The management of wild deer in Scotland: Deer Working Group report

Section 11 Wild Venison and Food Safety

1 The cull of over 100,000 wild deer in Scotland each year produces a substantial annual harvest of wild venison. There are no statistics on the actual amount, but it is generally quoted to be around 3,500 tonnes a year. This approximate estimate is based on multiplying the recorded annual cull total for each species by an average ‘larder’ weight for each species.^[1] As red deer make up around half the recorded annual cull and are significantly larger than the other species, red deer account for over 75% of the wild venison produced each year.^[2]

2 Venison is the main income each year from the overall management of wild deer in Scotland, whether that value is through direct use of the carcases by those involved in killing the deer or through selling the venison. As has been long recognised, the availability of commercial outlets for wild venison and the prices paid are key factors in the economics of deer management. Any significant reductions in them (for example, due to food safety concerns) could have important consequences for deer management.^[3]

11.1 Background

3 Commercial markets for wild venison were slow to develop in Scotland during the 20^th century. The management of red deer on open hill range in the Highlands produced significant quantities of venison, for example, an estimated 800 tonnes a year in the 1930s.^[4] However, many estates did not regard the carcases as a potential commercial asset, but simply as a by-product of managing the deer for sport and paid little attention to the quality of any carcases they might sell to a venison dealer.

4 In the 1950s and 1960s, there were significant improvements in the prices paid for venison due to the start of exports. The Red Deer Commission (RDC), established in 1959, hoped that the price increases would result in improvements in the management of red deer based on an approach that was more focused on the production of venison.^[5]

5 The main consequence of the price increases, however, was to stimulate the beginning of the pioneering Scottish research into red deer in the 1960s that led to the start of deer farming in Scotland.^[6] Venison from farmed red deer is now a major component of the retail market for venison in the UK and elsewhere. However, much of the farmed venison consumed in the UK is imported, mainly from New Zealand.^[7]

6 The amount of farmed venison currently produced in Scotland is relatively small. Farmed deer are managed as agricultural livestock and agricultural census statistics show that the number of deer kept on farms in Scotland increased between 2008-18 from around 6,000 to around 9,500.^[8] The total annual production of farmed venison in Scotland was estimated to be around 70 tonnes in 2018 compared to the estimated 3,500 tonnes of wild venison.^[9]

7 While deer farming developed in the 1970s and 1980s, there continued to be an export market from Scotland to Europe for wild venison. That market accounted for around 80% of Scotland’s wild venison supply at the end of the 1980s and, at that time, getting a better price for their venison was seen as one of the main reasons for estate owners deciding to form a Deer Management Group together.^[10] There also started to be an increasing number of initiatives from that time, aimed at improving the condition of carcases for sale and developing home markets in Scotland to reduce the vagaries of relying so heavily on the export market.

8 Progress since has resulted in the development of the Scottish Quality Wild Venison (SQWV) quality assurance scheme.^[11] Forestry and Land Scotland (FLS) and Scottish Natural Heritage (SNH) are both members of the scheme for their venison production, along with an increasing number of private estates and others producing significant quantities of venison from red deer each year. FLS is generally credited with setting the benchmark for standards of traceability and carcase handling.

9 Both FLS and SNH have provided financial support to the SQWV scheme, which is now considered to cover approximately half of the weight of wild venison produced in Scotland each year.^[12] FLS and SNH have also provided financial support to help develop the Scottish Venison Association (SVA), which plays a significant role in developing the marketing for both wild and farmed Scottish venison.^[13]

10 The Scottish Government has a clear interest in promoting the market for Scottish venison, both as Scotland’s largest producer of wild venison through FLS and to support the scale of the wider annual harvest required each year as an essential part of managing Scotland’s wild deer. Venison is also a Scottish product with many positive dietary attributes.^[14]

11 Currently, about two thirds of the estimated 3,500 tonnes of Scottish wild and farmed venison is used in the UK and one third exported to EU countries (mainly Germany, Belgium and Holland), with around 1,200 tonnes of farmed venison imported to the UK each year (mainly from New Zealand, Poland and Ireland).^[15]

12 With venison seen as a growing market, the Scottish Government and venison processors and producers are keen to see that Scottish venison benefits from the potential opportunities. In 2018, as parts of its support for the venison market, the Scottish Government took forward proposals to register the name “Scottish Wild Venison” as a ‘Protected Geographical Indicator’ under EU quality schemes for agricultural products and foodstuffs.^[16]

13 The Scottish Government also held a ‘Venison Summit’ in March 2018 to focus attention on promoting markets for Scottish venison and to integrate venison into the Government’s strategic goals for Scotland’s food and drink sector, ‘Ambition 2030’.^[17] This resulted in the establishment of a Scottish Venison Strategy Working Group with membership from public and private sectors.

