Defra offices – London
Attendees:
Mr John Swift - British
Association of Shooting and Conservation (Chair)
Dr Mark Avery - RSPB
Mr John Batley - Gun
Trade Association
Mr Stephen Crouch - National
Game Dealers Association
Mr Adrian Gane - Country Land and Business Association
Mr Robert Gray - Countryside
Alliance
Prof. Len Levy - Institute
of Environment and Health
Dr Deborah Pain - Wildfowl
& Wetlands Trust
Dr Stephen Tapper - Game
and Wildlife Conservation Trust
Secretariat
Mr Tim Andrews - Defra
(Secretary)
Ms Lucy Munro - Defra
1. Apologies, welcome and introductions
1.1 Apologies were received from
Dr James Kirkwood of the Universities Federation for Animal Welfare.
2. Review and discussion of published minutes of the 26 April
2.1 The Chair raised one member’s point that the Terms of Reference
effectively ask members of the Group to have a ‘triple-hatted’ role (providing
personal expertise in the light of their own organisation’s views while
reflecting wider views of others in their sector of interest).
2. 2 The Group recognised the difficulty of finding a phrase that
encompasses everyone’s position, and for some, to formally represent a spectrum
of the views [of organisations in their sector] is almost impossible. It was agreed
that members of the Group would strive, beyond providing personal expertise, to
represent science-based and objective view points from their sector but were not
expected to represent the full spectrum of views that might be held and
expressed within their sector.
2.3 It was asked why FSA officials were not in attendance and it was
explained that since the Group is an independent group government officials would
only attend by invitation.
3. Review of Actions from last meeting and sign off of revised Terms
of Reference (ToR)
3.1 It was advised that the Group’s Terms of Reference are published
in their final form on the website. (The Group formally ratified these later).
3.2 The Group discussed decision making and it was suggested that if
the Group’s aim is working towards consensus on a topic it could be more
representative if each sector represented in the Group had one vote, rather
than each Group member having one vote. This was because some sectors have greater
representation than others.
3.3 Following discussion it was agreed that the Group’s role is
advisory. The aim is to be able to provide advice based upon the consensus
view. It was difficult to see the relevance of voting. The Chair gave his
reassurance that both minority and majority views would be recorded and any
significant minority views would be included alongside any recommendations that
might be eventually made by the Group. This was because any future policy would
be decided by government and minority views would be needed to inform any political
decisions involved.
3.4 The Group noted that an action from the last meeting (Action
1.1) had been for all Group members to consider who should be involved in
subgroups. Following discussion it was concluded that discussion about
involvement of people in subgroups was premature because consideration was still
being given to gathering primary evidence. Only when the primary evidence had
been gathered and the risk assessment process decided upon could the Group take
a view about who from outside the Group might best be involved in the risk
assessment. Suggestions were invited. Discussion about subgroups dealing with
the outcomes of risk assessment would come after that.
3.5 The Group discussed the research the Food Standards Agency was
commissioning into the consumption of game meat and venison (see inaugural
meeting) and the relevance of such research to the Group’s work. Defra was
requested to liaise with FSA to find out the timeframe for this research (Action
2.1 Defra/FSA).
3.6 It was suggested that if this research was not commissioned soon
its conclusions might not be any help to the Group. The Group reflected on the
need for such research to involve deer management and gamekeeping interests. It
was also noted that the European Food Safety Authority scientific opinion on
lead included comprehensive risk assessment based on a large amount of game
consumption data provided by EU Member States.
3.7 The Group expressed its wish to discuss the design and evidence base being
considered for the FSA research with them. This was because of its possible relevance
to the work of the Group. It was agreed that Defra contact FSA with a view to
inviting them to the next meeting for this purpose (Action 2.2
Defra/FSA).
3.8 The Group was reminded that there are some UK-specific research results
already available from work done by the WWT and RSPB - [post meeting note: Potential Hazard to Human Health from
Exposure to Fragments of Lead Bullets and Shot in the Tissues of Game Animals.]
