Analysis of Submissions: Proposed amendment to the Animal Products (Specifications for Products Intended for Animal Consumption) Notice 2006

Proposed amendment to the Animal Products (Specifications for Products Intended for Animal Consumption) Notice 2006

No.

Clause

Submission comment¹

NZFSA Response

3

General

We have been through the proposed amendments and reasons and agree with them all. We have no issues with any of them.

Our only concern is that the intention of the proposed amendment is clearly stated but the proposed new wording was not presented. It is our belief that the actual wording proposed should have been published in order that we can check that the intention is being delivered without any inaccuracy or ambiguity.

This is particularly a problem for the three proposed amendments in table two relating to the implementation of the outcomes of the Animal Feeds Review.

NZFSA have taken a general approach to consult on a clear intent rather than specific proposed wording. The intent of the proposal is the important aspect rather than the details of the wording.

4

General

I have reviewed the proposed changes set out in Table 1. There are only a few that might affect rendering operators, and none of these appears to be of concern.

I do not feel able to comment on the proposals outlined in Tables 2 & 3.

Submission agrees, in general, with the overall proposal.

2

4(1)

Deleting reference to crude carbolic acid etc. I am not sure if this is an issue. Although we have used "Jeyes Fluid" in the past I am not aware of anyone currently applying to raw offal for rendering. We have anecdotal evidence that the use of Jeyes Fluid is beneficial to the stability of the offal, having the dual effect of denaturing and giving improved FFA of tallow. It would be a pity to lose the opportunity to further trial this. If trials were to be done for residue testing I would be concerned at the level of proof required for clearance. Plants can arrange their own trial in this regard, but what is the acceptable level when taking in to account that the meal is to be further processed at the feed mill. Is this a commercial decision depending on their process and the final user (species)?

Addressed by the following NZFSA response.

4

4(1)

The proposed change to “Denatured animal material and product” re carbolic acid could perhaps allow for a risk assessment of its use, rather than an outright ban, but I note that this would require specific knowledge of the intended use of the material.

Submission agrees with the proposal.

The use of carbolic acid and cresylic disinfectant will continue to be allowed but the operator will have to determine by analysis that the use will not adversely affect the suitability for processing of animal material, or fitness for intended purpose of the animal product.

1

15(1)

In effect, does this mean that unless the water being used is from the “public / town supply” you need to have a water reticulation management plan?

Yes, that is correct. This was a requirement in the original specifications and has not been changed as a result of this amendment.

The change only related to the examples of water sources other than “of a standard administered by an independent supplier under the Health Act 1956”. The amendment has no impact on what operators are required to do.

1

28(4)

We agree with the clarification of this labelling requirement to only include imported “live” animals and not imported animal products.

Submission agrees with the proposal.

1

32(2) and 32(4)

Can a RMP premises choose to follow either subclause?

i.e. when transferring bulk animal material from one RMP premises to another we could choose to either denature it and transport it in covered leak-proof bins (as per 32(2)) or use secure leak-proof bins without denaturing it (as per 32(4)).

Your description is correct.

Bulk animal material or product for further processing, including for rendering being transported between premises operating under risk management programmes may use either option. All requirements relating to the option chosen must be met.

2

32(2) and 32(4)

Rewording seems reasonable.

Submission agrees with the proposal.

1

32(4)(a)

Is the intent for the bins to be lockable or would the term “tamper evident” be more appropriate.

In practice this requirement could be difficult to meet. We receive fish material for rendering from RMP premises and it is transported in various manners e.g. in small chiller trucks, large (covered) tip truck (specifically designated for fish scraps). In the latter case the cover is a heavy duty tarpaulin held down by bungee cords (like used on a ute). The fish scraps are transferred directly from their premises to ours.

Also, do fish cases fit into this category as the fish material is not packaged as such?

Would a chiller truck be expected to be padlocked?

What is the risk that is being managed by having a “tamper proof closure”?

Most fish is minimal risk raw material and therefore Clause 73(1) regarding security doesn’t apply (and there is no equivalent requirement for minimal risk raw material, whether it is to be rendered or not).

In the case of minimal risk raw material derived from fish a provision has been added that exempts it from the requirement to denature or use a “tamper proof” closure.

2

32(4)(a)

I have concerns at the requirement for "secure sealed" which is apparently a current requirement and not proposed for change. I have not been aware of this requirement. Product transported in bulk truck & trailer units is always covered by a tarpaulin but to my knowledge never sealed.

This issue was followed up with the submitter, it related to materials that were covered by 73(2). Clarifying the relationship between 32(2) and 73(2) has addressed this concern.

4

32(4)(a)

The change proposed for 32(4)(a) to allow for “tamper evident” rather than “secure sealed” appears reasonable.

Submission agrees with the proposal.

1

Clause 32(2)

[Linkage to 73(2)]

Good idea to have a linkage to sub-clause 73 (2).

However, most fish is minimal risk raw material and may not necessarily be rendered either (e.g. packing fish heads) so aren’t covered by 73(2).

In effect denaturing is still required (or a “tamper proof closure” if you follow 32(4)).

In the case of minimal risk raw material derived from fish a provision has been added that exempts it from the requirement to either denature or use a “tamper proof” closure.

4

Clause 32(2)

[Linkage to 73(2)]

Clarification of the relationship between 32(2) and 73(2) would be welcome. The exception should be clearly defined.

Submission agrees with the proposal.

1

35

We agree with changing the requirement to “one-up / one-down” traceability.

Submission agrees with the proposal.

2

35

Traceability should be on a "one down/one up basis" i.e. supplying meet works and purchase of meal/tallow.

Submission agrees with the proposal.

1

75

We agree with this change to improve clarity.

Submission agrees with the proposal. Refer to following row for further information.

2

75

Agree with removal of "where appropriate", however I have concerns about the definition of "microbiological surveillance".

This clause relates to medium risk raw material. In this situation it is considered that microbiological surveillance is always considered necessary. Therefore “where appropriate” has the removed. Submission agrees with this part of the proposal.

The proposal to clarify the term “microbiological surveillance” has been rejected in favour of addressing this in the Rendering Code of Practice.

4

76

I assume that the proposed change to Clause 76 will make clear that tallow with insoluble impurities below 0.15% is to be treated as if it was not of ruminant origin.

The change to clause 76, which has now become clause 82A, does make it clear that tallow is considered to be protein free if the maximum level of insoluble impurities in the tallow does not exceed 0.15% by weight.

1

86

We agree with this change to improve clarity.

Submission agrees with the proposal.