Introduction
This guide outlines the regulations associated with the supply of wild deer carcases. An interpretation of the regulations is given in the document “Guidance on Hunting and Processing of Wild Game for Human Consumption”, developed by the Food Safety Authority of Ireland. This should be considered as essential reading on the subject. Please note that many of the terms used in the text (highlighted in bold) are explained in the ‘definitions’ section at the end of this guide. This guide is linked to the Carcass Preparation series of guides and the Larder Design and Legislation guides.
Legislation
The key aim of current food legislation is that all food for human consumption is safe to eat. The European Legislation outlined below and the food safety authority of Ireland Act 1998 provides the framework for food legislation in the Republic of Ireland. Regulation (EC) No 178/2002 sets generral food law requirements, including establishing traceability of food, feed and food producing animals.
The General Food Regulations 2004 (as amended) provides for the enforcement of certain provisions of Regulation (EC) 178/2002 (including imposing penalties) and amends the Food Safety Act 1990 to bring it in line with Regulation (EC) 178/2002.
Since 1 January 2006, all game (which includes wild deer) supplied for human consumption must meet the requirements of Regulation (EC) No 852/2004, which sets general hygiene rules applying to all food businesses. In addition Regulation (EC) No 853/2004 which sets additional hygiene rules applying to certain businesses producing food of animal origin. Section IV of Annex III of that regulation covers wild game supplied to and processed in approved game handling establishments (AGHEs).
Food and meat legislation applies in different ways in different scenarios. The following list describes typical situations and gives a summary of the relevant legislation and recommended best practice.
Private Domestic consumption
The regulations specifically relevant to wild game meat do not apply to private domestic consumption. Although the regulations are not applicable, the hygiene standards implied are relevant and it is recommended that they are still followed.
Supplying in-skin carcasses to the final consumer
A primary producer can supply in-skin carcasses, in small quantities directly to the final consumer or to local retailers that supply direct to the final consumer, under the “primary producer exemption”. The term ‘small quantities’ has not been defined in Irish legislation.
You are not a food business under the regulations but you are nonetheless responsible for supplying safe food under Regulation 178/2002. Rules on food traceability may be interpreted by your Local Authority as a need for your premises and/or vehicles to be registered. Carcass records should be kept to ensure traceability and it is recommended that carcasses are initially inspected by a trained person before being supplied.
Temperature controls should be maintained and premises should comply with the requirements of Regulation (EC) No 852/2004.
Note: A business which buys up carcasses and then sells them on to retailers cannot use the primary producer exemption, even if the quantities are small and the retailers local.
Supplying in-skin carcasses to an Approved Game Handling Establishment (AGHE)
If you supply in-skin carcasses to an AGHE, you need to be registered as a food business (this includes your deer larder if you use it to store carcasses before they go to an AGHE and any vehicles you use when you are supplying an AGHE). You must comply with general hygiene requirements for primary production and associated operations.
Any carcases taken to or picked up by an AGHE must have undergone an initiall examination by a ‘trained person’ and that carcass be tagged with the ‘trained person’s’ registered number and the time and date of killing. It must also be accompanied by an intake document which will include such information such as the species, sex and location of where it was shot, together with deer hunting licence number of the hunter and a statement (signed by the trained person) either that the animal was free from any abnormal behaviour, carcass characteristics or environmental contamination, or describing any such features that were found. A guide on how to complete this intake document is provided by DAFM on their website, link provided at the bottom of this guide.
An AGHE will not normally accept a carcass without a trained person’s declaration but may do so if it is accompanied by its head (not antlers) and heart, lungs and liver. It is advisable to check with the AGHE before collection/delivery.
A carcass should reach the AGHE as soon as possible. Temperature controls must be maintained and carcass records must be kept to ensure traceability. AGHEs may have their own specific requirements with regard to how they would prefer carcasses to be supplied.
Premises must comply with the requirements of Regulation (EC) No 852/2004.
Other routes of supply
These are dealt with in the FSA Wild Game guide1 which also has a useful question and answer annexe.