14 In September 2018, the Strategy Working Group published its report ‘Beyond the Glen, A strategy for the Scottish Venison Sector to 2030’.^[18] The aim is to increase the deer farming sector in Scotland significantly, with annual production increasing from 100 tonnes to 850 tonnes by 2030, as a result of increasing the annual harvest from 1,700 to 15,000 animals.^[19] While no increase is anticipated in the production of wild venison, the aim is to improve the market return by increasing the amount of wild venison sold in value added products.

15 At the same time as these developments, however, there have continued to be serious concerns over wild venison and food safety standards following the E.coli outbreak in processed wild venison in 2015.^[20] Food Standards Scotland (FSS) has established through its inspection programmes that there are serious non-compliances and concerns around food safety and traceability systems in the venison and game meat sector.^[21] FSS has therefore drawn attention to a number of steps that it could take if there are not improvements made to the poor working practice currently evident.

16 The SVA and SQWV fully recognise the need for zero tolerance for poor practice as “another food scare associated with venison would have highly serious consequences”.^[22] One of their responses to the situation has been, for example, to produce three new videos with SNH for the Wild Deer Best Practice guidance on handling carcases to appropriate standards after they have been shot. The competence of those shooting deer in that and other respects, was considered earlier in Section 8 of this Report.

11.2 Venison Dealers’ Records

17 There has been a relationship between Scotland’s deer legislation and the licensing of venison dealers since the Sale of Venison (Scotland) Act 1968. That short, four section Act introduced two measures:

• Firstly, in s.1, the requirement for each Local Authority (counties and large burghs) to establish a register of the persons in their area authorised to deal in venison (i.e. selling or offering for sale the carcase or any edible part of the carcase of a deer lawfully killed or taken). Section 1 also required each Local Authority to send the RDC every year on the 1^st January, a list of those in their area registered as venison dealers.
• Secondly, in s.2, the requirement for venison dealers to keep ‘a book’ in which they recorded all their purchases and receipts of venison in a prescribed form including the sex and species of deer. Section 2 also required venison dealers to keep their records for at least three years and to make available their records for inspection by any person acting under the authority of the Secretary of State or the RDC.

18 The 1968 Act was repealed by the Deer (Amendment) (Scotland) Act 1982, when s.11 of that Act amended the Deer (Scotland) Act 1959 to incorporate a new Part IIIA with the cross-heading ‘Licensing of dealing in venison’. In the new Part, ss.25A-25F elaborated on the requirements in the 1968 Act, while retaining the requirement for Local Authorities to send the RDC a list of dealers each 1st January and the authority of the RDC to inspect venison dealers’ records.^[23]

19 The 1982 Act was then followed by The Licensing of Venison Dealers (Prescribed Forms etc.) (Scotland) Order 1984 under s.25B of the 1959 Act. This provided for the first time a prescribed template for the information to be recorded by dealers, as the power to do this by Order in the 1968 Act had not been used.

20 The 1984 Order remains in force and the Group considers that aspects of the information required in the prescribed form are no longer adequate for contemporary circumstances. In particular, given concerns over standards of food safety and traceability, there is a need for significantly improved information on the form about the source of the venison recorded on it. The Group considers that FSS should have a lead role in re-designing the form for contemporary circumstances.^[24]

21 The Working Group recommends that The Licensing of Venison Dealers (Prescribed Forms etc.) (Scotland) Order 1984 should be replaced by a new Order that requires clearer and more robust information on the prescribed form about the source of any purchases or receipts of wild venison.

