John Swift briefing Nov 2014 and my article in reply.

‘Much to do about nothing’

by Ian Summerell

John Swift came to the DI meeting and reported the findings of a Norwegian report. People who eat lead shot game meat had higher lead level than people who don’t. I cannot accuse John Swift of lying but I make the accusation that he was misleading and disingenuous in his reporting.

The new report from Norway is the “Consumption of lead-shot cervid meat and blood lead concentrations in groups of adult Norwegians.” Meltzer et al (2013)

The Abstract of the report states:

Several recent investigations have reported high concentrations of lead in samples of minced cervid meat. This paper describes findings from a Norwegian study performed in 2012 among 147 adults with a wide range of cervid game consumption. The main aim was to assess whether high consumption of lead-shot cervid meat is associated with increased concentration of lead in blood. A second aim was to investigate to what extent factors apart from game consumption explain observed variability in blood lead levels.


Median (5and95percentile) blood concentration of lead was 16.6 mg/L (7.5and39 mg/L). An optimal multivariate linear regression model for log-transformed blood lead indicated that cervid game meat consumption once a month or more was associated with approximately 31% in crease in blood lead concentrations. The increase seemed to be mostly associated with consumption of minced cervid meat, particularly purchased minced meat.

However, many participants with high and long-lasting game meat intake had low blood lead concentrations. Cervid meat together with number of bullet shots per year, years with game consumption, self-assembly of bullets, wine consumption and smoking jointly accounted for approximately 25% of the variation in blood lead concentrations, while age and sex accounted for 27% of the variance. Blood lead concentrations increased approximately 18% per decade of age, and men had on average 30% higher blood lead concentrations than women. Hunters who assembled their own ammunition had 52% higher blood lead concentrations than persons not making ammunition.

In conjunction with minced cervid meat, wine intake was significantly associated with increased blood lead. Our results indicate that hunting practices such as use of lead based ammunition, self-assembling of lead containing bullets and inclusion of lead-contaminated meat for mincing to a large extent determine the exposure to lead from cervid game consumption.

After reading this you may be thinking that hunters that eat lead shot game are doomed! I believe this is no more than scare mongering, we had the scare in fresh chickens last week and soon we may see a report in the shooting press reporting the high levels of lead in game meat is dangerous and reporting the findings in the Norwegian study.

The Norwegian study had no control group.

The average BLL at 19.3 ug/l in the Norwegian Study was below other EU studies at 20-30ug/l.

I would point out that this stud shows that Norwegian hunters who eat lead shot game have lower BBL than the EU average.

We are told that lead is toxic. They banned lead for wildfowling, they now want to have a total lead ban for all shooting. That is the aim of the WWT and RSPB, the WWT reported this in a BBC news report and the RSPB have reported their intent on their web site.

Oh, they say, they’ve removed lead from paint, lead from pencils and lead from petrol.

Lets look at this a little closer, over the years we have been told that lead is toxic, CO2 is the cause of Anthropogenic Global Warming (AGW) and carrots help you see in the dark.

I do not intend to go into detail of CO2 but we have been told that CO2 is the cause of global warming were as in fact NASA tells us that there has been no global warming for over 15 years. I believe this was to create a market for CO2 and alternative energy systems.

They haven’t removed the lead from the inside of pencils. Lead wasn’t put into the graphite, it was in the paint on the outside of the pencils.

The wartime propaganda told the British public that carrots helped you see in the dark. This was to make the Germans think RAF pilots ate carrots to see in the dark, to hide the fact that we had radar.

That brings back to TOXIC lead. Lead is toxic in high concentrations and the lead they put into paint and petrol was not the lead we use for shooting. The lead we use in shooting is solid lead and may have a little bit of antimony in it to make it harder.


Lead in petrol was not solid lead, in was Tetraethyl lead and it had a chemical formula of (CH3CH2)4 Pb. Researching this article I found a web site reporting that the level of lead in the air reduced year on year from 1920 but when Tetraethyl lead was removed from petrol it started to go up year on year. The theory is that the Tetraethyl lead in petrol combined with the lead in the air and fell to the ground.

