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The First Three Years

Challenges for NZFSA: from the executive director, Andrew McKenzie

When NZFSA was set up on 1 July 2002, the changes heralded far more than a shift to new offices and a new brand.

For the first time in New Zealand’s short history, the many strands required to create an effective food safety ‘net’ for food consumers both at home and abroad were brought together under one roof. While about three quarters of the new authority’s staff came from one place (the former MAF Food Assurance Authority) and the balance from the Ministry of Health, NZFSA and its goals took on a fundamentally new shape.

At the handover on 1 July 2002, a seemingly daunting array of challenges awaited the new authority. It had regulatory responsibility for an industry that exports $18 billion of food products; an industry with around 30,000 separate participants ranging from small takeaway outlets to multi-million dollar export giants; an industry that directly or indirectly employed 590,000 New Zealanders; and an industry with a direct influence on the health and well-being of all those who consume its products.

Emerging food safety hazards

It started its work in a dynamic operating environment – one in which new hazards are constantly emerging.

New hazards can come in many guises. As NZFSA’s primary predecessor organisation predicted in the 1990s, foodborne illnesses through disease pathogens comprise one of the biggest single threats to food safety. Previously insignificant pathogens – some E. coli or Salmonella species, for example – have in recent years emerged as serious threats to public health.

In addition to this, we travel and trade far more than we used to. The range of foods we produce, import and eat has grown rapidly, alongside our appetite for new taste and dining experiences. This expanding range of food choices exposes us to a greater range of potential risks from foodborne illness.

Paradoxically, while consumers are becoming more adventurous in their food choices, they are also growing increasingly conscious of food safety issues and less tolerant of perceived risks. They are making much greater demands for information and assurances from those who produce the food they eat.

A cohesive food regulatory programme

Into this environment, the new authority has had to ensure the smooth transition of everyday food safety regulation; it also had to set in place processes that would review and bring the whole system together into an efficient, effective, consistent and fair food safety regulatory programme.

NZFSA was set up to: 'Protect and promote public health and safety and facilitate access to markets for New Zealand food products and by-products.'

Meeting the goals that role entails has required a top-to-bottom review that includes the three main players in the food safety system: the regulator, the food industry and the consumer. With the authority’s responsibilities encompassing both food exports and the food consumed in New Zealand (local product and imported), the first step has been to look at how we can put in place the world-leading programme we are aiming for.

Domestic Food Review

The laws governing food sales in New Zealand have not been reviewed for many years and various inconsistencies and duplications have inevitably crept in. With the formation of NZFSA in 2002 the opportunity emerged for developing a more integrated and modern approach to the sale of food with consistently high standards across all sectors.

A five-year Domestic Food Review (DFR) has been initiated and, by the end of our first three years, the consultation process was well underway. The DFR is looking into the roles of all groups involved in food regulation – local authorities, district health board public health units and NZFSA. The review will take into account the needs of modern industry, consumers and the government.

The DFR will affect everyone involved in the sale of food, from large manufacturers through to corner dairies. Two main types of food safety management will be used. In general terms, the smaller the risk the less intervention and the simpler things will be. The two types proposed are:

1. Risk-based management programmes (Food Control Plans): Food businesses will have the choice of using an ‘off-the-peg’ template for their plan, or modifying a template to suit their circumstances. More complex operations, such as some food manufacturers, will develop their own custom-made plan to suit their particular activities.

2. Food Handler Guidance: This will be in the form of advice for one-off events involving food sales, such as fundraisers. The emphasis will be on guidance and education, with tips for food handlers.

The regulatory model

The regulatory model that underpins risk-based food safety management has required a fundamental shift in attitudes and behaviour by the food industry. While the regulator (NZFSA) produces standards and codes of practice, and defines the outcomes it requires to meet food safety targets, it is up to the industry to make this happen and take responsibility for meeting safety and suitability requirements, while the verifier independently audits their compliance.

While the New Zealand food safety regulatory model will remain (see diagram), roles and responsibilities may be reallocated following the DFR to ensure transparency, accountability and consistency across the country.

Getting the DFR underway has been undoubtedly one of the greatest challenges for NZFSA during its first three years, and it has set in motion a process that will continue for several years to come.

Click to enlarge image

Risk-based approach and the export sector

For the larger export-based sectors in the food industry, the risk management principles that underpin the Domestic Food Review are already well established as part of their operating culture. When NZFSA came into being in mid 2002, the process of industry taking up ownership of risk management was well underway. This continued apace throughout the first three years. For example, under the Animal Products Act 1999, most meat and seafood processors have now developed and submitted detailed Risk Management Plans. Dairy products came under the Animal Products Act in July 2005.

Knowledge base

Creating standards for the food industry does not happen in a vacuum. The whole concept of risk-based management of food safety rests upon understanding the risks involved.

From its inception, NZFSA has set out to strengthen the knowledge base used to identify, assess and manage risk.

