"TRAINED HUNTERS" AND FOOD CHAIN INFORMATION REQUIREMENTS

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.