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12TH January 2009 Eric Poudelet
SANCO, Directorate E Safety of the Food Chain
E2 Hygiene and Control Measures,
European Commission
B-1049 Brussels, Belgium
Dear Mr Poudelet
I am not sure if you are still in this post or whether I should be addressing this letter to Tom Golden or to Ron Dwinger. If that is the case I would be very grateful if you would pass this letter on to the appropriate person.
In any case I write as the president of the Federation of European Deer Farmers’ Associations (FEDFA) to highlight our concerns as to the feasibility of implementing what we understand may be the requirement for a veterinary surgeon to be present when farmed deer are killed in the field by free bullet (originally Regulation (EC) No 853/2004 (Annex III, Section III:Meat of Farmed Game), 3 (j).
As you may remember this issue was taken up by my predecessors when it was first proposed and the requirement was relaxed at the last minute in December 2005.
Markos Kyprianou at that time told us to start lobbying in plenty of time before the Regulation was to be revised in 2009 and this we attempted to do by meeting Tom Golden first in March 2006 and again in March 2007 when we proposed that all deer killed by free bullet be considered as wild deer which seemed a simple way of resolving the problem.
In June 2007 you wrote to us (SANCO/E2/RD/mb/D(2007) 520523) to say that this solution was not acceptable but that you believed you had found an alternative solution to resolve the problem. Dr John Fletcher replied to your letter on 3rd July 2007 welcoming this and asking how we could help progress things.
We are now however having several member states who are represented on FEDFA contacting us to say that it is not possible to implement this requirement for the following reasons: it is too time consuming for the vet to have to spend several hours awaiting the shooting of a very small number of deer; it is dangerous for the vet to have to sit in a small vehicle such as an agricultural tractor with a marksman with a loaded rifle; the presence of the vet distracts the marksman potentially compromising the welfare of the deer. It has also been explained to us that the object of bleeding is to ensure death and given that farmed deer are head shot with a full bore rifle which ablates the brain the deer are already dead and are never stunned.
This issue is the single most important to European deer farmers and if the relaxation is taken away it would cause major problems for the deer industry.
FEDFA is having its spring meeting in Brussels March 24-25th and if it was thought helpful we would be happy to meet and discuss this further. If it is possible to arrange a meeting please let me know so that we can adjust our program according to the time for such a meeting.
Yours sincerely
Rolf Eriksson
President of FEDFA
Backahojden 63, Igelfors
SE-612 95 FINSPANG
SWEDEN
+46 (0)705 94 04 48
Office:
Rolf Eriksson, Backahojden 63, Igelfors, SE-61295 FINSPANG, SWEDEN