Lead in paint was white and red lead, white lead is lead carbonate or lead sulphate, and red lead is lead tetroxide. White lead was the main white lead pigment used in some paints. Red lead was used in metal paint and primer coatings.

The lead used in shot and bullets is not toxic in its solid state and is very stable.

Now lets look at the Norwegian report, they report hunters that eat lead shot game meat having higher levels of lead in their blood than people who do not. This may be true but how toxic is the level they have?

We know the human body needs trace elements of metals and minerals. You need Iron and Zinc. You also have trace elements of silver and lead. I’m told we also need trace elements of Arsenic!

It is said that the phrase born with a silver spoon, was because people that used silver cups for wine and drinks had trace elements of silver in the blood helping to fight off diseases.

Question, do we also need a trace element of lead in our blood? I do not know the answer.

How much lead did the Norwegian hunters have in their blood?

The Norwegian report says that an average of 22.3ug/l lead was found in the blood of hunters that eat lead shot game meat. That was higher then people who did not eat lead shot game meat.

How toxic is 22.3 ug/l of lead in the blood?

ug refers to micrograms and L is litres, so there is 22.3 micrograms of lead in every litre of blood. To put this into prospective the average is a trace element of a really very small tiny amount of only 0.0000223 grams of lead per litre of blood.

That is the claim and we are being told that we should reduce that lead level. John Swift told the DI back in 2010 that there is lead in the food chain and we have to find ways to reduce it.

What is the safe level of lead in blood?

I work with lead in the workshop and Health and Safety tell me that the max level of lead in my blood should be not more than 600ug/l, at that level I have to stop working with lead. At 500ug/l I have to see a doctor. That is 0.000600 grams per litre of Blood.

If I read the American study Schafer (2005) correctly, the blood lead levels in the general population are expected to be around 15 μg/dL.,15 ug/dl is 150 ug/l.

That is why at the end of the Norwegian report, that an average of 22.3ug/l in hunters eating lead shot game is lower than the average American at 150ug/l, comes to the clear conclusion that “the risk at an individual level is low or negligible.”

So all this hype about higher lead levels in people who eat lead shot game is no more than scare mongering. This article is headed, ‘much to do about nothing’ or are we to believe the hype that lead shot game is toxic, my conclusion is that it is “much to do about nothing!”


Appendix 4 report from john Swift


Report to the DI Partnership meeting 25 November 2014

This report has been listed as a “Lead Ammunition Group Update” and I am happy to tell you where things stand and answer questions if I can. But I stress that I am speaking in my capacity as a trustee of DI Ltd because I think there is something that DI needs to be thinking about carefully.

As far as the Lead Ammunition group is concerned, since you have asked, I can apprise you that I have drafted a Report pulling together and consolidating the wide range of evidence from four detailed risk assessments, as well as discussions in committee and subgroups covering human health and wildlife impacts of lead ammunition. That was largely completed in October and is now being checked for technical accuracy and balance – and distilling a straightforward executive narrative. I am hoping to get that feedback by the end of November but whether I do is another matter, and how much time will be needed to make all the corrections and re-editing is uncertain until I do. Circulation to stakeholders will follow. Then finally submission to Defra and FSA, who will need time, before they decide what to do. So the timetable remains rather open.

Chairmanship of the Lead Ammunition Group means that I pay close attention to anything connected with lead ammunition. If something could impact the objects and business of the Deer Initiative I draw it to the attention of the Board, which I did the other day.

To start with the obvious the Deer Initiative’s responsibility is for deer, good management, promoting conservation priorities, preventing damage, road accidents and disease, and so on. It relies for this in part on being able to control deer numbers. And that in turn is much helped by the possibility to dispose of shot animals as high quality venison food products, whether that involves “local distribution in small numbers”, or more particularly to larger retailers or export. If markets could be at risk it is a serious issue. And it is therefore important to keep antennae finely tuned.

One of the topics the Lead Ammunition Group has been addressing is the possibility of harm to an increasingly game-eating public – in our case caused by lead bullet fragments. We have to answer the question whether ammunition lead can be present in game at levels enough to present significant health risks to children and adults, depending on the amount they eat of course. But the additional question for DI is also whether authorities in other countries to which we export venison, believe the answer is “yes”.

