The Regulation Diaries (4): PrimeSafe’s War on Fat

‘Bone stocks, pâté de tête, rillettes, and of course I want to render lard…’ I listed the products for The Auditor that I was planning to make once the new commercial kitchen was approved.

‘Oh, yes, I have a few butchers who want to render lard. You have to do clostridium testing, you know,’ she informed me.

‘Really? Is there any reason why? You know it’s just melting fat, right? It’s pretty much the same thing as making rillettes but with no meat, just fat…’

‘But it’s rendering, so you have to follow the rendering standard,’ she enunciated slowly for me.

‘The rendering standard? Is that in the Standard for the Hygienic Processing of Meat and Meat Products?’ I asked.

‘No, it’s a different standard for rendering products,’ 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 butcher’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: ‘The process of heat treating raw materials to remove moisture and/or liberate fat.’

Now that’s a pretty broad definition, and taken to its logical conclusion, could potentially apply to any cooking process of meat. Bacon, for example, is ‘heat treated’ 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 bacon…

Speaking with my colleagues in New South Wales, I quickly learned that this is another area where it’s a bummer to be a Victorian butcher. The New South Wales Food Safety Authority does not interpret rendering lard in a butcher’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 Victoria…

I rang a microbiologist at one of Melbourne’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 didn’t call it ‘rendered lard’, I called it ‘melted fat’. Heh. They were onto me, and I was knocked back on melting fat. I said I’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 Stuart’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.

‘But you knew I was in America, Inspector, and I don’t answer my phone over there because it’s expensive,’ I said. ‘Couldn’t you have given me the feedback in writing so we could progress this?’

‘I tried to ring you twice and it hasn’t been a month, Tammi. It’s complicated so I needed to talk to you on the phone about it,’ she said forcefully.

‘But surely if it’s complicated you should give it to me in writing so I can understand the requirements and comply?’

‘Look, you were away and I tried to contact you. And it has not been a month, it’s been…’

‘Right, Inspector, I don’t need your excuses on why you couldn’t respond in a timely fashion. Please just tell me what’s wrong with the product descriptions,’ I blurted out, totally exasperated.

‘So you submitted these products but you can’t render lard unless you’re going to do clostridium testing…

‘I took the lard off the list, Inspector, as you told me that before I left. I’d like to speak to your manager about it, but not right now, so go on…’

‘Right, but you didn’t take out two other products… I can’t pronounce them…’

‘You mean rillettes and pâté de tête? Those aren’t rendered products, they’re cooked, like any other cooked product. I accept that I have to discuss the rendered lard interpretation, but rillettes and pâté de tête are different.’

‘I’ve spoken with my manager and she agrees, they’re rendered products as well and cannot be approved without submitting them for testing.’

‘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?!’ I tried logic.

‘Tammi, you’ve had your answer.’

‘No, I haven’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?’

‘Bacon is a cooked product. It goes to 65C for a minimum of 10 minutes.’

‘Inspector, rillettes go much higher than 65C for much longer than 10 minutes. They’re also a cooked product.’

‘Tammi, you’ve had your answer.’

Gah. Lost that round, but not to logic or science, to pedantry and power.

‘What else, Inspector?’

‘Well, I’m not clear on your single-muscle cures about the acceptable range for humidity. You’ve put 65 to 85% relative humidity but what’s the allowance? How far below 65% is allowed?’

‘There’s no allowance below 65%, Inspector. That’s the range – 65 to 85%.’

‘Well, it’s not clear. I need you to write that as 75% plus or minus 10%.’

‘You realize that’s the same thing, right, Inspector? 65 to 85% is 75 plus or minus 10.’

‘But it’s not clear, Tammi. You need to write it as 75 plus or minus 10.’

Gah. ‘Okay, Inspector, if I must write it that way to get these products approved I will.’

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 pâté de tête. In my covering email I wrote:

‘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 pâté de tête 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):

‘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 at Jonai Farms & Meatsmith

1)       Uncooked Cured Meat Products,

2)       Pâté de Tête

3)       Stocks

4)       Trotters and Ears

Compliance of these procedures will be reviewed at your next scheduled audit with SGS.’

And so there it is. We can’t make rillettes or render lard without expensive testing our colleagues elsewhere don’t have to conduct, and given how small our operation is, it’s not financially viable for us to make those products. So if you want liberated fat, Victoria, you’ll need to get it from Big Food or from interstate.

Read more of The Regulation Diaries…

Part 1: PrimeSafe’s War on Salami Days

Part 2: PrimeSafe’s War on Farm Gate Shops

Part 3: PrimeSafe’s War on Meat

Published by

Tammi Jonas

The infrequent and imperfect yet impassioned musings of a farmer, meatsmith, mother, wife, sister, daughter, friend and cultural commentator with a penchant for food and community…

4 thoughts on “The Regulation Diaries (4): PrimeSafe’s War on Fat”

  1. rillets ,, rendered???!!! Idiotic and unresearched response. Not like it’s a brand new meat product. Not like they couldn’t find out all about it and say “can you hold off for a few months while we create suitable food safety guidelines to regulate this product as it’s becoming a popular option so we need to become familiar with it”. Fingers crossed. … Still living in hope. Keep it up Tammi

  2. Having read you Blogs, it looks like they are avoiding giving written clarifications because if they were tested in through a legal system the interpretation would be related back to the FSANZ standards and they would be hard pressed to have their interpretations stand up .
    I would consider that all formal conversations be in writing and their bullying is to deter you from challenging further. It means you are presenting your processes rather than they determining through their interpretation.

    The following is only an opinion but would be an interesting conversation.
    The hock can quite happily be made with a low to moderate temperature or cold smoke, if your HACCP plan and monitoring reflect that the product is only processed to a temperature of say 50 it is a raw product. If you consider that a steak is rare at 50C dependant on what PrimeSafe calls a cooking temperature which would be interesting. In theory you have cooking instructions on the package.

    If it is only bine soaked then it will keep very well anyway with the low temperature, the flavour should be more intense. That was the method used before in invention of pumping devices.
    The same goes for traditional bacon this is either hand salted or brine soaked and is treated the same way. The results are pretty amazing and the keeping quality is excellent through this curing process. No cooking involved. It moves any bacterial concerns to the outside of the product which is then the only place of any discussion.
    there are the guidelines for smallgoods production available on the MLA website for download they were updated this year and are quite helpful. I didn’t read that you knew about them. PrimeSafe should have been represented on them as were all other regulators

  3. This makes me so angry…. we have a premier that wants to support the economy of the state by signing a free trade agreement with China so they can buy our farms to sell their product back to China- this means we will need to support the remaining small farmers here in order to get quality product on our table (whilst supporting our local economy). Yet we seem to live in state where this no free trade within in the state…… (ie people buying the products they want from the producers they want) ….thanks to the state. Free trade seems to be a selective concept.

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