Deer waste requirements for food business

[charlieboy-shooter]

Hi,

I would be grateful for the advice on the legal or acceptable requirements in England on the disposal of the following deer by-product waste parts on a healthy carcass once registered as a food business.

Head
legs
skin

Eventually had an EHO round to inspect my larder. HACCP's x2 previously submitted as my scenarios. I thought all was agreed and acceptable through numerous conversation and the documents submitted but he wanted to know and made a big thing about all the waste, unused parts and these added as a note to my HACCP. By his own admission he does not know the correct answer yet but by the fact that it is over a year since 1st contacting my local authority and the level he has gone to so far. Therefore as I need to document it. I need to be correct and disposing any amount, even when butchered for my own use, in my general waste is not an option in his opinion.

However, as ever I may have said to much as I clearly couldn't claim my right to silence. So I told him truthfully but only verbally, that the

Gralloch is either buried/ covered or left out for buzzard, kites or at baited areas which are agreed with the land owner away from water courses and foot paths.
The offal when fit for use. liver, heart, kidneys is either given to my dogs or given freely to work colleagues for dog food or left with the gralloach. Which he seemed fine with.
Did not state what I did with skins but offered that in future a skinned carcass would be supplied with the skin to the butcher as his waste.
Heads, that a few people had the bucks heads but avoided the doe and pricket heads scenario.
legs. dog food again but in reality a small %.
Bones from a carcass butchered by me as freely given dog food.

Having a dedicated collection for the odd head, skin and legs or 2 ( well 8 legs in that case ) is another undesirable cost.

Yes, I know a year after starting the ball rolling I should have covered this already.

Thanks

 

[VSS]

Basic rules of thumb:
If the waste is generated in the field (eg, gralloch) you can dispose of it in the field.
If the waste is generated in a larder / cutting room that's a registered food premises (eg, butchery waste) then it needs to be disposed of via a licenced waste carrier.
If the waste is generated in your private kitchen (eg, food waste) then chuck it in the domestic bin.

 

[Sharpie]

Hi,

I would be grateful for the advice on the legal or acceptable requirements in England on the disposal of the following deer by-product waste parts on a healthy carcass once registered as a food business.

Head
legs
skin

Eventually had an EHO round to inspect my larder. HACCP's x2 previously submitted as my scenarios. I thought all was agreed and acceptable through numerous conversation and the documents submitted but he wanted to know and made a big thing about all the waste, unused parts and these added as a note to my HACCP. By his own admission he does not know the correct answer yet but by the fact that it is over a year since 1st contacting my local authority and the level he has gone to so far. Therefore as I need to document it. I need to be correct and disposing any amount, even when butchered for my own use, in my general waste is not an option in his opinion.

However, as ever I may have said to much as I clearly couldn't claim my right to silence. So I told him truthfully but only verbally, that the

Gralloch is either buried/ covered or left out for buzzard, kites or at baited areas which are agreed with the land owner away from water courses and foot paths.
The offal when fit for use. liver, heart, kidneys is either given to my dogs or given freely to work colleagues for dog food or left with the gralloach. Which he seemed fine with.
Did not state what I did with skins but offered that in future a skinned carcass would be supplied with the skin to the butcher as his waste.
Heads, that a few people had the bucks heads but avoided the doe and pricket heads scenario.
legs. dog food again but in reality a small %.
Bones from a carcass butchered by me as freely given dog food.

Having a dedicated collection for the odd head, skin and legs or 2 ( well 8 legs in that case ) is another undesirable cost.

Yes, I know a year after starting the ball rolling I should have covered this already.

Thanks

I'm no expert, but on the scale that you seem to be operating, just put it in the black wheelie bin. 20 kg per week is allowed. Bag it up discretely, the binmen do often take a look inside and might throw a wobbly if they see piles of skin and other bits, even though it's allowed. Some might even be a bit anti. Keep records. Or if you have a glut, freeze the rest 20kg per bag, or I suppose even 40 kg if you have fortnightly collection, and average it out That's rather a huge amount really, assuming that you leave the gralloch behind where you shot the deer, if the landowner is happy for you to do so, but nothing for eg. a butchers' shop who inevitably have to pay for commercial collection and disposal,, and may not thank you for adding yours to that.

Not sure how you are doing things, but if operating using the hunter's exemption alone, you may not sell to a butcher a skinned carcase. It has to be primary product, "in the fur". Of course many butchers are not set up to skin animals, but there might be ways around that, e.g. sell it to them "in the fur", then once it is their property offer to skin it for them yourself. That would have to be within their HACCP of course. Just saying.

