Beekeeper food processing registration

[itma]

link as requested:

https://docs.google.com/viewer?a=v&...u9mNF_&sig=AHIEtbQeGKkRHuDqDh_R_VDfwSzWVCOG7A

or just search for "a safe start for food businesses.pdf"

Thanks, but that one really raises more problems than it solves.
Says registration is not required for "The premises is a domestic property where ... Honey is prepared and bottled (but not sold to the public)" -- and since its a non-definitive explanation and not legally constructed, I wonder if it actually just means that registration isn't required if no honey at all is going to be sold to the public.

Seems from *that* document that if you register as a "food premise", then you also have to separately register for Health and Safety, must display the Health and Safety law poster, must display a specific 'No Smoking' sign "prominently" near the entrance, get Employers Liability Insurance and display the certificate, have your gas formally signed off once every year, register with HMRC.... Oh, and then it raises the question of disposal of "Trade Waste" - mustn't put anything 'trade' in with domestic refuse for collection!

I can't believe that hobby beeks usually jump through all those hoops.
Asked around at the last association meeting and nobody there (not a big group, but some with 10+ hives) had registered ...

Incidentally, there most definitely IS an exemption from registration for premises used as 'food premises' for less than 5 days in any 5 week period.
That is helpful, until it is recognised that food (honey) storage and selling counts as 'use' of the premises.

People who run a food business for five days or more in any five consecutive weeks, which involves storing, selling, distributing or preparing food, need to register as food premises.

http://www.medway.gov.uk/environmen...safetyservice/registrationoffoodpremises.aspx

So one route would be to limit one's home processing (extraction/bottling) to 5 days in any five weeks, and to store product elsewhere in registered premises (or in a private car - another exemption from registration/inspection! IIRC. Anyway, that is going to open up car insurance questions "in connection with any trade" etc ... )

 

[Rosti]

As with Baggyone & Veg, I am registered with my local food safety team. Painless, cost free and no complications (to date)

None of us produce honey with the intent of causing others a problem, but what if someone who purchases your honey see's you as an opportunity to 'make money' via a claim of some kind? Why wouldn't you register and ensure that within reason you have your local Food Safety team in your camp?
Hope for the best, plan for the worst.

 

[Baggyone]

Hi Baggy. I have my visit next Wednesday. Can you let me know what sort of questions you got asked? Did you provide a cleaning rota? Did they check the cleanliness of the kitchen, fridge etc. in the last throws of doing my kitchen up (painting this weekend). Do they give you a rating at the end?
I also agree with VEG why not register its hood for business as people know they are purchasing from a clean environment.

Has anyone done a food hygiene course on line, it costs about £13.00? I am tempted but do not want to waste my money if it does not add any value.
Jacqui

Food hygiene course is worthwhile as it will answear alot of the questions YOU need to ask of yourself in food prep. My EHO has not done the visit as yet but remember I am the only Beekeeper that is registered. Boston enviromental health dept is very progressive. They currently have no experience of Beekeepers and so are using me as a learning tool and as a way of getting their requirments sorted out.
Yes you should get the food rating if they do an inspection.

Baggy

 

[VEG]

only prob with the food hygiene course is it has nowt to do with honey production, yes the cleaning and so on does but food temps and which cutting board to use isnt much use when extracting honey, it isnt a requirement either. I did mine 3 years ago but wont be doing it again unless it becomes a requirement.

 

[Baggyone]

I call that a very small amount!? Do you sell it all?

The quote was for a single hive, I get more than that, and yes I sell the vast majority of my honey. I will probably only consume 20lb out of the 5 or 6 hundred lb of this years harvest.

Not many butchers shops have the ability to say that the honey on the honey roast ham is possibly from the customers gardens. We sell a lot of it. Traceability is a big issue in the food game (butchers especially) since the last major e-coli outbreak to hit our industry. Do a search on Mason Jones and find out what we face on a day to day basis.

Baggy

 

[richardbees]

the 5 or 6 hundred lb of this years harvest

Bleedin 'ell, Baggy, you're doing well if you see getting that from your 5 colonies.

Three consecutive sunny days have refilled a few of my super frames with nectar, after they ate the Spring honey crop and were fed sugar for a fortnight! I'll be very surprised if I get 10lb /hive as bad weather is forecast for the rest of the month.

 

[Baggyone]

Already have a couple of hundred lb in the tank which i have never had at this time before. ALL my honey has come in July and have'nt had less than 100lb a hive yet. If the weather beats me then thats how it goes.

 

[MartinL]

Any honey I sell, is a by-product of my hobby.
It has many uses, if people choose to eat it then that's their choice!
I for one, will not be registering!

