Food Chain Information Requirements under Regulation (EC) No. 853/2004 of the Eurpoean Parliament and of the Council of 29 April 2004 (laying down specific food hygiene rules for food of animal origin).

There appears to be a degree of misinformation and confusion amongst hunters and others as to what is required under the above Regulation (generally described as the “EU Food Hygiene Regulations”). The following extracts from the Regulation set out exactly what is required in relation to wild game meat (including large and small wild game).

It is important to note that Chapter 1, Article 1 (3) of the Regulation, dealing with the scope of the Regulation, provides as follows:

(3) This Regulation shall not apply in relation to:

(a) primary production for private domestic use;

(b) the domestic preparation, handling or storage of food for private

domestic consumption;

(c) the direct supply, by the producer, of small quantities of primary

products to the final consumer or to local retail establishments

directly supplying the final consumer;

(d) the direct supply, by the producer, of small quantities of meat

from poultry and lagomorphs slaughtered on the farm to the

final consumer or to local retail establishments directly supplying

such meat to the final consumer as fresh meat;



(e) hunters who supply small quantities of wild game or wild

game meat directly to the final consumer or to local retail

establishments directly supplying the final consumer (emphasis added).

(Extract)



SECTION IV: WILD GAME MEAT

CHAPTER I: TRAINING OF HUNTERS IN HEALTH AND HYGIENE

1. Persons who hunt wild game with a view to placing it on the market for human consumption must have sufficient knowledge of the pathology of wild game, and of the production and handling of wild game and wild game meat after hunting, to undertake an initial examination of wild game on the spot.

2. It is however enough if at least one person of a hunting team has the the knowledge referred to in point 1. References in this Section to a ‘trained person’ are references to that person.

3. The trained person could also be the gamekeeper or the game manager if he or she is part of the hunting team or located in the immediate vicinity of where hunting is taking place. In the latter case, the hunter must present the wild game to the gamekeeper or game manager and inform them of any abnormal behaviour observed before killing.

4. Training must be provided to the satisfaction of the competent authority to enable hunters to become trained persons. It should cover at least the following subjects:

(a) the normal anatomy, physiology and behaviour of wild game;

(b) abnormal behaviour and pathological changes in wild game due to diseases, environmental contamination or other factors which may affect human health after consumption;

(c) the hygiene rules and proper techniques for the handling, transportation, evisceration, etc. of wild game animals after killing; and

(d) legislation and administrative provisions on the animal and public health and hygiene conditions governing the placing on the market of wild game.

5. The competent authority should encourage hunters’ organisations to provide such training.

(Extract)

CHAPTER II: HANDLING OF LARGE WILD GAME

1. After killing, large wild game must have their stomachs and intestines removed as soon as possible and, if necessary, be bled.

2. 2. The trained person must carry out an examination of the body, and of any viscera removed, to identify any characteristics that may indicate that the meat presents a health risk. The examination must take place as soon as possible after killing.

3. Meat of large wild game may be placed on the market only if the body is transported to a game-handling establishment as soon as possible after the examination referred to in point 2. The viscera must accompany the body as specified in point 4. The viscera must be identifiable as belonging to a given animal.

4.

(a) If no abnormal characteristics are found during the examination referred to in point 2, no abnormal behaviour was observed before killing, and there is no suspicion of environmental contamination, the trained person must attach to the animal body a numbered declaration stating this. This declaration must also indicate the date, time and place of killing. In this case, the head and the viscera need not accompany the body, except in the case of species susceptible to Trichinosis (porcine animals, solipeds and others), whose head (except for tusks) and diaphragm must accompany the body. However, hunters must comply with any additional requirements imposedin the Member State where hunting takes place, in particular to permit the monitoring of certain residues and substances in accordance with Directive 96/23/EC;

(b) In other circumstances, the head (except for tusks, antlers and horns) and all the viscera except for the stomach and intestines must accompany the body. The trained person who carried out the examination must inform the competent authority of the abnormal characteristics, abnormal behaviour or suspicion of environmental contamination that prevented him or her from making a declaration in accordance with (a);

(c) If no trained person is available to carry out the examination referred to in point 2 in a particular case, the head (except for tusks, antlers and horns) and all the viscera except for the stomach and the intestines must accompany the body.

5. Chilling must begin within a reasonable period of time after killing and achieve a temperature throughout the meat of not more than 7 °C. Where climatic conditions so permit, active chilling is not necessary.

6. During transport to the game-handling establishment, heaping must be avoided.

7. Large wild game delivered to a game-handling establishment must be presented to the competent authority for inspection.

