The red grouse and medicated grit scandal: it’s hard to swallow

Just when you thought that all the detrimental environmental and health hazards associated with driven grouse moor management had been exposed, and just when you thought you understood the extent of corruption and/or incompetence by the government agencies responsible for preventing the detrimental environmental and health hazards associated with driven grouse moor management, along comes something else to make your jaw drop.

This time it’s medicated grit.

First, some background about medicated grit: what it is, why it’s used etc., for those who may be new to this.

The red grouse’s diet is predominantly heather. Heather can be quite fibrous and tough so the grouse ingest grit that can be found naturally on grouse moors to help digest their food. All perfectly natural. Red grouse also suffer from infestations of the parasitic Strongyle worm, which live in the gut and can cause cyclical ‘population crashes’ of red grouse every 4-5 years. Again, all perfectly natural. However, these cyclical population crashes are not very popular on intensively-managed driven grouse moors because they result in less red grouse available to kill. When your business model depends on a high density of red grouse to shoot, you want to avoid these natural population crashes at all costs. So in the 1980s the grouse shooting industry came up with a brilliant wheeze: they worked out that if they added a pharmaceutical wormer drug to the grit, they could ‘medicate’ the grouse without too much effort and halt the population crashes. Genius, eh?

The original drug used in medicated grit was Fenbendazole and this grit was placed in piles at regular intervals across grouse moors so the red grouse could eat it with easy access. The amount of grit put out depended on the density of grouse so sometimes these grit piles would be placed as frequently as every 75 m. The use of this grit was quite successful in that it reduced worm burdens in red grouse by an average of 44% and, more importantly to the grouse moor manager, increased grouse productivity by 40%. Great! More grouse available to kill! However, the drug and the fat used to bind the drug to the grit were temperature-sensitive, which meant that if there was an unseasonably mild spring, the drug would melt too soon and thus attempts to medicate the grouse during the crucial period would fail.

Not to worry, though. In 2007 the industry came up with a solution – switch to another wormer drug (Flubendazole) and another fat with a weather-resistant coating. This new grit contained 5% Flubendazole, the maximum strength permitted (licensed) for use in the UK. Tests showed that this new medicated grit would persist in the environment for much longer: 70% of the active drug remaining after nine months of being laid out, and 50-60% remaining after 18 months.

To comply with the law (which states that this drug must be withdrawn from use no later than 28 days before the start of the grouse-shooting season on 12th August to ensure the drug doesn’t find its way in to the food chain), some (but not all) grouse moor managers started to use ‘medicated grit boxes’ which comprise two compartments, separated by either a hinged or a sliding door. One compartment holds the medicated grit and the other compartment contains non-medicated grit. This allows the moorland gamekeeper to simply close off the medicated grit compartment at the appropriate time, assuming the gamekeeper is diligent and isn’t tempted to leave out the medicated grit for longer than the law allows.

Photo: medicated grit box. Image by Richard Webb.

Medicated grit tray by Richard Webb Lammermuirs

Not every moor uses specialist grit boxes though. Some moors use a home-made version:

Photo: breeze block grit dispenser. Image by Phil Champion.

Medicated grit Phil Champion

And some moors place the grit directly on to cut pieces of turf:

Photo: grit on cut turf. Image by Richard Webb.

Medicated grit upturned turf Richard Webb

Whilst the use of medicated grit boxes might seem a very good idea, they are not without their problems. When red grouse use the boxes, they can sometimes scrat around for quite some time while they choose which piece of grit they want to pick up. This can result in large amounts of faecal matter being deposited inside the box which in turn can spread disease to other grouse using the box. The ‘best practice guidelines’ issued by GWCT encourages the regular removal of all these faeces but it’s apparent that this isn’t happening on all moors. This may well explain the recent increase in the highly contagious ‘Bulgy Eye’ disease in red grouse that’s being reported on moors in northern England as well as Scotland.

Photo: grit box contaminated with grouse faeces. Image by Raptor Persecution Scotland.

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Although some grouse moor managers were using double strength medicated grit, they still weren’t satisfied with performance so a new ‘super-strength’ medicated grit has been developed which is ten times the strength (and according to grouse moor management ‘guru’ Mark Osborne, can be twenty times the strength). The ten times strength grit contains a suspension of 50% Flubendazole, which is far greater than the 5% limit permitted for use in the UK. The manufacturers get around this by using a Special Import Certificate.

In addition to the use of medicated grit, some grouse moor managers are also using direct-dosing methods whereby the grouse are caught in the middle of the night and have a tube shoved down their throats to deliver a few mls of an anthelmintic drug.

So, with all these pharmaceutical wormer drugs being given to red grouse, you might expect a high level of monitoring by the statutory agencies to ensure that these drugs are not entering the food chain when people are eating shot red grouse, right? Pretty much all other meat destined for human consumption is subject to rigorous testing so red grouse shouldn’t be any different, right?


You may remember back in July we blogged a little bit about the use of medicated grit on driven grouse moors, in response to a ludicrous claim by SNH that red grouse are ‘healthy’ and ‘natural’ to eat (see here). We said we were interested in the testing regime and had read that the Food Standards Agency was responsible for testing shot red grouse as well as for randomly sampling medicated grit boxes.

