â€˜Bone stocks, pÃ¢tÃ© de tÃªte, rillettes, and of course I want to render lardâ€¦â€™ I listed the products for The Auditor that I was planning to make once the new commercial kitchen was approved.
â€˜Oh, yes, I have a few butchers who want to render lard. You have to do clostridium testing, you know,â€™ she informed me.
â€˜Really? Is there any reason why? You know itâ€™s just melting fat, right? Itâ€™s pretty much the same thing as making rillettes but with no meat, just fatâ€¦â€™
â€˜But itâ€™s rendering, so you have to follow the rendering standard,â€™ she enunciated slowly for me.
â€˜The rendering standard? Is that in the Standard for the Hygienic Processing of Meat and Meat Products?â€™ I asked.
â€˜No, itâ€™s a different standard for rendering products,â€™ and The Auditor showed it to me on her computer.
Further investigation revealed that PrimeSafe treats the simple process of rendering fat from a wholesome carcass into lard in a retail butcherâ€™s shop the same as rendering the fat off a condemned carcass at a rendering plant.
In the Australian Standard for the Hygienic Rendering of Animals and Animal Products (AS5008:2007), the definition of rendering is: â€˜The process of heat treating raw materials to remove moisture and/or liberate fat.â€™
Now thatâ€™s a pretty broad definition, and taken to its logical conclusion, could potentially apply to any cooking process of meat. Bacon, for example, is â€˜heat treatedâ€™ to remove moisture, and while not seeking to liberate fat, I see the freedom-loving slick of it at the bottom of my smoker each fortnight when I make our uncommonly delicious baconâ€¦
Speaking with my colleagues in New South Wales, I quickly learned that this is another area where itâ€™s a bummer to be a Victorian butcher. The New South Wales Food Safety Authority does not interpret rendering lard in a butcherâ€™s shop under the standard written for rendering plants, and no clostridium testing is required for them to make the product. And yet they can sell their lard here in Victoriaâ€¦
I rang a microbiologist at one of Melbourneâ€™s most respected testing laboratories and had a good chat about the science. He was in firm agreement that there is no higher risk of the presence of clostridium perfringens in rendered lard from a wholesome carcass than there is in bacon, ham, pate de tete or rillettes.
So I pulled a Joel Salatin and submitted my product descriptions (on 27 May), but I didnâ€™t call it â€˜rendered lardâ€™, I called it â€˜melted fatâ€™. Heh. They were onto me, and I was knocked back on melting fat. I said Iâ€™d discuss it with the manager at a later date.
I went to America on an #epicfairfoodtour and asked many other butchers, food scientists, and food safety experts their views on the safety of rendering lard. All agreed that the PrimeSafe interpretation was inappropriate.
The Inspector responded to Stuartâ€™s query while I was overseas (24 June) to say there were issues with the product descriptions but she needed to tell me about them as I am the licensed operator of our boning room. He asked whether she could put it in writing as I was away, but she said she needed to speak with me by phone.
Upon my return, nearly a month after submitting the product descriptions, I emailed The Inspector (26 June) to ask why such a delay in giving feedback on the products. She rang me back shortly after I sent the email and said she tried to ring me while I was in America.
â€˜But you knew I was in America, Inspector, and I donâ€™t answer my phone over there because itâ€™s expensive,â€™ I said. â€˜Couldnâ€™t you have given me the feedback in writing so we could progress this?â€™
â€˜I tried to ring you twice and it hasnâ€™t been a month, Tammi. Itâ€™s complicated so I needed to talk to you on the phone about it,â€™ she said forcefully.
â€˜But surely if itâ€™s complicated you should give it to me in writing so I can understand the requirements and comply?â€™
â€˜Look, you were away and I tried to contact you. And it has not been a month, itâ€™s beenâ€¦â€™
â€˜Right, Inspector, I donâ€™t need your excuses on why you couldnâ€™t respond in a timely fashion. Please just tell me whatâ€™s wrong with the product descriptions,â€™ I blurted out, totally exasperated.
