on wildlife and issues surrounding possible alternatives to lead. The Group will be established for an initial 12-month period, after which progress will be reviewed by Defra & FSA.


  • To advise Defra/FSA on what the significant risks to wildlife from the use of lead ammunition are and what levels of risk these pose in the short, medium and long term. Also any perceived risks which the evidence indicates are not significant.
  • To advise Defra/FSA on possible options for managing the risk to human health from increased exposure to lead resulting from the use of lead ammunition notably in terms of food safety (including game shot with lead ammunition and spent lead shot deposited on agricultural land).
  • To advise Defra/FSA of any significant knowledge gaps that may hinder the identification or assessment of risks, the development of technical solutions or the development of government policy.
  • To advise Defra/FSA on any communication issues, and possible solutions, concerning the relaying of balanced information on issues surrounding the use of lead ammunition to the media, general public and stakeholders.
  • To advise DEFRA/FSA of any significant impacts of possible advice or solutions on shooting activity and associated recreational, wildlife management, economic and employment impacts.


The Group may convene various sub-groups as necessary. The Group must be balanced and fair in their investigations and findings, making reasonable efforts to take account of all available information and views.

A high level group consisting of a person (or persons) from each of the following key sectors will, within the remit set out by Defra & the FSA, take strategic decisions for, and give direction to, the whole group (including sub-groups). Group members will represent the spectrum of views from their sector, not their organisation. The key sectors are: conservation, animal welfare, environment, human food safety, gun & ammunition makers/traders, and shooting and deer management interests. The Group will be overseen by a chairperson appointed by Defra and FSA.

Defra, FSA and the Chair will agree who will sit on the Group. The Group may consult experts as necessary. The Group may convene sub-groups to look in more detail at relevant issues. Sub-groups should be as inclusive as possible and must be balanced and fair in their investigations and findings. Sub-groups must be given clear aims and deadlines by the Group and report their findings exclusively to the Group.

Secretariat Support

Defra will provide the secretariat support to the Group (but not sub-groups) in the form of minute taking and arranging meetings/rooms. Defra/FSA will provide rooms for meetings for the Group. Whilst the need for face to face meetings is recognised, the use of ‘green alternatives’ such as e-mail, tele/video conferencing are to be encouraged. The Group will define its own operating principles within these terms of reference.

Financial Support

No financial support is being offered, either to organisations or individuals.


  • At the end of the first year the Group must produce a written report on progress for Defra/FSA.
  • During the year, the Group must inform Defra/FSA of any key findings as they become apparent.
  • Any scientific data or research used to underpin the written report must be of a quality that would withstand peer review.
  • The Chair will provide a single point of contact for the formal disclosure of advice from the Group to Defra/FSA. Individual group members must not disclose advice outside the Group.

Status of Advice

Advice should not be limited to actions for government and should cover advice to non-government organisations. However, any conclusions or recommendations of the Group will be taken into consideration by Defra/FSA when developing policies, but neither Defra nor FSA will be bound by any advice.


The key purpose of the Group is to inform government policy development. Advice from the Group will become publicly available, but Defra/FSA are likely to need time to consider and discuss the advice prior to wider dissemination. Defra /FSA will therefore decide on the timing of publication of any advice and prior to that all group members must respect confidentiality.

*Note: Defra has policy responsibility for this issue in England only, but the Devolved Administrations will be kept informed. The FSA has a UK wide remit.

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