So an FoI was sent to the FSA to ask them for the following information:

  1. How many individual birds (red grouse) were tested in England and Scotland in each of the following years: 2010, 2011, 2012, 2013, 2014? Please provide a breakdown of each country in each year.
  2. From how many geographically separate grouse moors did these birds originate? Please provide a breakdown of county for each year.
  3. On what dates were these birds tested? Please provide a breakdown for each county in each year.
  4. How many of the birds tested in each year were found to contain the presence of illegal residues of Flubendazole? Please provide a breakdown of each county in each year.
  5. If illegal residues were detected in any bird, what action, if any, was taken?
  6. How many individual grouse moors in England and Scotland were randomly visited in each of the following years (2010, 2011, 2012, 2013, 2014) to test the contents of grit boxes for the presence of Flubendazole? Please provide a breakdown for each country in each year.
  7. How many grit boxes were inspected on each grouse moor of each year in each country? Please provide a breakdown of each moor, in each country, in each year.
  8. On which dates were these inspections made? Please provide a breakdown of each moor, in each country and in each year.
  9. How many of the inspected grit boxes were found to contain Flubendazole? Please provide a breakdown of each moor, in each country, in each year.
  10. If any illegal residues were detected in any grit box, what action, if any, was taken?

The FSA said they didn’t hold the information and recommended contacting the Veterinary Medicines Directorate (VMD) at DEFRA who should be able to help. It turns out that ‘the VMD are the competent authority for the National Surveillance Programme which is carried out in accordance with EU Directive 96/23/EC. This is implemented nationally under The Animal and Animal Products (Examination for Residues and Maximum Residue Limits) (England and Scotland) Regulations 2015 and The Animal and Animal Products (Examination for Residues and Maximum Residue Limits) Regulations 1997 as amended’.

So the same FOI was sent to the VMD. Their response was as follows:

“The VMD’s Residues Team haven’t taken any red grouse samples under the National Surveillance Scheme (NSS) in the years you cite, nor in any other year. We don’t therefore have the information you request”.

A further FoI was sent to the VMD to ask why they hadn’t collected any samples from any red grouse, ever. This was their response:

“The legislation does allow us to sample red grouse, but the issue is that we do not have any details of abattoirs processing this species. We continue to sample partridge and pheasants at abattoirs – these are from game shoots and taken to abattoirs to be gutted and cleaned. The abattoirs have to hold a licence to be able to do so.

In accordance with the Legislation, we must take samples at the primary production point – on farm or at abattoirs. But as we do not have any details of abattoirs processing red grouse, we have been unable to carry out any sampling under the surveillance programme.

If you do have concerns that there is use of an unauthorised substance or the withdrawal period is not being observed you should contact the Local Authority”.

Wed 6 May - CopyWe were fascinated by the idea of gamebirds being sent to “abattoirs” to be gutted and cleaned. We’d never heard of that, although we did know that some gamebirds are sent to game processing plants to be plucked etc. One such plant is Yorkshire Game, which we also knew processed red grouse. So another FoI was sent to the VMD to ask for a list of all “abattoirs” and processing facilities they had visited in the last five years to sample pheasant and partridge, as we were keen to see whether Yorkshire Game appeared on their list. Surely, if we, as ordinary members of the public, knew that Yorkshire Game processed red grouse, then the specialist team from the VMD would also know that….it’s kind of their job to know! We also asked why, if the legislation states that samples must be taken at the primary production point (“on farms or at abattoirs”) no samples had been taken at any red grouse ‘farms’ (grouse moors)?

This was their response:

“Under the programme samples are taken at abattoirs and some of these abattoirs also act as a processing facility.  Attached is a list of all game samples taken including the abattoir from 2011 to date. [Ed: this list did indeed include Yorkshire Game, as well as a number of other processing facilities in England and Scotland].

Samples taken on farms are from animals in a managed environment and the animals are usually housed to allow the sampling officer to target a specific animal to be sampled.  The practicalities of taking a sample from birds that are roaming free would be more difficult and take up additional resources.

However, since my last e-mail the VMD have now successfully identified a number of abattoirs where red grouse is processed.  As a result the National Surveillance Programme for 2016 will include sampling from red grouse and full results will continue to be published on gov.uk”.

So, it turns out that the VMD had been sampling pheasants and partridge at Yorkshire Game (and other game processing plants known by us to process red grouse), but were apparently unaware that red grouse were also available to sample there. That’s kind of hard to believe, isn’t it?

Their response to why they haven’t sampled red grouse directly at grouse moors is also hard to believe. They state that sampling free-flying birds would be difficult (yep, that would be true) but don’t say anything about why they haven’t sampled dead (shot) birds at the end of a day’s shooting.

It’s good to hear that this ‘specialist’ team “has now successfully identified a number of abattoirs where red grouse are processed” and we look forward to seeing the results of extensive sampling that should begin in 2016.

But the VMD still hadn’t answered the question about testing medicated grit boxes on grouse moors, to see whether the anthelmintic drug had actually been withdrawn within the statutory withdrawal period or whether it was still freely available to the grouse at the on-set of the shooting season. So, another FoI was submitted to ask how many grit boxes on grouse moors had been tested over the last five years. This was their response:

“The prescribing of wormers in grouse grit is permitted under the rules of the prescribing cascade in the Veterinary Medicines Regulations 2013. Use of medicines in animals under the cascade is down to the professional judgement of the prescribing veterinary surgeon, taking into consideration the impact on the animals concerned, in response to a specific animal welfare need. Therefore, the VMD does not specifically monitor such use.

A statutory withdrawal period when using medicines under the cascade has to be applied and that means that the medicated grit must be removed from the grouse moors at least 28 days prior to the shooting of the birds.  The Legislation referred to in my previous e-mail sets out that primary products of animal origin should be sampled and grit is not included in the programme. Samples of red grouse muscle will be taken as part of the 2016 programme”.

Amazing! So a pharmaceutical drug of at least ten times the licensed strength permitted (twenty times the strength if you believe Mark Osborne) is being used on grouse moors without ANY statutory monitoring whatsoever! Isn’t that astonishing? Do you think that the public would accept other meat industries (e.g. dairy farmers) getting away with this lack of regulation and scrutiny? No, of course they wouldn’t, so how come the grouse shooting industry is exempt?

