Meat for the Table
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- Last updated: 14/10/2019
The end of the doe season arrived and, for me, a lull in stalking activities. I only take a couple of young bucks over the summer, so my attention was focused on other things. One job I needed to do was register as a food business, as I had changed premises. No doubt you envision me making venison sausages and pies, but no, most of my cull; around a 100 animals per year, goes to the game dealer. I return perhaps 12 carcasses to the Estates, ready for their freezers.
As I do not sell any prepared meat, you may ask why should I register with the local authority, bringing paperwork and inspections upon myself? There are two main reasons. Firstly, it has been a legal requirement since 1st Jan 2006 to register under Regulation (EC) 852/2004 and Regulation (EC) 853/2004, the EU Food Hygiene Regulations. This has slowly been gaining traction, such that any person taking deer carcasses to a dealer needs to register.
Once registered and following hygiene guidelines (don’t we all, anyway?), should there be an outbreak of salmonella, E. coli 0157, Campylobacter or other food poisoning situation, you can be seen to be complying with the law. If not, I can see the Daily Mail headline now: ‘Rogue deer stalker makes dozens ill’. Compared to other countries, we are very lightly regulated here in the UK. To keep it that way, we should conduct ourselves in a manner that shows us as a responsible bunch, thus avoiding further legislation forced upon us.
Secondly, the process is not onerous. My local council (Wiltshire) has a form online, most of which does not apply to myself, as they are more interested in the likes of fast food shops, asking about opening hours and other employees etc. On the phone, the environmental health officer said I am low risk, so will probably just keep my data on file, although they may come and inspect.
I know each Council operates differently and some stalkers will get a visit, but there should be no nasty surprises, as there is a national guideline that they all should follow: The Wild Game Guide, (an internet search will find it). It is 38 pages long and happily written in plain English. In summary, the EU food hygiene regulations regard the shooting or hunting of wild game for human consumption as a ‘primary production activity,’ therefore a hunter acting alone or as part of a shooting party is a primary producer, if all they do is eviscerate and leave in the skin. What the stalker then does determines if he needs to register or not. There are three scenarios that could apply, summarised here:
The first scenario, is the hunter who shoots a just few deer per year for home consumption only. This includes venison given to friends and family, relying on a hunter’s exemption from the regulations, the key point being the product is not for sale. No need to register! The second, is the hunter who supplies small quantities of game to the final consumer or to local retailers that supply the final consumer. No registration required, although the hunter must comply with the food safety act 1990 and Regulation 178/2002, which covers traceability. The exemption from registration comes from the ‘small quantities’ clause.
The third, is the hunter who supplies the game dealer, or Approve Game Handling Establishment (AGHE), either directly (field to dealer) or via a holding chiller belonging the Estate or stalker. Many stalkers fall into this band, me included and registration is required of the premises and vehicle transporting the carcasses, as the hunter is part of a supply chain of a product that ultimately ends up for sale.
A further scenario, probably not applicable to most of us and beyond the scope of this article, is one where the hunter sells venison to the final consumer from a retail premises (i.e. they have processed the carcass beyond evisceration). The person must register with the Local Authority as a food business, under Regulation (EC) No. 852/2004, comply with hygiene regulations and have a food safety management procedure based on HACCP principles.
Obviously, someone buying in unlimited game from Estates or stalkers, then processing and selling on to retail or wholesale businesses is a dealer and needs to register as an AGHE, under veterinary control. Within the last decade, this has become expensive for the game dealer to pay for full time veterinary presence, resulting in the closure of many small game businesses. I know of one in Bristol and another close to Newbury that closed their doors. Certainly, the Bristol operation was exemplary, but having a vet on site sucked out any profit the business made.
Focusing on the ‘small quantities’ exemption clause for a moment, this major fudge causes much confusion. It allows the primary producer (stalker) to sell to small local retailers; EG your local butcher, several carcasses, or to the final consumer without having to register. Now, how much does ‘small quantities’ mean three a year, or a week? The guidance notes say, ‘Small quantities is regarded as self-defining, because demand for in-fur or in-feather carcasses from final consumers and local retailers is limited’, but that is not at all helpful.
I asked the British Deer Society (BDS) and British Association of Shooting and Conservation (BASC); they were also cagey about stating a number, reiterating it’s a rather grey area. I would hazard a personal guess at 12 a year, as that means one a month, which seems manageable to me and wouldn’t constitute a profitable business, but I could be wrong!
As someone who has had poachers on land I control, I would like to see the supplying of venison to local retailers ended altogether. It may inconvenience the stalker, who quite properly sells one or two Roe to the local pub occasionally. However, in the wider scheme of things, traceability through registering just may bring poaching incidents tumbling down. An example of this working in another industry being scrap metal dealers having to pay for incoming scrap by bank transfer or cheque only. I’m sure lead is still stripped from church roofs, but it’s no longer the big problem it was, as there is a direct link to the person receiving payment - traceability. Perhaps a halfway solution would be for the stalker to continue to sell to the pub, but with a tag that states the hunter’s number and receives payment by transfer only, the onus being on the pub to keep a record of the purchase in their accounts; there is traceability in this method, too. I live in hope.
By registering with the local authority, whether you get a visit or not, you are declaring that you adhere to basic food hygiene principles, which are covered in the DSC1, which also qualifies you to be a ‘trainer hunter’ to spot disease. I disagree that anyone can be competent after completing the basic course, but that’s the law. The diligent stalker wanting to do the right thing is at least on the path to producing venison that is fit to eat, keeping them within the law.