3.9 The availability of unpublished data from an internal membership questionnaire
survey conducted by BASC was raised again (see inaugural meeting) and it was
noted that the question of its availability would be considered by BASC’s
Research Advisory Committee.
3.10 The Chair closed this agenda item by asking the group whether
the ToR could be formally signed off. All agreed.
4. Discussion of Group Website and communications (All)
4.1 The Group expressed gratitude to Lee Selvester of BASC for
producing an excellent website. Very positive feedback was received from
members of the Group – they felt the site was easy to follow and is well
presented and will help ensure that those with an interest in the Group’s work
can keep up to date. The Group agreed that the website will provide one
excellent tool for engaging with those with an interest in the debates surrounding
the Group’s work.
4.2 The Chair reported that he had received a response from a person
who had visited the website to say that the Clay Pigeon Shooting Association
should be involved in the LAG process. The Chair contacted the correspondent to
explain the situation and how there would be opportunities for involvement as
the process develops.
5. Progress on ‘Primary Evidence’ gathering
5.1 The Group noted that several members of the Group (see inaugural
meeting minutes) across different sectors had engaged in email correspondence on
the gathering of the primary evidence.
5.2 The Group reconfirmed that the primary evidence is the evidence
that can directly inform the assessment of potential risks of lead ammunition
for wildlife, human health and the environment.
5.3 One of the conclusions of this exchange had been that the various
sources of primary evidence need to be categorised.
5.4 The Group agreed that primary evidence might come from three
sources:
- Peer reviewed and
published papers from recognised and established journals (to include those
which have ISBN numbers and those published by accredited organisations and
expert bodies.)
- Unpublished reports
of recognised quality such as internal reports that have been commissioned but
not necessarily published (to perhaps include unpublished proceedings of
technical or scientific conferences, workshops and seminars).
- Articles from other
journals or other sources that contain evidence of recognised quality and
relevance but not falling within the other two categories i.e. “grey
literature”.
5.5 The Group discussed the significance of the geographical origin
of research and agreed that the primary need is for its relevance to any risk
assessment in the United Kingdom to be clear. For example a report citing shot
densities in Spain would probably not be relevant due to its special location
but medical or veterinary research into the physiology or clinical effects of
lead on animals or people could be relevant wherever it had been conducted.
5.4 The Group noted that the gathering of key references was under
way and that use of some of this is not cost free.
5.5 The Group was reminded that the Peregrine Fund’s Idaho conference proceedings provide freely published information and the link has been
circulated to those who have expressed an interest. Caution was expressed that
such proceedings also include contributions in the form of abstracts whose conclusions
could not be checked.
5.6 The Group noted that it would be difficult to make available some
scientific papers on the LAG website (due to journal copyright restrictions) and
the Group accepted that this would not be so much of an issue so long as the
references themselves are clearly set out so that those with an interest could
access them.
5.7 It was queried which category the papers already referenced on
the website fall into. The FERA report for example was considered to fall into
category 2 above i.e. the category of other reports not peer reviewed. Caution
was expressed that by appearing on the website such publications might attract undue
prominence. It might appear that the group endorses specific conclusions when
this is not the case. It was agreed nonetheless that these papers are important
as they have contributed to driving the Lead Ammunition Group process and, as
such, they should be publicly available. The Group agreed that papers published
on the website in this way should carry a disclaimer to explain that they are
reports which the group is looking at along with other information yet to be
gathered. The Group has taken no position on any conclusions expressed in any
of the reports on its website.
Action 2.3 Defra to supply wording for this which will be discussed
at the next meeting.
5.8 The Group agreed that the Primary Evidence Subgroup might filter
the evidence presented by supplying tags to identify a report’s geographical
focus and also its “applicability”. It was noted that FSA’s remit covers Scotland but Defra’s remit does not. Defra will however keep devolved counterparts
informed. It was agreed that applicability should be judged for the whole UK.
