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Proposed amendment to the Verification 2005 Statement of Policy: operators affected by the NZFSA’s Animal Feeds Review

30 July 2008

«Name»

«Add1»

«Add2»

«Add3»

Dear Sir or Madam

Introduction

This letter is to advise you of a proposed amendment to the Verification 2005 Statement of Policy, relating to certain secondary processors of pet food for the New Zealand market. The proposed amendment is part of implementing the outcome of the NZFSA’s Animal Feeds Review.

This is the third letter sent to secondary processors of pet food outlining various aspects of implementing the outcome of the NZFSA’s Animal Feeds Review. The previous letters, dated 30 October 2007 and 9 June 2008, are available on the NZFSA web site at http://www.nzfsa.govt.nz/animalproducts/subject/petfood/index.htm.

The background outlining which operators are affected by the NZFSA’s Animal Feeds Review is included in Attachment 1.

Animal product businesses that are operating under a risk management programme (RMP) will not be affected by the proposed amendment.

Relationship between the proposed amendment to the “Verification 2005 Statement of Policy” and the “Draft Export Verification Statement of Policy Animal Products”

The Draft Export Verification Statement of Policy Animal Products was recently published on the NZFSA web site. When it is finalised, it will replace the export part of the Verification 2005 Statement of Policy.

The NZFSA requirements for the performance of verification activities for animal product businesses that only supply the New Zealand market will continue to appear in the Verification 2005 Statement of Policy in the interim. In the longer term this will probably be replaced by a dedicated New Zealand market Verification Statement of Policy.

Verification

Background information relating to verification, under the Animal Products Act, is outlined in Attachment 1.

Proposed amendment to the Verification 2005 Statement of Policy (and subsequent amendment)

It is proposed to amend Schedule 2, Initial verification frequencies and ceiling by deleting the following three categories:

Table 1: Existing verification frequencies and ceilings

Animal product business	Domestic
	Highest initial frequency	Ceiling frequency
Primary and secondary processors of seafood for human and animal consumption, including fishing vessels	Step 5	Step 7
Secondary processors of mammals and birds for animal consumption	Step 7	Step 7
All other processors of animal product for animal consumption	Step 5	Step 7

And replacing them with the following items:

Table 2: Proposed verification frequencies and ceilings

Animal product business	Domestic
	Highest initial frequency	Ceiling frequency
Primary and secondary processors of seafood for human consumption, including fishing vessels	Step 5	Step 7
Secondary processors of animal material or product for animal consumption operating under a risk management programme (RMP)(1)	Step 7	Step 7
Secondary processors of pet food(2) that: • is raw meat or other animal material or animal product that results from the death of the source animal; and • sells animal material or animal product by way of wholesale; and/or • undertakes processes other than size reduction or packing; • Note: refer exemptions below.	Step 7	Step 7
Secondary processors of pet food(2) that: • is raw meat or other animal material or animal product that results from the death of the source animal; and • sells animal material or animal product by way of retail sale only; and • whose processing are limited to size reduction and/or packing; • Note: refer exemptions below.	Step 8	Step 8
All other processors of animal product for animal consumption	Step 5	Step 7

⁽¹⁾ secondary processors of animal material or product are required to operate under a risk management programme (RMP) if they intend to export animal product, which requires an official assurance.

Secondary processors of animal material or product that only produce animal product for the domestic (New Zealand) market are not required to operate under a RMP. If they elect to operate under a registered RMP, verification of the RMP must be preformed in accordance with the verification frequencies and ceilings relating to RMPs.

⁽²⁾ pet food means any material prepared and traded as food for cats or dogs, and includes any such product intended for cats or dogs but fed to other pets or captive animals.

This definition is from the Animal Products (Exemptions and Inclusions) Order 2000.

Where the relevant verification step frequencies mentioned above are:

Table 3: Performance based verification frequencies

Verification step	Verification frequency
Step 5	3 monthly
Step 6	6 monthly
Step 7	1 yearly
Step 8	5 yearly (20% of businesses within the business category each year)

It must be remembered that the verification frequency can become more frequent if the outcome of verification visits are unacceptable.

Initial verification

Secondary processors of pet food will be required to list annually with NZFSA in accordance with the relevant specifications that are to be included in the Animal Consumption Specifications. The initial listing with NZFSA must occur by 1 October 2009.

Prior to being listed as a secondary processors of pet food that is animal material or product (including raw meat) that results from the death of the source animal, an initial verification visit must be completed by a recognised verifying agency. The verifying agency will provide the operator with a report relating to this verification, a copy of which must accompany the application for initial listing. This verification must be completed within 3 months of applying for this listing.

The purpose of this verification visit is to verify compliance with the relevant specifications that are to be included in the Animal Consumption Specifications, relating to procuring animal product from regulated sources and being able to demonstrate this has occurred, before the operation commences.

Costs associated with verification

Individual operators subject to the above verification requirements will be charged for these verification visits. The charge will reflect the verifier’s time relating to the verification, including preparation, on-site visit and writing up the result of the verification. A cost will also be incurred to cover the verifier’s travel costs. The overall cost will depend on the complexity and size of the operation. For operators who receive bulk raw products that are not in retail ready packaging and then package it for retail sale (whether or not they slicing and/or dicing product prior to packaging) would incur a charge in the vicinity of $300 plus the verifier’s travel costs to and from the operators premises.

Other costs

There will be costs that individual operators will be charged that are additional to the verification costs that are described above. As a result these are outside of the proposed amendment to the Verification 2005 Statement of Policy relating to operators affected by the NZFSA’s Animal Feeds Review.

Costs associated with annual listing

The Animal Products (Fees, Charges, and Levies) Regulations 2007 also include specified charges for various other applications and listings fees. Currently there is no provision for an annual listing fee for the secondary processing of petfood described above. An indicative fee for this listing would be $200 incl. GST.

You are invited to make submissions in this draft by 5:00 pm, Friday 29 August 2008.

Submitters are asked to include the following information with their submission:

• The name and title of the submitter;

• Organisation’s name where applicable;

• Submitters address and contact details (phone, fax and email if available);

• The title and number of clause(s) commented on where appropriate.

Submissions should be addressed to:

Lennox Vellekoop

Programme Manager (Animal Products)

New Zealand Standards

NZFSA

PO Box 2835

Wellington

Fax: 04 894 2643

Alternatively, responses can be emailed to lennox.vellekoop@nzfsa.govt.nz

All submissions are subject to the Official Information Act 1982. Therefore if you consider that all or part of your submission is commercially sensitive or should be treated as confidential, please state this clearly when making your submission.

Yours faithfully

Judy Barker
Assistant Director (Production & Processing)

New Zealand Standards Group