 

[Baggyone]

The problem is MartinL, and I agree with your sentiment, is that a hefty fine could rather knock the shine out of what is a rather lovely hobby. Some EHO are very trigger happy and if they ever looked into it, they could make it a requirement that the BBKA, Bee Farmers and Beebase all declere the databases for their areas. Prohibition notices and all that codswallop.
The problem is as always, the guidelines are vague.

Baggy

 

[MuswellMetro]

we have been through this before so lets go back to the primary legislation rather than local pdf of locoal interpritartion

Registration is voluntary not a requirement for hobby beekeepers extracting and bottleing from home
this is from the 1991 as amended by later legislation

(4) Subject to paragraph 6 of Schedule 3, regulation 2 also does not apply to domestic premises used for the purposes of a food business if—


(a)the proprietor of the business does not reside there, and the business does not consist of or include the peeling of shrimps or prawns;
(b)the proprietor of the business does reside there, but the only commercial operations carried out there in relation to food or food sources are—
(i)the sale of food ancillary to the provision of accommodation in not more than three bedrooms, or
(ii)the sale, or preparation for sale of honey (wherever collected), or of horticultural or viticultural produce harvested on the premises.


full link

http://www.legislation.gov.uk/uksi/1991/2825/regulation/3/made

i have no idea why DR Stitson link says different but i would suggest a mis interpretation by an EHO of small local council

They have a right to inspect but you dont need to register unless you want to or you are not a hobby beekeeper AND/OR do it on commercial premises rated for non domestic buisness rate or run a guest house like PH

 

[Black Comb]

Thanks MM.
First class advice as usual.

 

[psafloyd]

Thanks MM.
First class advice as usual.

 

[MuswellMetro]

Thanks MM.
First class advice as usual.

HOLD I GAVE BAD ADVICE

it has not be updated and parts have been revoked, i will research further

sorry but i did not notice until i looked at it again

 

[MuswellMetro]

HOLD I GAVE BAD ADVICE

it has not be updated and parts have been revoked, i will research further

sorry but i did not notice until i looked at it again

sorry it was repealed when eu reg 852/2004 came in but under EU reg 853/2004 registration is not required for small production

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;

link

http://www.fsai.ie/uploadedFiles/Reg853_2004(1).pdf

and it looks like storage is ok, as honey storage is not dependant on temperature control

2. Without prejudice to Article 6(3) of Regulation (EC)
No 852/2004, establishments handling those products of animal
origin for which Annex III to this Regulation lays down requirements shall not operate unless the competent authority has
approved them in accordance with paragraph 3 of this Article,
with the exception of establishments carrying out only:
(a) primary production;
(b) transport operations;
(c) the storage of products not requiring temperature-controlled
storage conditions;

i did not realise my notes were out of date

 

[MuswellMetro]

The eu Guidance notes confirms Honey production need not reigister

3.2. Establishments handling food of animal origin for which no detailed
requirements are laid down
For certain products of animal origin (e.g. honey), the Regulation does not lay
down detailed rules. In that event, the food of animal origin must be handled in
accordance with the relevant requirements laid down in Regulation (EC) No
852/2004 and also with the general rules for products of animal origin laid down
in Regulation (EC) No 853/2004 (in particular the rules on products from
outside the Community referred to in Article 6).
Since for these products there are no requirements in Annex III of Regulation
(EC) No 853/2004, establishments handling the products need not be approved
nor need they apply an identification mark on the food.


link to €EU guidance notes

http://ec.europa.eu/food/food/biosafety/hygienelegislation/guidance_doc_853-2004_en.pdf

I am still researching, so this is not yet final

 

[mbc]

Does this mean that I can get rid of the pointless little sink and boiler the eho suggested ?

 

[BBG]

Oh for the days at our farm when there were acres of sheds and easily hosed and cleaned concrete and tiles in the dairy and elsewhere.

Oddly we registered for a Hawker's licence to sell ice-cream back then (farm diversity hadn't yet come in).

I'm sure the licence gave the right to cook sausages, make pies and all manner of stuff. Considering the premises weren't that suitable (despite EHO telling me I was too fussy??) it surprised us.

Regs changed dramatically.

 

[Baggyone]

Having read the regulation 853/2004 its clear that honey production is not considered of animal origin and therefore is covered by the different regulation 852-2004. Nice section about honey in there (link http://ec.europa.eu/food/food/biosafety/hygienelegislation/guidance_doc_852-2004_en.pdf
so it defines what we do as primary production so long as it is done on our own premises, do it away from home and you no longer qualify as primary production. How this relates to beekeepers like me who do their extracting at father in laws house cos its just not feasible at home, I'll find out from EHO.
So the golden thing is the statement "small quantities" and this is supposed to be clarified by member states. And once again we have the lack of guidence from government. Why can't they simply say "1000lb and you need to register below that forget it"

Baggy