8. In addition, unskinned large wild game may be skinned and placed on the market only if:

(a) before skinning, it is stored and handled separately from other food and not frozen; and

(b) after skinning, it undergoes a final inspection in accordance with Regulation (EC) No 854/2004.

9. The rules laid down in Section I, Chapter V, apply to the cutting and boning of large wild game.

The following notification was circulated today 29 August 2011 by the Department of Agriculture, Fisheries & Food:

“Food Chain Information for Wild Deer

From 1st September 2011, a FCI document must be completed for each wild deer received at Game Handling Establishments approved by this Department. The hunter should complete the first part of the form (see link below). Please note that although the form refers to trained persons, there are currently no trained hunters in Ireland. However, training will commence in the near future. Therefore untrained hunters should tick the box for “No, and a trained person isn’t in a position to sign the declaration” and leave the second part of the form blank. Untrained hunters must present the form along with the whole deer including the head and all viscera (internal organs), expect (stet)* for the stomach and intestines, to the Game Handling Establishment”.

* except?

The FCI Form is available at:

http://www.agriculture.gov.ie/media/migration/foodsafetyconsumerissues/controlsonmeat/foodchaininformation/LargeWildGameFCIdoc24aug11240811.pdf

The following “Trader Notice” has also been circulated, dated 24 August 2011:

Department of Agriculture, Fisheries and Food

Trader Notice: MH No. 12/2011

To: Operators of all DAFF approved Game Handling Establishments

Subject: Large Wild Game Food Chain Information (FCI) Document

Background

From 1st September 2011 a FCI document (attached) must be completed in respect of each wild deer received at DAFF approved Game Handling Establishments. The document should be completed by the hunter, the trained person (where relevant) and the Game Handling Establishment. It should be retained by the Game Handling Establishment.

Obligations on the hunter

The first part of the document must be completed by the hunter. This includes the date and location where the animal was shot. There is a choice of three boxes to be ticked. The first box should be ticked if the hunter is a Trained Person as allowed for under the Hygiene Regulations. (Currently there are no trained hunters in Ireland, but training of hunters will commence in the near future.)

The second box is ticked if the hunter is not a Trained Person, but a Trained Person was present when the animal was shot. This person could be the gamekeeper or the game manager who is part of the hunting team, or located in the immediate vicinity of where hunting is taking place.

In all other cases, the third box should be ticked and the carcase must be accompanied to the Game Handling Establishment by the head and all viscera, except for the stomach and intestines. This will be the case for all Irish hunters at the opening of the 2011 hunting season.

In future, where a Trained Person has signed the declaration the carcase need not be accompanied by the head and viscera.

Obligations on the Trained Person

Box 2 should be completed by a Trained Person who either shot the animal or was present when the animal was shot. If the Trained Person is satisfied that;

• the animal did not display any abnormal behaviour before killing,

• the body and the viscera do not show any abnormal characteristics, and

• there is no suspicion of environmental contamination

then the first part of box 2 should be signed.

However, if the Trained Person has noted any evidence of health risks then the second part of box 2 should be completed detailing the possible health risks and the head and all viscera except for the stomach and intestines must accompany the carcase.

Obligations on the Game Handling Establishment

The Game Handling Establishment should ensure that each wild deer carcase is accompanied by a properly completed FCI document. The final part of the FCI document should be completed by a trained operative at the establishment. The Game Handling Establishment should ensure that the carcase is accompanied by the head and the viscera, other than the stomach and intestines, unless the Trained Person declaration has been completed.

The FCI documents must be kept on site and made available on request for examination by Department staff. The FCI documents must be correlated with the relevant carcase identification.

Any abnormalities recorded by the Trained Person must be brought to the immediate attention of Department personnel.

Meat Hygiene Section

Department of Agriculture, Fisheries and Food

Grattan Business Centre

Portlaoise

24th August 2011

COMMENT

The following comment is addressed to HCAP-Certified deer hunters, from Deer Alliance HCAP:

It is regrettable that neither the Department of Agriculture, Fisheries & Food nor the Food Safety Authority of Ireland saw fit to consult with the different deer organisations representing organised, licensed, competence-assessed and certified hunters in Ireland before adopting the procedures set out in the new “FCI” framework. The Deer Alliance engaged in discussions with DAFF and FSAI some three years ago but could not obtain support or approval for the “Trained Hunter” module which the Deer Alliance wished to incorporate at that time. The imposition of a FCI requirement at short notice (three days before the 2011-2012 Season opens) and without consultation seems unlikely to yield optimum response or effectiveness. However the Deer Alliance is already considering proposals for a FCI Module to form part of a revised HCAP Programme to be introduced in 2012 (subject to discussions and finalisation of planning for 2012, between now and year-end) and in the meanwhile expects shortly to be offering an add-on module to those hunters who are already HCAP-Certified, being more than 1000 in number.

