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Code of Practice: Processing of Bee Products

2 Development of an RMP based on an RMP Template

2.1 Businesses whose products and processes are fully covered by the approved COP

2.1.1 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 relevant RMP template provided in sections 4 and 5 of this document. The RMP template is a simple form that the operator completes by filling in the required information in the appropriate boxes.

The requirements 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 any of their own written procedures.

Confirmation by the operator that the RMP meets all the legal requirements for a valid RMP will simply involve signing a declaration in the RMP template.

2.1.2 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.

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

2.2.1 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 will need to write their own documentation for those parts of the RMP that are not covered or vary from the COP (e.g. HACCP application, 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 process, procedures or parameter to consistently meet all relevant regulatory requirements and produce products that are fit for their intended purpose. Confirmation of the effectiveness of any alternative process, procedure or parameter may involve the collection and analysis of evidence by the operator (e.g. data from testing or trials, published scientific information, report from an expert). A protocol for the collection of data should be prepared by the operator as discussed in Chapter 4 of the Risk Management Programme Manual.

2.2.2 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.

2.3 Steps for the development, registration and implementation of an RMP based on the RMP template

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