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Removal of RMP 3 Year Review

25 November 2008

From 1 July 2008 operators of registered risk management programmes will no longer be required to submit a three year review of their programmes to the New Zealand Food Safety Authority.

The requirement to undertake a review of your Risk Management Programme (RMP) within one month of the 3 year anniversary of the initial registration date has been in effect since the implementation of the Animal Products Act 1999 (APA). To satisfy the requirement NZFSA provided two options:

• Obtain a full re-evaluation of the RMP by an accredited evaluator; or

• Complete the RMP 3 year review form.

The requirement for review was implemented to ensure that operators met their obligations under the Act, specifically to provide evidence that:

1. any significant amendments have been registered;

2. the plan is still operating as intended and remains applicable to all operations within its physical boundaries;

3. any minor amendments are captured

During the development of the Animal Products (Risk Management Programme Specifications) Notice 2008, NZFSA reviewed the purpose of the three year review. The review identified that the requirements being managed by the three year review process were already being adequately addressed through the verification process and through the operators own systems for notification.

As a result the decision was made to remove the requirement on operators to submit a formal review of their risk management programme to NZFSA. Operators will now be expected to ensure that they are meeting their obligations under the APA by continuing to update and amend their RMPs as required, and through use of notifications or applications for certain matters in respect to their RMPs.

What does this mean?

As at 1 July 2008 NZFSA will cease processing three year reviews. As an operator you are no longer required to submit a three year review to NZFSA on or prior to the date specified in the documentation that accompanied your current notice of registration.

NZFSA has developed a form to facilitate notifications to NZFSA or changes to your risk management programme that do not require registration under section 25 of the Animal Products Act 1999 but are required to be notified or are of a nature that impact registration details that are to be shown on the public register of risk management programmes. This can be found at: http://www.nzfsa.govt.nz/animalproducts/publications/forms/index.htm

Operator Responsibilities

As an Operator under the APA you are responsible for the continued maintenance and amendment of your risk management programme to ensure the programme is still operating as intended. Operators of a registered risk management programme are reminded of the following duties:

1. To ensure that the operations of the animal product business do not contravene the relevant requirements of and under this Act, including the requirements set out in the risk management programme;

2. To ensure that the risk management programme is consistent with the requirements of regulations and specifications in force from time to time under this Act;

3. To adequately implement and resource all operations under the programme, including provision for the instruction, competency, and supervision of staff to ensure the delivery of animal product that is fit for intended purpose;

4. To ensure that all operations under the programme are commensurate with the capability and the capacity of the premises or place, facilities, equipment, and staff to deliver animal product that is fit for intended purpose;

5. To give relevant recognised persons such freedom and access as will allow them to carry out their functions and activities under this Act, including verification functions and activities;

6. The operator of a registered risk management programme also has the duty to notify the Director-General, in advance where practicable, and otherwise as soon as possible, of any change in the operator’s recognised risk management programme verifying agency.

Additional requirements on operators of RMP’s are specified in the in the following publications:

Animal Products (Risk Management Programme Specifications) Notice 2008

Animal Products (Requirements for Risk Management Programme Outlines) Notice 2008

Animal Products Act 1999 Statement of Policy: Operator Responsibilities during Registration of a Risk Management Programme (Version 1)

If you have any questions in regards to the removal of this requirement or are unsure what you are required to do please email approvals@nzfsa.govt.nz .

Charlotte Treffers

Advisor (Production & Processing)

Approvals and ACVM Group