Meat Act 1981
Technical Directive

Meat Technical Directive             Priority:  Normal
Contact for Queries: Neil Armitage, National Manager (Systems)
Phil Ward, Technical Policy Manager
  File: 
Date:   23 April 2002 Publication Ref: OMAR

TD 02/035 - Implementation of IS 3, IAS 3, IS 6, IAS 6 and IS 8, IAS 8

1

Background

1.1

The implementation of IS, 3 IAS 3 and IS 6, IAS 6 requires a standard of development and documentation that complies with IS 8, IAS 8. With the deferred implementation of IS 8, IAS 8 it is necessary to provide for the mandatory introduction of IS 3, IAS 3, and IS 6, IAS 6 with an appropriate level of documentation of systems.

1.2

There are several programmes that require documented operating procedures, e.g. SSOP's, Prerequisite programmes, HACCP and Performance Based Verification. Of these, HACCP is the only programme that had required standards for technical development and documentation. However, all premises licensed under the Meat Act 1981 are experience in some form of documentation that, when applied to implementing IS 3 and IS 6, provide an adequate level of process control, as an interim measure, without being quite as rigorous as the standards in IS 8, IAS 8.

1.3

MAF Verification Agency has in place a programme for developing competencies in personnel carrying out evaluation activities for the purpose of recognising documented systems as valid. Personnel who meet the requirements of the competency specification will have demonstrated skills in certain aspects of quality systems including an evaluation of a documented system. The programme is ultimately required to ensure the attainment of skills at least equivalent to NZQA level 4.

1.4

It is now feasible to develop documented systems which should provide industry and the VA with a high level of confidence that the technical aspects of these programmes should be equivalent to the requirements for Risk Management Programmes (RMP's) as described under the Animal Products Act. 1999.

1.5

In order to facilitate:

(i) the implementation of IS 3 and IS 6,

(ii) developing an appropriate implementation standard for documented production systems according to IS 8, IAS 8,

(iii) the calibration of evaluators in MAF VA, and

(iv) developing a list of authorised evaluators,

the following implementation procedures are proposed.

1.6

This directive establishes IS 3, IAS 3 and IS 6, IAS 6 as the basic operating standard for premises. The standard for documentation will not be defined but is expected to be adequate to ensure process control. This standard of documentation will be an interim measure and such operating systems will ultimately need to satisfy the requirements of IS 8, IAS 8 to be recognised as valid. This directive will also offer a voluntary mechanism for premises to develop documented systems which should provide industry and the VA with a high level of confidence that the technical aspects of these programmes should be equivalent to the requirements for RMP's.

2

Aim

2.1

To require the implementation of IS 3, IAS 3 and IS 6, IAS 6.

2.2

To provide for an appropriate level of documentation for IS 3, IAS 3, and IS 6, IAS 6 documented systems to facilitate the implementation of the specifications.

2.3

To provide procedures for the voluntary implementation of IS 3, IAS 3, and IS 6, IAS 6, documented to IS 8, IAS 8 standards.

2.4

To amend IS 8, IAS 8.

3

Procedures

3.1

Adoption of IS 3, IAS 3 and IS 6, IAS 6

3.1.1

The specific requirements for hygiene and sanitation, and edible processing that are applicable to premises shall comply with the requirements of IS 3, IAS 3 and IS 6, IAS 6.

3.1.2

The systems shall, at a minimum:

  • be documented to a reasonable standard in an appropriate company format,
  • meet the outcomes required by IS 3, IAS 3 and IS 6, IAS 6, and
  • include the requirements of the General and Specific Principles set out in IS 3, IAS 3 and IS 6, IAS 6, and
  • in respect of Manual 4, IS 5, IAS 5, IS 7, Manual 9, IS 9 and Manual 14 meet the specific requirements of those specifications.

3.1.3

Documented operating systems which have been developed under requirements for SSOP's, pre-requisite programmes, PBV and Class I, II, III and IV approvals may continue to be used but are to be reviewed and brought into line with the specifications in IS 3, IAS 3 and IS 6, IAS 6 by the implementation date.

Note:

Documented systems approved to the specification outlined in Section 3.1 will not be recognised as meeting a technical standard for documented systems required by IS 8, IAS 8.

[This form of 'lesser' documentation is an interim measure. Companies will be required to validate these systems, and have them evaluated and recognised as valid, in order to comply with the requirements for RMP's. Companies may voluntarily implement the option outlined in Section 3.2 at any time.]

3.1.4

HACCP shall continue to be used. Approved HACCP plans are not expected to need re-documenting to meet the requirements of IS 8, IAS 8.

3.1.5

The documented systems shall be assessed and, subject to demonstrating adequate process control, be approved by competent personnel in the Verification Agency in a manner similar to "Class I approvals".

3.1.6

The General Manager of the Verification Agency shall determine the competency of VA personnel and, when satisfied, issue the person with a letter delegating an authority to approve documented systems within the following classes:

(i) IS 3, IAS 3, Manual 4, IS 5, IAS 5, IS 7, Manual 9, IS 9 - all Technical Supervisors are eligible.

(ii) Sections 2, 3, 4, 5, 6, 11, 12, 13 & Appendix I of IS 6, IAS 6 - all Technical Supervisors are eligible.

3.1.7

In relation to approving specialised processes:

(i) Approving of sections 7, 8, 9, 10 of IS 6, IAS 6, shall only be carried out by Technical Specialists who are competent in preservation systems and hold letters of delegation from the Director Animal Products.

