With concerns about New Zealand’s supermarket duopoly, and a rising consumer preference for ‘local’ , dealing directly with farmers/growers, is it time to review the regulations around on-farm meat processing? Rebecca Flannery reports.
To get an understanding of where we might head with on-farm meat processing, we first need to detour back in history.
Way back in 1998, our rural butchers faced upheaval in the form of the Animal Products Act (APA) in 1999.
It came like a freight train in the night, out of nowhere, and seemingly for no good reason. Note: there has never been a recorded health issue from the consumption of on farm processed meat by a qualified butcher – never.
The APA is New Zealand’s legal framework for processing animal material into food, such as meat and dairy products. It established a risk management system that requires all animal products traded and used to be ‘fit for intended purpose’ through meeting New Zealand animal product standards.
There is also a weird rule around day-to-day care of an animal called the 28-day rule. It goes like this – only animal owners actively engaged in the day-to-day maintenance of an animal, or other animals of the same kind, for at least 28 days immediately preceding slaughter, may engage a listed service provider to kill and process that animal. This applies to cattle, deer, sheep, goats, and pigs.
Rural Butchers are either Homekill Service Providers (HKSP) who are paid to kill and/or process unregulated meat from unlicensed premises such as farms, by the owners of the animals; or they are Dual Operator Butchers (DOB), who as well as providing farm processing services, also operate as a retail butchery, processing/selling regulated meat sourced from licensed premises.
The purpose of the APA was to regulate the production and processing of animal products, and govern the slaughter, processing and sale of food intended for human and animal consumption, irrespective of where in the production or processing chain they occur.
The real issue with the proposed act was that all home kill (on farm processing) was to become illegal, which didn’t seem to serve any real purpose at all.
The alarm was raised, and word spread that home kill may become a thing of the past and would have a negative impact on rural butchers.
Dannevirke butcher John Shannon called a meeting in Pahiatua in 1998 to explain how this was going to affect businesses. The first chair of the group set up in the wake of that meeting, Craig Merrit, says it was clear that help from a national advocacy organisation was needed.
“We decided that we needed to get organised,” Craig says. It was John who contacted Federated Farmers.
This resulted in swift action from Feds and in 1998 the Rural Butchers Industry group was formed.
Craig recalls: “I got the job of chairman and began journeys to Parliament to talk to various members – John Luxton was the Minister of Agriculture, Damien O’Connor the Labour spokesman. We succeeded in getting a few changes in section 6 which allowed us to continue working and also allowing the Dual Butchers to retail regulated meat -and do homekill as well.”
While all this was going on MAF personnel agreed to work together with the new industry group on a Risk Management Plan (RMP) for dual operators.
The selling or trading of unregulated meat is illegal, and Dual Operator Butchers (DOB) must ensure that the regulated and unregulated meat and meat products are kept separated. Both Homekill Service providers and DOBs are now required to be registered on the MPI website.
In a presentation by MPI to the Rural Butchers’ 2022 Conference in Queenstown last month, Senior Advisor Animal Products Mitchell Newcome spoke about the regulatory redesign of the Animal Products Act changes that affect our butchers saying, “At this stage for our DOBs the changes will be limited to terminology, and references.”
Therefore, every time the template refers to a piece of the old legislation, it will need to reflect the new legislation. “An example of this is DOB RMP template – it references the human consumptions specifications and will need to be updated to the appropriate place in the production supply and processing notice.”
Additionally, where MPI have changed terminology and requirements, this will also need to be updated. The way water is considered and dealt with is another good example; MPI don’t refer to potable water any more. “Water is just called water and needs to be fit for its intended purpose. This is achieved by meeting standard water standards and addressing any hazards,” Mitchell said.
Rule 71 of the Animal Products Act states a dual operation cannot be under the same roof.
The logic of various other sections are difficult to follow. For example, you can shoot a wild animal, take it to a butcher and have it “stamped” (inspected by a meat inspector – meaning it can be sold to the public). But you can’t shoot a farmed animal, take it to your butcher, and have it stamped – makes no sense, right?
