After 1st January 2006, new EU Regulations require that all wild game and venison being supplied to game dealers must have been previously inspected by a ‘trained person’. What constitutes adequate training to carry out this inspection properly in the eyes of the Food Standards Agency (FSA), which is the relevant authority in the UK, has been much debated.
Assessment of Suitability as a Trained Hunter
It has been agreed that a Vocationally Related Qualification (VRG) administered by approved awarding bodies and based on agreed National Occupation Standards (TCOs 2 & 3) will be drawn up by the Lantra Awards and will become the recognised route for qualification as a ‘trained person’ after 1 January 2006. The British Deer Society (BDS) and others have been assisting Lantra in the formulation of this new VRQ and has provided most of the legislative and large game questions. The Society may also provide the necessary pictures from our image library to support the national assessment process. The outline plan is for the VRQ assessment to be carried out in three sections:
A general module covering the hygiene rules and legislation applying to all game;
A large game module;
A small game module.
Each assessment module will consist of 20 questions drawn from 100 questions relating to that subject and the pass mark will be 70% correct in each module.
Candidates will be allowed to attempt just the general module and one other module to obtain a partial certificate (either large or small game). However because the requirement is not very onerous, it is anticipated that most people will opt for taking the full certificate straight away so they can sell both large and small game in the future if ever the need arises.
A very substantial number of game keepers, individual hunters and others who have no qualifications in this field yet wish to sell game after 1st January 2006 require to be qualified as ‘trained persons’. Many of the shooting organisations are now developing short courses in order to get such people qualified in time.
The National Gamekeepers Organisation has already started training for its members in England. By the beginning of June 2005, 1,062 NGO members had been trained on one day courses costing £100. This has been done with the agreement of the FSA subject to an ‘audit’ of the training at a later date.
The BDS is planning to offer similar training covering both large and small game in the near future. The names of those interested in gaining the hunter’s qualification are already being collected and a form on which to register such an interest has been put on the BDS website and is being sent out to all those who enquire. The first priority must be to train any persons who have no meat hygiene qualifications at all because those with other qualifications may be exempt (see below). A short manual is being prepared to enable candidates who may have no technical knowledge to prepare themselves in advance. Then, after a one day course of illustrated lectures, candidates will be assess to confirm that they have absorbed the necessary knowledge – the cost will be £80 to include manual training. This BDS training will also be subject to FSA audit but because we will be using the VRQ format which has already been approved, FSA is likely to be satisfied.
Discussions have also taken place to decide whether those who already hold another qualification such as the Deer Stalking Certificate or Gamekeeper’s NVQ will be exempt from the VRQ. No final decision has yet been made but it seems very likely that FSA will accept Deer Stalking Certificate (DSC Level 1) as sufficient to satisfy the large game requirement subject to hunters being given some additional information. DMQ is submitting an application to FSA to get agreement that all 8,000 holders of the DSC Level 1 on the DMQ database can become so qualified. Obviously among other subjects, holders of DSC Level 1 would require up to date information on the new legal developments which have been introduced since they gained their original certificate. This ‘new information’ would probably be issued in the form of a short training manual or the Industry Guideline document which is being prepared (see below) together with a ‘trained persons’ certificate, for a simple administrative fee.
If required, deer managers could take some additional training and a short assessment will then enable them to extend their large game certificate to a full game handling certificate including the small game qualification.
Game Dealing after 1 January 2006
The EU Regulations also introduced a concept of exemption from the need for veterinary inspection for small quantities of game sold locally by hunters directly to the final consumer or to a retail outlet e.g. shop or restaurant which supplies the final consumer. Definitions of these exemptions are generally but not formally agreed and ‘small quantities’ will be less than 300 deer or 10,000 small game. ‘Locally’ will mean the local authority area in which the game was killed or those immediately adjacent to it but will include game sent by carrier or post directly to the final consumer anywhere.
However, in the UK no sale of game or venison is allowed without a venison/game dealer’s licence unless it is to a licensed dealer. This UK legislation and the new EU legislation will continue to run in parallel until the Game Acts and Deer Acts are repealed or amended. Anyone supplying game will still have to be registered as a game dealer. If they are doing minimal processing or selling game in the skin or feather, simple registration may be all that is required. They will also have to be registered as food businesses and inform the Local Authority of the exact extent of their activities and any change in them.
All game larders and anywhere else used during production, preparation or supply of game will also have to be registered as food business premises with the same local authority. All processing of game must adhere to the health and hygiene requirements as laid down in the EU legislation. Approval may be required to process game into game meat. If the ‘small quantities’ thresholds are exceeded or game is sold further afield or to another dealer rather than to the final consumer or a retail shop, the law will require the dealer to be approved by the Meat Hygiene Service (MHS) and all product to undergo veterinary inspection. In this case the plant will be known as an Approved Game Handling Establishment (AGHE). All small game entering such a plant and most large game must have been previously inspected by a ‘trained person’. It is then labelled and does not have to be accompanied by the pluck or head unless a problem is detected. The game then undergoes yet another inspection by a MHS vet.
Full details of the new laws and official rules and interpretation together with individual responsibilities and requirements will eventually be published in a set of Industry Guidelines. These will be available free on the web or in hard copy from FSA sources later this year.