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

The Regulation Diaries (3): PrimeSafe’s War on Meat 

Our first regularly scheduled audit after The Salami Wars was just a few weeks after we returned from our research trip to France and Italy. (NB Audits are undertaken by private third-party auditors, who submit their reports to PrimeSafe, which is a statutory authority.)

I was determined to give The Auditor nothing to worry about – I would show that we had understood our mistake in letting salamis leave the property, and that I keep an exemplary boning room.

The Auditor seemed quite solicitous as she commenced the audit – she of course knew of The Salami Wars and appeared to have some sympathy for how we felt at the destruction of our food. The Audit was going very smoothly, paperwork all in order, the place spotless… and then she looked to the bottom of the display fridge.

‘Why are those smoked hocks in cryovac?’ she asked.

‘Um, because they keep better?’ I answered nervously.

‘But they’re ready-to-eat products, and you don’t have a Listeria Management Plan,’ she declared.

Ah, crap. Bugger and gah! So they farking are.

Or are they? Let’s examine the evidence…

Ready-to-eat products are ‘ordinarily consumed in the same state as that in which they are sold’ according to the Australian Standard for the Hygienic Production and Transportation of Meat and Meat Products (AS 4696:2007).

But PrimeSafe treats all products that have gone through a cook process (to a minimum of 65C for a minimum of 10 minutes) as RTE. And you can’t cryovac RTE products in Victoria without a Listeria Management Plan in place. Such a plan requires monthly listeria testing and quarterly testing of every product in its package exactly as it will be sold.

What does that mean in practice? Say we sell whole hams at Christmas, and sliced and half hams the rest of the year (in addition to sliced pastrami and other RTE products). We have to send off five whole packages per quarter of each product: five whole hams, five half hams, and five packages of sliced ham. The lab tests for listeria and then throws the meat away.

We only do whole hams at Christmas, and we only do about 40 of them. But this requirement would mean I would have to send five of those to be tested and disposed of. That’s 12.5% of our hams thrown away. Or about $1000 in product, just for the whole hams. So to vac pack our RTE products would, we’ve estimated, cost us around $5000 per annum in testing and sacrificed product.

Cost aside, we cannot stomach the idea of all that wasted food, especially from animals we’ve raised so mindfully and whose lives we’ve taken for the sole purpose of food. What total disrespect to simply throw that meat away. And so we’ve opted not to pursue vac packing our RTE products. It means we have to run a tighter production model (we glad wrap our hams and hocks), but if that’s what it takes to respect the lives we take then it’s what we will continue to do.

PrimeSafe considers smoked hocks to be RTE products, meaning we can’t vac pack them. Bacon, interestingly, has an exemption from the RTE rule – you are allowed to vac pack bacon because, as both The Auditor and The Inspector have told me, ‘culturally, Australians cook bacon’. Smoked hocks don’t have this exemption for reasons beyond me, in spite of the clear cultural evidence that Australians cook smoked hocks (ham & pea soup, anyone?).

And so when The Auditor asked why I’d vac packed my hocks, it was because she was about to slap me with a ‘critical’, my first.

Following procedure when a ‘critical’ is identified during an audit, The Auditor rang PrimeSafe. She spoke with The Inspector, and then handed the phone to me. The Inspector explained that The Auditor was going to have to condemn my smoked hocks – that is, make me pull them out of their plastic, put them into a bin, and pour poison over them. Déjà vu?

I asked whether we could have them tested?


I asked whether I could take them into my house for us to use?


I asked whether I could feed them to our dogs?


And so, weeping quietly, I pulled around 15 smoked hocks out of the fridge, cut the plastic off them, and put them into the same bin our salamis were poisoned in just a couple months earlier. The Auditor asked me to get the disinfectant I clean the floor with and poured it over the top of the hocks.


She then explained to me that PrimeSafe would put us on an Intensified Audit Schedule. Typically after a ‘critical’ a shop will go on intensified audits for a minimum of four audits. That means an audit per week for a minimum of four weeks, at our expense (our audits average $350-$550 per audit).

Apparently the perverse incentive of this cost-recovery model to find a critical is lost on PrimeSafe and indeed the Victorian government?

