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ACVM Customer Survey 2004 Graphs and Comments
ACVM Processes
The majority of respondents felt there was enough information provided to give them a good understanding of the ACVM Group’s role, although several commented that the information was complex and that the use of legal terms made it difficult to fully understand the Group’s role.
“Most users don’t have a training (nor wish to have one) in legal jargon or legal thinking. If we are told what to do to comply, we will endeavour to do it.”
Several other respondents felt there needed to be a consistent interpretation of the legislation and its requirements
“Everyone I speak to has different interpretations. These interpretations are ever changing.”
Most respondents felt enough information was provided although several commented that it could be communicated better, especially in regards to processes and the recent changes.
“This is not easy legislation to communicate. Need more publicity type material.”
Several people also commented that even though there was a substantial amount of information provided that they were still ‘confused’ about what is required of them and / or the processes that need to be followed.
“Basically it is clear that any product must be assessed but not clear how to assess a product itself.”
“…Requirement and obligations should be very plain.”
“Never really sure where to look for confirmation. Headings and subject titles all sound the same.”
Most respondents found the application process either ‘average’ or ‘difficult’. Issues raised by respondents included:
• lack of clarity as to what was required of registrants;
• duplication and amount of paperwork required for registrations;
• different interpretations of the Act by ACVM Group staff; and
• slow processing of applications.
Suggestions to improve the process included:
“…a simple companion/guide to completing application forms might be useful…”
“Simple one step…maybe flow chart…HELP document for each type of application or each type of product, i.e. broken down and more specific.”
“Speed up processing, especially technical assessment. Simple approvals should be handled by ‘customer service’ people – not require technical checking.”
“More examples of information required, labelling and perhaps a filled out application. A ‘holding hands’ tutorial on the website would be helpful.”
One respondent also noted
“We find the application process is slow. To help overcome this we are now getting data assessment for efficacy and safety done independently which hopefully should help.”
However another respondent commented that they found the process simple and it was “straight forward and well explained.”
Respondents felt that in general they were kept informed of changes that affected them.
Some respondents didn’t feel that changes were communicated in an effective way, as one commented “being notified about changes and knowing how to interpret that knowledge are two different things.”
Other suggestions on improving communication were:
• making sure major changes were communicated to registrants early;
• increasing consultation periods;
• changing the website before the changes come into effect and noting the date the change is effective;
• creating a section on the website which details all changes, allowing registrants to cross-check, or highlight changes; and
• ensuring details are provided for the primary contact.
Communication
The vast majority of respondents indicated they preferred email as a method of communication, but most also noted that it depended on the issue and the type of information that was being conveyed as to which method they preferred, i.e. more complex issues or legal issues should be communicated by letter.
“All are appropriate at times. The written word allows one to reread the document and digest it. It’s probably the preferred medium. However a follow up phone call may be required to clarify something.”
Suggestions for improvement included:
“It is important that assessors make their emails clear. It is sometimes quite an effort to determine exactly what is being asked.”
“…need to know what ACVM preferred method is in terms of when an email is acceptable, similarly letter/phone call.”
“Case officers – one person mainly responsible for each company.”
“…documentation by email is acceptable for non-legally binding information/decisions.”
Most respondent found AgVetLink was always or usually an informative and worthwhile publication. Several respondents commented that they would like AgVetLink to be more frequent. Other suggestions for improvement included:
“More info on plant compounds. AgVetLink very heavy on animal health issues.”
…”AC & VM issues separated out in the bulletin.”
Email was again the preferred method of communication. And as before respondents noted that it depended on what information was being communicated. Most felt that significant and complex information (i.e. legislation amendments) should be disseminated via workshops although significant changes should also be communicated in a written form as not everyone can attend workshops and ready reference material was required.
Respondents ‘usually’ find the ACVM Group website user friendly, although several noted that the search facilities could be improved as documents are sometimes difficult to find.
One respondent suggested:
“A search option, e.g. how do you find ‘controls’ - by going to a reg. product and double click on controls or GRAS list.”
Another commented:
“Some PDF files (labels) can be difficult to read or download. Major issues is that some labels text print is unreadable and therefore useless to have to check for compliance etc & ACVM requirements.”
Respondents felt the comments and ideas they raised with the ACVM Group were ‘sometimes’ and to a lesser extent ‘usually’ taken seriously.
Some comments and suggestions included:
“On occasions answers to issues can vary from different sources within group. Political answers aren’t helpful as can delay moving forward thereby increasing costs or reducing opportunities.”
“Need to be more relaxed and receptive to discussions with clients. Work alongside people and listen more.”
“A more public ‘chatroom’ type situation where all queries raised are seen by all interested applicants/registrants etc, and the considered reply by ACVM as well.”
“There could be more consultation with stakeholders and opportunities for stakeholder input. Most people like to see evidence that their views have been heard and taken into consideration.”
“Sometimes the reviewers call is a bit inconsistent.”
“Hard at times to know who to talk to. If you have account managers, they are not always obvious to the accounts, and when staff are changed, companies do not always get told who their new account manager is.”
Service
No comments or suggestions were requested for these sections.
A number of respondents combined their overall impressions of the ACVM Group with suggestions for improvements so these have been combined below.
Issues of communication, complexity (of legislation and interpretation of same) and slowness of the application process were raised most often as concerns. Respondents also commented that a better explanation of the process would be helpful.
Some respondent also commented that they would like to meet more of the ACVM staff.
Other suggestions included:
“Less general information and better access to specific information would be excellent.”
“Produce user-friendly, jargon free guides defining minimum requirements to be met.”
“A helpline with friendly informative personnel.”
“Some standardisation re new staff and their training on application forms and processes…”
“More flexibility with respect to the acceptance of new additional information prior to final approval of an application.”
“When there is a query regarding registration there is a long turn-around by the time a letter is issued from ACVM and received by the registrant. It would be good to get an email copy so that the data required can be prepared and returned to the ACVM faster. Particularly some of the requests are very minor and could be dealt with by email.”
“perhaps engage casual staff to assist at peak times.”
“simplify the requirements and the process.”
Suggestions of topics to be covered in workshops; AgVetLink and on the website were:
Workshop
• current methods for assessing stability;
• role of data assessors;
• GAP requirements and DAS (or AgVetLink);
• calculations of ADI’s; setting of MRL’s (or AgVetLink); and
• ACVM processes (or AgVetLink);
• adoption of VICH guidelines; and
• GMP training – basic through to advanced.
AgVetLink
• changes in registration requirements;
• explain review and evaluation; and
• PAR advertising – clarify issues and requirements and obligations.
Website
• drug data sheets with contraindications and withholding periods;
• changes to registration / reminders; and
• examples of required wording for label updating.
New Zealand Food Safety Authority
68-86 Jervois Quay
PO Box 2835
Wellington
NEW ZEALAND
Phone: +64 4 894 2500
Fax: +64 4 894 2501
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