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Code of Practice: Processing of Bee Products
12 Operator Verification and Other Operational Requirements
Amendment 2
June 2006
12.1 Purpose and scope
To verify compliance to documented procedures and to confirm the effectiveness of the RMP by ensuring that operator verification, including internal audits, are undertaken at the required frequencies.
To ensure that other operational requirements are met by the operator.
12.2 Mandatory requirements
12.2.1 RMP Spec 14
The operator must document an operator verification system including:
a. the activities to be performed, and their frequency;
b. any actions to be taken when all or part of the risk management programme is not effective; and
c. any recording and reporting requirements.
12.2.2 RMP Spec 25
The operator must notify the Director-General in writing, without unnecessary delay, of any change to the name or position or designation of the person(s) responsible for the day-to-day management of the risk management programme.
12.2.3 RMP Spec 26
The operator must document procedures for notifying the Director-General of any emerging, new or exotic biological hazards or new chemical hazards that come to the operator's attention in relation to the risk management programme without unnecessary delay.
12.2.4 RMP Spec 27
The operator must document procedures for notifying the recognised risk management programme verifying agency in writing, without unnecessary delay, of the following issues relating to the operation of the risk management programme:
a. any significant concern about fitness for intended purpose of any bee product:
b. where the cumulative effect of minor amendments necessitates the registration of a significant amendment to the risk management programme as provided in section 25 of the Act:
c. where the risk management programme is considered to be no longer effective:
d. where the premises are not or no longer suitable for their use:
e. where anything within the physical boundaries of the risk management programme is used for additional purposes or by other operators and the risk management programme has not adequately considered relevant hazards or other risk factors.
12.2.5 RMP Spec 28 (1)
The following activities that result in changes to the risk management programme require registration as an amendment in accordance with section 25 of the Act except where they are done on a trial basis and the affected bee product is not traded:
a. making major alterations to the processing facilities or equipment:
b. relocating processing operations to a new physical address (except where this is already permitted for mobile premises and vessels):
c. processing animal material or animal product that is not covered by the risk management programme, except:
i. where the product and process are similar, and
ii. a documented risk factor identification and hazard analysis has shown that all risk factors associated with that animal material or animal product are already adequately addressed by the risk management programme:
d. setting up a new process or process modification that is not covered by the risk management programme, except:
i. where the process or process modification is similar to existing processes, and
ii. a documented risk factor identification and hazard analysis has shown that all risk factors associated with that process are already adequately addressed by the risk management programme:
e. making any other changes that introduce new risk factors, or adversely impact on existing risk factors:
f. merging two or more registered risk management programmes:
g. splitting a registered risk management programme into two or more risk management programmes:
h. adding a business to a multi-business risk management programme except where the Director-General’s approval under section 17A of the Act applies to a type of business, premises or place rather than to specific businesses.
12.2.6 RMP Spec 28 (2)
The operator must, when making an amendment, consider whether consequential amendments to other components of the risk management programme are necessary.
12.3 Procedures
12.3.1 Scope and frequency of internal audit
12.3.1.1 Internal audits must be undertaken by the person responsible at an appropriate frequency to ensure compliance with the documented RMP, including GMP and process control procedures, and to identify and correct any problems.
12.3.1.2 A review of the RMP must be undertaken at least annually and when:
• significant changes in the product, process or premises are made; or
• the RMP is not working effectively.
12.3.2 Audit procedures
12.3.2.1 Observations made during the internal audit and corrective actions taken must be recorded.
Internal audits should consist of a review of records, reality checks, and confirmation that deficiencies or non-compliances identified from the last audit have been rectified. • completeness and accuracy of required information; • documentation of corrective actions; • any trends, new hazards, recurring problems; and • compliance with documented control procedures. Reality checks should include observation of: • workers’ performance and compliance with documented hygienic procedures and operating procedures, • compliance with process parameters such as processing times and temperatures, and • hygienic status of the premises internal and external environment, facilities and equipment. All deficiencies found at previous audits should be followed up. |
12.3.2.2 When ongoing or recurring non-compliances occur, the following actions must be taken:
a. investigate to determine possible causes of non-compliance;
b. take appropriate corrective actions to regain control and prevent recurrence of the problem;
c. increase surveillance of the system; and
d. review the RMP or the relevant GMP programme and make necessary changes.
Significant amendments to the RMP must be evaluated and registered.
12.3.3 Product testing
12.3.3.1 Moisture content measurements must be performed by a suitably skilled person using documented methodologies (including calibration procedures) and/or calibrated equipment.
12.3.3.2 All results of product tests must be recorded.
12.3.4 Notification procedures
12.3.4.1 The day-to-day manager of the RMP must contact the NZFSA (Attention Programme Manager, Production and Processing, Approvals and ACVM Standards) without delay when it is necessary to notify the Director-General for reasons specified in RMP Spec 25 and 26 (refer to sections 12.2.2 and 12.2.3 of this document).
12.3.4.2 The day-to-day manager of the RMP must notify the recognised risk management programme verifying agency in writing (e.g. by email or letter) as required by and for reasons specified in RMP Spec 27 (refer to section 12.2.4 of this document).
12.4 Records
Records giving the following information must be kept by the operator:
• internal audit reports
• other information or evidence relating to operator verification activities (e.g. test results).
• copies of any communication sent to the NZFSA or the recognised RMP verifying agency.
• any corrective action taken (including restoration of control, product disposition and prevention of recurrence).
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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