5.9 The Group discussed in further detail the use and applicability
of research from sources outside the UK. Examples of research, influencing
factors and considerations from biological, human health and veterinary fields
were considered. The Group concluded that research and primary evidence would
have to be judged carefully as it to its relevance. If necessary appropriate scientists
can be invited to address the Group and it was stressed that evidence will not be
accepted or dismissed uncritically.
5.10 It was re-iterated that judgements as to relevance will have to
be on a case by case basis but it will be helpful if the Primary Evidence Group
sees it as part of its remit to give assessments where this may not be clear.
5.11 The Chair asked if there were other instances where overseas
research might be particularly applicable or irrelevant. It was suggested that geographical
origin was immaterial in the context of ballistics and research into non-lead
ammunition.
5.12 It was suggested that site-based research and research on
species not found within the UK might be irrelevant. It was accepted however that
while caution was appropriate such evidence may shed light on principles relevant
to the Group’s work and future advice.
5.13 From this, it was determined that research in the fields of
physiology, human and veterinary health and in the technological fields such as
ballistics might be especially relevant whatever its origin. Care would always
have to be exercised when assessing relevance to potential risks in the UK. This is because local factors such as diet may be influential.
5.14 The Group considered research stemming from the REACH regulations
(Registration, Evaluation, Authorisation and Restriction
of Chemical substances) and whether it might be relevant. The Group was
given to understand that some studies will not be finalised until September and
that the information would be internationally focussed. It was suggested that
it would be worth speaking to the REACH group in due course but no immediate
action point was raised.
5.15 It was suggested that links be put on the Group’s website to
reports and publications that are freely available (i.e. can be accessed at no
cost). The following were suggested for inclusion:
- The Peregrine Fund 2008 Lead Ammunition
Conference information[1]
- The EFSA scientific opinion on lead [2]
- [post meeting note: further detail on two
particular reports has been provided][3]
The Chair asked if publications that are not cost-free, such as
those from certain journals, could be summarised and referenced for the website.
It was said that this would require a lot of work and was therefore not
practical.
5.16 The Group briefly discussed when new information should be published
on the website and agreed that it could be made available as soon as a form of
words had been agreed to reflect the fact that inclusion of material on the
website did not imply that the group endorsed its conclusions, simply that it
was among information being considered (see 5.7 above).
5.17 Concerns were raised that conclusions in published abstracts may
be unreliable. Reference to the full published report should be given and if
appropriate it was suggested by the Chair that reports might carry an explanation
from the Primary Evidence Subgroup. It was agreed that full references should
be posted along with the primary evidence base.
5.18 The Group then formally agreed that the Primary Evidence
Subgroup be established to include Dr Debbie Pain, Dr Steven Tapper, Dr John Harradine and Prof. Len Levy. The Chair asked if there were other names as this would not
be a regarded as a closed group and could be enlarged if necessary.
5.19 The Group invited Prof. Len Levy to chair the Subgroup and
Prof. Levy said he was willing to do so but would rely heavily on the other
members.
5.20 The Group tasked the Subgroup to prepare a report on the
primary evidence base and provide a summary of key research so as to inform the
Group and any subsequent subgroups in due course. The Group concluded that the Subgroup
will be responsible for finalising its own criteria and guidelines along the
lines discussed above. It will advise the main Group of these in due course.
Its aim will be to prepare a list of research together with the criteria for selection
and any commentary on reliability or relevance. It was also agreed that the Subgroup
will also make recommendations to the main Group as to what form any risk
assessment might take.
5.21 The Group noted that many of these issues are being discussed
in other countries and that there are international considerations and
influences. It was agreed that a separate page on the website should be created
to set out relevant legal obligations and agreements. The group agreed to request
that Defra provide information on relevant national and international legal
obligations and agreements (see 7.2 below). Action
2.5 PES and Webteam.
6. Subgroups i. Structures
(JS) ii. Recommendations for chairs (All)
6.1 The Group received a preliminary oral report from John Batley
whose sector of interest concerns the gun and ammunition trade in which field
his knowledge lies. His report outlined his personal thoughts in respect of some
wider considerations.