A number of queries have surfaced in recent weeks concerning the nature of the Deer Alliance Hunter Competence Assessment Programme (HCAP).

Deer Alliance HCAP is an assessment and certification body only. It does not provide training, either in preparation for the HCAP process, or generally. The different deer organisations, including the Irish Deer Society through its various branches, or the Wild Deer Association of Ireland, do provide training both on an ongoing basis, and through pre-HCAP Workshops. IDS and WDAI are participating bodies within the Deer Alliance, and interested persons can get further information on membership and membership benefits from their respective websites, www.irishdeersociety.ie or www.wilddeerireland.com.

The Deer Alliance has published a Stalker Training Manual cost €35.00 including p. & p. Order Forms can be downloaded from the website, www.deeralliance.ie, where further information on the framework and terms of reference of HCAP is also available. Candidates are expected not to rely exclusively on the Stalker Training Manual but to look to the many other sources of information which are available, and on their own experience in the field.

Lyme disease, or ‘Borreliosis‘, is a bacterial infection passed to humans through a tick bite. It is currently the fastest growing vector-borne disease in the world. The bacteria is shaped like a corkscrew (called a spirochete), which enables it to burrow through body tissue which most other bacteria wouldn’t be able to penetrate. This makes Lyme a serious and potentially debilitating disease causing a host of symptoms such as heart and nervous system problems, including palsies (paralysis) and meningitis and if left untreated can cause motor and sensory nerve damage, brain inflammation and/or arthritis.

Lyme Disease is commonly misdiagnosed as other illnesses such as CFS (Chronic Fatigue Syndrome or ME), Multiple Sclerosis and Fibromyalgia. Early diagnosis and treatment is essential to help those infected make a full recovery. If left undetected it can develop into disseminated or late Lyme Disease and can be extremely difficult to eradicate and can cause serious, long term health problems.

Research has shown that ticks collected in the areas of Counties Kerry, Galway, Connemara and Wicklow do carry the borrelia bacteriam therefore people in these areas may be at risk of being bitten by infected ticks. Followers of deer, whether as stalkers, photographers or just as general enthusiasts, should be aware of the threat to health from this source.

For more information, go to www.ticktalkireland.org, or download an information leaflet at www.ticktalkireland.org/lymeleaflet.pdf

Images of an albino Sika hind.

Photographs taken by Paul Clinch in Wicklow, April 2011. Despite her rounded head, this deer is believed to be three to four years old and has been sighted on numerous occasions. She runs with a herd of “ordinary” Sika, with no apparent behavioural difficulties.

With thanks to Paul Clinch.

“Is it Possible to Build Consensus on a National Deer Management Strategy?” is the theme of a conference to be held at the Hodson Bay Hotel, Athlone, Co. Westmeath on Saturday 2 April 2011. Key speakers have been lined up, including Jamie Dick (Queen’s University, Belfast), Peter Watson (The Deer Initiative, UK), Declan Little (Woodlands of Ireland), Jim Walsh (Irish Deer Society), Ciaran Nugent (Forestry Division, Department of Agriculture, Fisheries & Forestry) and Barry Coad (Coillte Teoranta). Liam Nolan, Deer Alliance HCAP, will deliver a paper dealing with issues affecting hunters.

As places are limited, early booking is advised. Further information is available from Robert Henaghan, telephone 086 822 2838 or email, robhenaghan@yahoo.co.uk. Cost is €25.00 per person, to include lunch & refreshments. Cheques (payable to Irish Deer Society) to R. Henaghan, Callocoon, 104 Caiseal Cam, Roscam, Galway, Co. Galway.

A final Deer Alliance HCAP MCQ for 2010 will be held at 8 p.m. on the evening of Wednesday 29 September 2010 at Lynham’s Hotel, Laragh, Co. Wicklow.

This will be followed (for successful candidates) by a Range Test, to be held on Saturday 9 October 2010 at Midland Rifle Range, Blue Ball, Tullamore, Co. Offaly (commencing at 10 a.m.).