(ii) Approving of HACCP plans shall only be carried out by personnel who hold NZQA unit standard 12626.

3.1.8

Compliance Standard

Verification of compliance shall be carried out according to the requirements for Performance Based Verification (PBV), equivalent to TD99/49 or its successor.

3.2

Optional Procedures for Adopting IS 8, IAS 8

3.2.1

Documented systems approved under this Option shall comply with the requirements of IS 8, IAS 8, as amended in Section 3.3.

[It is intended that this Option should provide a high level of confidence that the technical construction and presentation would be equivalent to that required for RMP's under the Animal Products Act 1999.]

3.2.2

Requirements of IS 3, IAS 3 and IS 6, IAS 6 shall be developed into documented systems and implemented according to the following conditions:

(i) in relation to IS 3, IAS 3, the scope of the documentation is to be not less than a complete section except that the following multiple sections should each be regarded as complete sections:

  • sections 2 and 6,
  • sections 7 and 13,
  • sections 8, 9, 10 and 12, and
  • sections 16 and 17.

(ii) in relation to IS 6, IAS 6 the scope of a documented system is not to be less than a complete section.

(iii) in relation to the sections selected in IS 3, IAS 3, and/or IS 6, IAS 6, the documentation shall apply to all operations of that type that are carried out by the plant, i.e. the whole plant sanitation and pre-operation check programme, or post slaughter management of all species and types of boning.

3.2.3

Documented systems shall be evaluated by an Evaluator and recognised as valid according to the requirements of IS 8, IAS 8 as amended by this Directive. The Evaluator shall be an authorised evaluator, Section 3.2.4 (iv).

3.2.4

Calibration of evaluators

[The competency specification TD 01/120 specifies a level of skills at NZQA level 4. The calibration procedures described in this sub-section will be applied as an interim measure until the competency standard is registered as a unit standard by NZQA, and assessors have been appointed.]

(i)

Personnel employed by MAF VA who have substantially satisfied the competency requirements for evaluators, TD 01/120, will need to complete a calibration exercise to the satisfaction of a peer review before conducting a full evaluation.

(ii)

For the purpose of initially calibrating the evaluator, the evaluator will make a desk evaluation of the documented system and submit an overall written assessment for peer review. A group of peers, recommended to include MAF VA, MAF Food, and industry nominee(s), will carry out an independent desk assessment of the document to form an opinion of the system and, based on a consensus view, determine if the evaluator assessment was adequate.

(iii)

If the evaluators desk assessment was adequate, the evaluator may proceed with an appropriate course of action, e.g. complete evaluation procedures and recognise the document as valid or return the document to the company if it fails to satisfy the requirements of IS 8, IAS 8.

(iv)

After completing a satisfactory calibration evaluation and satisfying all requirements for evaluator competency (TD 01/120), the person will be listed by MAF Food as an authorised evaluator.

(iv)

The calibration exercise does not need to be repeated if a person is an authorised evaluator.

3.2.5

Compliance standard

(i)

A register of documented systems recognised as valid shall be maintained by the Technical Supervisor according to IS 8, IAS 8: Section 3.

(ii)

Verification activities required by IS 8, IAS 8: Section 6, shall be maintained by the company and the Technical Supervisor and according to any other requirement relating to verification, e.g. PBV.

(iii)

If the documented system is found to be deficient, or the requirements of the system are not being followed by the company, the Inspector is to intervene and take what ever action would be appropriate given the powers of the Inspector provided under the Meat Act 1981 and the requirements of Performance Based Verification.

(iv)

A documented system that is found to be deficient shall be corrected and re-validated otherwise it shall be removed from the register.

(v)

If the requirements of a documented system are not being followed, the system shall be removed from the register.

3.3

Amending IS 8, IAS 8

3.3.1

Add to the definitions, Section 1.2:

Evaluator means a person who is deemed competent to recognise the validity of a documented system.

3.3.2

The term "[Technical Supervisor (Inspector in Charge)]" shall be replaced with the term "Evaluator" where ever IS 8, IAS 8 refers to validation responsibilities of the Inspector or to evaluating documented systems or to recognising documented systems as valid.

3.3.3

The term "[Technical Supervisor (Inspector in Charge)]" shall be replaced with the term "Evaluator" where ever IS 8, IAS 8 refers to validation responsibilities of the Inspector or to evaluating documented systems or to recognising documented systems as valid.

4

Cancellations

4.1

TD 99/66 is cancelled and replaced on receipt of this Directive.

5

Implementation

5.1

The procedures described in Section 3.1 may be implemented from December 1998. These will become mandatory from 1 October 1999.

5.2

Optional procedures described in Section 3.2, as a voluntary programme, may be implemented from December 1998. Companies may choose to progressively implement these optional procedures whilst developing and refining operating systems documented under Section 3.1.

5.3

The Amendments to IS 8, IAS 8 described in Section 3.3 apply from December 1998.

5.4

All premises shall draw up a programme to demonstrate how they will meet all outstanding issues. The programme shall be drawn up by 1 July 1999, the implementation plan should be agreed to by the VA Technical Supervisor as reasonable.

5.5

With regard to validation of chillers and freezers as required in Sections 3 and 4 of IS 6, IAS 6 these shall be validated by 1 July 2000. NB: this allowance is provided only due to the seasonality of some operations and the availability of the necessary stock to permit the validations to be completed.

5.6

With regard to all other matters, completion shall be 1 October 1999

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