22 When the Deer (Scotland) Act 1996 came into force, ss.33-36 under the cross-heading ‘Licensing of dealing in venison’ carried forward the provisions in the 1959 Act with little change other than their formatting in the Act. The requirement to send a list of dealers each year continued with the Deer Commission for Scotland (DCS), as did the authority for the DCS to inspect dealers’ records, and this has remained the case since SNH took over from the DCS in 2010.

23 SNH has continued occasionally, like the RDC and DCS, to accompany the police to particular dealers to check for evidence of deer that have been unlawfully killed (for example, females out of season without authorisation).^[25] However, unlike its predecessors, SNH has not continued to collate all the venison dealers’ records each year to compare those totals with the cull totals from cull returns as part of understanding the market in venison.

11.3 Cull Returns and Dealers’ Records

24 The RDC started collating dealers’ records in 1970 following the 1968 Act, and from 1973 published both cull return and venison dealer totals for red deer. The results available from then until SNH took over in 2010 cover the two periods 1973-1990 and 1997-2009, as shown in Figure 24 (a table showing the underlying data can be found in Annex 8).^[26] The figures over the two periods reflect a very significant change in the use made of the carcases from the annual culls.

25 During the 1973-90 period, the venison dealers’ totals for red deer were usually higher than those recorded from cull returns (13 out of 18 years). During that period, the RDC estimated that properties were retaining about eight per cent of their red deer carcases for their own use (c.2,000-3,750 deer). The RDC considered that the venison dealers’ totals still tended to be higher despite that allowance due to carcases sold to dealers by owners and occupiers not making cull returns.^[27]

26 However, by the end of the 1973-90 period, a trend was already starting to emerge where the red deer cull return totals were higher than those from the venison dealers. By the end of the subsequent 1997-2009 period, the red deer cull return totals tended to be over 30% greater than the totals from venison dealers. The difference was around 20,000 red deer carcases a year.

27 During the 1997-2009 period, the trend was the same for roe deer, with the cull return totals of c.30,000-32,000 being up to 30% greater than the venison dealer totals in the later years, a difference of around 8,000-10,000 carcases a year.^[28] It is also reported that, while this trend was not apparent for sika and fallow, both species showed a fairly consistent pattern during 1997-2009 with the cull return totals around 38% greater than the venison dealers’ records. This indicated that, based on the average recorded annual culls of c.5,000 for sika and c.1,374 for fallow, another 1,900 and 500 carcases respectively per year were not going to venison dealers.^[29]

28 A number of factors could have resulted in some under-recording of the number of carcases going to dealers.^[30] The actual total culls will also have been higher because a significant number of the deer shot in Scotland each year are not recorded in the cull return system.^[31] However, the totals in the paragraphs above give a clear indication that, by 2009, over 30,000 deer carcases a year were potentially being retained by producers for their own or local use rather than supplied to venison dealers.

29 While some carcases have always been retained by owners, occupiers and hunters for their own and local consumption, the scale of increase shown in Figure 24 appears to reflect a significant change in the venison market towards more sales to local outlets (including hotels and restaurants).

30 Key factors in this change are considered to have been the relatively low venison prices available from dealers, the improved availability of local outlets for venison and the derogation under EU game meat regulations from 2004 allowing direct sales of venison in-fur (i.e. in-skin) locally.^[32] This exempted from the requirements of the meat regulations “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”.^[33]

31 In this definition, ‘small quantities’ is “regarded as self-defining because demand for in-fur or in-feather carcases from final consumers and local retailers is limited”.^[34] The use of ‘local’ refers to the premises or game larder where a hunter prepares the venison for supply to local retailers rather than where a deer was shot.

32 The meaning of ‘local’ is regarded as “within the supplying establishment’s own county plus the greater of either the neighbouring county or counties or 50km/30miles from the boundary of the supplying establishment’s county”.^[35] In Scotland, the very large size of many of its rural Local Authority areas compared to most European countries, means the interpretation of ‘local’ can potentially cover very large distances.

33 The increase in retained carcases recorded up to 2009 suggest the development of a significant market for the local consumption of wild venison in Scotland. At the time, an industry review of Scottish venison in 2010 reported that venison dealers recognised the increasing trend of greater carcase retention and that “This was viewed by the game dealers as an area where hygiene or quality failure could easily occur with the consequence that it could damage the industry in the eyes of the consumer – a bad outbreak of food poisoning for instance”.^[36],

34 The development of local markets for wild venison for local consumption appears to have been on a very significant scale during the last 20-30 years. There seems to be no account of that development, but it occurred during a period when the amount of Scottish venison being exported was declining. As noted previously in this Section, around 80% of all Scottish venison was exported in 1990, while this had declined to around 60% by 2001 and appears to have continued on a downward trend since then towards the current one third of Scottish venison.

