Deer waste requirements for food business

[foxdropper]

Glad you took in the manner it was meant sir .Many would of thrown the toys out along with the dummy .Keep at them mate and come the season if you want a hand ,don’t hesitate to ask ,I’ll be there .

 

[Leec6.5]

Glad you took in the manner it was meant sir .Many would of thrown the toys out along with the dummy .Keep at them mate and come the season if you want a hand ,don’t hesitate to ask ,I’ll be there .

I knew you’d see it that way, you know exactly what I’m dealing with so I knew you’d have a cackle over it

 

[Sharpie]

It’s good to know somebody else other than myself has realised we do not need half the red tape others fall for just to put a deer into a GDHE .

Yes, there seems to be far too much dogmatism surrounding this. You only have to skim (sorry @Alantoo ) the responses to the consultation on the first draft of the proposed update to WGG for England/Wales to realise this.

Prepare yourself for a long read.

The text of which, BTW I do not have sight of. If anybody could forward me a copy anonymously I'd like to see it to put the summary of substantive comments in context. It was only issued to those who had already registered an interest before the eight week consultation started. Even if I had done so I doubt that anything I had to say would have been considered substantive.

It's classic civil servant timescales, spend a year putting together something rather poor, then bung it out just before school holidays start then demand responses to be delivered to a deadline for you to cast an eye over once you have returned. Meanwhile the consultees have to work away during the best of the Summer. Issued 15 July, deadline 11 September. 2020. Maybe also working to that sort of timescale for a second draft. Only two years later.

Let the consultees do the hard work to try to knock it into shape for you lazy civil servants. Covid excuses notwithstanding. All of this can be done working from home.

Detailed Proposals
There is no change in policy in this new guidance, merely a clarification or EU
Regulations and change in layout to improve readability. We anticipate that this guide will
be well-received as the industry have requested these changes, and they have been
involved in shaping this new guidance.
Impacts
These minor additions ensure that the guidance fully reflects the current legislation with
the changes intended to provide greater clarity and to enhance understanding of the
rules surrounding the supply of wild game for human consumption. The FSA assessment
of the impact of the updates, is that the changes will present a relatively low
familiarisation cost to those hunters and retailers that the guidance is relevant to, and to
local authorities. We estimate an average familiarisation time of 20 minutes

Read/skim it here: https://www.food.gov.uk/sites/default/files/media/document/wild-game-consultation-response.pdf I've only spent about an hour doing so, again. Clear whatever the draft said, it was a work in progress, and still not yet into second draft..

Much of it is focussed on the AGHE's responses, unsurprisingly, however that should not be the key focus on what matters to we stalkers, who may never have any intentions of suppling to an AGHE.

The Scots meanwhile have cracked on, and issued theirs. I'll start off by quoting just one question/response that ISTM demonstrates a rather defensive attitude by the writers of this one. Then follow up with some of my own selections.

BASC The guidance infers the WGMH Guidance is for England,
Wales and Northern Ireland. Are FSA Scotland
producing their own WGMH Guide? Surely the legislation
is applicable across the UK?

Response: Food Standards Scotland have their own guide called
The Wild Game Guide

I won't bother to include the standard responses, which are invariably "Comment noted. We will aim to provide further clarity on
this within the guidance."

The British Deer
Society
The British Deer Society has previously been one of your
primary contacts having a key interest in wild deer and
venison handling but unfortunately we appear to have
been omitted from your current list as named in your
consultation Annex B. We will obviously wish to respond
to this consultation with regard to venison. I would be
extremely grateful if you might amend this oversight
please in your published documentation on the website
and for your future records.

Forestry Commission
Waste And the Waste Regulations. ABPR does not apply to
wild animals. See section 13 page 2 of ABP reg i.e. (13)
In addition, in order to prevent risks arising from wild
animals, bodies or parts of bodies of such animals
suspected of being infected with a transmissible disease
should be subject to the rules laid down in this
Regulation. This inclusion should not imply an obligation
to collect and dispose of bodies of wild animals that have
died or that are hunted in their natural habitat.

Forestry Commission

Processing and supply of game meat by retailers
Paragraph 1 – ‘Can you confirm that there can be no
retail to retail trade of wild game meat supplied by
hunters, if so please make this clear?’
Paragraph 2 - No, they can supply from AGHEs also.
Suggest “Retailers can supply wild game meat
purchased from any legitimate source. However, a
retailer who receives wild game (in-fur/feather) or wild
game meat direct from hunters must only supply that
meat to a final consumer, (i.e. walk in customers in
restaurants, butchers, hotels, pubs, farm shops), not to
another food business. Retailers using this exemption are
expected to comply with Regulation EC 852/2004 and
Regulation EC 178/2002.”