The grouse shooting industry will probably argue that they have ‘best practice guidelines’ for the use of medicated grit – and indeed they do – but who will believe that they’re adhering to these guidelines? We don’t. This is an industry that routinely breaks the law so we’d fully expect them to ignore ‘best practice guidelines’, especially if they know the authorities aren’t checking.

Anyone still fancy eating a ‘natural’ and ‘healthy’ red grouse? Go on, it’s good for you – as well as all that toxic lead, there’s free, high-dosage wormer included too! Yum!

And what about the environmental consequences of using this high persistence pharmaceutical drug in an open landscape of supposed high conservation value? What short and long-term effect is it having and how does it impact on other species? Nobody knows. Is anyone researching this or is it yet another case of turning a blind eye to the actions of the grouse shooting industry?

An argument could easily be made that shot red grouse is actually ‘hazardous waste’. The HSE’s definition of hazardous waste is this:

‘Waste is considered ‘hazardous’ under environmental legislation when it contains substances or has properties that might make it harmful to human health or the environment. This does not necessarily mean it is an immediate risk to human health, although some waste can be’.

It’s time driven grouse shooting was banned. Please sign the petition HERE


Misleading conclusions from Scot Gov’s 2014 wildlife crime report

Wildlife Crime in Scotland 2014 reportYesterday the Scottish Government published its latest report on wildlife crime: ‘Wildlife Crime in Scotland: 2014 annual report’ (see here).

It was accompanied by a Government press release (here) with a headline statement claiming ‘ Recorded wildlife crime dropped by 20 per cent in the period 2013-2014‘. This claim has been regurgitated, without real examination, in much of the national press, which will give the public the impression that all’s going swimmingly in the fight against wildlife crime in Scotland. This couldn’t be further from the truth.

Let’s start with the report’s name. It claims to be the ‘2014 annual report’, but actually the period covered by the report is the 2013/14 financial year: April 2013 to March 2014. That means the majority of the data are from 2013 (9 months worth) – these are wildlife crimes that took place as long ago as 2.5 years and the most ‘recent’ took place 18 months ago (March 2014). Many more offences occurred during the nine months between April-Dec 2014 but they are not included in this report. Although the report itself does explain the reasons behind this odd time-frame selection, the report’s title does not, which means anyone just browsing the headline news will be given a false impression of how recent these findings are. It’s a small point, but it’s an important one.

However, there are bigger issues than just a misleading report title.

If you take the report’s data at face value (which we don’t – more on that in a second) and accept that it’s representative of all reported wildlife crime in Scotland between April 2013 and March 2014, you might also accept that the claim of a 20% reduction in recorded wildlife crime is accurate. But if you look at the data (Table 1), you’ll notice that this supposed broad reduction (i.e. reduction of recorded wildlife crimes in general) is actually almost entirely due to a large reduction in one particular area of wildlife crime: specifically, fish poaching. To then apply this reduction of a specific wildlife crime to all other types of wildlife crime in a broad sweeping statement is wholly misleading.

Our main issue with this report, as with previous reports, is the Government’s insistence on only using crime data that has been recorded by the Police. Although this report does attempt to address this problem by including separate sections on data collected by others (e.g. Scottish Badgers, SSPCA), these data are still not included in the overall analysis of wildlife crime trends because these incidents weren’t recorded on the Police national crime database. A good example of this is shown in Table 10, which details the number of wildlife cases investigated by the SSPCA. The report accepts that cases investigated solely by the SSPCA (as opposed to cases where the SSPCA has assisted the Police) are not included in the ‘official’ recorded crime data because ‘they are not recorded on the police national crime database’. So in effect, 69 cases that were investigated solely by the SSPCA during the period covered by the report are absent from the national figures. It seems bizarre that even though these data are available (of course they are, they appear in this report, albeit in a separate section!) they are still excluded from the main analysis. This blatant exclusion immediately reduces our confidence in the robustness of the ‘national’ data.

Another blatant exclusion of data is demonstrated in Table 17 in the Raptor Persecution section. This table identifies only 16 bird of prey victims from the mass poisoning in March 2014 known as the Ross-shire Massacre, excluding the other six victims that were found. The report justifies this exclusion by explaining that evidence of poisoning was not found after examinations of those six raptors. That’s fair enough, but surely we’re not expected to believe that those six victims all died of natural causes, in the same small area, and at the same time, as the 16 confirmed poisoning victims? They don’t appear in the figures because a crime couldn’t be identified, but they still died as a result of this crime and to pretend otherwise is nonsense.

An additional problem that erodes public confidence in the accuracy of the ‘national’ data is the issue of how carefully wildlife crimes are recorded. A report published earlier this year (which includes part of the period covered by this latest Government report) revealed systemic problems with the under-recording of several types of wildlife crime as well as failures by the police to undertake follow-up investigations on reports of suspected wildlife crimes (see LINK report here). If the police don’t follow up with an investigation, the incident is unlikely to be recorded as a crime. Until these issues are suitably addressed, the accuracy of ‘official’ ‘national’ wildlife crime data will inevitably be viewed with suspicion.

So, we don’t have much confidence in this report’s data and we certainly don’t agree with the Government’s claim that (overall) recorded wildlife crime has reduced by 20%, but there are some positives. It’s clear that more thought has been put in to the material contained in this year’s report and there is definitely more clarity about the sources used. That’s good progress.

There are also a couple of things in this report that we are particularly pleased to see.

