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Animal Products Act – Risk Management System

January 2006

Animal Products Act 1999
Information Pamphlet

The Animal Products Act, establishes a regulatory regime that requires all animal products traded and used to be ’fit for intended purpose' by meeting the appropriate New Zealand animal product standards. The risk management system potentially covers all animal material along the production and processing chain from source to the market.

The risk management system comprises the following main types of controls:

• risk management programmes;

• regulated control schemes;

• controls relating to animal material and products exports; and

• controls on certain functions.

Risk management programmes

A risk management programme (RMP) is a written programme designed by each animal product business to manage its biological, chemical and physical hazards. A RMP is based on the principles of Hazard Analysis and Critical Control Point (HACCP).

A RMP will require:

• identification of the business name and the name of the person who is ultimately responsible for the programme;

• definition of the scope of the business and identification of the products and their intended use;

• systematic identification and analysis of the hazards inherent in animal material, animal product and processes;

• detail of how those hazards will be managed;

• documentation and record keeping; and

• provision for verification by recognised agencies independent from the business.

These programmes are to be tailored by individual businesses to deliver products that are fit for intended purpose. However many industries have developed RMP Codes of Practice that incorporate a template and/or model RMP. Aspects which require some degree of tailoring include the animal materials used, the processes used and the product range. Standards are to be outcome based and an RMP describes the procedures that will be implemented by the business to achieve the relevant standards.

Registration of risk management programmes: All RMPs are to be registered with the NZFSA. An RMP that is tailored for a specific business would likely require evaluation by an independent person (an NZFSA recognised evaluator), whereas an RMP that is fully based on an NZFSA approved template would not. Key information about a registered RMP (not commercially sensitive) is published on a register maintained by NZFSA.

Verification: The operation of an RMP must be verified on an ongoing basis. This is to check that the business is doing what the RMP says it will and that the RMP continues to deliver product that is fit for intended purpose. Verification must be performed by an NZFSA recognised verification agency.

Within certain limits, verification is performance based allowing for variation in scope, depth and frequency of verification that needs to be undertaken. Good performing operators will benefit over time.

Regulated Control Schemes

Regulated control schemes (RCS) allow the NZFSA to set up requirements for the management of hazards not able to be managed by individual risk management programmes or by animal product business operators — or which might be more cost effectively managed by this means. An RCS may be established to meet NZ standards or for overseas market access purposes.

These schemes are expected to apply mostly to monitoring hazards at source or for applying controls to certain parts of the production or processing chain.

Export of animal material and products

The Animal Products Act aims to ensure that export requirements are consistently met, and to manage risks to the integrity and reputation of New Zealand's official assurances and systems. The Act does not require mandatory export certification. It provides for the issue of official assurances to be given (these are usually in the form of certificates). The Act also provides for Government to issue statements as to New Zealand animal product standards in other situations.

Safeguards for export products include:

• registering exporters;

• placing duties on exporters;

• provisions set by the Director-General relating to the issuance and use of official assurances;

• New Zealand's interpretation of market access requirements;

• MAF-provides and maintains information covering overseas market access requirements available to exporters and others with the need to know.

Performance of key functions

Key functions, such as the evaluation of RMPs, are required to be performed by persons that are recognised by the NZFSA. This is to ensure individuals are competent to do the job. Also, some functions require the persons performing them to be subject to the management of a recognised agency. This is to ensure that there are management systems in place to ensure the continual delivery of the function. Specific duties apply to both recognised agencies and persons.

In addition the risk management system identifies the following key responsibilities:

• Duties apply to all risk management programme operators.

• Exporters are required to be registered – and duties apply to them.

NZFSA is responsible for administering the Animal Products Act, for setting New Zealand animal product standards and specifications (after consultation with affected parties), providing official assurances and for all associated approvals and registrations. NZFSA is responsible for monitoring and auditing the risk management system and addressing non-compliance.

This publication is not a legal interpretation of the Animal Products Act or the Animal Products (Ancillary and Transitional Provisions) Act and is intended only as a guide.