Within the restriction dossier, the Health and Safety Executive (HSE) has detailed a significant body of evidence of the lethal and sub-lethal effects of lead ammunition on birds.

The evidence relates to a ‘primary exposure pathway’ for birds who utilise a gizzard to grind up food as part of their digestive process. Usually these birds would consume grit, which would sit in the gizzard to aide the grinding of food items for digestion. In some cases, lead gunshot is mistakenly consumed.

Due to the grinding action and conditions within the gut, lead is taken up through the digestive tract. The lead uptake is proven to affect birds, from a range of sub-lethal impacts as well as ultimately causing their death if enough lead is ingested.

There is also a body of evidence presented in the restriction dossier about the impacts of lead on human health. Sub-lethal effects include neurotoxicity, kidney effects including renal disease and cardiovascular effects.

Although the evidence does not directly or solely attribute lead ammunition as a cause, either through primary or secondary exposure, lead is a ‘zero-threshold’ neurotoxin, which evidence shows has impacts on the IQ of children and ‘in-utero’ effects on a developing foetus.

Dietary exposure to lead in game meat is an means by which humans may consume lead, and it is clear from the evidence presented by HSE that existing meat processing practices cannot eliminate all lead contamination from game meat.

It is for these reasons that HSE are seeking to eliminate the risk of lead contamination in game meat reaching the human food chain.

We do not consider the evidence presented by HSE in the restriction dossier relating to secondary exposure to birds from lead ammunition to be conclusive. Based on the evidence presented, we do not consider restrictions related to this potential exposure pathway to be necessary or in line with the level of risk.

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