6.2 Mr Batley said that the economic, employment and other impacts of
any recommendations on ammunition would need to be considered. There needs to
be balance drawn on the facts, figures and assessments on the implication for
the trade and related matters.
6.3 Mr Batley continued that many believe that no effective
alternative to lead ammunition has yet been found. Game shooting is
economically important to rural economies. Virtually all game shooting is on
private land and it supports many small local businesses. Game shooting takes
place in the low season for the hotel and other trades and a substantial part
of the rural economy is reliant on it.
6.4 Mr Batley offered to lead a subgroup to consider such wider
considerations for example economic impacts of possible future recommendations
on shotgun cartridge manufacturers, airgun pellet manufacturers, sporting
agencies and target shooting organisations. He invited the Group’s thoughts and
discussion.
6.5 The Chair thanked Mr Batley for his report and his offer and
invited the Group to consider whether this area of work might be taken up by such
a formal subgroup. He reminded the Group that that the first purpose of
subgroups is to gather reliable and best possible information to inform the
Group’s work.
6.6 One view was that subgroups should not stray into looking at the
business impacts at this stage.
6.7 It was suggested that such a subgroup might be premature as risk
assessment has not yet been done. The Group has not reached any conclusions
about what advice to give and the emphasis should be on a step by step
approach.
6.8 One member said here that there are four or five alternatives to
lead ammunition and from this stage it should be considered how these are
presented to the shooting world. In response it was pointed out that the
stepwise approach means the Group should not discuss solutions before it has
decided what the problem really is.
6.9 Another member added that the shooting interest is not the only group
the Group has to consider and another added that the Primary Evidence Subgroup
needs to get underway with collecting the data so that context for other
specialist subgroups is provided.
6.10 The Chair summarised that the Primary Evidence Subgroup will
provide the platform for the risk assessment. Such wider possible impacts and considerations
could be relevant to consideration of the primary risks which that Group had
been asked to advise on. Lack of good information and fears among affected
stakeholders, whether justified or not, could be risks in themselves.
6.11The Chair proposed that John Batley continue his work with a
view to setting out a concise proposal with a clear remit and who might be involved
for the next meeting. The focus should be on gathering quality information to
inform the work of the Group in its primary tasks.
6.12 John Batley was invited and accepted to work on such a proposal
and asked to circulate some possible terms of reference etc for consideration
by the Group at the next meeting. Action
2.6 JB
6.13 It was suggested that it would be useful if the remit of the
proposed group included progress in other countries where changes in
legislation may have incurred economic impacts. This suggestion was supported by
other Group members and it was noted that even where there are geographical
differences lessons can be learned.
7. Project Planning – review of suggested timetable / milestones
provided by Secretary
7.1 It was proposed that the Group set an aim within its timeframe for
all Group members to achieve a good understanding and perspective of the
evidence base. This was endorsed and will be essential for the stepwise
approach in drawing evidence bases together so that risk assessment is rigorous.
It was suggested that a layman-friendly overview of recent key research would
be valuable and that one might be provided at the next meeting.
7.2 The Group asked Defra to pull together all the regulations,
guidelines and Directives which are relevant to the Lead Ammunition Group. Action
2.7 Defra.
7.3 Tim Andrews gave an overview of the gantt chart/project plan
produced for the Group’s work. He indicated that this was a living document and
would be amended as the work progressed. The Group discussed key milestones and
TA agreed to amend the chart in light of these.
Action 2.8 Primary Evidence Subgroup will prepare a presentation summarising
information in selected key information sources by the end of June (for the Group
meeting on 6 July).
Action 2.9 Primary Evidence Subgroup will endeavour to provide a
list of references for key evidence sources which the Group will consider (on 6
July) and have it finalised by the middle of July.
Action 2.10 Primary Evidence Subgroup will then pass this final list
to the website team for publication by the end of July.
7.4 It was considered that the risk assessment process might be
started in September/October 2010 and any outputs from the process (risks) made
available for consideration by sector/specialist subgroups in the first quarter
of 2011. It was identified that preparation of the Group’s progress report to
DEFRA/FSA would require the attention of the Group as a whole and a provisional
target for the progress report was set as July/August 2011.