The full calendar of HCAP sctivities for 2010 having concluded on 28 August 2010, these additional events are being held primarily to facilitate applications already on hand from candidates previously unable to participate and now needing HCAP Certification in order to obtain Coillte Stalking Permits, in line with the policy adopted by Coillte Teoranta in 2001 and in place since 2005.

Applications for both dates will be accepted from previously failed candidates provided appications to repeat are received immediately.

In any event, the closing date for applications for both events will be first post on Friday 17 September 2010 and under no circumstances will applications received after that date be accepted.

A final list of candidates eligible for the MCQ will be posted here on or about Friday 24 September 2010, and a list of candidates eligible for the Range Test will be posted here on or about Monday 4 October 2010.

The Green Party Bill as promulgated by the Minister for Environment, Heritage and Culture and moved as a Government Bill, was passed by Dail Eireann on 29 June 2010 and will now go to Seanad Eireann for ratification before going to the President for signature and commencement as the Wildlife (Amendment) Act 2010.

The Bill repeals section 26 of the Principal Act which provided for the granting of a licence for staghunting, and has the effect of ending the life of the Ward Union Hunt, which has been the only staghunting pack of hounds in Ireland and which was formed 156 years ago. Section 3 (2) of the Bill effectively bans staghunting on horseback, and provides as follows:

(2) Subject to subsection (3), a person who hunts deer with two or more dogs shall be guilty of an offence.

(a) a licence granted under section 29 of this Act, or
(b) a permission granted under section 42 of this Act.

Section 4 of the Bill also corrects a legal lacuna in firearms licensing provisions introduced in 2009, whereby the requirement for a game licence as part of the firearms certificate was overlooked by the Department of Justice and the Garda Siochana when giving effect to new provisions.

Section 4 provides as follows>

Section 29 (as substituted by section 4 of the Firearms (Firearm Certificates for Non-Residents) Act 2000) of the Principal Act is amended—
(a) in subsection (5)(a), by substituting “Subject to subsection (5A), where”
for “Where”, and
(b) by inserting the following subsection after subsection (5):

(b) This subsection applies to a firearm certificate that is granted—
(i) in respect of a shot-gun, and
(ii) on or after 1 August 2009 but before 1 August 2012.

A further amendment tabled by Deputy Joanna Tuffy, Labour, which would have had the effect of ensuring that female deer could not be shot between May and September of any year under a Section 42 Permission, was not accepted.

The original Bill as drafted would have had the effect of prohibiting the hunting of deer with two or more dogs by ordinary deer hunters but was amended following representations by the Wild Deer Association of Ireland, fully supported by the Irish Deer Society and the Deer Alliance (as previously reported here). WDAI in particular are to be congratulated for their excellent work and sustained lobbying on this issue.

Further to our previous posting on this subject, the statement set out below was issued on 1 June 2010 by Minister of State Michael Finneran in relation to an amendment to the Bill:

“The Wildlife (Amendment) Bill, 2010 was published on 20 April 2010 to give effect to the commitment in the renewed Programme for Government to prohibit the hunting of deer with packs of dogs. The Government decided that this particular hunting practice should cease for animal welfare and public safety reasons. This short Bill also increases the maximum fines for wildlife related offences which were last increased in 2000. This legislation will have no implications for other country pursuits such as fox-hunting, hare-hunting, hare coursing or deer stalking.

It was never the intention that the legislation would place any restriction on lawful deer stalking. Accordingly, the Minister is in consultation with Parliamentary Counsel on an amendment to the Bill to address the fears expressed by these organisations representing deer hunters that the provisions of the Bill will inadvertently affect the legitimate practice of deer stalking. This amendment relates to Section 3 of the Bill”.

(Posted 2 June 2010)

The Deer Alliance, acting in conjunction with the Wild Deer Association of Ireland and the Irish Deer Society, recently made a presentation to the Oireachtas Joint Committee on the Environment, Heritage and Culture in relation to the Wildlife (Amendment) Bill 2010, which is nearing finalisation in the Oireachtas.

Section 3 (2) of the Bill provides that it shall be an offence to hunt deer with two or more dogs.

The Deer Alliance, WDAI and IDS are of the opinion that this provision, if it becomes law, will impact negatively on the practice of deer stalking and on efficient and humane control and management of wild deer, as it will affect situations where dogs can be used to track shot or injured deer, or where dogs are used to drive deer off farmland.

Discussions, which were initiated by WDAI, are ongoing. All Joint Committee members present at the hearing, which took place on Tuesday 25 May 2010, appeared to support the views expressed by the delegation. A full transcript of the proceedings has been made available to the participating deer organisations.