Absolutely agreeIf not already done, you should also raise the barriers directly to Scottish Venison.
If the Scottish Government are looking to encourage a greater number of wild venison processors, this is the sort of obstacle that would benefit being reviewed.
Scottish Venison Association
Everything you might want to know about Scottish venison from both wild and farmed deer.www.scottish-venison.info
Had enough of bureaucracy
- Thread starter User00056
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^^^^ Totally
Meanwhile, back at the birthing pool of Lowland fallow, the population goes from strength to strength!
K
K
the Scottish Parliament are currently considering proposals to change deer legislation in Scotland. One of these proposals is to abolish the venison dealers licence.
You can make your views known on a Scottish Parliament consultation here
Natural Environment (Scotland) Bill - About you - Scottish Parliament - Citizen Space
You can make your views known on a Scottish Parliament consultation here
Natural Environment (Scotland) Bill - About you - Scottish Parliament - Citizen Space
Freeforester
Well-Known Member
I wonder how those selling in the same way as I did can operate now, it may be that different cooncils put different interpretations on the requirements, there’s at least one Aberdeenshire based operator working this way that I know of, and it was never an issue with either EHO or FSA sidekick when they came a calling. It just makes no sense at all that you as a service provider cannot operate as you describe, I’d be seeing them in the Courts about that, they are overstepping the mark, and aren’t above the Law, irrespective of their views. Set a precedent that they must observe.
You’re still responsible that the meat you offer is fit for human consumption, per the trained hunter certification and irrespective of whether it is you or a mate who has actually grassed the animal, and as a small scale producer every pack you offer is sold under the responsibility of you the producer, less so the actual hunter.
I've sent this off to Dave Doogand MP, and forwarded it to the associations I mentioned at the end. Guess we'll see if anything comes of it.
Please feel free to copy and amend to suit yourselves if anyone has a mind to? Guess the more noise made the better?
Sorry, it's a bit of a ready
'Dear Mr Doogan,
Knowing of your support for local small businesses I would like to bring to your attention the matter of the Scottish version of the Wild Game Guidance document, in particular where it relates to the supply of wild venison, and the restrictions on primary producers contained within?
To give you some background I, as well as many others across Scotland, run a small wild venison business aimed at raising awareness of, and supplying wild local venison to local farmers markets with a view to increasing peoples’ access to this fantastic natural resource. To this end, I have built and supplied a small but fully-equipped butchery on my premises, along with obtaining the necessary certification, equipment, training, insurances, and licenses to allow me to carry out my business on a small part-time basis. The venison I provide is all shot by myself, and processed, packaged, and labelled by myself on my premises. We take huge pride in what we produce, but find ourselves restricted by the legislation as it pertains to Scotland. Namely, that the legislation in England, Wales, and Northern Ireland permits a primary producer such as myself to purchase in-skin carcasses from qualified and verifiable sources, (namely other stalkers) whereas the Scottish legislation does not. As part and parcel to this, I would also like to raise the question of the Scottish requirement for me to hold a Venison Dealers License, and its continued relevance if existing legislation prohibits the purchase of carcasses?
The relevant section of the Wild Game Guide Section 4.4 for Scotland states:
‘This exemption applies to those persons processing wild game and supplying wild game meat from their own retail establishment, such as a farm shop, providing that the supply is of small quantities direct to the final consumer or local retail establishments who directly supply the final consumer. To be eligible for this exemption, the preparation and processing of wild game meat must be performed by somebody who played an active part in the hunting process’.
This is an additional clause to the Primary Producer, Requirements and Exemptions Table relating to the direct supply of ‘small quantities’ of wild game meat to the final consumer. This clause does not exist in the guide as it pertains to England, Wales, and Northern Ireland, and it is this section I would respectfully seek your support in challenging.
As you are no doubt aware, a large percentage of deer shot in Scotland are as a result of planned culls on various large estates, with the majority of the carcasses going the central Accredited Game Handling Establishments, which then process the meat further and distribute it to various supermarket suppliers and exporters. In addition, a large amount of venison for sale is imported from New Zealand and other countries, and is then offered for sale to consumers via various outlets. We have a phenomenal natural resource in our wild deer, and at present, the majority of stalkers who do not process their deer for their own consumption are in the position of having to use AGHE for disposal. For stalkers out-with large estates to have local outlets for their supply can only be a positive move to raise awareness of venison, and make it freely available to local communities.