First, let’s go back to Table 10 (SSPCA data). You may remember (if you have a long memory) that in March 2014, the Government opened its consultation on whether to increase the investigatory powers of the SSPCA. That consultation closed in September 2014 and, over a year later, we’re still waiting for a decision. It’s our understanding that one of the main sticking points is with Police Scotland (who, as you’ll recall, strongly objected to an increase of powers – see here). Apparently, the current sticking point is that Police Scotland are worried that they’ll be excluded from wildlife crime investigations because the SSPCA ‘refuses to work with them’. However, if you look at Table 10, you’ll notice that 50% of all wildlife cases taken by the SSPCA during the period covered by this report were undertaken in partnership with the Police. That’s 50%. Does that look like an organisation that is refusing to work with the Police? It doesn’t to us.

The second point of interest in this report appears in Table 18b. This table provides information about recorded bird of prey crimes between April 2013 and March 2014. Have a look at the 7th entry down:

Species: Hen Harrier

Police Division: Aberdeenshire and Moray

Type of Crime: Shooting

Date: June 2013.

Why is this of particular interest? Well, cast your mind back to January 2014 when we blogged about a vague Police Scotland press release that stated a man had been reported to the Crown Office ‘in relation to the death of a hen harrier’ in Aberdeenshire that took place in June 2013 (see here). So it turns out this hen harrier had been shot. Amazing that it took over two years for this information to be made public. But that’s not the most interesting bit. For this unnamed individual to be reported to the Crown for allegedly shooting this hen harrier means that the Police have some level of evidence that they think links him to the crime. If they didn’t have evidence, he wouldn’t have been reported. So, the alleged crime took place 2.4 years ago. The Crown Office was notified 1.9 years ago. What’s happening with this case? Is there going to be a prosecution? Why such a long delay for a crime that is deemed a ‘priority’ by the Scottish Government?


The gift of grouse: spectacular propaganda from the Angus Glens

Gift of GrouseWe love it when the grouse shooting community produces its propaganda pieces to spoon-feed to the (sym)pathetic right wing elements of the national press. It’s usually a masterclass in foot-shooting and provides us with ample material for a good laugh.

Take this month’s latest offering –  a published, commissioned report from the University of the Highlands & Islands:

Grouse Shooting, Moorland Management and Local Communities: Community Perceptions and Socio-Economic Impacts of Moorland Management and Grouse Shooting in the Monadhliaths and Angus Glens

and a video produced by the Angus Glens Moorland Group (basically all the gamekeepers that work there) entitled:

The Untold Story: Driven Grouse Shooting’.

The publication of these two pieces was celebrated at a Parliamentary reception last week (see here) hosted by Fergus Ewing MSP, Minister for Business, Energy and Tourism (a long-standing supporter of the Scottish Gamekeepers’ Association) and attended by gamekeepers and luminaries from the grouse shooting industry such as Doug McAdam from Scottish Land & Estates.

The report mostly suggests that there is great support for grouse moor management and all its ‘benefits’, from within the two communities surveyed. We’re not going to say very much about these findings at the moment other than to say that we are aware that someone has been analysing the survey questionnaire data and has discovered some fundamental flaws that basically render the report’s findings obsolete. We’ll return to this once the analysis has been completed. The report can be downloaded here: Grouse Shooting Moorland Management and Local Communities_2015

What we do want to blog about now is the hilarious video produced by the Angus Glens gamekeepers. This video (watch it here) was first published on the Inglorious 12th, timed to coincide with the opening of the grouse shooting season. It formed part of a new campaign called ‘The Gift of Grouse’, which is a one-year propaganda offensive, heavily promoted (and maybe even funded) by Scottish Land & Estates, and others, aimed at cleaning up the media image of the grouse shooting industry. Check out their website here.

For some reason, the video has now been re-launched this month, perhaps to coincide with the publication of the commissioned report. Whatever, that doesn’t really matter. This video really is a gift and an almighty own-goal.

You would think that if the grouse-shooting industry wanted to portray an image of lawful, environmentally-sensitive management, that they’d choose to focus on an area that wasn’t notorious as a massive wildlife crime scene, wouldn’t you? Well, apparently not.

This video is brilliant. It includes interviews with head gamekeepers from five grouse-shooting estates in the Angus Glens; some of these estate names will be very familiar to regular readers of this blog. The interviewees are: Jason Clamp (Millden Estate), Garry MacLennan (Invermark Estate), Martin Taylor (Glenlethnot Estate), Danny Lawson (Glenogil Estate) and Bruce Cooper (Glenprosen Estate). [Incidentally, one of these head keepers shares his name with a gamekeeper who was formerly employed on Skibo Estate in 2010 when three poisoned golden eagles were found poisoned. What an amazing coincidence. No prosecution for poisoning those eagles, natch, although the sporting manager was done for possession of a massive stash of banned Carbofuran].

The video provides a heart-warming narrative of the daily lives of gamekeepers in the Angus Glens, complete with a soothing musical backing track, where the keepers are keen to explain how they care for the welfare of all the wildlife in the Glens and how the emphasis is no longer on just the grouse, apparently.

Jason Clamp (Millden) says: “We’re not looking for massive bags of grouse” and “We’re not looking to kill thousands of grouse“.

That’s an odd statement coming from the head keeper of perhaps one of the most intensively-managed grouse moors in the area. According to the Millden Estate sales brochures (2010 and 2011) great emphasis is placed on the record number of grouse that have been killed / are available to be killed and this is a prime selling point. Record bag sizes are also apparently the main reason the estate owner decided to withdraw his estate from sale in 2011 (see here).

We’re also told by Garry MacLennan (Invermark) that the Angus Glens are great for raptors (ahem – see below) and the video bizarrely cuts to show what looks remarkably like a Gyr/Saker hybrid falconry bird….whatever it is, it certainly isn’t a native species and it certainly isn’t a wild bird living in those Glens.