11.4 Current Position

35 As described above, SNH has not collated the total numbers of deer carcases going to venison dealers in any year since it took over in 2010. The Group also learnt from SNH that it was not receiving the annual lists of dealers from all Local Authorities, and that Local Authorities are required to supply these to SNH under s.33(6) of the 1996 Deer Act. SNH was also not following this up with Local Authorities until the information was requested by the Group.

36 The Group recognises that SNH is already supporting the wild venison market as described above, because of its significance for deer management. However, the Group considers that SNH should also be using its powers in relation to venison dealers’ records as part of developing a clearer understanding of the market.

37 Figure 25 shows the distribution of the 178 licensed venison dealers in Scotland in early 2018, and Figure 26 shows the number in each Local Authority area. This total compares, for example, with the total of c.120 in 1990 at an early stage in the change described above to a reduced proportion of the annual culls going to venison dealers.^[37]

38 In 1990, the great majority of 120 dealers were relatively small scale with three main dealers accounting for 75-80% of the carcases supplied to dealers.^[38] The current pattern might be considered similar. In 2018, 12 of the 178 licensed venison dealers were Approved Game Handling Establishments (AGHEs), while over half the overall total consisted of private estates (78), FLS (15) and SNH (2) properties. The remaining dealers were retail butchers (23), farm shop and food retailers (18) and individuals (30).^[39]

39 There is, however, no information available on the number of wild deer carcases processed each year by venison dealers and, as discussed further below, SNH experienced difficulty in trying to obtain this throughput data from some of the main dealers. The most recent information on throughput is therefore from 2009. The total recorded annual cull remains still broadly similar to then at 100,000+ and, at this stage, there also appears no particular reason to suppose that the respective proportions of the annual cull retained for local use or sold to venison dealers have changed significantly in the last 10 years.

40 While the Group recognises the limited quality of the information available to it, the implication is that a substantial proportion of the annual cull continues to be retained for home or local consumption. This might be estimated to be 25,000 or more carcases each year from the previous records and indicates that around a quarter or more of the total cull is being used for local consumption under the EU derogation and thus outwith the EU game meat regulations and requirements.

41 That rate of local consumption appears low compared to some other European countries.^[40] However, the Group considers that the increased level of local consumption in Scotland has many attributes that are in the public interest if the food is safe (for example: potentially a better price for suppliers; added value retained locally in rural areas; healthy type of meat; local produce for residents and visitors; potentially lower carbon footprint than livestock meat; fewer travel miles, etc.).

Figure 26 Estimated number of venison dealers in Scotland by Local Authority area (2018)

Local Authority	Licensed Dealers
Aberdeen City	0
Aberdeenshire	10
Angus	6
Argyll & Bute	28
Clackmannanshire	0
Dumfries & Galloway	14
Dundee City	1
East Ayrshire	2
East Dunbartonshire	0
East Lothian	5
East Renfrewshire	0
Edinburgh City	1
Falkirk	0
Fife	6
Glasgow City	0
Highland	57
Inverclyde	0
Midlothian	0
Moray	3
North Ayrshire	3
North Lanarkshire	2
Orkney Islands	0
Perth & Kinross	13
Renfrewshire	0
Scottish Borders	5
Shetland Islands	0
South Ayrshire	1
South Lanarkshire	3
Stirling	7
West Dunbartonshire	0
West Lothian	3
Western Isles	8
Total	178

Source: SNH

42 The Group recognises that there may be some additional information available on aspects of the venison market. However, the Group considers that there appears to be an overall lack of clarity about the use of the carcases of the 100,000+ wild deer shot in Scotland each year and the extent of local consumption as part of that. A key concern is the issue of food safety whether the venison goes to dealers or is used for local consumption. The increases in the ranges and numbers of wild deer are potentially a factor in this by increasing the number and distribution of deer hunters.