I am of the understanding that NatureScot, and the Scottish branch of the British Deer Society are working to resolve some of the existing legislative issues, and would respectfully ask for your support in any move to bring the Scottish legislation in-line with that of England, Wales, and Northern Ireland. I have also written to seek support from the British Association for Shooting and Conservation, The Game Conservancy Trust, The Scottish Venison Association, and the Scottish Gamekeepers Association.
I attach both copies of the Wild Game Guide for your information, and look forward to your reply in due course.
Kind regards'
Freeforester
Well-Known Member
A scenario: we already understand and accept that all deer entering the human food chain are to be passed as fit by the trained hunter/s doing the culling, irrespective of whether the deer carcase is destined for an AGHE or sold to the end consumer directly to from the trained hunter; the employee of either the AGHE, the local butcher in his shop or indeed a butchering or packing/labelling mate helping out in your shed does not require this certification, surely?
Sauce for the goose, sauce for the gander; and
A rose by any other name would smell but as sweet..
It all seems to come down to the potential mis/interpretation of the sentence,
‘To be eligible for this exemption, the preparation and processing of wild game meat must be performed by somebody who played an active part in the hunting process’ - which I feel is poorly/loosely worded and therefore open to misinterpretation. For example, It does not say ‘…must ONLY be performed by…’ yet it seems that your Angus cooncil bods are interpreting it as such; the preparation.. could be deemed to include all that the trained hunter observes before, during and after the shot and subsequent post gralloch field inspection; it does of course neither say ‘…the preparation and/or processing of wild game meat…’. Both the trained hunter and eventual butcher processor are construed to have played an active part in the preparation and the process, just as trained hunter and the local licensed butcher or AGHE employee.
The ‘somebody’ can surely be yourself and/or your ‘agent’ per the Scottish VDL consignment criteria.
For the purposes of the exercise I see any agent helping you secure your carcasses as doing so under your control and/or direction ( it is you who are seeking you/your agent to secure a carcass for your activity eg at a time and date of your requirement), which suggests that both ‘have played an active part in the hunting process’.
To discriminate against the small producer is unsustainable, never mind plain wrong. For regional variations or interpretations to apply is just silly.
Sauce for the goose, sauce for the gander; and
A rose by any other name would smell but as sweet..
It all seems to come down to the potential mis/interpretation of the sentence,
‘To be eligible for this exemption, the preparation and processing of wild game meat must be performed by somebody who played an active part in the hunting process’ - which I feel is poorly/loosely worded and therefore open to misinterpretation. For example, It does not say ‘…must ONLY be performed by…’ yet it seems that your Angus cooncil bods are interpreting it as such; the preparation.. could be deemed to include all that the trained hunter observes before, during and after the shot and subsequent post gralloch field inspection; it does of course neither say ‘…the preparation and/or processing of wild game meat…’. Both the trained hunter and eventual butcher processor are construed to have played an active part in the preparation and the process, just as trained hunter and the local licensed butcher or AGHE employee.
The ‘somebody’ can surely be yourself and/or your ‘agent’ per the Scottish VDL consignment criteria.
For the purposes of the exercise I see any agent helping you secure your carcasses as doing so under your control and/or direction ( it is you who are seeking you/your agent to secure a carcass for your activity eg at a time and date of your requirement), which suggests that both ‘have played an active part in the hunting process’.
To discriminate against the small producer is unsustainable, never mind plain wrong. For regional variations or interpretations to apply is just silly.
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David Barker
Well-Known Member
The VD is not the best but if taken away they will put something in its place. Scottish Venison is run by Dick Playfair and he is well tied up with Highland Game i doubt you will get much change from him.
Highland Game have far too much influence in the venison industry, throughout the UK not just in Scotland.
I've had a very rewarding conversation with 'a certain person' this morning. Many thanks @Conor O'Gorman for passing on my email. I don't want to come over as too reticent to give details, but I don't want to put anyone on the spot. However, there's a ball rolling and we can only awaiting an outcome in due course.
What would be very useful is a summary of typical concerns and barriers that we as recreational stalkers are experiencing when it comes to outlets for both carcasses and processed venison. If any of you guys care to take the time to pm me with particular concerns or obstacles you've come across I'd be happy to collated them and pass them on prior to the Scottish Venison Association AGM
What would be very useful is a summary of typical concerns and barriers that we as recreational stalkers are experiencing when it comes to outlets for both carcasses and processed venison. If any of you guys care to take the time to pm me with particular concerns or obstacles you've come across I'd be happy to collated them and pass them on prior to the Scottish Venison Association AGM
We already do, under the 'Small Quantities' provision in the table. What we desperately need is for the caveat that we must either shoot it ourselves, or be present, to be removed. What's the point of training guys to 'Trained Hunter' standards under the DSC if they're then limited to dealing with AGHE?