Probably the most amusing thing about this video (and there is an awful lot to laugh at) is the title: ‘The Untold Story’. Oh, the irony.

Here are some of the untold bits of the untold story that, unsurprisingly, don’t feature in this film:

Known raptor persecution incidents in the Angus Glens 2004-2014 – 

2004 May, near Edzell: long-eared owl and two short-eared owls starved to death in crow cage trap.  No prosecution.

2004 May, Invermark Estate: peregrine nest destroyed. No prosecution.

2006 March, Glenogil Estate: poisoned rabbit bait (Carbofuran). No prosecution.

2006 April, Easter Ogil: poisoned buzzard (Alphachloralose). No prosecution.

2006 April, Easter Ogil: poisoned tawny owl (Alphachloralose). No prosecution.

2006 May, Glenogil Estate: poisoned rabbit bait (Carbofuran). No prosecution.

2006 June, Glenogil Estate: poisoned woodpigeon bait (Carbofuran). No prosecution.

2006 June, Glenogil Estate: Traces of Carbofuran found in estate vehicles & on equipment during police search. No prosecution. Estate owner had £107k withdrawn from his farm subsidy payments. This was being appealed, but it is not known how this was resolved.

2006 July, Millden Estate; poisoned sheepdog (Lindane). No prosecution.

2007 November, Glenogil Estate: Disappearance of radio-tagged white-tailed eagle ‘Bird N’ coincides with tip off to police that bird been shot. No further transmissions or sightings of the bird.

2008 May, ‘Nr Noranside’: poisoned white-tailed eagle ‘White G’ (Carbofuran, Isophenfos, Bendiocarb). No prosecution.

2008 May, ‘Nr Noranside’: poisoned buzzard (Bendiocarb). No prosecution.

2008 May, ‘Nr Noranside’: poisoned mountain hare bait (Carbofuran, Isophenfos, Bendiocarb). No prosecution.

2008 May, Glenogil Estate: 32 x poisoned meat baits on fenceposts (Carbofuran, Isophenfos, Bendiocarb). No prosecution.

2008 October, ‘Glenogil Estate: poisoned meat bait on fencepost (Carbofuran). No prosecution.

2009 March, Glenogil Estate: poisoned buzzard (Carbofuran). No prosecution.

2009 March, Glenogil Estate: poisoned buzzard (Carbofuran). No prosecution.

2009 April, Millden Estate: poisoned buzzard (Alphachloralose). No prosecution.

2009 July, Millden Estate: poisoned golden eagle ‘Alma’ (Carbofuran). No prosecution.

2009 August, Glenogil Estate: poisoned white-tailed eagle “89” (Carbofuran). No prosecution.

2010 May, ‘Nr Noranside’: poisoned red kite (Carbofuran). No prosecution.

2010 September, Glenogil Estate: poisoned buzzard (Chloralose). No prosecution.

2010 October, Glenogil Estate: poisoned buzzard (Carbofuran). No prosecution.

2010 October, Glenogil Estate: poisoned pigeon bait (Carbofuran). No prosecution.

2010 October, Glenogil Estate: poisoned pigeon bait (Carbofuran). No prosecution.

2011 February, Airlie Estate: buzzard caught in illegal crow trap. (see below)

2011 March, Airlie Estate: 3 x buzzard caught in illegal crow trap. Prosecution (!) but dropped after statement from suspect given to SSPCA deemed inadmissible.

2011 April, Millden Estate: shot buzzard. No prosecution.

2012 April, ‘Nr Noranside’: Remains of buzzard found beside pheasant pen. Suspicious death.

2011 June, Rottal & Tarabuckle Estate: dead kestrel inside crow cage trap. No prosecution.

2012 February, ‘Nr Edzell’: spring-trapped buzzard. No prosecution.

2012 February, ‘Nr Bridgend’: remains of buzzard found under a rock. Suspicious death.

2012 May, Millden Estate: satellite-tagged golden eagle seemingly caught in spring trap, then apparently uplifted overnight and dumped on Deeside with two broken legs & left to die. No prosecution.

2012 May, Glen Esk: disappearance of sat-tagged red kite. No further transmissions or sightings of bird.

2013 January, Invermark Estate: white-tailed eagle nest tree felled. No prosecution.

2013 November, Glen Lethnot: poisoned golden eagle ‘Fearnan’. No prosecution.

2014 October, Nathro: shot buzzard. Prosecution? Unknown.

There’s also no mention of the massacre of mountain hares known to take place across the Angus Glens. This photo shows a pile of slaughtered hares photographed on Glenogil Estate in 2012:

mountain-hare-cull-angus-glens-large - Copy

And no mention of the “savaged, stripped and blasted land” as portrayed in this photograph of Millden Estate in 2014 (by Chris Townsend):

Interestingly, a Parliamentary Motion has now been lodged (Jamie McGrigor, Tory) congratulating the Angus Glens gamekeepers on their video and welcoming the Gift of Grouse initiative. The motion hasn’t attracted a lot of support although some of the signatories are surprising, to say the least (see here).


Natural England to issue guidance on deployment of gas guns on grouse moors

Bird scarer 1 - Copy

Here’s some excellent news….

In early September we encouraged blog readers to contact SNH and Natural England to ask whether they would provide urgent guidance on the deployment of gas gun bird scarers, particularly on grouse moors where we believe these devices have been used illegally to disturb hen harrier breeding attempts (see here).

SNH responded quickly in mid-September and said they would investigate the deployment of gas guns with regard to the law and may provide guidance on their use if it was deemed appropriate (see here).

