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Progress on implementing the outcome of NZFSA’s Animal Feeds Review:

6 May 2009

«Name»

«Add1»

«Add2»

«Add3»

Dear Sir or Madam

Requirements on operators affected by the Animal Feeds Review

The purpose of this letter is to update you on progress with implementation of the outcome of the NZFSA’s Animal Feeds Review that has occurred since my letter dated 30 July 2008. The main change since my last letter is the issuing of requirements, which are outlined below.

If you are unsure whether you are affected by the changes outlined in this letter you should refer to the attachment, which outlines who is affected. It also recaps on some of the information provided in previous letters, available under the heading ‘Animal Feeds Review’ on the NZFSA web site at http://www.nzfsa.govt.nz/animalproducts/subject/petfood/index.htm.

Animal Products (Specifications for Products Intended for Animal Consumption) Notice 2006 requirements

An amendment¹ the Animal Products (Specifications for Products Intended for Animal Consumption) Notice 2006 (AC Specs) was signed on the 20^th of April 2009. The majority of the requirements in this amendment came into force on the 1^st of May 2009. The only exception is a listing requirement that comes into force in the 1^st October 2009 and is explained later in the letter.

Operators affected by the ‘Animal Feeds Review’ are referred to as ‘further (pet food) processors’ in the AC Specs and are required to meet specific requirements outlined in ‘Part 7A – Further processing of pet food’. A copy of the relevant information from the Animal Products (Specifications for Products Intended for Animal Consumption) Notice 2006, Administration Consolidation (Version 1) has been included for your information. This Consolidation is simply the original AC Specs and amendment combined into one document for easier reading.

If you are a secondary processor, who is operating under a registered risk management programme (RMP) that covers all your operations, you are not affected by these changes. This may be because you export and require official assurances or you have elected to operate under a registered RMP.

The three significant requirements in Part 7A that ‘further (pet food) processors’ must meet are:

1. listing with NZFSA; and

2. procuring animal material for further (pet food) processing only from regulated sources²; and

3. have a documented tracking system that demonstrates compliance with the requirement to only procure from regulated sources.

1. Listing

Existing ‘further (pet food) processors’ are required to list with NZFSA, using ‘Listing Form AP61: Listing of Further (Pet Food) Processors with NZFSA’, by 1 October 2009. A copy of this form has been enclosed for you to complete.

Presently there is no fee for listing as a ‘further (pet food) processor’ and this will be the case until 1 July 2009. NZFSA has consulted³ on an application fee of $149.60 per application plus an assessment charge on hourly basis. Therefore when the fees and charges⁴ are next updated in July 2009 there is likely to be an NZFSA service charge for listing but if you apply prior to 1 July there will be no fee.

After initial listing, all ‘further (pet food) processors’ must re-list when the information (e.g. business name) provided in this listing form changes, except for changes to the principal categories of processing (section 5 of AP61). If there are any changes to the details provided in section 5 you must advise NZFSA as outlined in AP61 but re-listing is not required in this situation.

When NZFSA consulted on these proposed requirements⁵ annual listing with NZFSA was proposed. This proposal was changed to only require re-listing when key details change e.g. business name, the general processing operations undertaken (section 4 of AP61). Therefore if there are no changes to the key details for a number of years, re-listing will not be required.

2 & 3. Demonstrating that animal material has been procured from regulated sources

To meet this requirement you will need to have a ‘traceability and inventory control’ system, which is essentially just a recording system for incoming product, product ‘in store’ and outgoing product. To clarify, your outgoing records do not have to identify individuals who buy retail pet food, identify these as retail sales would be sufficient.

If you have an existing ‘traceability and inventory control’ system this will probably already meet the new requirements. You may wish to review Part 7A to confirm that you are recording all the relevant information.

NZFSA is currently developing a simple ‘traceability and inventory control’ system. This is to assist smaller ‘further (pet food) processors’ who either do not currently have a system in place or do not have an adequate system. Use of the NZFSA developed system will not be a requirement therefore you can still develop your own system.

NZFSA will be writing to you again shortly with a copy of this system, if you wish to use it.

In the interim, until this guidance NZFSA will not take any actions against ‘further (pet food) operators’ who are not able to demonstrate that the animal material they are using has been procured from regulated sources.

Verification

To be able to demonstrate that animal material has been procured from regulated sources the operator must be able to trace this animal material through to animal products that have been produced.

‘Further (pet food) operators’ will be subject to verification to ensure they are complying with the requirements outlined above. The verification frequency will be as consulted on in my last letter, dated 30 July 2008, namely:

- yearly, in the case of operators who sell animal material or animal product by way of wholesale and/or undertakes processes other than size reduction or packing; or

- 5 yearly (20% of businesses within the business category each year), in the case of operators who sells animal material or product by way of retail sale only and whose processing are limited to size reduction and/or packing.

Operators 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.

If you have any queries regarding this letter please contact:

Lennox Vellekoop

Programme Manager (Animal Products)

New Zealand Standards

NZFSA

PO Box 2835

Wellington

Ph: 04 894 2632

Fax: 04 894 2643

lennox.vellekoop@nzfsa.govt.nz

Yours faithfully

(signed)

Judy Barker
Assistant Director (Production & Processing)

New Zealand Standards Group

¹ The title of this amendment is the Animal Products (Specifications for Products Intended for Animal Consumption) Amendment Notice 2009.

² A ‘regulated source’ is a source of ‘regulated animal product’ and includes risk management programme operators, other ‘further (pet food) processors and processors operating under the Food Act 1981. ‘Regulated animal product’ is in turn is defined in the Animal Products Act 1999.

³ In the NZFSA ‘Fees and Charges for Approvals and Related Functions, Public Discussion Paper No 01/08, March 2009’

⁴ Specified in the Animal Products (Fees, Charges, and Levies) Regulations 2007.

⁵ In the ‘Proposed amendment to the Animal Products (Specifications for Products Intended for Animal Consumption) Notice 2006’