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Attachment: Operators affected by NZFSA’s Animal Feeds Review

Background

As outlined previously, the Government has agreed to a number of changes in the way certain secondary processors of pet food are regulated. 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.

The decision to change the requirement was made following a public consultation process undertaken by the New Zealand Food Safety Authority (NZFSA) between August and October 2006. Information relating to NZFSA’s review of regulation of animal feed, including pet food is available on the NZFSA web site at http://www.nzfsa.govt.nz/policy-law/consultation/animal-feeds/index.htm, where you will find the discussion document and associated information paper.

Amendment

The outcome of this review was that, in general, secondary processors of pet food that is raw meat or other animal material or animal product that results from the death of the source animal (e.g. red meat, offal, poultry or fish), that are:

• regulated under the Agricultural Compounds and Veterinary Medicines Act 1997 (ACVM Act 1997); and

• were exempted from additional control mechanisms under the Animal Products Act 1999 (Animal Products Act)

are no longer exempt from additional control mechanisms of the Animal Products Act. This exemption has been replaced by specifications, issued by NZFSA, which require secondary processors of pet food to maintain prescribed documentation to demonstrate that animal material has been procured from regulated sources and to list with NZFSA.

These changes do not affect secondary processors who are required to have a risk management programme.

Of the above secondary processors, the only ones that are not affected by this change, and hence will continue to be regulated under the Agricultural Compounds and Veterinary Medicines Act 1997 (ACVM Act 1997), are those processors that handle:

• raw meat or animal material or animal product that has been rendered; or

• raw meat or animal material or animal product that:

• is acquired in a ready-for sale state; and

• has been subject to primary processing in accordance with a registered risk management programme by an earlier processor.

These changes do not affect secondary processors who are required to have a risk management programme.

Are you affected by these changes?

Secondary processors of pet food who are affected by these changes have been defined in the 10 March 2008 amendment to Animal Products (Exemptions and Inclusions) Order 2000. The Order requires operators that are secondary processing pet food that is raw meat or other animal material or animal product that results from the death of the source animal to comply with any applicable requirements of Parts 2 to 4 of the Act. It should be noted that the Animal Products Act definition of process is “includes kill, slaughter, dress, cut, extract, manufacture, pack, preserve, transport, and store”, which is comparatively broad.

Examples of secondary pet food processors that are affected by the new requirements are operators who:

• manufacture dog rolls;

• manufacture baked biscuits using any animal product other than rendered product;

• receive bulk raw products that are not in retail ready packaging and then package it for retail sale. This may include slicing and/or dicing product prior to packaging.