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Question and Answers from Stakeholder Meetings

20 December 2007

Why is NZFSA managing products not related to food uses?

The ACVM Act has always had an mandate to manage agricultural compounds and veterinary medicines used in non-food areas. For example, agricultural chemicals used in forestry and veterinary medicines used on companion animals such as cats and dogs. However, NZFSA recognises since becoming a stand alone Government Department (rather than a semi-autonomous body attached to the Ministry of Agriculture and Forestry) it needs to better communicate to stakeholders that its mandate is wider than just food.

What is the status of biocidal films/paints applied to walls or other surfaces etc in food processing facilities under the ACVM Act and Animal Products Act?

Biocidal films/paints would be defined as agricultural compounds if claims were made to control insects or pathogens of animals and/or plants and therefore be subject to the ACVM Act. Such products no longer require approval under the Animal Products Act when used in Meat and Seafood premises. There is no regulatory assessment of such products used in Dairy premises. Rather such products must comply with any requirements specified in the regulatory assessment of the Dairy Premise. Manufacturers of such products can have a non-regulatory assessment of their products to indicate whether they comply with any specifics for such products in the regulatory assessment report of the Dairy premise.

Why does NZFSA wish to regulate these possible new product groups when ERMA is already managing them?

The Government when it was reforming the legislation in this area back in the 90s agreed that both the HSNO and ACVM Acts should be developed as they manage different sets of risks. At the same time Government agreed that the two organisations administering each Act should work closely together to ensure there was a complementary system to minimise duplication as much as possible.

In managing hazards of substances under the HSNO Act, it does not manage certain aspects such as manufacturing and quality control of products which the ACVM Act manages. When also considering the risk areas managed under the ACVM Act, there are valid reasons for NZFSA to have an interest in these products. However, as has been stressed at all stakeholder meetings, the level of regulatory oversight may be very light as the Act has the ability to exempt products from registration.