Deer waste requirements for food business
- Thread starter charlieboy-shooter
- Start date
Exemption, for crying out loud. Bl**dy phone autocorrect
Actually it is you who are wrong about that.
The hunter's exemption still applies. We may supply whatever either directly to the consumer (which I have received, as a consumer, i.e. bought a furry carcase from another stalker then skinned and cut it up myself. Quite a few times, it's much cheaper than paying to stalk my own and I pay a bit more than game dealer rates, with less of the transport costs for my contacts to drop it off at my place, or me collect it from them. Or supply it to local retail outlets. Butchers, pubs, restaurants, burger vans, some very classy establishments also. Done on trust, but I've not been let down yet.
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I would respectfully suggest you keep reading up to, and including, para 17.
Which states for direct supply you are exempt from hygiene rules but you are REQUIRED TO REGISTER WITH YOUR LOCAL AUTHORITY AS A FOOD BUSINESS.
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foxdropper
Well-Known Member
Vac pack the skins .Saves hell of a lot of freezer space .
Nope, you are still wrong about that. That's talking about supplying beyond local, via internet and mail order.
Local in my area is rather large, the county and the bordering ones. And talking about cut meat (nope, I don't think any internet/mail order suppliers sell complete furry carcases) Meat boxes yes, and again the rules are simple enough, once you do successfully register as a food business, despite some arssey uneducated PITA jobsworth trying to put imagined obstacles in your way. On an ego-boosting power trip maybe. They really are not all like that.
Now I could not ask @Norfolk Deer Search to sell me a carcase whilst passing by for me to take home to Sussex, that would be beyond local for me and him. But I can source such stuff from Kent, Sussex East and West, Surrey without breaking any rules. Though of course he would be breaking no rules to sell to me on his doorstep. What I chose to do with it afterwards, and where I took it to, for my own personal consumption would be my responsibility.
If I had shot it myself, or just as part of a hunting party, pretty much anywhere, even Scotland, I could take it home and commence the proceedings., at least I think so. Respecting the cold-chain along the way (wrapped in an old duvet with a bunch of frozen milk bottles of water inside the cavity, been there done that.
Used to shoot a few deer in North Norfolk and took them home (duvet, frozen milk bottles etc.) for personal use. OK could have passed them off locally and forged my tags, but that would have been quite disreputable. Besides any surplus had a ready market locally, so what would have been the point ?
I don’t understand how something can be there in black and white and people still get it wrong. The requirement is not restricted to those that sell via the internet!!
Let’s try it another way, flow chart taken from the same document
Supplying in the skin to the end consumer or someone that sells to the end consumer refers you to para’ 15-17 inclusive. 17 is not covering just the last section of para 16 (or the 2 elements would have been written together) it is covering all game supplied under this exemption. Which is an exemption from food hygiene regulations because you are not processing anything!!
The flow chart also states you are responsible for safe food under The Food Safety Act and Regulation 178/2002.
There is a footnote to para 17 which states
1 Under Regulation 178/2002 ‘food business’ means ‘any undertaking, whether for profit or not and whether public or private, carrying out any of the activities related to any stage of production, processing and distribution of food’.
Therefore supplying in the skin you are conducting an activity related to the distribution of food and defined as a food business, the key word on the foot note is ANY, which is all inclusive not just limited to the internet!
How is that so difficult for an intelligent person to understand!
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Maybe also have a read of the BASC advice: Get down to business – our guide to selling venison locally -
It is pretty clear what your obligations are.
It is pretty clear what your obligations are.
Nope, a hunter, supplying primary product, un-processed, in the fur or feather carcases, in small quantities, to local retailers, who may then process it themselves (as a food business) for direct sale to the public (not move it on to any other retailer), is not required to register as a food business.
This, as I understand it, is the basis of the "hunters' exemption" for primary production.
It only becomes mandatory once you start skinning it and maybe cutting it as well. Or to supply in the fur to an AGHE, in which case you must also provide a trained hunter declaration from someone who was present at the time of the shooting and conducted the necessary inspection then.
Paragraph 17 is the ambiguous/poorly written one. It starts off by saying that even primary production is a food business. But later acknowledges that, actually some hunters, even estates, might not be food businesses. You can't have it both ways. If you are not in reality a food business, then to be required to register as one, is not compulsory. Actually maybe not even valid.
This is a myth, so frequently repeated that it seems to have become unquestionable. Doesn't stop it from being untrue.
I repeat, it is still perfectly legal for a stalker without any formal qualifications, to shoot a deer, gralloch it, cut off the head and feet, then sell it to a local retailer. Or direct to a member of the public. Without any requirement to register as a food business, because they are not a food business, they are not doing any processing..
You still don't believe me ? Well take a look at the current modern Scottish Wild Game guide. (the rules are the same throughout GB), though the Scots have the added complication of Venison dealer licensing)
https://www.foodstandards.gov.scot/downloads/FSS_Wild_Game_Guide-_December_2021.pdf
How is that so difficult for an intelligent person to understand!