The technical reasons for concern, and I don’t want to bore you with technical jargon, are that food health authorities in this country (FSA) and in EU (EFSA) as well as globally through WHO, are of the view, on the strength of much science, that the gap between public lead exposure levels from a normal diet is already too close to exposure levels causing known and specified clinical health risks – and the policy is to reduce lead exposure wherever possible. That indeed has happened in recent years. But concern has also been expressed for people who eat a lot of game as part of their diet, so called “high level consumers” and double-especially so for children and expecting mums, and triple especially so for children and expecting mothers and women trying for a child in high consuming households.

The source of this risk is the well-known neurotoxic impact of lead when ingested and getting into your blood stream, and especially the risk to the foetus’s or young child’s developing brain. This happens at very low levels of exposure from ingested lead. In fact there is no lower level below which harm will not be done – for which there is solid science. Lead harms just about every organ and biochemical system in the body to some degree but brain damage is the most important.

The risks from eating deer meat and deer meat products – veni-burgers, sausages and pates and so on, have been rather assumed to be less than the potential hit from eating game birds – not least because a lot of venison comes from game farms where they are head or neck shot – or imported from New Zealand.

You will be able to read my report into all this and the risk assessments in due course once formally submitted to Defra and FSA, but in the meantime two reports have recently been published from Norway and Sweden that should not be ignored and may be helpful.

These address, by good research such as has not been done in UK (1) ammunition lead levels in cervid meat products (which have been found to exceed permissible lead levels in other types of food products for the market) (2) blood lead levels in consumers (which have been found to approach or exceed reference levels for benchmark harmful health effects), and (3) options and advice, based on pretty rigorous and now painstaking study, on prudent consumption levels and carcass handling practice that will ensure a safe product, help secure future markets for venison and ensure “bon appetit”.

The studies I refer you to are:

  1. The Opinion of the Panel on Contaminants of the Norwegian Scientific Committee on Food Safety, entitled “Risk Assessment of Lead Exposure from Cervid Meat in Norwegian Consumers and in Hunting Dogs”. This was dated 18.06.13 with ISBN number 978-82-8259-096-9.
  1. The Swedish National Food Agency Report #18 dated 2014 for which there is an official English summary – entitled Lead in Game Meat.

You must read these for yourselves with a cold towel around your head, because the findings are nuanced. But some of the most pertinent findings to me from Norway were:

  1. Lead concentrations can be found at 25 cm distance from the wound channel in red deer and wild boar shot with various unknown ammunition. This broadly coincides with Peter Green’s advice to BDS in October 2009.
  1. Associations between game meat consumption and blood lead concentration have been studied in four population studies in Norway. In the three studies performed in the years 2003-2005, a significant association between game meat consumption and higher blood lead concentration was only seen in the subgroup of male participants in one of the studies (the Norwegian Fish and Game study).
  1. In the more recent fourth study, the Norwegian Game and Lead study conducted in 2012, the median blood lead concentration was in the lower range of medians measured in most European and Norwegian studies over the previous 10 years. But – and it’s a big but – this study also confirmed (1) association between cervid meat consumption and concentrations of lead in blood and (2) that those with frequent (monthly or more often) cervid meat consumption had about 30% higher average levels of lead in blood than those with less frequent consumption. However to be fair, there was a wide range, and many participants with high or long-lasting game meat intake had low blood lead concentrations.
  1. The increase in blood lead concentrations seemed to be associated with consumption of minced cervid meat particularly purchased minced meat.
  1. Blood lead concentration was significantly higher in participants who reported self-assembling of lead-containing bullets. Thankfully not too many children do home loading.
  1. The third big but is that blood lead concentrations measured in participants in the Norwegian population studies are in the range of, and partly exceeding, the reference values for increased risk of high blood pressure and increased prevalence of chronic kidney disease in adults, and for neurodevelopmental effects in children. The additional lead exposure from cervid meat in frequent (monthly or more often) consumers of such meat is therefore of concern.
  1. So what are they doing about it? Removal of meat around the wound channel reduces the lead exposure from cervid meat consumption. Lead’s fragmenting and distribution is dependent on several variables. The available studies did not allow a firm conclusion on the amount of meat needing to be trimmed around the wound channel in order to remove lead originating from the ammunition. Other possible measures to reduce lead exposure from cervid meat would be to use lead based ammunition with low fragmentation (bonded bullets), or ammunition without lead.