43 SNH does not have any statutory responsibilities for food safety or the regulation of venison dealers. However, as discussed further below, the Group considers that SNH should have for its responsibilities in the deer-venison equation under the deer legislation, a much clearer picture than at present of the use of the carcases of wild deer.

44 Markets for venison are key to underpinning the annual cull of deer required in Scotland each year. The Group considers that SNH should therefore ensure that Local Authorities fulfil the requirement under s.33(6) in the 1996 Act to supply it annually with a list of current licensed venison dealers. The Local Authority area-based list of dealers could be made publicly available for use by deer hunters and others.

45 The Group considers that SNH should monitor the distribution and capacity of dealers in relation to the information that it has on the distribution of annual culls. This could indicate areas where there may be difficulty in disposing of carcases for those carrying out culls, due to the lack of dealers or adequate carcase chilling or lardering facilities. This may particularly be the case in areas where the need for deer control is relatively new and expanding.

46 A lack of adequate chilling or lardering facilities for deer hunters to use is considered to be the case in parts of the Central Belt.^[41] As a result, SNH has been given a lead role in helping to develop cooperatively owned chilling or lardering facilities in appropriate areas as part of implementing the public/private strategy for venison mentioned above.^[42]

47 The Group considers that SNH should also be making more use of its authority under s.34(2) of the Act to inspect venison dealers’ records. The Group consider that SNH should be in a position to collate the overall total of carcases going to dealers either annually or on a regular basis. This would give information on the capacity of current dealers, while enabling SNH to identify the proportion of the annual reported cull that does not go to venison dealers as part of understanding the scale of local consumption.

48 The collation of venison dealers’ records should be substantially easier than in past decades, as it is anticipated that all or nearly all dealers will keep computerised records. It might be noted that, while s.34(1) of the 1996 Act still requires dealers to keep a ‘book’ in which records should be entered as in the 1968 Act, s.36 refers to “book or document” and a document is interpreted in legislation as meaning “anything in which information is recorded in any form”.^[43]

49 SNH did not find it easy, however, when it approached seven main venison dealers in 2018 to obtain summary carcase throughput data for 2016/17 and 2017/18.^[44] Not all the dealers responded, perhaps recognising that it is not a requirement in the deer legislation to do so. With those that responded, “The format in which the information was provided and the level of detail within it, varied between each respondent. Two of the respondents provided information in the form required of The Licensing of Venison Dealers (Prescribed Forms, etc.) (Scotland) Order 1984, but even here the recording format varied between the two. ”^[45]

50 The nature of the responses SNH received meant that summarising the carcase data was “extremely labour intensive” and restricted the value of combining the different data sets.^[46] The Group considers that, while SNH can inspect a dealer’s record and, under s.34(4), take copies of “any book or document”, SNH should also be able to require a ‘summary carcase return’ from venison dealers that summarises the dealer’s throughput of wild deer carcases for a particular year.

51 The Group considers that an amendment to s.34 to provide the authority to require a summary carcase return, could use an approach similar to that used for SNH’s existing power to require a cull return. SNH or other persons with the authority in s.34(2) would serve a notice on a venison dealer requiring a ‘carcase return’ recording the species, numbers and sexes of the deer carcases in their records in a specified period of up to three years.

52 At present, under s.34(5) of the 1996 Act dealers are required to keep their records available for inspection for three years after the last entry in a previous ‘book’, while three years is also the current period for which venison dealers licences can be valid under s.33(4). The format in which a return is to be submitted should also be set out clearly in amending s.34. This might be achieved through secondary legislation, as the current prescribed form Order discussed above does for individual carcases. This should also make a clear distinction between carcases that were first recorded by a dealer, and any carcases they might purchase from another dealer that have already been recorded.

53 The availability of annual totals from venison dealers would clarify the scale of the local consumption that does not go through dealers. The Group considers that both SNH and FSS have an interest in understanding that pattern of direct use and sale more clearly.

54 For SNH, improved understanding of local consumption would enable it to improve its support for that sector of the overall venison market. SNH already makes a significant contribution to promoting the venison market because of its importance to deer management. However, for understandable reasons, it might be considered that SNH’s support has been largely focused on larger scale producers and wider markets.

