Registering as a food business - direct supply

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I registered with my local authority a year or so ago and like you, they didn't really have a clue to start with. I had to point them in the direction of the FSA Wild Game Guide.

Once the EHO had done a bit of research it was a relatively easy process - I provided a HACCP and Risk Assessment, they inspect my premises and transport ( a domestic garage and a carcass tray in the back seat of my car and that was it.

Some have stated that a Venison Dealers Licence is also required and I discussed this specifically with the EHO, who reverted to the LA's lawyers and were adamant that it was not - I am simply selling my own produce not dealing in venison (defined as buying and selling).

Section 36 of the Deer Act (Scotland) (not sure if England is any different states
36Offences in connection with venison dealing.
(1)Subject to subsection (2) below, any person who—

(a)sells, offers or exposes for sale; or

(b)has in his possession, transports or causes to be transported for the purpose of sale at any premises,

any venison shall be guilty of an offence.

BUT the important word is "Dealing" and the definition of dealing is the activity of buying and selling. An individual hunter simply selling game they shot themselves in not dealing.
I'm thinking of doing the same, like you would be in my garage where I have a stainless table, chiller etc would that be okay? I should add this isn't the sole use of the garage which is why I'm not sure it will be okay
 
Thanks Ben, but who interpreted that particular implementation of the legislation? Has it been tested in the courts. The Deer Act specifically mentions dealing not selling.

Application for a VDL may not be a big step but is expensive if you only process a few carcasses a year.

I have summit a question on the requirement for a VDL to the Wild Game Guide consultation as it currently is not clear on this alleged requirement.
This is potentially another barrier to shortening the supply chain, although I acknowledge that food safety is paramount
Look on Nature Scotlands site (they are a Government body) it states quite clearly to buy or sell venison it must first have passed through a licensed venison dealers.
Not that difficult to register but a bit more accountability and paper work.
 
I'm thinking of doing the same, like you would be in my garage where I have a stainless table, chiller etc would that be okay? I should add this isn't the sole use of the garage which is why I'm not sure it will be okay
I do know people who have registered as a Food Business for venison using their normal kitchen area, so it doesn't necessarily have to be a dedicated facility.

In the first instance I would recommend picking up the phone and having a word with your local Environmental Health Officer, as they are typically very helpful. Discuss the challenges with them and see what they suggest.

With a shared-use garage, rather than a dedicated larder, you may find you get more questions around things like pest control, provision of washing/waste facilities, drainage, hygiene, etc. but I doubt any of them will be insurmountable. You may need to expand your HACCP report though, to show that you have considered all the implications.
 
I do know people who have registered as a Food Business for venison using their normal kitchen area, so it doesn't necessarily have to be a dedicated facility.

In the first instance I would recommend picking up the phone and having a word with your local Environmental Health Officer, as they are typically very helpful. Discuss the challenges with them and see what they suggest.

With a shared-use garage, rather than a dedicated larder, you may find you get more questions around things like pest control, provision of washing/waste facilities, drainage, hygiene, etc. but I doubt any of them will be insurmountable. You may need to expand your HACCP report though, to show that you have considered all the implications.
thank you, I have spoken with them about having the butchery done at an actual butchers for the meat to be used as "meat boxes" but just reading this thread made me wonder further about the removal of the butchers themselves

ill speak to them and see what they say, worst case I can do it in the kitchen but would ideally look to break down the carcass into primals in the garage for ease of space (so as not to upset the boss)
 
Look on Nature Scotlands site (they are a Government body) it states quite clearly to buy or sell venison it must first have passed through a licensed venison dealers.
Not that difficult to register but a bit more accountability and paper work.
all cleared up and sorted a while ago,👍
 
Just a quick update. Had my EHO inspection on Friday. It was more of a chat than anything else with me explaining exactly what it is I would be doing with any deer. More than happy with everything I have in place. Very impressed with the HACCP I was kindly sent by a member on here. 5 star rating and ready to start supplying the local community with some amazing, healthy meat!

Thanks to everyone who has assisted me with this journey.
 
Just a quick update. Had my EHO inspection on Friday. It was more of a chat than anything else with me explaining exactly what it is I would be doing with any deer. More than happy with everything I have in place. Very impressed with the HACCP I was kindly sent by a member on here. 5 star rating and ready to start supplying the local community with some amazing, healthy meat!

Thanks to everyone who has assisted me with this journey.
Congratulations, and well done :tiphat:
 
Just a quick update. Had my EHO inspection on Friday. It was more of a chat than anything else with me explaining exactly what it is I would be doing with any deer. More than happy with everything I have in place. Very impressed with the HACCP I was kindly sent by a member on here. 5 star rating and ready to start supplying the local community with some amazing, healthy meat!

Thanks to everyone who has assisted me with this journey.
Well done
 
I thought I'd stick this up here as I know a few folk have either done this or are thinking of it but these posts are often tucked away in other threads.

So first off, this isn't a thread about do you / don't you need to register in order to take a carcass to the game dealer. That's been covered extensively elsewhere - see here for example: Registering as a food business

I registered with Manchester City Council about 3 years ago as a Food Business. By the inspectors own admission, my application sat on their desk for a few weeks as they didn't know what to do with it! They'd never come across this scenario before and are more used to dealing with restaurants and takeaways. They came out, gave me a quick inspection but to be honest, it was more of a fact finding mission as they didn't really understand the process, but were very friendly and genuinely curious. I've probably only taken a handful of carcasses to the dealers over the last 3 years, but I know I'm covered if asked and the whole process was free and took about an hour of my time (10 mins to fill in the online application, 45 mins for an inspection / chat).