Surely someone qualified to shoot, inspect, gralloch, and transport a carcass is far better placed to assess its suitability to enter the chain than a vet in an AGHE who may not have the faintest idea about deer and stalking?
I think the risk in what you're asking for is that they'll turn round and say you want all the benefits of being an AGHE without actually being an AGHE, and tell you that there's no need to change anything because all you have to do is become an AGHE under the current regulations.
The counter position, I suppose, is to accept a geographical restriction on the source of the carcasses you buy in, in return for being "different" from a full-on AGHE.
Note for everyone, I am referring to Scotland, where the rules are different and more restrictive than England.
@Quixote - thats what I thought as well, until I applied for BDS Wild Venison network and did some research. One of the BDS' requirements is that those in Scotland hold a Venison licence. See here on page 3/4
Anyway, hopefully all this gets changed.
Becoming an AGHE is completely outwith the reach of smaller guys like @sauer, myself, and guys like us. I'd be perfectly happy with a geographical restriction as 'local' is one of my base tenets.
We don't need huge volumes like an AGHE, all we want is the provision to be able to buy in a few carcasses each year to supplement what we shoot ourselves. For myself, this would make it feasible to attend more local markets, and also potentially offer farmgate sales. For local stalkers, in Sauers case it provides them a useful butchery service, and in mine it provides them both a limited local outlet, and a fairer deal than they currently get. Multiply those two potential scenarios across Scotland, and it'll make a difference to a lot of folks I'll wager
Same here.
When I kicked up a bit of a fuss about the Venison Assurance scheme, and how it was basically cutting out all small-scale producers, the chap I spoke to just shrugged his shoulders and told me to become an AGHE if I wanted to join.
But that's way beyond what I want, need or can afford.
Same here. All we want is to be able to buy in a couple of carcasses when it suits us to do so. We can still operate (well, I can. Poor old Paul has had the rug pulled out from under him, and he makes a very good point regarding what legislation butchers must comply with when processing carcasses for third parties
) but it greatly limits the quantity and frequency with which I can do it. And I don't accept the food safety argument at all. Most of us operate far in excess of what we're actually obliged to comply with, as it's a passion rather than a living. And incidences of food poisoning attributable to the actual source of venison just don't exist. The whole thing is a hash of badly-worded, poorly-thought out contradictions
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Did that on the consultation for the Natural Environment Bill.If not already done, you should also raise the barriers directly to Scottish Venison.
If the Scottish Government are looking to encourage a greater number of wild venison processors, this is the sort of obstacle that would benefit being reviewed.
Scottish Venison Association
Everything you might want to know about Scottish venison from both wild and farmed deer.
Not convinced it will be listen too....
I'm not sure I can agree completely with you on this point. Whilst many stalkers do measure up to the standards expected and maintained by many, you only have to look at some of the photographs and questions posed on social media to realise that not all DSC1 stalkers out there are "competent" on the inspection and gralloching aspects and given that there are substantially fewer DSC2 qualified stalkers out there (some of whom I'd similar question as competent) that's even less of a "trained" field. Whilst not all vets are as knowledgeable on UK deer as most competent stalkers, they have a minimum of 4 years training (if they hold a related degree) or typically 5-6 years training, coupled with significant on-the-job training. I'd therefore expect a vet in an AGHE to be significantly more competent on diseases , infections and animal physiology than your typical stalker. I've done 2 witnessed stalks on vets for their DSC2 and their competence was beyond doubt.
Ultimately though, if this uniquely Scottish restriction was to be lifted, it comes down to you as the processor to determine whether the carcass is suitable to enter the food chain post processing and I have no doubt that you and the vast majority of others in a similar position, would refuse to handle questionable carcasses.
My relationship with my EHO is based on risk. As long as I stay below a fairly low threshold, he is perfectly happy with my current arrangements. Above that, he requires enhanced facilities which I completely agree with, but given the poor current market I am perfectly happy to stay below that threshold as there simply isn't the profitability in it. I do not understand why a similar approach isn't being taken North of the border given that the risks are essentially the same. Back to your original point: why, just why, do we have different rules for England (and Wales) and Scotland? It makes no sense!
Freeforester
Well-Known Member
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