Natural England has gone further. Their response (from Alan Law, Chief Officer of Strategy and Reform) confirms that the use of gas guns near Schedule 1 breeding birds is unlawful and that their use in Special Protection Areas would likely require written consent from Natural England, depending on the specific feature(s) for which the site has been designated.

Natural England says it is in the process of drafting guidance, which will be available prior to the start of the 2016 breeding season.

That’s brilliant news – well done to everyone who took the time to contact NE about this issue. The grouse shooting industry will be thrilled and will no doubt be wishing to thank us all for our help. No need, it was our pleasure. They’ll be even more thrilled if, come the next breeding season, anybody spots any gas guns being used on grouse moors and reports it to the police. Even better, report it to the RSPB Investigations Team who are more likely to follow up.

Here’s one of several responses we’ve seen from Natural England:

Thank you for your recent email relating to the use of gas guns within Special Protection Areas (SPAs) and expressing your concerns around the potential impact of the use of gas guns upon Schedule 1 birds. 

For Schedule 1 species, it is an offence for any person to disturb any wild bird included while it is building a nest or is in, on or near a nest containing eggs or young. As a result, the use of gas guns outside the bird breeding season is not unlawful.

With respect to the use of gas guns within a SPA, depending on the specifics of what interest features the site is notified for, the land manager may be obliged to seek Natural England’s written consent prior to locating and using gas guns. Landowners and managers of SPA land are provided with specific guidance on what activities require a consent and we issue this on a site by site basis.

We have recognised that there is a need for some general guidance on the use of gas guns and are in the process of drafting this in collaboration with the relevant partners. I will arrange for you to be sent this guidance as soon as it becomes available, which will be in advance of next year’s breeding season.

 Many thanks again for your interest in this matter.

 Yours sincerely

 Alan Law

Chief Officer, Strategy and Reform

Natural England


Iceland: “Food you can trust”?

Iceland (the supermarket) really wants us to believe that the food they sell is “food you can trust“. It’s their tagline. It appears twice on the front of this store we recently visited. If the customer fails to notice it as they enter the shop they get another opportunity to read it as they walk away. It’s clearly an important marketing strategy for this company.

Iceland Food you can Trust - Copy

It’s an interesting word, ‘trust’. Synonyms include ‘confidence’, ‘belief’, ‘faith’, ‘sureness’, ‘certainty’, ‘assurance’. It implies ‘freedom from suspicion/doubt’.

Antonyms include ‘disbelief’, ‘doubt’, ‘uncertainty’, ‘distrust’.

Food you can trust” is certainly an interesting choice of tagline. As consumers, we might all expect the food we buy from high street supermarkets to be trustworthy, yes? Well, no, as the recent horse meat scandal showed. In fact it was as a result of the horse meat scandal that Iceland rolled out this tagline in a bid to reassure customers of the quality of its foods. Since then, Iceland has gone to great lengths to demonstrate that nay, their beefburgers do not contain horse (see here). Marvellous, what a comfort.

But what about trusting other food sold by Iceland? Say, red grouse for example? As regular blog readers will be aware, this summer Iceland began selling frozen red grouse that was shot last year. When this news broke in July, we had a number of questions to ask of Iceland (see here) about how the sale of this product fitted in with their published statement on corporate responsibility, especially as they claim to be “committed to providing safe, healthy and ethically sourced food”. We wondered how Iceland could meet these standards when Marks and Spencer had abandoned their red grouse sales for two years running (here and here) because they couldn’t meet their own ethical standards?

Sadly, Iceland CEO Malcolm Walker failed to respond directly to our questions – he was probably too busy being trustworthy – and instead Iceland published a rather vague statement on its website (see here). Incidentally, it was noted in the August 2015 minutes of the Lead Ammunition Group meeting that ‘the Iceland supermarket website information on game was not in line with current Food Standards Agency guidance’ (see here).

Following Iceland’s press statement, we asked more questions of Malcolm Walker, specifically about our concerns (distrust) that the red grouse being sold in his supermarkets could be described as safe, healthy and ethically sourced (see here). Alas, it seems that being ‘trustworthy’ doesn’t include being transparent about the food supply chain – Mr Walker has refused to answer the questions. So instead of being filled with ‘confidence’,’ belief’, ‘faith’, ‘sureness’, ‘certainty’ and ‘assurance’, we are left with ‘disbelief’, ‘doubt’, ‘uncertainty’ and ‘distrust’ of this product.

We’ve got a feeling this won’t be the last we hear about Iceland red grouse this year…..

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Iceland 6 - Copy

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Environment Minister misses the point

annie-with-her-sat-tagIn August this year, over 300 blog readers emailed Environment Minister Dr Aileen McLeod in response to the news that Langholm hen harrier ‘Annie’ had been found shot dead on a Scottish grouse moor (see here). Well done to all of you who took the time to write.

The Minister issued a press statement within a few hours. The response time was impressive, the content wasn’t (see here).

Now a month later, the Minister has been responding to the individual emails that she received (well, one of her civil servants has been responding on her behalf). We’ve been sent a number of these responses and they’re all identical. Here’s what the response says:

Thank you for your letter of 11 August 2015 to the Minister for Environment, Climate Change and Land Reform, Dr Aileen McLeod. I have been asked to respond on her behalf. Please accept my apologies for the delayed response.

Let me reassure you that the Scottish Government has been and remains committed to tackling wildlife crime. Since 2007 we have built a strong and broad-based Partnership for Action against Wildlife Crime in Scotland (PAW Scotland) involving conservationists, land managers and law enforcement.

We also have a group dedicated to tackling raptor persecution – the PAW Scotland Raptor Group – which is made up of representatives from law enforcement and government agencies, RSPB, Scottish Raptor Study Groups, Scottish Land & Estates, Scottish Gamekeepers Association, British Association for Shooting and Conservation, Game & Wildlife Conservation Trust and the Cairngorms National Park Authority.