7.5 Defra was tasked with providing examples of the form the
progress report might take. It was said that a range of reports could be
provided for the group to consider.
Action 2.11 Defra and FSA
7.6 It was suggested that a draft consultation period in advance of
the production of a final recommendations report should be provided for in the
Gantt chart.
Action 2.12 TA
8. Next Steps (All)
8.1 It was agreed the Primary Evidence Subgroup will continue its
work under Professor Levy and work towards reporting back to the group by the
end of June and for the website by the end of July.
8.2 John Batley will continue his work and bring a firm proposal to
the 6 July meeting. He may make preliminary contact with organisations who may be
able to help him such as:
- CPSA (Clay Pigeon Shooting Association)
- NGO (National Gamekeepers Organisation)
- BDS (The British Deer Society)
- The Deer Initiative
8.3 The Chair asked if any further organisations are being put
forward at this stage for this subgroup. The NRSA (The National Small-bore
Rifle Association) was suggested.
8.4 It was suggested that the next meeting take place on 6 July pm.
This was agreed.
It was requested by the Group that the Chair invites the FSA to the
next meeting.
Action
2.13 Chair
8.5 The main points that the Group would like information on
concerns FSA’s current position on what they intend to do and also what
research they already have accessible in this area. One member said that the Group
needs to know where the FSA stand on the health issue relating to lead. Action
2.14 FSA
9. Any other business
9.1 In the previous minutes it was mentioned that there were a small
number of reports where lead had turned up in animals. It was requested that
these cases be referred to in the next publication of minutes.
Action 2.15 Defra/FSA to establish what these reports are and
reference them for the minutes.
Summary
of Action points arising from this meeting
Action 2.1 Defra
to liaise with FSA to find out what timeframe for their aforementioned
research.
Action 2.2 Defra
to contact FSA with a view to inviting them to the next meeting.
Action 2.3 It
was agreed that the papers published should carry a caveat/disclaimer to
explain that these are reports which the group is looking at along with other
information. Defra to providing wording for this for the group to consider.
Action 2.5 The
Primary Evidence group and webteam to set up a separate page on the site for
legal obligations and agreements.
Action 2.6 John
Batley to circulate a proposal with draft terms of reference for his proposed sub
group.
Action 2.7 Defra
to pull together all the regulations, guidelines and Directives which are
relevant to the Lead Ammunition Group.
Action 2.8 Primary
Evidence Subgroup to give a presentation to the main group on selected key
information sources (6 July).
Action 2.9 Primary
evidence subgroup to provide a list of references of the key evidence which the
group should consider by the middle of July.
Action 2.10 Primary
evidence subgroup should pass this list of key references to the website team
for publication by the end of July.
Action 2.11 Defra
and FSA were tasked with providing a model of what this report should look
like. It was said that a range of reports could be provided for the group to
consider its output format.
Action 2.12 TA
to amend Gantt chart for sign off at next meeting
Action 2.13 The
Chair to invite the FSA to the next meeting.
Action 2.14 FSA
to provide information on their current position on what they intend to do [in
reference to lead ammunition] and also what research they already have
accessible in this area.
Action 2.15 FSA
to provide background information on the cases referred in the first set of
minutes whereby they were made aware of a small number of incidents where
animals have ingested spent lead ammunition leading to animal welfare and food
safety concerns. [It was requested that this information should be published
with the latest minutes.]
[3] Pain DJ, Cromie RL, Newth J, Brown MJ, Crutcher E, et al. (2010)
Potential Hazard to Human Health from Exposure to Fragments of Lead Bullets
and Shot in the Tissues of Game Animals. PLoS ONE 5(4): e10315.
DOI:10.1371/journal.pone.00103
Hunt WG, Watson RT, Oaks JL, Parish
CN, Burnham KK, et al. (2009) Lead bullet fragments in venison from rifle-killed deer:
Potential for human dietary exposure. PLoS ONE
DOI:10.1371/journal.pone.0005330.]
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