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Code of Practice: Processing of Bee Products

Part 1 - Overview

3 Risk Management Programme

Amendment 0

July 2005

3.1 What is a risk management programme?

A risk management programme (RMP) is a documented programme designed to identify and manage hazards and other risk factors in relation to the production and processing of animal material and animal products, in order to ensure that the resulting animal product is fit for intended purpose. The risk factors that need to be considered in the development of an RMP are:

• risks from hazards to human and animal health;

• risks from false or misleading labelling; and

• risks to the wholesomeness of animal material or product.

An operator’s registered RMP will be “legally binding” so it must be developed and implemented in accordance with relevant New Zealand legislation. Overseas market access requirements and commercial quality issues are not required to be part of the risk management programme.

The Risk Management Programme Manual provides comprehensive information on the principles and components of an RMP and provides guidance for their development.

3.2 RMP configurations

An RMP may be developed for a single business or for multiple businesses.

3.2.1 Single-business RMP (Sections 12(3) and 12(4) of the Act)

A single RMP that covers the operations of a single-business located in a single-site is the simplest form of an RMP and its use is encouraged, whenever applicable. This is likely to be the most suitable RMP configuration for majority of honey extractors and packers.

A business may also decide to have more than one RMP. This may be useful when the operation can be logically and clearly split by product, process or premises. For example, a single business involved in the extraction and packing of honey may wish to have two RMPs – one covering the extraction process and the other the packing process. This arrangement can give flexibility to the operator in terms of making RMP amendments. It also allows for the suspension or deregistration of one RMP without affecting the other. However, consideration should be given to the practicality and cost of managing more than one RMP within a single business, and any market access requirements.

3.2.2 Multi-business RMP (Section 17A of the Act)

An RMP may apply to more than one business, if the Director-General approves such an arrangement for the particular business. The approval will depend on the operator being able to demonstrate that:

• the programme is appropriate to all businesses or part-businesses that it covers;

• the registered operator of the programme will have sufficient control, authority and accountability for all matters covered by the programme in relation to the other business or part-business subject to its coverage; and

• the applicant has obtained the consent or otherwise taken into account the views of any person whose business or part-business is to be covered by the programme.

An example where a multi-business RMP could apply is in a situation where the honey packer decides to include the operations of several extractors under a single RMP. In this case, the packer must have sufficient control, authority and accountability for the related activities of the extractors. The extractors must consent to this arrangement and should only supply bulk honey to the particular packer covered by the RMP.

Certain market access requirements, for example European Union (EU) listing requirements, do not allow this RMP configuration to be used. Therefore, this is not likely to be a suitable RMP configuration for majority of honey processors.

3.3 Contents of a risk management programme

3.3.1 Contents

The documented RMP must include the following:

• Good manufacturing practice

Good manufacturing practice (GMP) includes the practices and procedures designed to ensure the consistent production of products that are safe and suitable for their intended purpose, and that meet relevant regulatory requirements. It includes several interacting components such as hygienic practices, process control and quality assurance systems. GMP is usually documented by the operator in supporting systems of their RMP.

GMP is the foundation for Hazard Analysis and Critical Control Point (HACCP) and RMPs. It may also be referred to as Good Operating Practice (as used in the NZFSA Domestic Food Review discussion papers).

GMP for the processing of honey and other edible bee products is discussed in Part 2 of this COP.

• Application of HACCP principles

The operator must apply HACCP principles, as appropriate to the product and process, to ensure a systematic approach to the identification and analysis of hazards and their control. This is covered in Part 3 of this COP.

• Identification of other risk factors and their controls

Other risk factors related to the wholesomeness of the product and risks from misleading labelling must be identified in the RMP. The control measures for addressing the identified risk factors must also be documented in the RMP. These are presented in Part 4 of this COP.

• Other RMP requirements

Other RMP requirements such as business identification, operator’s details, physical boundaries, and provision for verifiers’ rights must also be documented in the RMP. These requirements are covered in the RMP templates provided in Part 5 of this COP.

3.3.2 RMP Components

The RMP should include the following components:

• Operator, business and RMP identification

• List of RMP documents

• Management authorities and responsibilities

• Scope

• Animal material and animal product description

• Process description

• Good Manufacturing Practice

• Application of HACCP (identification, analysis and control of hazards to human or animal health)

• Identification and control of risks to wholesomeness

• Identification and control of risks from false and misleading labelling

• Identification and competency of responsible persons

• Corrective action for unforeseen circumstances

• Recall procedures

• Confirmation of validity

• Operator verification

• Notification requirements

• Provision for verification activities & verifiers rights

• Document control and requirements for records