In a a biosecurity incursion such as FMD, all stock movements stop, all the plants stop processing and the country’s red meat sector stops – with immediate effect.
This raises the question of who’s going to feed the people, and a discussion point at the Rural Butchers Conference was now is as good a time as any to review the on-farm processing rules to allow our rural butchers to safely and legally process farm animals for local sale.
There are lots of reasons to support on farm processing:
- Animal welfare – less stress on the animal at end of life.
- Community – Quality proteins are price prohibitive for many families, on farm processing could help make this more attainable for families.
- Biosecurity – Not moving stock unnecessarily, including under a FMD-type scenario.
Adoption of microprocessors could require a legislative but as it stands a butcher cannot process on farm – stock must travel to an abattoir. That will simply not work if we experience an FMD incursion.
Again, there has never been a reported health issue from the consumption of on farm processed meat by a qualified butcher – never.
The Federated Farmers Rural Butchers industry group is managed by an executive and gets involved as necessary in policy and issues that affect the sector. Rural Butchers also get together every year for a general meeting and conference, and the 2022 event in Queenstown drew around 40 members.
The opportunity to socialise and network is always the highlight, but there was plenty of discussion too on challenges facing the sector.
We visited two amazing operations in Central Otago, and The Grocer gave a fantastic presentation on what real change looks like – readers may recall during the first lockdown Feds advocated fiercely for the butchers, bakers and green grocers to still be able to operate.
Not just a butchery, Jane and the team at The Fridge are about as bespoke as you can get, with a delicatessen and a large range of cheeses, salamis, and condiments. The Fridge also has its own line of goodies, such as spice rubs for meat, and pinot noir onion marmalade.
Last year owner Jayne McMillan grew and processed horseradish, which is not as simple as it sounds. It’s a highly manual process, with all the peel needed to be removed by hand. “It stings your eyes, because when horseradish is cut or shredded it produces a mustard oil called Allyl isothiocyanate,” Jayne told the rural butcher conference delegates.
The Fridge is serious about sustainability. “We’re trying to get down to almost zero organic waste if we can.” Every part of the animal is used, rendering all the fat down for cooking fats, wild bird food and now the local pharmacy is using their fats for soaps, moisturising creams, and hypoallergenic creams. What is left over gets used in pet rolls.
“We welcome our customers to bring their own reusable containers for us to fill. Every little bit to help the environment is fantastic,” Jayne said.
Craig Hamilton of The Grocer gave us an insight into the workings of his business and the re-branding exercise he undertook to meet the first lockdown rules.
His butcher shops rebranded under The Grocer are at Lorneville, Invercargill and Woodlands put special focus on ‘front of house’.
“That’s something butchers don’t traditionally focus on, with investment generally focused on back of house infrastructure like mincers, equipment and trucks,” Craig said.
Today the business includes a bakery, pies, homemade preserves, milk, bread, as well as meat processing, and a big chunk of the business is now on-line.
The Butcher’s Block
Director and co-owner of The Butcher’s Block, Adam Mulholland, showed Queenstown conference delegates around his Wanaka butchery. The Butcher’s Block has been around for over seven years with a firm focus on traditional methods, particularly around the correct ageing of carcasses.
The shop is extremely busy, Adam puts this down to locals who just love the quality “and the customer service and knowledge and our traditional methods, plus our traceability. I think people also like the idea of local food for local people.”
With the current threat of an FMD incursion looming Adam questions current rules around the Animal Products Act. “It says we cannot kill on a farm for a farm and get a stamp.” This means a meat inspector has signed off on the product – which in the event of an incursion is problematic as all transportation of livestock would stop.
“We embrace the concept of paddock–to–plate eating wherever possible, sourcing our meats from fully traceable New Zealand suppliers, predominately Central Otago and Otago farms,” Adam said.