However there is a technicality that if you transport any of the stuff, you must register your specific vehicles as part of the registration. Say if you have to take home the gralloch and other bits with you. Can't have dodgy types running around anonymously with piles of class 3 waste to be got rid of incorrectly, fly tipping style or worse.

Same applies to transporting e.g. a skinned carcase.

Animal by-product categories, site approval, hygiene and disposal

It's all there, but in your case, see the final paragraph.

Disposing of small quantities of ABPs
If you are a retail business producing a total weight of less than 20kg of raw or partially cooked meat, fish or shellfish waste per week, you can send this waste to landfill each week.

There is no need to register with APHA, however you do need to keep records of the type and approximate weight of ABP sent to landfill each week.

This is a weekly limit, not an average limit over a number of weeks.

This is for England/Wales.Rules are more stringent in Scotland.

 

[T.eddie]

it really is a shame your EHO is either unknowing or a PITA to be honest. Mine was comfortable that providing its small volumes this could just go in the bin. I indicated it would likely be 1 or 2 a month if im lucky and he was comfortable with that. I hope yours will eventually do a 180 and actually work with you to get it signed off

 

[charlieboy-shooter]

If the waste is generated in the field (eg, gralloch) you can dispose of it in the field.

Can the head and legs full into this. I always remove head and legs at home. However if removed is it acceptable to bury the head/ legs or does this come under the butchery waste really ? clearly the landowner needs to agree to me burying heads on his land.

If the waste is generated in a larder / cutting room that's a registered food premises (eg, butchery waste) then it needs to be disposed of via a licenced waste carrier.

My 2 scenarios are in-fur or skinned so only the skin and small amounts of trim as waste. hence hope to supply skin to butcher as waste.

However , The largest / heavier waste is when I skin, debone and butcher for me.

 

[paulbshooting]

Into year 2 of my small veni business, all the larder trim goes to local raw dog feeders who pick up. The fur and very small quantities of blood shot meat go in the domestic waste wheelie bin. As a small producer the EHO was fine with that.

 

[charlieboy-shooter]

Not sure how you are doing things, but if operating using the hunter's exemption alone,

I wished. I tried that route but he was having none of it. He has had no previous experience of game but does seem to love to quote Regs and rules.
I guess its the nature of the job but his interpretation on various points has generally been differed from mine and he has always seemed to leaned towards stricter end with no considerations to what is reasonably practicable even when such wording is stated.

Thank you for your reply. I will look into the info supplied in greater detail.

 

[Leec6.5]

Hi,

I would be grateful for the advice on the legal or acceptable requirements in England on the disposal of the following deer by-product waste parts on a healthy carcass once registered as a food business.

Head
legs
skin

Eventually had an EHO round to inspect my larder. HACCP's x2 previously submitted as my scenarios. I thought all was agreed and acceptable through numerous conversation and the documents submitted but he wanted to know and made a big thing about all the waste, unused parts and these added as a note to my HACCP. By his own admission he does not know the correct answer yet but by the fact that it is over a year since 1st contacting my local authority and the level he has gone to so far. Therefore as I need to document it. I need to be correct and disposing any amount, even when butchered for my own use, in my general waste is not an option in his opinion.

However, as ever I may have said to much as I clearly couldn't claim my right to silence. So I told him truthfully but only verbally, that the

Gralloch is either buried/ covered or left out for buzzard, kites or at baited areas which are agreed with the land owner away from water courses and foot paths.
The offal when fit for use. liver, heart, kidneys is either given to my dogs or given freely to work colleagues for dog food or left with the gralloach. Which he seemed fine with.
Did not state what I did with skins but offered that in future a skinned carcass would be supplied with the skin to the butcher as his waste.
Heads, that a few people had the bucks heads but avoided the doe and pricket heads scenario.
legs. dog food again but in reality a small %.
Bones from a carcass butchered by me as freely given dog food.

Having a dedicated collection for the odd head, skin and legs or 2 ( well 8 legs in that case ) is another undesirable cost.

Yes, I know a year after starting the ball rolling I should have covered this already.

Thanks

Your moaning about having to pay to get rid of
A few heads and feet?

I have to remove all red deer gralloch from my permission because of horse riders!

Have a wild guess what that is costing every year?

 

[Sharpie]

Oh, forgot to point out that the Wild Game Guide is there to study. The England/Wales version is old now, last updated 2015 and long overdue an update which had been promised last year but not yet happened. Whereas the Scottish version has, and I rather suspect the England/Wales update when it eventually appears will be very similar. I'd just look at the Scottish one for now. Same legislation across GB.