Some clear questions remain:

  • Who decides what is and isn’t treated as a RTE product?
  • Is there really a need to put a shop on intensified audits for a mistake such as mine? The rest of the audit found absolutely nothing wrong.
  • Is there a cheaper and less onerous way to control the risk of listeria in RTE products? (eg you could pasteurize product in the vac pack to eliminate the risk without expensive, wasteful testing)

But now it’s time to share another voice from Victoria’s beleaguered meat industry…

Felix Gamze of Gamze Smokehouse in Wangaratta has been a great mentor and friend to us as we’ve navigated Victoria’s difficult regulatory terrain. He’s been a butcher for nearly 30 years, and has had his own negative experiences with PrimeSafe. Felix shared the story below with me for The Regulation Diaries as he’s as committed as we are to seeking changes in the current situation to make it better for Victoria’s meat industry to do what we do.

In 2008 the Listeria guidelines came into place, effectively introducing guidelines and restrictions that forced 90% of butchers to stop making ham, bacon and smallgoods in their retail butcher shops in Victoria (something they had been doing for ever). I was one of the very few to persist with making my own smallgoods due to the passion I have for charcuterie.

Having been making smallgoods from my retail butcher shop for over 25 years I was determined to keep going due to the encouragement of my loyal customers. I thought, ‘well it can’t be too hard to comply with the guidelines as I have been safely making product for a long time and have never had a food safety issue.’

Not long after the new guidelines came into place our industry body put on an information evening in the local area and all the butchers from the region who were interested in continuing to make smallgoods attended. Now let’s be honest, the room consisted of middle-aged butchers whose formal academic education averaged about form 4. This group of people were trained and very experienced in butchery, smallgoods making, food safety and running a small business.

The information session took about 2 hours and at the end we were all expected to fully understand and implement the new guidelines in our businesses! This was not the case and many of us left not fully understanding our new responsibilities. The new guidelines just put another job on the ever-growing requirements of a small business owner. The larger manufacturers didn’t have the same concern as they would now just employ another staff member to cover the area full time.

A lot of the guidelines focused on food safety, something we were all very aware of and complied with for many years without a formal set of guidelines. But another large part was the introduction was copious amounts of paperwork, laboratory testing, and bureaucracy all of which were poorly explained, implemented and set out, not to mention very costly. It was clear that what Prime Safe was looking to do was to stop the small local butcher making and selling smallgoods, something that the big guys in the industry were obviously very happy about.

Soon after the information evening I had my first audit under the new guidelines and it wasn’t a very pleasant experience. At my first attempt I didn’t correctly complete the paper work required and the auditor failed me. I had a visit from Prime Safe the next day. During the visit from Prime Safe they destroyed all my products buy pouring bleach on it and took my cooking licence off me for 2 years!

Now, this was not due to any food safety issues, it was purely a paperwork non-compliance issue. From that point I could have easily given up and stopped what I loved doing, but that’s what they wanted me and every other butcher in Victoria to do.

After two years of jumping through every hoop they put in front of me I managed to get my licence back and start making smallgoods again.

I was then asked to give evidence in the 2013 State Government Inquiry into the Impact of Food Safety Regulation on Farms and Other Businesses where I shared my experience with Prime Safe and offered suggestions on cutting red tape. Since this enquiry there has been no recommendations taken up by Prime Safe from the Inquiry and now 2 years later they are having another review… I wonder what this will achieve.

Recently we decided to run Smallgoods and Butchery Masterclasses at our new facility where I would instruct a hands-on day of butchery and salami making. Once Prime Safe got wind of this they contacted me, instructing me that I was not allowed to conduct such a class. If I wanted to continue with the classes we would need to change it to making a fresh sausage and not a salami.

Each year I sell 100’s of kg of pork mince to local customers for them to make salami at home in June and July with some people having many years of experience and family heritage and others no idea at all. The families that have been making it for generations I have no worries about, but the average Joe that is interested in the art of charcuterie without access to a family with generations of experience I worry about. So I thought it would be a good idea to teach these people how to make salami safely and give them the knowledge to pass onto their family and start their own traditions. Obviously Prime Safe didn’t see it that way.

We have run a number of these classes and the days have been a great success with butchery, smallgoods information and fresh sausage making taking place but unfortunately no salami.

Maybe one day we will be able to work with our regulator and not have them trying to trip us up. I will say one thing in addition to this and that is that I am always very concerned when speaking up with regards to past experiences with Prime Safe that my licence will be put in jeopardy.