We have pursued a number of initiatives since 2007, including for example

  • the first restrictions on the use of General licences by those convicted of wildlife crimes
  • tightening up of law relating to trapping and snaring, including the introduction of training and registration requirements for operators
  • new provisions in the Wildlife and Countryside Act relating to the protection of the nests of birds such as white-tailed eagles and protection against harassment for birds such hen harrier
  • the introduction of vicarious liability provisions for offences related to wild birds

Some of these initiatives were ground-breaking in the UK and have now also been adopted by England and Wales.

There are also a number of pieces of current work which are underway, which I will take this opportunity to update you on.

Pesticides Disposal Scheme – this Scottish Government funded scheme ran from 23 February to 29 May 2015. The scheme has removed over 720kg of highly dangerous toxic chemicals from Scotland’s environment and ensured they cannot be used to poison wild birds. Details about what was removed from Scotland’s environment were published on 9 September. There remains no good reason for people to retain these substances.

Wildlife Crime Penalties Review – this review has taken a comprehensive look at whether the penalties available to the courts in wildlife crime cases are adequate and appropriate. The review has been submitted to Ministers and will be published shortly.

Further restriction of General Licences – this new procedure which has been recently introduced will see restrictions being imposed on the use of general licences over land where it is believed the wildlife crime has taken place. A number of cases have been under consideration and I expect further news to be made public imminently. SNH will publish details of imposed restrictions when it is appropriate to do so.

Law enforcement obviously has a key role to play. Since being established, Police Scotland has ensured that there is a wildlife crime liaison officer (WCLO) in each police division and has also already delivered and made significant commitment to ongoing training not only for existing WCOs, but also to other officers force wide. Police Scotland aim to bring a consistent and professional approach to wildlife crime investigations, including the use of modern forensic techniques.

The Crown Office and Procurator Fiscal Service has a dedicated Wildlife and Environmental Crime Unit with four specialist Procurators Fiscal who have developed an extensive knowledge in this area, and have now secured the first prosecution in relation to vicarious liability. There has also been the first custodial sentence for a gamekeeper found guilty of killing wild birds.

The Scottish Government has previously stated that it would be prepared to consider the licensing of shooting businesses to further regulate this sector, however it is important that we are able to assess the impact of the measures that have been recently implemented, or are still to be fully implemented, before consideration is given to the introduction of any further regulatory measures. We do not consider it is appropriate to react to every instance of criminal activity with further changes to the law. Scotland already has some of the strongest laws to deal with wildlife crime. Appropriate action by the law enforcement agencies is the correct response to wildlife crime, as with any other criminal activity.

I hope that this response demonstrates the breadth of work that is ongoing in this area.

Yours faithfully,

Karen Hunter

Wildlife Crime Policy Officer


As you can see, it’s full of the usual guff about ‘commitment’ and ‘partnership-working’ yada yada. But there are a couple of things that particularly interested us –


We have pursued a number of initiatives since 2007, including for example

  • the first restrictions on the use of General licences by those convicted of wildlife crimes
  • tightening up of law relating to trapping and snaring, including the introduction of training and registration requirements for operators
  • new provisions in the Wildlife and Countryside Act relating to the protection of the nests of birds such as white-tailed eagles and protection against harassment for birds such hen harrier
  • the introduction of vicarious liability provisions for offences related to wild birds

Some of these initiatives were ground-breaking in the UK and have now also been adopted by England and Wales“.

Hmm. As far as we’re aware, only one of these “ground-breaking initiatives” has been adopted elsewhere, not “some of them”. The one that has been adopted is the restriction on the use of General Licences by those convicted of wildlife crimes. Although this can hardly be called a “ground-breaking initiative” when the person who is no longer permitted to use a General Licence on account of a relevant conviction can simply apply to the statutory agency (SNH or Natural England) for an individual licence to enable them to continue their trapping and killing activities as if they hadn’t been convicted at all!

The introduction of training and registration requirements for snare operators has not “also been adopted by England and Wales“. And how’s that going in Scotland, by the way? Ooops, looks like Police Scotland has cocked up big time by issuing duplicate tag numbers to 60 individuals, due to ‘an administrative error’ – see here. Brilliant.

The new provisions of the WCA relating to extra protection for white-tailed eagles and hen harriers  has not “also been adopted by England and Wales” because the enabling legislation is Scotland-specific (see here).

The introduction of vicarious liability provisions for offences related to wild birds has not “also been adopted by England and Wales“. Indeed, the Westminster Government has thus far refused to consider it as a serious option (see here and here).

Aileen McLeod MSP3The other statement in the Minister’s response that interests us greatly is this:

The Scottish Government has previously stated that it would be prepared to consider the licensing of shooting businesses to further regulate this sector, however it is important that we are able to assess the impact of the measures that have been recently implemented, or are still to be fully implemented, before consideration is given to the introduction of any further regulatory measures. We do not consider it is appropriate to react to every instance of criminal activity with further changes to the law“.

In our opinion, the last sentence indicates that the Minister has completely missed the point. Nobody is asking, or expecting, further changes to the law in response to every instance of criminal activity. That would be ludicrous. The point that we, and everyone else who sends her emails is making, is that every criminal raptor persecution incident is yet further evidence that the current measures are clearly not working!

Since the latest ‘new measures’ were first announced by former Environment Minister Paul Wheelhouse in July 2013 (see here), many of which are still to be implemented over two years later, we have seen a continuous number of reported crimes (which undoubtedly will be the very tip of a very large iceberg). Here are some of them, all detailed on this blog, and we expect there to be many more that haven’t yet made it in to the public domain:

June 2013: Shot buzzard found close to a grouse moor in the Borders, later revealed to have also been poisoned.

