Thanks for flagging this, I'll look later. I've just registered locally as a food business and I feel this might not be a bad idea to make it harder for poachers to supply pubs etc
Good luck! That was my thoughts but the hoops to jump through to get solely producer accreditation with no local BQWV Processor to take it means it's a waste of time and money as I would not be able to label my products, only the carcasses.
My response to the consultation adds more detail:
Thank-you for the opportunity to comment on the Draft V2 of the BQWV Standard.
Sadly, whilst I do note some positive changes, under my current arrangements, I still cannot qualify as a processor and, given the absence of local BQWV AGHE/Processors, I see no benefit in the addition of further documentation, processes and record keeping to merely qualify as a BQWV producer if there is no improved route-to-market. I do not necessarily disagree with the majority of the BQWV Producer requirements but, at the volume/scale I work at, some remain disproportionate and arguably unnecessary activities. For example, over and above my extant documentation and processes, to be an accredited producer I would need to produce and document to BQWV assessors’ standards:
- 1.2: A complaints procedure
- 1.3: An emergency plan
- 1.7: Documented COSHH assessment
- 1.8: A Risk Policy
- Additional site changes to support 4.3 (chiller surroundings) and 4.5 (annual calibration of temperature readers)
I am a Limited VAT-registered company with 5* Local Authority Food Business registration where I am the sole producer, director, and owner. Typically, I take around 50 carcasses a year from my local area (last year was 75) but with no AGHE in my local area and the small number of carcasses typically available at any time, I process the venison in my domestic situation for sale to locals and through a very local Farm Shop. The Standards as written frankly do not support such modest enterprises where the sales revenue does not support investment in enhanced facilities. I’m very much stuck in a “Catch-22” situation where the deer need managing but are not present in sufficient numbers to warrant (and recoup) additional investment. Sadly, I'm destined to remain a "Fred in a Shed" and I see even at V2, the BQWV Scheme is aimed at much larger enterprises where it is both reasonable and economically viable to conduct all the processes and activities required for BQWV accreditation. I haven’t even looked at the producer charges but having made a loss last year I cannot afford additional expenses for no material gain to my turnover. Those few carcasses not processed by myself and sold in fur within the local area principally through word-of-mouth or social media, solve any potential need to move excess carcasses into an AGHE or BQWV Processor where frankly I would get less money.
I despair at the lack of a co-ordinated pan-Government Department strategy to manage deer in the landscape and most importantly, create a meaningful route to market for the venison that results. Whilst NE’s recent Deer Strategy and FE’s woodland support grants are promoting increased management, nothing has been done to stimulate the market for venison and with the new CL55 night-shooting licences I foresee increasing numbers of carcasses being presented to an already over-supplied small AGHE/Processor chain for minimal revenue. Indeed, there is open discussion of carcass disposal as being the only viable route in deer heavy areas such as Sussex or Lincs. Small-scale producers like me are arguably considerably more numerous than the Oakland Parks, Vickers, Hampshire Game, Highland Game, etc, and are possibly processing more animals in total, yet there is no simpler registration option.
In summary, even with the changes V2 introduces, I see the BQWV scheme remaining as a tool for the large suppliers already active in this market and not for the more modest producers and processors like me.
britishqualitywildvenison.co.uk