Definitions
Approved Game Handling Establishment (AGHE) – An establishment, approved by the Food Safety Authority of Ireland, for processing wild game for general sale both within the Ireland and for exports.
Final consumer – Ultimate consumer of a foodstuff who will not use the venison as part of any food business operation or activity.
Food Business Operator (FBO), Registration – To protect public health, competent authorities need to be able to identify those who are operating a food business, the address where the business is located and the activities that are carried out, this is known as “registration”. Existing forms of registration, e.g. deer hunting licence number in the case of wild deer and DAFM herd number in the case of park deer, may meet the requirements.
Game meat – Once the skin has been removed from a “primary product” carcass it becomes “game meat”.
Hazard analysis Critical Control Points (HACCP)1 – The HACCP system is internationally accepted as the system of choice for food safety management. It is a preventative approach to food safety based identifying hazards and critical control points, and establishing, verifying, reviewing and recording food safety procedures and measures.
Hunting/Hunter – In this context hunting is a legal method of killing wild animals. The “hunter exemption” described in this guide applies to individual hunters and/or active members of hunting parties whether acting individually or as a group.
Larder – Premises used for keeping killed wild game, where primary products are stored prior to onward transport or processing.
Premises – Applies to any buildings, whether permanent or temporary, and mobile sales vehicles.
Primary Producer – The EU food hygiene regulations regard shooting wild deer, “hunting”, for human consumption as a primary production activity. An individual who shoots deer alone, a hunting party or an estate which organises shooting are all primary producers.
Primary product – Primary products in the wild game sector are the products of hunting – i.e. in-skin and in-feather game that has undergone no more than any necessary preparation that is part of normal hunting practice. For deer the maximum level of preparation is an in-skin carcass, empty of internal organs, with the head and feet removed.
Private domestic consumption – This would typically apply to deer that you have shot yourself or venison you have bought or have been given, whether still in-skin or as oven-ready carcases or game meat, which you will eat yourself or share with family or friends. The key point is that it is not for supply to anyone else as part of a food business. To explain where private domestic consumption ends and running a food business starts, the EU food hygiene regulations speak of “undertakings, the concept of which implies a certain continuity of activities and a certain degree of organisation.”
Small Quantities – Has no absolute figure set, the quantity is intended to be self limiting.
Temperature controls – FBOs are responsible for the safety of the food they supply. Freshly shot carcasses should cool to no more than 7°C within “a reasonable time after killing”. This period is not defined but, for example, overnight storage is almost certain to require active chilling unless the temperature of the storage facility can be relied on to be below 7°C because the ambient (outside) temperature is low enough. There is a general concept of maintaining the “cold chain” whereby a carcass cools progressively to below 7°C and neither it or meat from it is subsequently allowed to rise above that temperature. In-skin carcasses must not be frozen.
If transportation of carcasses or meat is to be prolonged, refrigerated transport will be required.
Even where FBO registration is not required it is strongly recommended that these temperature controls are adhered to.
Traceability – Regulation 178/2002 applies to all food business operators including primary producers, even those that benefit from exemptions, and covers the whole food and feed chain. The Regulation uses the principle of “one step back and one step forward” so that food can be traced along the supply chain. FBOs are required to have in place systems and procedures that allow for traceability information to be made available to competent authorities on demand. Copies of invoices and larder records may be sufficient. Key information is the name and address of the supplier/customer, the date and the nature of the products. Final consumers do not have to be individually identified. However, it is useful to record how much game is supplied direct to final consumers.
Trained Person – Individual who can produce evidence of training to cover the requirements of Regulation (EC) No 852/2004, and Regulation (EC) No 853/2004 as they apply to wild game, see below. An approved qualification such as the NARGC Game handling course approved by FSAI is the most robust way in which stalkers can show that they have the appropriate knowledge
.Wild Game – for the purposes of this guide, wild deer. Note: wild game must only have been killed by hunting. Deer killed by any other means e.g. road traffic accidents, must not be supplied for human consumption.