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Code of Practice: Processing of Bee Products

Part 1 - Overview

4 Development of an RMP based on an Approved Code of Practice

Amendment 0

July 2005

The Animal Products Amendment Act 2002 allows for an RMP to be based on a COP, a template, or a model if in the view of the Director-General it is valid and appropriate for businesses of that kind. A COP that is deemed as valid and appropriate after an assessment process carried out by the NZFSA will be formally recognised as an “approved code of practice”.

A COP is a valuable tool to use in the development of the RMP. Compliance to an approved COP will:

• ensure that the operator complies with current best practice or acceptable industry practices and procedures;

• ensure that the operator meets the relevant regulatory requirements; and

• simplify and reduce the cost of developing and evaluating the RMP.

The applicability of the approved COP to the particular business and the degree of the operator’s compliance to the approved COP will impact on the development approach and evaluation requirements for the RMP.

4.1 Businesses whose products and processes are fully covered by an approved COP

4.1.1 Development

When the COP fully covers the scope of the operation of a business, the simplest approach for developing an RMP is to use the appropriate RMP template provided. The RMP template is a simple form that the operator completes by filling in the required information in the appropriate boxes.

The requirement for the documentation of GMP supporting systems and the application of HACCP principles in the RMP can be met by incorporating the relevant sections of the COP into the RMP by reference. This means that that the operator will only need to write very few procedures that are specific to their operation. The operator’s RMP will, therefore, consist of the completed RMP template, the relevant sections of the COP that apply to their operation, and their own written procedures.

Confirmation by the operator that the RMP meets all the legal requirements for a valid RMP and that it will conform to the approved COP will simply involve signing a declaration in the RMP template.

Two RMP templates are provided in Part 5 of this COP. One template covers the processing of honey and dried pollen. The other template has been designed for use by beekeepers who do not extract their own honey and are only involved in the storage of bulk honey .

4.1.2 Evaluation

An RMP that is fully based on an approved COP does not require an evaluation prior to registration since the NZFSA has already determined that the requirements and procedures set out in the COP are valid and will deliver the relevant regulatory requirements. Verification of the accuracy of the documented RMP and operator’s compliance to the COP will be carried out at the initial verification by the contracted verifier.

4.2 Businesses whose products or processes are not fully covered by an approved COP, or those with significant variation from the COP

4.2.1 Development

Since the COP is limited in its scope in terms of the bee products, processes and procedures it covers, some businesses will need to tailor parts of the RMP template to meet their particular process variations. Some may also need to, or want to develop their own specific RMP.

Businesses whose products and processes are not fully covered by the COP, or who have decided to apply procedures or processing parameters that significantly differ from those given in the COP must write their own documentation for those parts of the RMP that are not covered or vary from the COP (including HACCP application and GMP procedures). The RMP template may still be used but the operator will need to add their own information or documents for those parts not covered by the template or COP.

The operator must be able to demonstrate the effectiveness of any alternative procedures or parameters to consistently meet all relevant regulatory requirements and produce products that are safe and suitable for their purpose. Demonstration of its effectiveness may involve the collection of evidence (e.g. data from testing or trials, published scientific information, report from an expert) by the operator for assessment of the accredited evaluator or the NZFSA.

4.2.2 Evaluation

An RMP that is not fully covered by an approved COP or has procedures that vary from the COP will need to be evaluated by an independent evaluator to confirm the adequacy of the RMP. Evaluation will involve a desk-top audit of the documented RMP and may require an on-site visit of the premises before registration of the RMP.

4.3 Steps for the development, registration and implementation of an RMP

The steps for the development, registration and implementation of an RMP are summarised in Figure 1. The diagram shows the steps for two options:

• Option 1: For businesses whose products and processes are fully covered by the COP.

• Option 2: For businesses whose products and processes are not fully covered by the COP, or who have decided to apply procedures or processing parameters that significantly differ from those given in the COP.

Figure 1. Steps for the development, registration and implementation of an RMP

* Significant amendments will require evaluation prior to registration