The latest Swedish report has moved things on and concluded that

  1. In all, lead levels were analysed for 200 samples of food product and lead levels ranged from below the level of detection (0.004 mg/kg) to hundreds and even thousands of mg/kg. The highest levels were found in the meat from the wound channels, but very high levels were also found in meat intended for consumption from the area around the wound channel.
  1. More than 40 percent of the cuts from roe deer, fallow deer and wild boar contained levels above the legal limit for beef, pork, mutton and poultry. There was a significant decrease in lead level with increasing distance from the wound channel.
  1. Lead levels were high for game taken with lead shot before cleaning but could be reduced by up to 100 times by removing any meat visibly affected by the shot or fragments. Alternatively, lead free ammunition can be used.
  1. Recent investigations in both Sweden and Norway show that consumers who eat game meat more often than once per month suffer from higher lead levels in the blood than consumers who do not eat game meat.
  1. In addition, the studies showed that there was a positive relationship between blood lead levels and the number of shots fired, and in the Norwegian study also from reloading of ammunition.
  1. Consumption of game meat and shooting independently may result in elevated blood lead levels of hunters’ families.
  1. So ….

Handling practices for game shot with lead ammunition – hunters


  • For game shot with bullets, remove the wound channel defined as any meat that is visibly affected by the bullet (or bloodshot) and an additional 10 cm of meat visibly unaffected by the bullet. All of this meat should be discarded.

Handling practices for game shot with lead ammunition – consumers


  • Avoid consumption of meat from the area close to the wound channel, unless the carcass has been cleaned in accordance with the advice above.

Handling practices for commercial game processing plants


  • Game processing plants and their retailers should develop procedures that ensure that game meat released on the market does not contain elevated levels of lead.

Additional information to be communicated

  • Consumers that eat game meat once or twice per year are unlikely to receive a portion with elevated lead levels, regardless of the choice of cut. The associated very limited lead exposure would not entail increased risks of negative health effects.
  • Game meat that already has been harvested (e.g. in freezers in households) and which can be expected to contain elevated lead levels need not be discarded, but consumption should be limited to once per month. The associated limited (exposure length) lead exposure would not entail increased risks of negative health effects.
  • Pregnant women, women planning to become pregnant and children 0-7 yrs. should continue to avoid eating such meat.
  • Using lead-free ammunition eliminates the problem of elevated lead levels in game meat and products made from game meat.

It’s certainly not my job to make judgments here today. It is up to the partners to decide what they feel they might/could/should do to safeguard future markets, which after all are pretty important if the partnership is to carry out its mission.

As things stand FSA has published advice to consumers but it is very vague indeed – nothing like the advice that is now being given in respect of children and mothers to be in Sweden, Norway, Spain and Germany.

All we know about carcass handling practices in UK is that people who shoot more game tend to take more care to remove the more obvious damage and lead fragments. But there is no information available to me what that amounts to.

Advice on precisely what needs to be done to ensure safe-meat is not part of the “best practice” syllabus.

There is some monitoring but I am not aware of testing or procedures within the supply chain for ensuring that lead levels in venison products going onto the market are not elevated.

Nor am I talking today in terms of responsibilities about not putting lead into the environment, or evidence of it getting into wildlife and collateral damage from killing or harming animals.

Of course there is a plan B – non-lead ammunition – which is another matter. I’m not aware of any systematic collection of “an industry view” in UK although there is a huge amount of knowledge about the efficacy of copper from other countries these days.

I would stress in closing that I am speaking purely as a Trustee of DI Ltd and not in my capacity as Chairman of LAG.

Thank you for listening and I hope it provides some food for thought a regards best practice – a stitch in time …

John Swift

25 November 2014


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