Contracts for butchery waste collections

[Gudgeon]

Hi, England based registered food business processing 30-40 deer p.a. At my EHO review today he said they were clamping down on businesses using domestic bins to dispose of their waste and that I needed to get something formal in place.
So I'm looking for a cost effective means of doing so and would be grateful for some real world experiences.
Thanks

 

[Grand Slam]

Do you have a local knacker man that would swing by and pick up. I explored lots of options with companies and even set up a contract with one. They messed me about for weeks and then decided to tell me they couldn't reach my area for collection. A quick google search brings up a few companies that cover Norfolk. Martlands being one.

 

[wytonpjs]

Interesting! Regs EC 1069/2009 Article 14 permits disposal of Cat 3 ABP in an authorised landfill after processing and this is enshrined in DEFRA's "Animal by-product categories, site approval, hygiene and disposal" regs for England, Scotland and Wales. This allows 20kg of raw trimmings from retail businesses to landfill each week. There is no need to register with APHA but you must keep records of the weight sent to landfill each week.

 

[The Singing Stalker]

There are a couple of things,
No 1 is Wytonpjs post above,
No 2 you can use the carcass for bait, for foxing, that would reduce the usage at your refuse centre, as you would be down to skin only and maybe a few carcasses.
No3 there are people who will take the carcass for their dogs. So you are down to skin again.

Those are what I would add to the paperwork, all legal and gives you 3 options.

Nb, I had my EHO in to see me last year, and no mention of it.

 

[Gudgeon]

Thanks guys. I will ask my EHO why I can't rely on EC1069. Thanks @wytonpjs I knew there was a reason I was religiously recording the weight of my waste!

Apparently Great Yarmouth borough are targeting all food businesses and insisting they have a waste management contract even businesses making cakes at home!!

We do have a fallen stock man on speed dial for our sheep so will give him a call tomorrow.

Thanks for the other suggestions. I can obviously do all of those, but I'd rather just bung it in the bin!

 

[Buchan]

Interesting! Regs EC 1069/2009 Article 14 permits disposal of Cat 3 ABP in an authorised landfill after processing and this is enshrined in DEFRA's "Animal by-product categories, site approval, hygiene and disposal" regs for England, Scotland and Wales. This allows 20kg of raw trimmings from retail businesses to landfill each week. There is no need to register with APHA but you must keep records of the weight sent to landfill each week.

Isn't wild game outwith the ABP regs?

 

[wytonpjs]

Isn't wild game outwith the ABP regs?

ABP is covered in para 9 of the WGG. It does make specific reference to "ABP generated from wild game as part of normal hunting practice (eg blood and green offal) and not collected after killing, are out of scope of the ABP regulations." It then goes on to say that:

"All ABP generated, other than part of normal hunting practice and not collected after killing, need to be correctly categorised, handled and safely disposed of (including records for traceability purposes) in accordance with the above UK government guidance (the regulations I gave above).

Whilst it then provides a Best Practice box, that only addresses ABP that are out of scope of ABP regulations. Trim, etc, is covered by ABP regulations and as there's nothing specific is contained in WGG, I defer to Defra's specific policy on ABP and consign it to landfill in my grey bin keeping within the 20Kg limit per week whilst maintaining records.

 

[Klenchblaize]

Just another pitfall, along with potentially HMRC, when registering as a "Small Food Business" in 2026?

K

 

[VSS]

20kg per week in domestic bin, as mentioned by others in this thread. All legal and above board. Just need to keep a record.
If you're only doing 30-40 deer per year, that'll easily deal with the lot.
Get an old freezer to keep waste, if you generate too much one week. Just dispose of it next week!
Anything removed outside the larder (eg, head, hide, hooves, gralloch) can be disposed of on the land, as it's just wild animal waste at that point, not butchery waste.

I also give away quite a lot of butchery waste for dog food.

Failing all the above, I get stuff collected by the same fallen stock company that takes my casualty livestock.

 

[Andyquadra]

If the bin is only collected once every 2 weeks, does that mean 40kg can go at once?

 

[Oldstalker]

Isn't wild game outwith the ABP regs?

I confess I always thought the Animal By-Products Order applies to wild game meat by-products.

 

[VSS]

If the bin is only collected once every 2 weeks, does that mean 40kg can go at once?

My bin is collected every 3 weeks.
The rules about butchery waste disposal don't mention collection intervals. Only that you can dispose of up to 20kg in the domestic bin in any one week.
I record 20kg going in the bin each week, but in reality I freeze it in 20kg sacks and then chuck 3 sacks in the bin on collection day.

 

[Gudgeon]

Thanks Tim for adding to the debate. I've already had a response from the EHO effectively ignoring the regulations and saying it is more about how the waste is transferred and using household collections for business waste means households are subsidising businesses. I haven't got time to argue the toss and he has given me a five star rating as long as I confirm that my fallen stock man will collect any excess waste, which he has done. Rest assured most of it will now be going as fox bait, to hungry dogs and other discrete places.

Thanks for all your input. Onwards and upwards.

 

[VSS]

Thanks Tim for adding to the debate. I've already had a response from the EHO effectively ignoring the regulations and saying it is more about how the waste is transferred and using household collections for business waste means households are subsidising businesses. I haven't got time to argue the toss and he has given me a five star rating as long as I confirm that my fallen stock man will collect any excess waste, which he has done. Rest assured most of it will now be going as fox bait, to hungry dogs and other discrete places.

Thanks for all your input. Onwards and upwards.

Trouble is, butchery waste emanating from a registered food business is not the same thing as wild animal waste such as gralloch, that's removed from the carcass in the field.
So, while it's ok to dispose of gralloch etc on the land or use as fox bait, you're on thin ice if you start using your butchery waste for that purpose, or disposing of it in "discrete places". I think if you were to tell your EHO that that is what you do you might lose a star off your rating pretty quick.

I think it's pretty poor that your EHO is effectively blackmailing you not to use a perfectly legal disposal method.

 

[Gudgeon]

Trouble is, butchery waste emanating from a registered food business is not the same thing as wild animal waste such as gralloch, that's removed from the carcass in the field.
So, while it's ok to dispose of gralloch etc on the land or use as fox bait, you're on thin ice if you start using your butchery waste for that purpose, or disposing of it in "discrete places". I think if you were to tell your EHO that that is what you do you might lose a star off your rating pretty quick.

I think it's pretty poor that your EHO is effectively blackmailing you not to use a perfectly legal disposal method.

I do understand all of that. I'm between a rock and a hard place though. The regulations say my small scale retail ABP3 can go to landfill. Council says yes but not in our household bin collections. If I tried to take it myself I'd need a waste carrier licence and when I get to the local tip they will say we don't accept your business waste.

Funnily enough the EHO said can't you just take it back to the farm and spread it round? Make up the rules as they go along? Who'd have thought it!!

 

[Gudgeon]

Final thing from me on this. Fallen stock man wants £30 per collection irrespective of weight (seems good to me). EHO man goes away for 2 1/2 years.

I just have to run an extra freezer to store my waste. Not the worst outcome.

Anyway back below the radar for a while.