For Your Information: F8-03 Field Recovery of Wild Mammals and Birds for Petfood
New Zealand Food Safety Authority
Animal Products Group
Date: 17 June 2003
From: Chris Kebbell, Programme Manager (Petfood).
The purpose of this communication is to convey the current NZFSA Technical Policy on the field recovery of wild mammals and birds for the purpose of animal consumption (petfood) at licensed premises or premises operating registered risk management programmes (RMP).
Historically wild mammals and birds have been harvested directly from the field for the purpose of human consumption and to a lesser extent for petfood manufacture. The harvesting of wild mammals and birds has occurred where operations have been approved (licensed under the Meat Act 1981, or registered RMP under the Animal Products Act 1999) for this purpose and where harvesting specifications have been formally notified.
The field recovery of wild mammals and birds for human and animal consumption poses risk to the final consumer if the harvesting programme is not managed appropriately. The harvesting risk arises from the possibility that field-recovered species may either be the target of; or live in areas where other mammals and birds have been the target of culling programmes utilising vertebrate poisons.
Animals that have been exposed to vertebrate poison either die very soon after exposure, or remain apparently healthy for a variable period of time and then possibly die – depending on the type of poison used and the dose consumed. Harvesting of animals that may have been exposed to poisons and from areas that are still within the non-harvesting time frames (notified for the type of poison), pose significant risk of exposing the final consumer to poison residues through the petfood product.
Harvesting by its very nature often involves the use of suppliers that operate outside the direct control of the petfood operator. While suitable training and approval of suppliers reduces the chances of error and fraud, the integrity of the harvesting programme remains heavily dependent on the suppliers ongoing understanding of requirements and their individual honesty and integrity. Recent events with the recovery of feral deer served as a poignant reminder that this is not always the case and that suitable monitoring programmes must be in place to verify established programmes and controls.
NZFSA Technical Policy on the field recovery of wild mammals and birds for petfood
The following represents the current NZFSA Technical policy on the field recovery of wild mammals and birds for petfood. This Technical Policy has been formulated to minimise the risk of poison residues and to support the integrity of NZFSA assurances as to product fitness for purpose.
All operators harvesting wild mammals and birds from the field will be subject to this Technical Policy. It must however be noted that this Technical Policy may be subject to change should further information come to light on the risks and hazards associated with recovery of wild mammals and birds from the field.
1) Vertebrate Poisoning Monitoring Programme
Operators that elect to harvest wild mammals and birds from the field must agree upon and participate in a statistically valid poison-monitoring programme designed to verify the effectiveness of the established controls within the harvesting programme. Where there is no industry agreed sampling programme for the species concerned, an individually tailored programme must be agreed upon with the NZFSA prior to the commencement of operations.
In line with government’s policy on cost recovery the operator must cover all costs associated with the monitoring programme.
The cost of the individual programme will be dependent on the:
Number of samples: This will be determined on a case by case basis (e.g. following consideration of factors such as estimated throughput, whether the wild mammals and birds are presented live or dead etc).
Sampling costs: To ensure the integrity of the sampling programme MAFVA verifiers must be used to collect and process all samples. The costs of this service will be at standard MAFVA rates.
Sample analysis cost: The cost of sample analysis will be dependent on the poison tested for and any individual lab cost variation – approximate cost:
Anticoagulants $112 per sample.
1080 $260 per sample.
Condition of Risk Management Programme:
Where an industry agreed sampling programme exists, all operators of RMPs will be required to participate in these programmes through the application of a condition to the individual RMP.
Where no industry agreed programme exists, the individually agreed sampling programme will be made legally binding through the application of a condition to the individual risk management programme through the registration process.
2) Verification Frequency
Operators that elect to harvest wild mammals and birds directly from the field will be the subject of increased levels of verification until the harvesting programme has clearly demonstrated adequate levels of operator/harvester control. The following condition will be applied to all risk management programmes registered for the direct field recovery of wild mammals and birds.
"Verification by the nominated Verification Agency must be undertaken at a frequency of every 2 weeks. This frequency of verification must continue until 5 successive targeted ‘acceptable’ verification audits have confirmed that the harvesting programmes is being operated in accordance with the RMP requirements. At the completion of this period verification must be undertaken in accordance with TD 99/49 and any subsequent amendment."
3) Harvesting Specifications
Wild mammals and birds may be harvested directly from the field for petfood in accordance with the following Technical Policy.
Petfood product obtained from human consumption operations
Operators may source petfood product from human consumption operations in accordance with any notified requirements for petfood (Human consumption premises licensed under the Meat Act 1981 or with risk management programmes registered under the Animal Products Act 1999).
Operators sourcing petfood product from human consumption operations will be exempt from the requirement for a residue-monitoring programme, unless wild mammals and birds are also sourced directly from the wild.
Direct field recovery of rabbits and hares
The NZFSA and New Zealand Petfood Manufacturers Association is currently finalising a code of practice to provide guidance on this activity. Operators harvesting rabbits and hares directly from the wild must comply with the requirements notified in this code of practice.
Other wild animal species
Where there are no specifications notified for the field recovery of a species of wild animal for animal consumption (petfood); operators must harvest the animal in accordance with requirements / specifications notified for human consumption.
Where no specifications exist for the harvesting of an animal species for human or animal consumption - no harvesting programme will be approved by the NZFSA, unless the programme is accompanied by a valid risk assessment that has fully considered the harvesting hazards for the intended species.
Until there is any notified change in the Technical Policy, persons are advised not to develop or seek registration of Risk Management Programmes that facilitate any form of activity that is not provided for in this document. Further advice can be obtained by contacting the NZFSA Programme Manager Petfood.
Disclaimer: This 'For Your Information' is intended for use as a guideline only and should not be taken as definitive or exhaustive. NZFSA endeavours to keep this information current and accurate. However, it may be subject to change without notice. NZFSA will not accept liability for any loss resulting from reliance on this information.
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