July 2013:  Buzzard shot in the throat in North Ayrshire.

August 2013: Red kite found shot close to a grouse moor in Leadhills.

September 2013: Poisoned buzzard found in Stirlingshire.

October 2013: Langholm hen harrier ‘Blue’ disappears.

October 2013: Half-made raptor trap discovered on a sporting estate in Angus.

December 2013: Buzzard died of ‘unnatural causes’ close to a grouse moor ‘near Tomatin’ [we now know it had been shot].

December 2013: Golden eagle ‘Fearnan’ found poisoned on Angus grouse moor.

January 2014: Man reported for hen harrier death in Aberdeenshire.

January 2014: Dead bird (species unknown) & suspected poisoned bait found in South Lanarkshire.

February 2014: Poisoned peregrine found close to a grouse moor in Leadhills.

March 2014: 22 poisoned raptors (16 red kites + 6 buzzards) found on farmland in Ross-shire.

April 2014: Man arrested for alleged attempted raptor trapping in Aberdeenshire.

April 2014: ‘Illegally-killed’ peregrine found near Stirling [we now know it had been shot].

April 2014: East Scotland sea eagle chick ‘disappears’ on Aberdeenshire grouse moor.

April 2014: Gamekeeper charged with allegedly bludgeoning & stamping on buzzard on a sporting estate in Dumfriesshire.

April 2014: Poisoned buzzard found in Fife.

May 2014: Masked gunmen caught on camera shooting at active goshawk nest in Cairngorms National Park.

June 2014: Allegations emerge of ‘coordinated hunt & shooting’ of a hen harrier on a grouse moor in Aberdeenshire last year.

June 2014: Hen harrier died on a grouse moor near Muirkirk “as result of criminal act”. We later discover it had been shot.

June 2014: Red kite found on railway line, shot in the head.

July 2014: Red kite found poisoned on a grouse moor in Stirlingshire.

September 2014: Red kite found poisoned on a grouse moor in Morayshire.

November 2014: Buzzard fatally injured after being shot & stamped on in the Borders.

December 2014: Tawny owl shot dead in East Lothian.

February 2015: Peregrine found poisoned on a grouse moor in Stirlingshire.

March 2015: Kitten found poisoned (Carbofuran) close to a grouse moor in the Borders.

March 2015: Hen Harrier ‘Annie’ found shot dead on a South Lanarkshire grouse moor.

May 2015: Red kite fatally injured after caught in illegal spring trap on a grouse moor in Stirlingshire.

July 2015: Buzzard fatally injured after found shot close to a grouse moor in the Borders.

August 2015: Buzzard shot dead in Loch Lomond & the Trossachs National Park.

August 2015: Red kite fatally injured close to a grouse moor ‘near Tomatin’ – cause of death “not due to natural causes”. [Was probably shot].

The Minister points to two recent notable successes – the vicarious liability conviction and the custodial sentence given to a raptor-killing gamekeeper. They were indeed huge results and were warmly welcomed at the time. However, they are still the exceptions to the rule and we have since seen a number of convictions this year that have resulted in the usual derisory sentences (e.g. Michael Johnston fined £400 for possession of banned poison Strychnine; Gamekeeper James O’Reilly given a 240 hours Community Payback Order for four offences including the use of a banned gin trap; Poultry farmer Michael Harrison fined £600 for shooting and stamping on a buzzard; Gamekeeper William Dick fined £2,000 for bludgeoning and stamping on a buzzard). We have only seen one vicarious liability conviction in three and half years since the new legislation was enacted.

We keep being told that ‘we need more time to assess the impact of the new measures’. Why do we? Isn’t it bleedin’ obvious that raptor persecution is continuing despite all the so-called partnership-working, new measures and deterrents? The Minister may well be irritated that her inbox gets bombarded after each raptor crime but she can expect more of the same each and every time we hear of yet another crime. And there will be more, mark our words.

She should also know that if and when she decides to make a stand with something forceful and tangible, she’ll be deluged with emails of appreciation and support.


Ross-shire Massacre: 18 months on

sleeping policeman 2It’s been 18 months since the corpses of 22 birds of prey (16 red kites and 6 buzzards) were found in a small area around Conon Bridge in the Highlands.

We know that 16 of these birds were illegally poisoned (12 red kites & 4 buzzards). Still no word on the other six victims.

Still no word on the type of poison used, although Police Scotland did eventually admit that it was an “illegally-held poisonous substance” (see here). Carbofuran is suspected by many of us (see here).

The details of this illegal mass poisoning have still been deliberately excluded from the quarterly SASA reports – the Government reports that are supposed to inform us about recent illegal poisoning crimes in Scotland.

Police Scotland still maintains that the birds “were most likely not targeted deliberately but instead were the victims of pest control measures” (see here) – even though they can’t possibly know this unless they have a suspect who has given a full confession.

We’re still waiting to hear whether MSP Dave Thompson’s request, back in November 2014, for a review of Police Scotland’s handling of this investigation will be undertaken (see here).

We’re still waiting to hear when the thousands of pounds worth of reward funds, that many of us donated, will be released by Police Scotland so that RSPB Scotland can redistribute them to support the work of their investigations team (see here).

Two months ago in July 2015 MSP Bill Kidd called on Police Scotland to tell the public more about the investigation (see here). We’re still waiting.

18 months on and still no arrests.

18 months on and still no charges.

18 months on and still no prosecution.

18 months on and still no conviction.

18 months on and still no justice.

18 months on and still no confidence in Police Scotland’s ability to solve this appalling crime.

Previous posts on the Ross-shire Massacre here.

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