Wild game guidance

Wild game guides and HACCP | Food Standards Scotland

 

[25 Sharps]

Your moaning about having to pay to get rid of
A few heads and feet?

I have to remove all red deer gralloch from my permission because of horse riders!

Have a wild guess what that is costing every year?

But at least it gives you something more to moan about . . . . .

 

[25 Sharps]

I'm no expert, but on the scale that you seem to be operating, just put it in the black wheelie bin. 20 kg per week is allowed. Bag it up discretely, the binmen do often take a look inside and might throw a wobbly if they see piles of skin and other bits, even though it's allowed. Some might even be a bit anti. Keep records. Or if you have a glut, freeze the rest 20kg per bag, or I suppose even 40 kg if you have fortnightly collection, and average it out That's rather a huge amount really, assuming that you leave the gralloch behind where you shot the deer, if the landowner is happy for you to do so, but nothing for eg. a butchers' shop who inevitably have to pay for commercial collection and disposal,, and may not thank you for adding yours to that.

Not sure how you are doing things, but if operating using the hunter's exemption alone, you may not sell to a butcher a skinned carcase. It has to be primary product, "in the fur". Of course many butchers are not set up to skin animals, but there might be ways around that, e.g. sell it to them "in the fur", then once it is their property offer to skin it for them yourself. That would have to be within their HACCP of course. Just saying.

However there is a technicality that if you transport any of the stuff, you must register your specific vehicles as part of the registration. Say if you have to take home the gralloch and other bits with you. Can't have dodgy types running around anonymously with piles of class 3 waste to be got rid of incorrectly, fly tipping style or worse.

Same applies to transporting e.g. a skinned carcase.

Animal by-product categories, site approval, hygiene and disposal

It's all there, but in your case, see the final paragraph.

Disposing of small quantities of ABPs
If you are a retail business producing a total weight of less than 20kg of raw or partially cooked meat, fish or shellfish waste per week, you can send this waste to landfill each week.

There is no need to register with APHA, however you do need to keep records of the type and approximate weight of ABP sent to landfill each week.

This is a weekly limit, not an average limit over a number of weeks.

This is for England/Wales.Rules are more stringent in Scotland.

Thanks for posting (and to the OP ) as I was going to raise the same query

 

[Leec6.5]

But at least it gives you something more to moan about . . . . .

I’m an Englishman i am entitled to moan

 

[Woodsmoke]

Legs. Dry, vacuum-pack, and sell at £2.50 each as luxury dog treats.

 

[Klenchblaize]

I maintain at best its a grey area and at worst an expensive nightmare! The same applies to the oft’ asked question around Building Control and Public Health compliant larder drainage. The more you press for clarity and in so doing appear to have greater concern and grasp than the Assessor, the closer you get to a letter requiring compliance with every imaginable.

K

 

[shakey jake]

im unsure of the code, but if its a buisness your waste should not go in the house hold bin. get a small commercial waste bin biffa type. they should know the relavant code.
i would be inclined to sell as much as i could for raw dog food, heads, lower legs, bones, ect. and freeze the rest till collection day

 

[willie_gunn]

We have discussed this before, see Stalking/shooting insurance for people who sell venison - scroll down and see the post from @jim_allen_uk who kindly made reference to this link from DEFRA: Animal by-product categories, site approval, hygiene and disposal

Disposing of small quantities of ABPs​

If you are a retail business producing a total weight of less than 20kg of raw or partially cooked meat, fish or shellfish waste per week, you can send this waste to landfill each week.

There is no need to register with APHA, however you do need to keep records of the type and approximate weight of ABP sent to landfill each week.

This is a weekly limit, not an average limit over a number of weeks.

Despite the above I still take my ABP's to the local butcher for disposal. They don't formally charge me for it, but I always round up my bill by 5 or 6 quid to cover for their trouble.

I also registered as a lower tier waste carrier (it is free).

 

[charlieboy-shooter]

Legs. Dry, vacuum-pack, and sell at £2.50 each as luxury dog treats.

Apparently, to do that I would need to register with trading Standards as it pet food ( lets not open that can of worms. Just my luck the EHO will have a identical twin brother that works for TS). Yes. the EHO has covered that but he said he should inform Trading Standards but would leave that up to me to notify them. Great what a nice bloke.

So if you want it for free they are all yours or whoever wants them.

 

[Sharpie]

Can the head and legs full into this. I always remove head and legs at home. However if removed is it acceptable to bury the head/ legs or does this come under the butchery waste really ? clearly the landowner needs to agree to me burying heads on his land.