This includes a broad-reaching science strategy and a knowledge base delivered by monitoring trends in foodborne illness. This is done through targeted research and ongoing programmes including the National Microbiological Monitoring Programme, the Total Diet Survey and the Food Residues Surveillance Programme.

From the outset, the authority has taken the widest possible view of food safety risks when gathering information. This is why it has included in the total food safety picture factors such as consumer knowledge of food handling, and consumption of ‘wild’ produce – everything from watercress and field mushrooms to the hunter’s bag of wild game.

A comprehensive review carried out for NZFSA by ESR in 2005 identified the most important microbial hazards associated with wild foods, as well as hazards from chemicals and natural toxins. This review will provide a scientific basis for any risk management activities that might be appropriate – public awareness programmes, for example.

Establishing dialogue

Characterising risk, based on scientific data, has always been an area for contention between food regulators and consumer groups. What science reveals to be the greatest risks – foodborne disease pathogens, for example – are not always accorded the same priority by consumer groups.

NZFSA has worked hard to establish dialogue with consumer groups over their concerns, and to give them representation during the process of standards development. It is a two-way process. Not only has the authority set out to listen to consumer views; it has also committed to promoting safe food practices through programmes such as the Foodsafe Partnership, or specific consumer guides such as Food Safety in Pregnancy and an extensive range of other food safety information.

Building on market access gains

Just as research data provides an important context for NZFSA’s regulatory work, so too does New Zealand’s trading relationship with the rest of the world. With 80 percent of the food we produce being exported, the consumers and regulators in our overseas markets assume great importance for our economy.

On the formation of NZFSA, New Zealand officials were actively engaged in trade negotiations on a number of fronts. One of these was the implementation of the New Zealand/European Union Veterinary Agreement, which recognises the equivalence of our programme and assurances and is already saving New Zealand food producers millions of dollars in compliance costs.

This agreement, and others like it, is built on New Zealand’s reputation as a world leader in food safety assurance systems. It is a hard-won reputation and retaining it does not give exporters an easy ride into world markets. The many market access gains are protected only through strict compliance with the programme.

Providing some of the leverage for our market access has been New Zealand’s active participation in international food safety standard setting, and our strong support of the principles of the WTO Sanitary and Phytosanitary (SPS) Agreement.

International leadership

NZFSA has picked up and built on this tradition of strong involvement in international trade forums. New Zealand chairs the key Codex Committees on Meat Hygiene and Milk and Milk Products, and participates in several Codex ‘horizontal’ committees, including those on Food Hygiene, Food Additives, Pesticide Residues, Food Labelling, Residues of Veterinary Drugs, and Methods for Analysis and Sampling. This leadership is helping us shape the international standards that serve as a framework for our global trade.

Closer to home, the Australia New Zealand Food Standards Code was implemented shortly after NZFSA was launched. This Code was developed by Food Standards Australia New Zealand (FSANZ) and mainly covers standards for labelling and composition. NZFSA contributes to the standards development process undertaken by FSANZ and implements and enforces the standards in the Code within New Zealand.

Strong linkages

Linkages such as the relationship with FSANZ were carefully thought through by NZFSA during its setup phase.

The authority was established as a separate agency attached to MAF. NZFSA has established strong linkages to other government agencies and is accountable directly to the Minister for Food Safety on food-related legislation.

Working relationships with industry and consumers have been enhanced; international linkages with trading partners and international food safety organisations have continued; and a whole-of-government approach ensures that policies relating to food are consistent.

An Officials Committee on Food Safety anchors this whole-of-government approach. It includes representatives from the Ministry of Foreign Affairs and Trade, Ministry of Health, Ministry for Economic Development, Treasury, Department of Prime Minister and Cabinet, Ministry of Consumer Affairs and Ministry of Agriculture and Forestry.

A separate Food Safety Advisory Board was set up to advise the Minister for Food Safety and provide assurance that food policies incorporate the consumer, industry and health outcomes sought by the government.

Three years down the track

In its first three years, NZFSA has been required to pick up and enhance the setting of food safety standards across New Zealand and for exports. It has been asked to bring all food safety management under one, risk-based, framework. And it has been asked to set itself up as a responsive, dynamic and accountable organisation with the right skills and structures in place to do the job.

Working in such a dynamic environment as the food business, NZFSA itself cannot stand still. NZFSA 2005, a project designed to look at NZFSA’s structure relative to functionality, was launched at the conclusion of our first three years. The review of our internal structure and the changes made will ensure NZFSA remains ‘fit for purpose’ and properly positioned to meet the needs of those who consume our food – both domestically and overseas – and the needs of the food industry.

But now that the authority is three years down the track, it is appropriate to reflect on the achievements of each of its business groups during that time, as they built their capabilities and made progress towards meeting their goals. This report marks a transition between the ‘old’ NZFSA and the organisation that has evolved and is now taking shape as a result of our review. We are looking back at our first three years through the eyes of the business units that existed during that period.

There is more about our new shape and future directions in the final section of this report.