Forestry Commission
Direct supply of small quantities of in-fur/in-feather game
carcases to the final consumer or local retailers
Column 2 – ‘No mention of trained person, the NEW
provision mentioned in the body text above.???? Or of
traceability’

Forestry Commission
Hunter training
Suggest re-write depending on whether all game
supplied must go through a trained hunter or just that
going to an AGHE. Please make a clear judgement on
this point.

Deer Management Qualification
In regard to Annex B DMQ Q considers they should be listed as an interested party.

Feedback to this consultation is centred upon the hunter
exemptions in respect of the supply of small quantities
and the requirements of FBO registration together with
trained hunter status and verification

Page 8 - Final bullet point in respect of the verification of
hunter status a trained person:
...

Clarity is sought on what verification is acceptable of
proof of any qualification.
DMQ are shortly to introduce identity cards which will
contain a photograph and registered number in respect of
the qualification of trained hunter. DMQ holds a register
of all such qualified persons.

Deer Management Qualification Page 14 FBO registration requirements.
In regard to trained hunters supplying direct to AGHE’s; if the supply is direct from the place of culling (field) to the AGHE and in which no processing has taken place i.e. in fur and no premises are used is the requirement within the current guidance indicating the need for FBO registration too onerous and unnecessarily bureaucratic given the existing legal safeguards of responsibility to supply safe food?

BASC
In relation to the section entitled Primary production for
direct or local sale by a hunter (in-fur/in feather),
Registration/approval, BASC believes this will be over
burdensome and bureaucratic for those hunters who
onward supply carcases in the fur and feather. They may
not have premises. For example, a stalker that takes the
carcase straight from the field to the
AGHE/Consumer/Butcher etc. has no premises to be
inspected or registered.
There may be some that are very occasional suppliers
again this may be seen as burdensome and bureaucratic
and may drive some sales underground which may
increase rather than reduce the potential for issues.
BASC feels those selling occasionally, locally small
numbers to a retailer supplying the final consumer or
direct to a final consumer, if one party of the transaction
is a FBO then this would suffice.

In relation to the section for primary production for direct or local sale by a hunter, it is not clear what the exemption is. Originally you were exempt from training but were required to have due diligence in place. It now appears that all persons have to be a Trained Hunter.

if a stalker registers as a food business but only so he can supply as per the “primary producers” paragraph, this is misleading as it suggests he needs to follow ABP regs and not just waste regs.

In relation to the section on waste under the heading of . processing and sale of game meat by retailers, waste is different from ABP. Gralloch etc left on the hill is waste, as are the bits we put in the bin at the larder, which is then subject to Waste Regs and taken away by an Approved Waste Handler. ABP are only relevant once it goes to an AGHE. Reg 1069/2009 states that it is NOT applicable to: • entire bodies or parts of wild game which are not collected after killing, in accordance with good hunting practice, without prejudice to Regulation (EC) No 853/2004; • (c) animal by-products from wild game and from wild game meat referred to in Article 1(3)(e) of Regulation (EC) No 853/2004 (which refers to the supply of small quantities by a trained hunter) • if a stalker registers as a food business but only so he can supply as per the “primary producers” his is misleading as it suggests he needs to follow ABP regs and not just waste regs.

BASC With regards to Hunter training, we believe there should no longer be any exemptions and all who supply large game in any quantity should be ‘trained hunters’ this should help with the venison supply chain and aid quality assurance through that chain. 853/2004 (retained EU legislation) details that persons who hunt wild game with a view to placing it on the market for human consumption must have sufficient knowledge of the pathology of wild game and of the production and handling of wild game and wild game meat after hunting, to undertake an initial examination of wild game on the spot. It is however enough if at least one person of a hunting team has this knowledge and is trained accordingly. With regards to the section on Hunter training, DMQ is an awarding body and carries out no training. It has one of the approved qualifications for the route to Trained Hunter (large game only).

Environmental Health Officer, Teignbridge District Council, Newton Abbot, Devon
Direct supply of small quantities of in-fur/in-feather game carcases to the final consumer or local retailers Column 2 – ‘Not true. The supply of in fur and in feather game only is primary production (PP) and as such is exempt from 852 (it says so right at the beginning of the regs). Therefore if 852 doesn’t apply to PP then the requirement to register, which is article 6 in 852, cant apply either. If the hunter skins the game then they need to be registered as this is considered processing and is more than PP.’