My 2 scenarios are in-fur or skinned so only the skin and small amounts of trim as waste. hence hope to supply skin to butcher as waste.

However , The largest / heavier waste is when I skin, debone and butcher for me.

If you use the hunters' exemption to supply in-the-fur to local retailers (butchers, pubs, restaurant's etc.) you do not have to register as a food business so can operate below the radar. It is still your responsibility to supply safe food though, so I would not advocate this, though it does still go on. Don't even have to be a "trained hunter" capable of spotting the more obvious signs of disease.

As I hinted at, even then there can be creative ways around the problem for those customers who aren't set up to do the skinning themselves.

It is only once you start skinning them or cutting up the meat, or supplying to an AGHE that you must do so.

I'm sorry that you seem to have an awkward EHO who should be helping you to set up correctly, rather than putting unnecessary obstacles in your way. Perhaps they lack knowledge and are defensive, but maybe that can be turned around and they can learn from you, as well as you from them.

Perhaps get your ducks in a row and tell them what you are going to do and leave it to him/her to tell you why you can't, and challenge it if you have to. but better to get them onside. Is it possible that they are "anti" and behaving unprofessionally ?

I've never done this myself, the little that I shoot all gets eaten by me, family and friends. Though I do have a great butcher who would take anything surplus, in the fur. So far it works the other way around though, I buy venison, wild boar etc. from him. He also gives me sausage skins gratis for when I do a run of those for myself.

Regarding the business side of things, you'll have to return a self-employment tax return, and if you are using more than a certain proportion of your house to do the work, also register that as a business premises and pay business rates, and business insurance of course.

For my self-employed work (completely different) from a three bedroom house, of which one room is my office, it works. 3Even then, there is a pull-out bed there for guests, actually for me, the guests get my bedroom, so it is still a bedroom. And I own it outright, have done for over twenty years since I paid off the mortgage,, so no landlord to persuade. Technically couldn't get away doing this with a smaller property, never mind a rented place.

 

[25 Sharps]

If you use the hunters' exemption to supply in-the-fur to local retailers (butchers, pubs, restaurant's etc.) you do not have to register as a food business so can operate below the radar. It is still your responsibility to supply safe food though, so I would not advocate this, though it does still go on. Don't even have to be a "trained hunter" capable of spotting the more obvious signs of disease.

As I hinted at, even then there can be creative ways around the problem for those customers who aren't set up to do the skinning themselves.

It is only once you start skinning them or cutting up the meat, or supplying to an AGHE that you must do so.

I'm sorry that you seem to have an awkward EHO who should be helping you to set up correctly, rather than putting unnecessary obstacles in your way. Perhaps they lack knowledge and are defensive, but maybe that can be turned around and they can learn from you, as well as you from them.

Perhaps get your ducks in a row and tell them what you are going to do and leave it to him/her to tell you why you can't, and challenge it if you have to. but better to get them onside. Is it possible that they are "anti" and behaving unprofessionally ?

I've never done this myself, the little that I shoot all gets eaten by me, family and friends. Though I do have a great butcher who would take anything surplus, in the fur. So far it works the other way around though, I buy venison, wild boar etc. from him. He also gives me sausage skins gratis for when I do a run of those for myself.

Regarding the business side of things, you'll have to return a self-employment tax return, and if you are using more than a certain proportion of your house to do the work, also register that as a business premises and pay business rates, and business insurance of course.

For my self-employed work (completely different) from a three bedroom house, of which one room is my office, it works. 3Even then, there is a pull-out bed there for guests, actually for me, the guests get my bedroom, so it is still a bedroom. And I own it outright, have done for over twenty years since I paid off the mortgage,, so no landlord to persuade. Technically couldn't get away doing this with a smaller property, never mind a rented place.

Wrong, the Hunters’ bullet demotion doesn’t exist any more, even to supply in the skin you have to be registered as a good business.

It’s been covered on here, several times!

 

[VSS]

Apparently, to do that I would need to register with trading Standards as it pet food ( lets not open that can of worms. Just my luck the EHO will have a identical twin brother that works for TS). Yes. the EHO has covered that but he said he should inform Trading Standards but would leave that up to me to notify them. Great what a nice bloke.

So if you want it for free they are all yours or whoever wants them.

Yep, as soon as you call it "pet food" it's a whole load more bother re: traceability etc. You really don't want that extra layer of hassle.
Just label the bag "venison scraps & trimmings, not for human consumption" and you're good to go