55 The Working Group recommends that section 34 of the Deer (Scotland) Act 1996 should be amended to empower those with the authority under that section, to require a licensed venison dealer to submit a return summarising their throughput of wild deer carcases during a period not exceeding three years and in a form to be prescribed.

56 The Group considers that maintaining the requirement for venison dealers to be licensed is an important component ensuring appropriate standards of food safety and traceability for venison. However, ss.33-36 in the 1996 Act that cover the “licensing of dealing in venison” are little different from the provisions in the original Sale of Venison (Scotland) Act 1968.

57 At the time of the 1968 Act, the reason behind the introduction of licensing was to help control poaching and other unlawful killing of wild deer, including killing them out of season following the introduction of close seasons for red deer in 1963 and other deer species in 1966. The priority now is food safety.

58 Those in s.34(2) that have the authority to inspect venison dealers’ records are the Secretary of State (i.e. Scottish Ministers), SNH or a person acting with their authority. While SNH is included as the RDC’s successor from the 1968 Act, now the key agency to include would be FSS. Similarly, while licensing dealers in the deer legislation because of its origins, it might now be expected to be in food safety legislation.

59 FSS has taken an active interest in wild venison and food safety as described earlier, and the Group considers that FSS should be empowered by amending the existing legislation to have a national role overseeing the separate licensing of dealers by each Local Authority. More generally, the Group considers that the Scottish Government should ask FSS to lead a review of the current provisions in ss.33-36 of the 1996 Act and recommend changes to ensure the arrangements are fit for purpose in contemporary circumstances.

60 The Working Group recommends that the Scottish Government should review sections 33-36 of the Deer (Scotland) Act 1996 that cover the licensing of dealing in venison, with a view to making changes in addition to the related recommendations in this Report, so that the arrangements are fit for purpose in contemporary circumstances.

61 As described earlier here, a significant proportion of the annual harvest of wild venison does not go through venison dealers and the Group regards the apparent growth of the this ‘local consumption’ sector over recent decades as potentially a very positive development in the venison market because of the local benefits it brings. The Group therefore considers the ‘local’ derogation from EU game meat regulations very important for the scope it provides. However, there is also a need for better information to improve traceability and accountability in the use of carcases in the local consumption sector.

62 The Group considers that a valuable step in that direction would be to include a question on the use of carcases in the existing cull returns that SNH can require under s.40 of the 1996 Act, of the species, numbers and sexes of deer culled on properties. The columns for each species and sex could, for example, be extended to give three or four options for the use or uses made of the carcases of the deer shot.^[47]

63 The Group considers that including the use of carcases in cull returns would be an important improvement in the information available. The collated information could be compared with the venison dealer totals nationally, as well as regionally and more locally, while providing an improved chain for traceability and accountability in the interests of food safety.^[48]

64 SNH could currently start to include the question on the use of carcases on its cull return forms. While s.40 only requires owners and occupiers to state the species, numbers and sexes of deer killed, SNH already includes other questions where answers would be considered voluntary. However, the Group considers that this question should be put on a statutory basis by amending s.40. The need for SNH to increase the geographic coverage of its use of cull returns for a range of significant reasons is discussed later in Section 21 of this Report.

65 The Working Group recommends that section of 40 of the Deer (Scotland) Act 1996 dealing with cull returns should be amended by inserting ‘and the use of the carcases’ at the end of sub-section 40(1).

66 An important additional aspect of ensuring high standards of food safety with wild venison, is the Trained Hunter status introduced by the EU game meat regulations and required under them for supplying venison to AGHEs. Enforcement of this requirement was one of the priority actions identified by SNH in its review under s.17B of the 1996 Act, of the competence of persons killing deer in Scotland.^[49] Enforcement of the requirement is not SNH’s responsibility.

67 The Working Group recommends that the Scottish Government should ensure that the requirement for those supplying venison to Approved Game Handling Establishments to be able to demonstrate Trained Hunter status under EU regulations is enforced.

68 As discussed in Section 8 of this Report, attaining Deer Stalking Certificate Level 1 (DSC1) provides Trained Hunter status. The Group’s recommendation that everyone shooting wild deer in Scotland should be required to attain DSC1 would ensure that those shooting deer for local consumption would also have Trained Hunter status.

