Food Focus November 2008
The backbone of the Animal Products Act – risk management programmes
NZFSA is responsible for administering the Animal Products Act 1999, a key regulatory component of which is the risk management programme (RMP). Food businesses that deal in animal products need to find their way around the Act and many will probably operate an RMP
The primary purpose of the Animal Products Act 1999 is to protect human and animal health by ensuring animal products are safe to consume, while the secondary purpose of the Act is to facilitate access to overseas markets.
This is done by regulating the production and processing of animal material and products in New Zealand. The Act governs primary processing of animal products, such as the slaughter and dressing of farmed and wild animals (including game estate animals) and the processing of seafood, poultry, dairy products and other items, such as bee products and eggs, for human and animal consumption. It also governs the secondary processing of animal product intended for export where an official assurance is required.
Risk management principles are central to this regime. For animal products, the optimal point at which to manage a risk may be anywhere along the production chain from the source to the market.
What is a risk management programme?
A risk management programme (RMP) is a written programme designed or adopted by each animal product business to manage its biological, chemical and physical hazards, based on the principles of Hazard Analysis and Critical Control Point (HACCP). It is also designed to ensure that animal product is wholesome and truthfully labelled.
In consultation with the relevant industry groups, a number of Codes of Practice (COPs) have been developed by NZFSA for particular sectors. When a COP covers the business operation, the business can base their RMP on the COP and where necessary tailor it to their own processes and products.
The RMP needs to include a range of information, such as:
• the business name and name of the person who is ultimately responsible for the programme
• the scope of the business, its products and their intended use
• any hazards identified in animal material, animal product and processes, and how these hazards will be managed
• a system of record keeping
• how the RMP will be verified by an independent, recognised verifying agency.
Once the RMP has been developed by the operator, it is likely to need to be evaluated. All RMPs need to be registered with NZFSA prior to commencing operations and then externally verified on an ongoing basis. This external verification checks that the business is following the RMP and that the RMP continues to deliver product that is fit for its intended purpose.
Who needs an RMP?
All primary processors of animal material (except those with exemptions) must have a risk management programme, including mammal, bird and seafood primary processors and dairy processors. In addition, a number of others also need RMPs, including:
• secondary processors of animal products intended for human consumption, except to the extent that they are subject to the Food Act regime or Medicines Act
• most avian egg processors and deer velvet processors
• renderers and blood-drying operations of mammals and birds
• retail butchers who are dual operator butchers
• anyone exporting animal products to countries that require official assurances.
Who doesn’t need an RMP?
Some people are exempt from the requirement to have an RMP, including:
• primary producers of animal products (eg sheep and beef farmers)
• dairy processors of dairy products consumed on premises
• fish on retail premises and fish sold by a combination of retail and wholesale where the trader has a food safety programme under the Food Act regime
• certain fish caught in the New Zealand Economic Zone
• certain dairy products that are multi-ingredient foods
• egg producers who sell direct to the consumer from 100 birds or less
• apiarists (unless exporting to countries requiring official assurance)
• persons harvesting whitebait and limited processing operations
• primary processors of animal material for purposes other than human or animal consumption (eg skinning and shearing)
• muttonbird primary processors.
Further information
Full details about who does and doesn’t need an RMP are given in the RMP manual
This manual has been designed to help operators develop and operate their RMP. It includes what is needed, how to get an RMP evaluated and registered, and key things about operating an RMP.
Exporters will need to check if overseas market access requirements need to be met in addition to the RMP.
How the RMP process works
Step 1 Development and validation
The RMP process starts with the operator reviewing guidance information on NZFSA’s website (including the RMP manual referred to above), as well as reviewing the available NZFSA-approved COPs, models and templates. Where they are available, there are advantages if an operator develops an RMP using an approved COP or template, in that it:
• ensures they comply with current best practice or acceptable industry practices and procedures
• ensures that the operator meets the relevant regulatory requirements
• simplifies and reduces the cost of developing and evaluating the RMP.
Once the operator has developed their RMP they need to check that it covers all the relevant processes in the operation, complies with the legislation and confirms it is capable of producing product that is fit for its intended purpose. The operator also needs to contract a recognised verifier, who will then confirm that they are willing to verify the RMP.
Step 2 Evaluation
The next step in the process, in most cases, is for the operator to employ an evaluator, who has been recognised by NZFSA, to evaluate the RMP. The evaluator confirms that the RMP does indeed cover the operations, and, as written, will deliver product that is fit for its intended purpose. The evaluator prepares a report that is provided as part of the application for registration of the RMP with NZFSA. Evaluation is not required when the RMP is fully based on an NZFSA-approved COP or template, for which the requirement for evaluation has been waived.
Step 3 Assessment and registration
NZFSA assesses all RMP applications and if satisfied, registers the RMP. An RMP must be registered with NZFSA prior to the operator commencing operations.
Step 4 Implementation
It’s up to the operator to ensure the processes are carried out in accordance with the registered RMP and that all the risk management activities are working effectively.
Step 5 External verification
With the RMP registered and operating, the operator now ensures that all operations under the RMP are being followed and that records are kept. They must also ensure that visits by the recognised verifier occur as scheduled. The frequency of visits is determined by the product, process and any market access requirements.
RMP case study – honey processor
Honey Valley New Zealand Limited packs and exports honey, comb honey and honey blends to Asia, Europe and the US – 98%of their production is exported and only 2% is used to supply the New Zealand market
Steve Lyttle, the Managing Director of Honey Valley, which was established in 1995, has been in the industry since 1968. As an exporter of honey products, Steve knows how important the RMP is for providing official assurance to countries he exports to.
When the business was established in 1995 he and his business partner/wife Carolyn established written procedures for all the factory processes. Carolyn’s background in ISO auditing for a major food exporting company made her appreciate the value of written procedures.
In 2006, RMPs became mandatory for the honey industry where export assurance was required and Steve was a member of the industry working group that worked with NZFSA to establish the industry template. This was a challenging task for the industry. In the past, the honey industry had operated using traditional processing methods with little or no supporting documentation relating to traceability or food safety.
Steve says he is “eternally grateful for the effort put in by NZFSA to help create a template that was user-friendly and recognised the unique processing requirements of the honey industry. The greatest help was in being able to talk firsthand to key NZFSA staff on a one-to-one basis when working through the implementation process”.
Because Honey Valley processed products outside the scope of the industry template it had to have its RMP evaluated prior to registration.
Steve explains, “this was achieved with ease because the evaluator was provided with the relevant documents that supported the additional processes”.
Extensions to the factory over recent months meant the RMP had to be amended to cover the enlarged site and extended building. “Again this was simply a case of supplying the relevant information to NZFSA and the process was completed within 10 days”, says Steve.
“While time-consuming at first, the RMP process actually helped us solidify our processes and clarify what we needed to do. Having existing written procedures in place made the transition to operating under a registered RMP a lot easier. Certain processes were unique to our business but it was simply a case of adding them in and getting them evaluated.”
Because the business raises export delivery documentation, Honey Valley is subject to quarterly audits. This, along with its internal audits, ensures they are fully RMP compliant at all times. Steve explains: “We do struggle with the number of audits we are subjected to, but appreciate it is an important part of the export assurance program.
“The establishment of our RMP has been a very positive step forward for our company and it is one of the best marketing tools we have at our disposal. With increasing food safety issues being highlighted around the world, it’s imperative to have a robust food safety programme in place. This makes it possible for us to receive premium prices for our exports – in some markets we are receiving a 50% premium above similar honey from other countries.
“Like all exporters we are keen to see regulations kept to a minimum, but in the case of our RMP it has been one of the best moves we have ever made.”