David Mullen offers a run down of the basic regulations that surround game meat and selling it into the food chain in the UK.
A number of recent discussions and presentations have highlighted widespread confusion over game meat laws. Although it has been seven years since the overhaul of the rules applying to game meat and game dealing in the UK, many people are still not aware of the regulations as they currently stand. So what do these, now seven-year-old changes to ‘how we have always done it’, mean for deer, venison and Deer Managers?
The EU food hygiene regulations regard shooting wild game – hunting – for human consumption as a primary production activity. This makes any individual who shoots game alone, a hunting party and an estate which organises shooting all primary producers.
Primary products in the wild game sector are the products of hunting – in-fur and in-feather game that has undergone no more than any necessary preparation that is part of normal hunting practice. This does not have to be done in the field, but can be done in game larders.
These primary products now have two main routes into the food chain: the primary producer’s own use or to be sold to a Game Dealer. For your own consumption there is no requirement to be a trained hunter or registered as a food business. But to supply game to a Game Dealer all animals must be inspected by a trained hunter.
Selling to a Game Dealer
The trained hunter would normally be the stalker. However, if the stalker is not a trained hunter there is the option of the stalker culling the deer but not gralloching or inspecting it. They must, however, observe the animals actions prior to culling (anti-mortem) and report any abnormal behaviour to the trained hunter who must be present at the gralloch and must also inspect the carcass and viscera. Following the gralloch and inspection, a numbered declaration must be attached by the trained hunter to each carcass. The declaration should state that, following an examination, the animal has been found to be free of any abnormal characteristics, abnormal behaviour or environmental contamination. If there is evidence of abnormalities or contamination but the carcass is still being submitted to the Game Dealer, abnormalities should be indicated by the trained person. This can be achieved by using the declaration form or tag to record this information but by striking through the declaration statement itself. In all cases the date, time and place of killing should be indicated.
Any primary producer supplying an approved game handling establishment (AGHE) must:
- Ensure a trained person is present and completes the relevant documentation.
- Be registered with the Local Authority under the registration of food businesses requirement.
- Comply with the food business operator’s responsibilities, including both the general hygiene provisions for primary production in Regulation 852/2004 and the specific provisions for the initial handling of large/small wild game in Regulation 853/2004 when it is subsequently supplied to a Game Dealer.
- Meet the traceability requirements of Regulation 178/2002.
Primary Producer Exemption
There is an exemption from the above rules when supply involves small quantities of in-fur/in-feather carcasses supplied either direct to the final consumer and/or to local retailers that directly supply the final consumer.
In the UK these terms are currently being interpreted as follows:
- Small quantities are now regarded as self-defining because demand for in-fur/in-feather carcases from final consumers and local retailers is limited.
- Local is within the supplying establishment’s own county plus the greater of either the neighbouring county or counties or 50 kilometres/30 miles from the boundary of the supplying establishment’s county.
- Direct supply to the final consumer is not restricted by what is local. An individual or an estate can supply final consumers who order from them via the internet/mail order, as well as those who collect themselves.
How do I become a trained hunter?
From December 2005 the requirements of EU Regulation 853/2004 (Wild Game Meat) have been an integral part of the DSC Level 1, so achieving the DSC Level 1 certificate from that date provides proof that holders have the knowledge required by the legislation for large wild game. Additionally there are a number of stand-alone courses that cover the requirements of the regulations.
The full Food Standards Agency Wild Game Meat guidance can be found at http://www.food.gov.uk/multimedia/pdfs/wildgameguide0611.pdf.
Additional Information can also be found at the following web pages:
Regulation compliant Carcass Tags are available from http://www.bds.org.uk/larder_equipment.html.
Larder image credit to Curtis Pitts and George Wisset-Warrener