â€˜So you submitted these products but you canâ€™t render lard unless youâ€™re going to do clostridium testingâ€¦
â€˜I took the lard off the list, Inspector, as you told me that before I left. Iâ€™d like to speak to your manager about it, but not right now, so go onâ€¦â€™
â€˜Right, but you didnâ€™t take out two other productsâ€¦ I canâ€™t pronounce themâ€¦â€™
â€˜You mean rillettes and pÃ¢tÃ© de tÃªte? Those arenâ€™t rendered products, theyâ€™re cooked, like any other cooked product. I accept that I have to discuss the rendered lard interpretation, but rillettes and pÃ¢tÃ© de tÃªte are different.â€™
â€˜Iâ€™ve spoken with my manager and she agrees, theyâ€™re rendered products as well and cannot be approved without submitting them for testing.â€™
â€˜Inspector, are you seriously telling me that when I get my carcasses back from the abattoir that PrimeSafe licenses, that the meat on those carcasses is wholesome but the fat no longer is?!â€™ I tried logic.
â€˜Tammi, youâ€™ve had your answer.â€™
â€˜No, I havenâ€™t, actually. Are you saying that the fat on my carcasses is not wholesome when they come back from an abattoir that you licence? And why is bacon okay but not rillettes?â€™
â€˜Bacon is a cooked product. It goes to 65C for a minimum of 10 minutes.â€™
â€˜Inspector, rillettes go much higher than 65C for much longer than 10 minutes. Theyâ€™re also a cooked product.â€™
â€˜Tammi, youâ€™ve had your answer.â€™
Gah. Lost that round, but not to logic or science, to pedantry and power.
â€˜What else, Inspector?’
â€˜Well, Iâ€™m not clear on your single-muscle cures about the acceptable range for humidity. Youâ€™ve put 65 to 85% relative humidity but whatâ€™s the allowance? How far below 65% is allowed?â€™
â€˜Thereâ€™s no allowance below 65%, Inspector. Thatâ€™s the range â€“ 65 to 85%.â€™
â€˜Well, itâ€™s not clear. I need you to write that as 75% plus or minus 10%.â€™
â€˜You realize thatâ€™s the same thing, right, Inspector? 65 to 85% is 75 plus or minus 10.â€™
â€˜But itâ€™s not clear, Tammi. You need to write it as 75 plus or minus 10.â€™
Gah. â€˜Okay, Inspector, if I must write it that way to get these products approved I will.â€™
When I submitted the minor revisions to our product descriptions (I also needed to include more detail on the weights of my single-muscle cures in the batch sheets), I took rillettes off the list, but left pÃ¢tÃ© de tÃªte. In my covering email I wrote:
â€˜Note that I have deleted rillette from the products until such time as I can discuss the rendering standard and its application to a cooked product such as rillette with The Manager. However, I have left pÃ¢tÃ© de tÃªte included as it is a boiled product not unlike a stock, not something anyone would define as ‘rendered’. I will await further advice before commencing production of this product.’
We received the following approval a week later (23 July):
â€˜Following conformation the humidifier has been installed as per the requirements of AS4696:2007, and the submission of the HACCP based procedures submitted 3 July 2015, PrimeSafe approves the manufacture of the following products atÂ Jonai Farms & Meatsmith
1)Â Â Â Â Â Â Â Uncooked Cured Meat Products,
2)Â Â Â Â Â Â Â PÃ¢tÃ© de TÃªte
3)Â Â Â Â Â Â Â Stocks
4)Â Â Â Â Â Â Â Trotters and Ears
Compliance of these procedures will be reviewed at your next scheduled audit with SGS.â€™
And so there it is. We canâ€™t make rillettes or render lard without expensive testing our colleagues elsewhereÂ donâ€™t have to conduct, and given how small our operation is, itâ€™s not financially viable for us to make those products. So if you want liberated fat, Victoria, youâ€™ll need to get it from Big FoodÂ or from interstate.
Read more of The Regulation Diaries…
Part 1: PrimeSafe’s War onÂ Salami Days
Part 3: PrimeSafe’s War onÂ Meat