The OP wishes to sell skinned carcasses, so yes he must register.
OK I am nit-picking, the point of this thread I think is how to register as a food business to allow selling processed meat, even just simply skinned, but also could be cut up, packed and sold locally from their doorstep, at the farmers market, etc. Even anywhere in the country via the internet, mail order etc.
This requires the approval of the EHO of the local council. Who ought to be supportive and give advice to anyone wanting to do so, and who has put the necessary infrastructure and record keeping in place, and continues to apply it.
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foxdropper
Well-Known Member
Good job Baggy isn’t available or you’d be tied up like a kipper mate .
I too agree with your thesis and was more or less told same by local authority .I signed up to avoid any unforeseen repercussions though .
Is that chart up to date though mate
I too agree with your thesis and was more or less told same by local authority .I signed up to avoid any unforeseen repercussions though .
Is that chart up to date though mate
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No, you are wrong. You are interpreting it as what you think it should say, not what it’s says.
And the BASC agrees with me
foxdropper
Well-Known Member
So what does that chart actually say ,I’m confused .Being accountable would necessitate the need to be trained in the first place which according to that chart isn’t needed .
I do know I’ve never been asked for any certs or paperwork when dealing with AGHE supplying in fur but I’ve always written my ID on all tags submitted .
Can we have a definitive answer on this please as it’s vexing me
I do know I’ve never been asked for any certs or paperwork when dealing with AGHE supplying in fur but I’ve always written my ID on all tags submitted .
Can we have a definitive answer on this please as it’s vexing me
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Supplying to an AGHE in the skin you must be registered as a food business.So what does that chart actually say ,I’m confused .Being accountable would necessitate the need to be trained in the first place which according to that chart isn’t needed .
I do know I’ve never been asked for any certs or paperwork when dealing with AGHE supplying in fur but I’ve always written my ID on all tags submitted .
Can we have a definitive answer on this please as it’s vexing me
Selling venison even in the skin, you must be registered as a food business.
tikkathreebarrels
Well-Known Member
Just a thought: a modest donation of meat/sausage/burger product might oil the wheels with the binmen?
It is simple enough.So what does that chart actually say ,I’m confused .Being accountable would necessitate the need to be trained in the first place which according to that chart isn’t needed .
I do know I’ve never been asked for any certs or paperwork when dealing with AGHE supplying in fur but I’ve always written my ID on all tags submitted .
Can we have a definitive answer on this please as it’s vexing me
Primary producers may supply in fur/feather direct to local retail establishments, or the consumer. No Trained hunter status required. No food business registration required. No HACCP food safety management plan required. Just keep traceability records (accounts, receipts etc.) Nevertheless you are responsible for the safety of what you supply, so best have your EHO on side and let them know what you are doing, show them your chiller etc.
This table, BTW, was produced by the BDS, who I respectfully suggest may be rather more au-fait with the rules regarding deer than say BASC.
The Hunter's Exemption is still alive and well.
Look, I could rock up at a farmers market etc. and set out my stall with rabbits, hare, pigeon, pheasant etc. in fur and feather, that I, or my hunting party have shot. No officialdom required .Much as I could also sell eggs, fruit, maybe even homemade jam or chutney or cake (that's a grey area that ISTR the Womens' Institute fell foul of, until common-sense prevailed) But if a customer got ill I might be responsible. That's why it's best to let your EHO know what you are up to.
BTW I buy my honey from an amateur bee keeper. That's allowed too. And my eggs from a box by the road, with an honesty box for the payment. (ooh delicious goose eggs in season, treat them well and they can last several months longer) Sometimes a pile of fruit and veg. also.
Mussels and oysters too when I'm up in North Norfolk, bagged up in re-purposed seed potato sacks. In a cool shed down the back, along the garden path, with just a rusty cashbox screwed onto the bench to deposit the coin. The freshest you will ever find. Mind, you these sorts of supply are really for local people and passed on by word of mouth.
This statement by BASC is simply not correct. They clearly know nothing about the detail of the legislation but seem to be parroting the falsehood.
AGHEs should be requiring a trained hunter declaration and backwards traceability (i.e. your tag), plus your food business registration. Maybe even a photo identity document to confirm that you are who you say you are, and if they wanted to, confirm that your trained hunter number is real, and assigned to you.
I'd expect them to want to see all that paperwork the first time you go to them, if only to cover their own back, but after that just your tag. At least that's what I would be doing, if I were managing an AGHE.
If they are taking in stuff without any of that, not even a tag, then they are being very naughty.
You really are beginning to sound like a stuck record.
Don't believe that the word of BASC is always gospel.
foxdropper
Well-Known Member
Just need to convince the SD massive now mate 
Have a read of the Best Practice Guidance. It is laid out there:
Yes, so as said it will be down to your local authority.
So perhaps you two can now agree to an honourable draw?
So perhaps you two can now agree to an honourable draw?
You’re referencing a 12 year old document that is out of date
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