Footnotes

1 Ashwood Management Services (2010). Scottish Venison: An Industry Review. The review, for example, used the average mean weights for each species used by Forest Enterprise Scotland at the time: red 47 kg; roe 12 kg; sika 24 kg; fallow 22kg.

2 Applying the above weights to the 2017/18 SNH cull statistics totals: red 2,850 tonnes; roe 500 tonnes; sika 150 tonnes; fallow 50 tonnes. A total of 3,550 tonnes.

3 The food safety issue from the use of lead ammunition is considered in Section 4.

4 Callander, R. and MacKenzie, N. (1991). The Management of Wild Red Deer in Scotland. Rural Forum, Scotland.

5 Callander and MacKenzie (1991), Op cit.

6 Callander and MacKenzie (1991), Op cit.

7 Scottish Government (2018). Briefing for the Government’s Venison Summit, 6 March.

8 See Section 12.

9 Scottish Government (2018) Op cit.

10 Callander and MacKenzie (1991) Op cit.

11 SQWV is run by an independent company overseeing the standards required by the quality assurance scheme.

12 Stated in a promotional video on the SQWV website.

13 The Scottish Venison Partnership became the Scottish Venison Association in April 2019.

14 For example, Food and Health Innovation Service (2015), ‘What’s hot in health – let’s talk venison’.

15 Scottish Government (2018) Op cit.

16 SG consultation paper (March 2018).

17 Scotland Food and Drink (2018a). Ambition 2030: A growth strategy for farming, fishing, food and drink.

18 Scotland Food and Drink (2018b). Beyond the Glen: A strategy for the Scottish Venison Sector to 2030.

19 Scotland Food and Drink (2018b) Op cit.

20 Scottish Venison Partnership, ‘Scottish Venison Report’, in ADMG Newsletter, Winter 2017/18.

21 SNH Strategic Deer Group, ‘Venison Production and Food Safety Concerns’, 8 May 2018.

22 Scottish Venison Partnership, Op cit.

23 In ss.25A and B respectively.

24 The information might include, for example: the property on which it was shot; the identity of the owner or occupier of the property; the identity of the supplier, if not the owner or occupier; and whether they have Trained Hunter status.

25 For example, SNH reported visiting some dealers with the police in 2017 (DWG meeting with SNH, 13 March 2018).

26 While some information is available for the blank years, the totals were not sufficiently clear for inclusion.

27 Callander and MacKenzie (1991) Op cit.

28 Ashwood Management Services (2010), Op cit.

29 Ashwood Management Services (2010), Op cit.

30 Daniels, M. (2007). Estimate of number of deer shot that do not go through game dealers. Deer Commission for Scotland.

31 See Section 2.

32 Regulation (EC) No. 853/2004.

33 Food Standards Agency (FSA) and Food Standards Scotland (FSS) (2015). The Wild Game Guide, Revision November 2015, p.11.

34 FSA and FSS (2015), Op cit, p.12.

35 FSA and FSS (2015), Op cit, p.12.

36 Ashwood Management Services (2010) Op cit, p.30.

37 However, the only E.coli issue to date has been at an Approved Game Handling Establishment, rather than in the local retention sector.

38 Callander and MacKenzie (1991) Op cit.

39 Callander and MacKenzie (1991) Op cit.

40 SNH Information Response 54.

41 Ashwood Management Services (2010) Op cit. In Scandinavia, 80% of carcases are considered to be used directly by hunters and 20% sold commercially.

42 Lowland Deer Panel Report to Scottish Natural Heritage, February 2019.

43 Scotland Food and Drink (2018b) Op cit.

44 Interpretation and Legislative Reform (Scotland) Act 2010.

45 SNH Information Response 54.

46 SNH Information Response 54.

47 SNH Information Response 54.

48 For example: (a) carcase not used in human food chain (e.g. not extracted or for some reason not fit for human consumption); (b) own consumption; (c) direct sale in the local area; and (d) sale to a venison dealer.

49 In the past, discussions about improving the traceability of carcases have include the suggestion of introducing a universal carcase tagging scheme. The Group considered that possibility, but considered that such a scheme would neither be a realistic or proportionate proposal as things stand with deer management in Scotland.

50 SNH (2016). Draft Review of Competence.