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Changes to Risk Management Programme Template for Eggs
12 June 2007
Name
Title
Company
Address
City
Dear Egg Producer
Egg producers have a duty under the Animal Products Act 1999 to amend their Risk Management Programmes (RMPs) to comply with current legislation. There have been amendments to legislation which require changes to all egg producers’ RMPs.
To assist egg producers with meeting their duties, NZFSA has amended the RMP Template for Eggs to:
- cover changes to legislation1;
- clarify several sections of the RMP Template based on feedback from egg producers and external verifiers;
- make it easier for future updates by putting all of the pages that must be filled out at the front of the document; and
- simplify the requirements for the three year review.
Amendments and additions to the RMP Template are highlighted in the new version for ready identification. The attached table provides a summary of changes to the Template and the reasons for the changes where this is not obvious.
The new Risk Management Programme Template for Eggs is posted on the New Zealand Food Safety Authority website at:
http://www.nzfsa.govt.nz/animalproducts/subject/eggs/index.htm .
In addition, to help egg producers with making the necessary changes, NZFSA has provided a copy of the RMP Template attached to this letter.
What does this mean for egg producers who already have registered RMPs?
Egg producers must bring their RMPs up to date by 31 July 2007. Instructions on how to do this are given below for each type of RMP currently registered.
Egg producers normally have to fill out a checklist at the 3 year anniversary of their RMP registration, explaining what changes they have made to the RMP. Egg producers that change to the new template will not have to use the checklist. Egg producers will need to confirm that they have changed to the new Template by completing and returning the declaration provided for this purpose.
The changes to the template are considered Minor amendments to an RMP, providing you are already the registered Operator of an RMP, so there is no requirement for evaluation or re-registration of the RMP.
The verifier will check that you have updated your RMP correctly at their next verification visit.
You must keep a copy of your old RMP for at least 4 years – but should clearly write on it that it is “out of date” and file it away so it is no longer used.
A. Further Instructions for egg producers with RMPs fully-based on the old Template
To amend your registered RMP, follow the instructions given in column 2 of Table 1 (which is attached to this letter).
B. Further Instructions for egg producers with RMPs partly-based on the old template
These egg producers must change the Template section of their RMP from the old to the new Template as described in “A” above.
In addition, any parts of their RMP that are not based on the template must be amended to incorporate changes made to current legislation, e.g. human consumption specifications (see web link in footer on front page). If any of these parts cover secondary processing of eggs, you may keep this as a separate attachment (amended as necessary) to the RMP Template. Alternatively you may decide to remove the secondary processes from the scope of your RMP and have them regulated under the Food Act regime.
C. Further Instructions for egg producers who have not used the template to develop their RMP
NZFSA strongly recommends that, for ease of updating and verification, these egg producers convert to the new RMP Template.
If you choose to continue with your customised RMP, you will have to make amendments to ensure that it is consistent with current legislation, e.g. human consumption specifications (see web link in footer on front page).
If part of your RMP covers secondary processing of eggs, you may keep this as a separate attachment (amended as necessary) to the RMP Template. Alternatively you may decide to remove the secondary processes from the scope of your RMP and have them regulated under the Food Act regime.
NZFSA welcomes feedback on suggested improvements to the RMP Template that may be considered for the future. If you have any suggestions for improvement, questions or would like further information please contact your external verifier in the first instance.
Disclaimer
Considerable effort has been made to ensure that the information provided in the Egg Risk Management Programme Template is accurate, up to date, and otherwise adequate in all respects. Nevertheless, this Template is approved STRICTLY on the basis that the Crown, the New Zealand Food Safety Authority, its statutory officers, employees, agents, and all other persons involved with the writing, editing, approval or publication of, or any other kind of work in connection with the Egg Risk Management Programme Template:
- a) disclaim any and all responsibility for any inaccuracy, error, omission, or any other kind of inadequacy, deficiency, or flaw in, or in relation to, the Egg Risk Management Programme Template; and
- b) without limiting a) above, fully exclude any and all liability of any kind, on the part of any and all of them, to any person or entity that applies the Egg Risk Management Programme Template.