Read Part 1 of The Regulation Diaries: PrimeSafe’s War on Salami Days

Read Part 2 of The Regulation Diaries: PrimeSafe’s War on Farm Gate Shops

‘Bred free range’ is NOT ‘free range’

‘Do you have free-range pork?’

‘Yes, it’s all free range!’

‘Oh, excellent! Which farm is it from?’

‘Otway Pork.’

‘Otway’s not free range.’


This has become a regular occurrence for me. Next I school the butcher, providore, or waiter on the difference between ‘bred free range’ (aka ‘outdoor bred’) and ‘free range’ and suggest they have a look at Otway’s website, where they themselves clearly state that they are ‘bred free range’. Ditto Western Plains.

Confused yet? Fair enough. Fortunately, I’m here to help. 😉 Let me explain the three systems for raising pigs we have in Australia so you need not be confused anymore.


Pigs are kept indoors their entire lives on concrete or slatted floors. In some systems the breeders are kept in individual pens with limited movement. In others pigs are kept in groups. Some of these systems use both group and individual pens. The industry is moving away from gestation stalls (where sows are kept immobile for their entire gestation period of 3 months, 3 weeks & 3 days) due to consumer demand for higher welfare standards.

Outdoor Bred (aka ‘Bred Free Range’)

Breeding sows are kept outdoors, and farrow (give birth) in huts with access to the paddocks until they’re weaned, typically at 4 weeks. The weaners are then kept in groups in open-sided straw-based sheds, also called ‘eco-shelters’, where they spend the rest of their lives until slaughter.

Free Range

All pigs are raised entirely outdoors, with free access to shelter and wallows at all times.

Within these three systems for raising pigs in Australia, there is diversity amongst farm management strategies in regards to tail docking, castration, vaccinations, weaning, sub-therapeutic antibiotics in feed, sow management, age for slaughter, and stocking density.

The peak body for pig farmers Australia Pork Limited (APL) has clear definitions for each system, and sets (voluntary) standards through the Australia Pork Industry Quality Assurance Program (APIQ). There are standards for ‘APL Gestation Stall Free’, ‘Outdoor Bred’, and ‘Free Range’.  As I understand it, after much discussion within the industry, APL endorsed ‘outdoor bred’ and rejected ‘bred free range’ as a label as it was deemed confusing for consumers who are trying to choose free range.

Unfortunately, most outdoor bred growers are still using the term ‘bred free range’ on their marketing materials, and butchers and provedores just as much as consumers are often confused by the distinction (I’m giving them the benefit of the doubt that they aren’t intentionally misleading customers).

In three separate butcher’s shops over the past two months I have asked where their pork labeled free-range was from and been told either Otway Pork or Western Plains, which are outdoor bred systems, not free range. I know of others who have had the same experience. I always tell the butcher that they’re wrong, and they apologise and profess ignorance.

I’m not interested in critiquing butchers, nor intensive or outdoor bred systems here, but I am interested in eaters being able to make informed choices. As I’ve written before, ethical decision-making is deeply reliant on the availability of accurate information. If you understand the difference in the systems and which one is in front of you, you can decide for yourself whether you are happy with that animal welfare standard. But if you are misled about the system, someone is taking that choice away from you, and you shouldn’t stand for it.

I recommend that for those who truly want only free-range pork, you do a couple of simple things:

1) always ask whether the pork is free range, whether it’s on a menu, in a butcher’s shop, or in a deli;

2) if they say it’s free range, ask the name of the farm. If it’s Otway or Western Plains, it’s not free range (there are other outdoor bred growers as well, but these two are by far the largest in Victoria);

3) print this out and take it to your butcher, cafe, or deli if they tell you an outdoor bred farm is free range – they may simply not know the difference.

4) buy direct from farmers, either at farmer’s markets or online. I have a list of free-range pig farms in Australia, as does Flavour Crusader.

Choice is great. We can all choose how we want to eat, and what sort of farming we support, so long as we can rely on accurate information. You may choose intensively-raised or free-range pork, caged or pastured eggs, conventional or organic fruit and veg, or a wholly vegan diet, but not if those of us who produce and sell the food don’t tell you the truth of what’s in it.