I'm now in the process of changing my registration from simply supply of in-fur to AGHE to direct supply to the final consumer. I don't want to end up with a couple of reds in the chiller that the game dealer won't take this winter (I've already had a farmer tell me that his turnips are my responsibility and I better not let the bloody deer eat them :lol:). We tend to eat most of what I shoot and give a load away to friends and family but I'd struggle to find freezer space for more than one red at a time so want to keep my options open.

Technically, I don't think there is any difference in requirement from a food business registration perspective, but as I'd previously only mentioned I'd be supplying carcasses to a game dealer I thought I'd drop them a note to let them know and make sure I was covered. The same inspector is dealing with me again this time and we've had a couple of chats by phone as she's sought clarity on a couple of points as I'm still the only person registered in Manchester on this basis. I've provided a HACCP (thanks @willie_gunn and @devon deer stalker who supplied the template), some photos of the area I'll use for butchery (an island in the kitchen - not a dedicated butchery area but they're happy with this as long as I follow the HACCP) and an example of the labels I'll use to ensure traceability. I also did the Level 2 Food Hygiene course online, which cost a tenner and took a couple of hours or so but seems to have been well received. All seems fine so far and just waiting final confirmation, which may take a week or two as the inspectors are pretty maxed out at the minute dealing with complaints about bars and restaurants not following social distancing regs apparently!
I just came on the SD to ask the exact question you have written about above So thanks for that.
Are you able to post or email a copy of your HACCP?
 
I just came on the SD to ask the exact question you have written about above So thanks for that.
Are you able to post or email a copy of your HACCP?
Just remember that the HACCP should be a "living document", not something that you stick in a drawer and forget about once it's written. It needs constant tweaking and updating to keep it current to both changes in legislation and changes in your activities.
 
Good evening Gents,

After having recently passing my DSC1 and also attaining my Wild Game Meat Hygeine Trained Hunter number, I’ve been looking on the net to see if there’s a starter for ten type proforma of a HACCP.
I’m not looking to freeload off anyone (genuinely) but would one of you kind gents point me in the correct direction please?
 
thank you, I have spoken with them about having the butchery done at an actual butchers for the meat to be used as "meat boxes" but just reading this thread made me wonder further about the removal of the butchers themselves

ill speak to them and see what they say, worst case I can do it in the kitchen but would ideally look to break down the carcass into primals in the garage for ease of space (so as not to upset the boss)
I am also investigating the registration process with my EHO. I currently use a local butcher to process the odd roe carcass for home consumption, but due to expanding opportunities, may soon have more than I can use.

To make life easier and quicker, and the end product certainly more presentable, and whilst I sort the larder/prep side out, I was wondering about using a butcher to do the actual butchery for me - all returned back to me vacuum packed as he would do for his own shop.

I had an initial discussion with the EHO (Surrey) who thought that the FSA did not allow this subcontracting of the butchery, but was going to check! The cold chain would be maintained and transported appropriately and the butcher is only 1 mile away so can’t see an issue, but may have missed something. T.eddie made reference to this possibility above, but the question wasn’t answered as he seemed to veer towards home processing!

They haven’t responded yet, but was wondering if others have experience of this so I can respond from a position of knowledge if I have to?

Thanks
 
I am also investigating the registration process with my EHO. I currently use a local butcher to process the odd roe carcass for home consumption, but due to expanding opportunities, may soon have more than I can use.

To make life easier and quicker, and the end product certainly more presentable, and whilst I sort the larder/prep side out, I was wondering about using a butcher to do the actual butchery for me - all returned back to me vacuum packed as he would do for his own shop.

I had an initial discussion with the EHO (Surrey) who thought that the FSA did not allow this subcontracting of the butchery, but was going to check! The cold chain would be maintained and transported appropriately and the butcher is only 1 mile away so can’t see an issue, but may have missed something. T.eddie made reference to this possibility above, but the question wasn’t answered as he seemed to veer towards home processing!

They haven’t responded yet, but was wondering if others have experience of this so I can respond from a position of knowledge if I have to?

Thanks
since this I have been signed off with a level 5 rating, I have this signed off for both selling to game dealer / butcher and also having the butchers process for me to sell. When I asked about the cold chain the answer was as long as within reasonable distance, about 30 mins or so from butcher to fridge/chiller or freezer then no active chilling was needed, but for anything longer or hot days some form of insulated box would be recommended as the same for the transporting for delivery
Ive not yet built a dedicated larder so shouldn't sell things that have been processed beyond just skinning unless done by the butcher.

However each council takes a different approach and I know @charlieboy-shooter was having more hassle with the cold chain requirement from his council
hope this helps
 
I am also investigating the registration process with my EHO. I currently use a local butcher to process the odd roe carcass for home consumption, but due to expanding opportunities, may soon have more than I can use.

To make life easier and quicker, and the end product certainly more presentable, and whilst I sort the larder/prep side out, I was wondering about using a butcher to do the actual butchery for me - all returned back to me vacuum packed as he would do for his own shop.

I had an initial discussion with the EHO (Surrey) who thought that the FSA did not allow this subcontracting of the butchery, but was going to check! The cold chain would be maintained and transported appropriately and the butcher is only 1 mile away so can’t see an issue, but may have missed something. T.eddie made reference to this possibility above, but the question wasn’t answered as he seemed to veer towards home processing!

They haven’t responded yet, but was wondering if others have experience of this so I can respond from a position of knowledge if I have to?

Thanks
I discussed this with my EHO some time ago, (Devon) he didn't have any issue, you just need to adapt your HACCP plan.
The positive side for me was the butcher did all the labelling and retail pricing.
However, I just can't be arsed these days, red/fallow to the game dealer, roe I eat myself/give away/sell as whole carcass.
Cheers
Richard
 
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