Yours faithfully
Sharon Wagener
Senior Programme Manager (Production and Processing)
New Zealand Standards Group
Table 1: Amendments to the RMP Template for Eggs
Amended Sections |
Instructions |
Pages |
Summary of Changes |
Reasons for Changes |
Risk Management Programme – business specific section |
All egg producers to fill in pages 1-14. Those egg producers that already have verification occurring do not need to get the letter referred to on the bottom of page 13, those that do not already have verification occurring will need to get the letter by contacting the person indicated in the foot note. All egg producers must sign and date the confirmation section on page 14, but only those with a multi-business RMP need to fill in pg 15. The majority of details required in pages 1 – 15 will be in the current version of your RMP, it is simply a matter of checking them to make sure they are current and writing the information into the new version of your RMP. To ensure that the information NZFSA has on file is current, the verifier will request a copy of the completed pages 1 - 15 at their next verification visit (either photocopy it or fill in two copies, one for yourself and one for the verifier) |
1-14 |
Change in format so that all “fill-in” parts are at the front of the Template rather than dispersed throughout the document. |
The revised format is intended to make it more obvious which parts of the RMP the egg producer must fill in and to make it easier to amend the RMP in the future. |
1 |
Reformatting of information relating to the nature of the egg producers business. |
Aligns to other NZFSA Templates and is clearer. | ||
2 |
Added surplus eggs from breeder farms. Added requirement for egg producers whose RMP does not cover both layer farm and packhouse, to explain why. |
Some eggs from breeder farms are used for human consumption. This was not allowed for in previous template. Some RMPs do not cover layer and packing operations eg: eggs are sent to another RMP for packing, unclear in version 1. | ||
3 |
Clarification of storage requirements related to shelf life (best before) claims. |
Shelf life of eggs is dependant on storage temperature and acceptable options are now provided for egg producer to select from. | ||
4 |
Added latest Human Consumption specification 107. |
So egg producers have latest requirements. | ||
4 - 9 |
Section 7, which begins on this page, now brings together all the Process Description and Controls formerly dispersed throughout Template. |
Much of the process control information that used to be in Attachment Q is operator-specific so it is better placed with other information about the operation. | ||
4 |
Feed manufacture moved to more logical place with clearer options given. |
The options reflect current industry practices that have been observed. | ||
5 - 6 |
Minor changes to various sections. |
To add clarity. | ||
7 |
Clarification of egg cleaning and washing requirements, including that only approved chemicals may be used. There are now more egg washing chemicals approved (4 in total) for egg producers to choose from refer http://www.nzfsa.govt.nz/animalproducts/registers-lists/manual15/index.htm. Egg drying has been separated out. |
Egg cleaning and washing is a key issue and poor egg cleaning/washing practices can be a risk to food safety. The revisions are intended to ensure safe egg cleaning and washing practices by egg producers | ||
8 |
Candling requirements clarified. |
Only eggs that are for human consumption must be candled. Eggs that have been pasteurized do not need to be candled. | ||
9 |
Operator-specific water information moved to here. |
To keep operator specific information together. | ||
10 - 12 |
Operator specific cleaning information moved to here. |
To keep operator specific information together. | ||
13 |
Footnote added with VA contact details. |
Information in original template’s cover letter is now out of date. | ||
14 |
Amended RMP document list with new and amended sections highlighted. |
To align with all other changes. | ||
15 |
Extra information required for multi-business RMPs |
Moved from separate guidance document. | ||
Record 1: Assessment of Water Supply Status |
If you have your own water supply, fill in all relevant parts of Record 1. If your water is from town supply, leave Record 1 blank. |
1 to 7 |
This is a completely new document, amended to align with changes to Human Consumption specifications, and to clarify requirements. It has also been moved so it is closer to other operator-specific information. |
Feedback was that the original version was difficult to follow. The action expected to fix any risks to the water (area where the water was “unsatisfactory”) was unclear. |
All Attachments |
Operator specific information moved to earlier section. Record requirements moved to Attachment P. Some other attachments reordered. Other minor changes. Monitoring clause reworded. Cross References updated. |
To add clarity or to align with changes to overall structure of document. | ||
Attachment D - Personnel Health & Hygiene |
2 |
Clarification of personnel and visitor requirements when moving between contaminated sheds. |
||
Attachment F - Layer Feed |
1 |
Moved from G. Reworded feed storage requirements to provide options other than silo storage. Management of feed storage container requirements clarified and provision made for feeding crops and food scraps to free range birds. |
Raised by egg producers at the 2005 Workshops. | |
Attachment G - Whole Flock Health Scheme |
1 - 2 |
Moved from F. Removal of specific reference to the Salmonella vaccine MeganVac. More information given on agricultural compounds and vet meds. |
Other types of registered vaccines are now available. Verifiers have identified incorrect use of chemicals on birds for mite control as a problem. | |
Attachment H - Water |
1 - 2 |
New requirement for LAS rather than MILAB approved laboratories. Option added for E coli or faecal coliform testing. Other minor changes. |
To align with changes in the Human Consumption specifications | |
Attachment J - Product Contact Packaging |
1 |
Minor amendments supplier guarantees for reused packaging no longer required, but reused packaging must be clean and correctly labeled. |
Raised by egg producers at the 2005 Workshops. Also to align with Human Consumption specifications. | |
Attachment K -Traceability/ Inventory/Labelling |
1 -2 |
Minor amendments. |
To align with changes in the Human Consumption specifications. | |
Attachment N – Operator Verification |
1 |
Requirements simplified. |
||
Attachment P - Records |
1 - 3 |
New section 4. |
Minimising the records required and including all required records in one location should make it easier for egg producers to comply with the RMP record keeping requirements. | |
Whole RMP = Business-specific Pgs 1-15, Record 1 & Attachments A - R |
Read, date and sign or initial each page. |
|||
Old RMP template |
Mark as “obsolete” and file for 4 years. |
Three Year Review Declaration by Egg Producers
Date: |
___________________________________________________________________________ |
Egg RMP Identifier: |
___________________________________________________________________________ |
Print name of person signing declaration: |
__________________________________________________________ |
(person signing declaration is to be the RMP Operator or Day to Day Manager)
To whom it may concern,
In consideration of the requirement to conduct a review of my Risk Management Programme within three years of registration, I confirm that I have amended my Risk Management Programme to comply with the current version of the Egg Risk Management Programme Template (version date June 2007).
Yours sincerely
Egg RMP Operator or Day to Day Manager of Egg RMP
__________________________________________________________________________
Post, fax or email completed declaration to the following address:
Glen Bradbury
Senior Advisor (Approvals – Production & Processing)
NZFSA
Approvals and ACVM Group
Level 5 - Telecom Network House
South Tower - Telecom Network House
68-86 Jervois Quay
PO Box 2835
WELLINGTON
Fax: 04 894 2566
glen.bradbury@nzfsa.govt.nz
1 In particular the the Animal Products (Specifications for Products Intended for Human Consumption) Notice - see http://www.nzfsa.govt.nz/animalproducts/legislation/notices/animal-material-product/human-consumption/admin-consolidation-of-hc-spec.pdf
New Zealand Food Safety Authority
68-86 Jervois Quay
PO Box 2835
Wellington
NEW ZEALAND
Phone: +64 4 894 2500
Fax: +64 4 894 2501
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