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Risk Management Programme Manual for Animal Product Processing

2 Resources for Developing an RMP

Amendment 3

October 2009

2.1 Introduction

This section discusses the various resources that you can use when developing your RMP.

The main resources that are available are:

1. this RMP Manual

2. the Animal Products Act 1999 and associated legislation (see 2.2)

3. codes of practice, templates and models (see 2.3)

4. dairy operational guidelines (see 2.4)

5. HACCP Plans (see 2.5)

6. generic RMP models (see 2.6)

7. existing procedures (see 2.7)

8. peer-reviewed scientific information (see 2.8)

9. predictive models (see 2.9); and

10. approved food safety programmes (see 2.10).

The development of tailor-made RMPs requires special skills, particularly in relation to HACCP application and the identification and analysis of risk factors.

You should seek external assistance if your own resource or skill level is limited. If you elect to use a consultant, you should choose one who has relevant industry experience and is either a recognised person (e.g. evaluator or verifier) or otherwise experienced with the APA and RMP requirements. If a recognised person is acting as a consultant then that person will not be able to verify or evaluate your RMP within certain time frames. This requirement is explained in the ‘Independent Evaluation and Verification of Risk Management Programmes’ Statement of Policy. This statement was written for non-dairy operators, but can also be applied to dairy operators.

2.2 The Animal Products Act 1999 and Associated Legislation

The Animal Products Act 1999 and its associated legislation are administered by the New Zealand Food Safety Authority. The legislation provides the regulatory requirements that all operators must comply with. The APA regime includes the following types of legislation:

• Acts

• Regulations

• Orders in Council

• Notices (including specifications)

• Standards (e.g. Food Standards, and Animal Product Standards made under notice)

• Directions

• Approved Criteria (for dairy material and product only).

Of particular importance when developing an RMP are the two sets of RMP specifications (see section 1.3.1.1). Excerpts from the RMP specifications are included throughout this manual.

To view the relevant legislation go to:

http://www.nzfsa.govt.nz/animalproducts/legislation/index.htm (non-dairy operators)

http://www.nzfsa.govt.nz/dairy/legislation/index.htm (dairy operators)

2.3 Codes of Practice, Templates and Models

An RMP may be based on NZFSA templates, models, or codes of practice, where these are available.

These are defined as:

1. A Code of Practice (COP):
Is a document which reflects agreed industry practice and provides information on meeting regulatory requirements.

2. Template:
A simplified RMP form with prompts for each mandatory requirement. (A “fill in the gaps” document).

3. Model:
A completed RMP that can be used as an example for replication in part or in whole.

A COP may incorporate a template and/or model. Any references in this manual to COP also apply to templates and models.

2.3.1 COPs, Templates and Models Approved under the APA

NZFSA may approve COPs, templates and models that meet regulatory requirements. These documents are expected to cover Good Operating Practice (GOP), HACCP application and other RMP requirements. NZFSA approved COPs, templates and models are available at:

• Dairy:
http://www.nzfsa.govt.nz/dairy/publications/cop/index.htm

• Other Animal Products:
http://www.nzfsa.govt.nz/animalproducts/publications/code-of-practice/index.htm

2.3.2 Advantages of Approved COPs, Templates and Models

If you follow an approved COP, template or model it will:

• ensure that you use current best practice or acceptable industry practices and procedures

• ensure that you will address the relevant regulatory requirements within your RMP; and

• simplify the evaluation (where an evaluation is required) and external verification of RMPs that are based on the approved document.

You will still need to tailor your RMP to suit your specific animal product business. The extent of this will vary depending on the applicability of the approved document to your business.

Parts of approved COPs, templates or models that are directly applicable to your business may be incorporated into your RMP by reference.

If you follow the recommendations in the COP you will only need to demonstrate consistent compliance with the requirements, rather than having to prove that the requirements are valid in the first place.

In most cases, if your RMP is fully based on an approved COP, template or model the requirement for evaluation will be waived.

2.4 Dairy Operational Guidelines

These guidelines were developed within the dairy industry and when followed will assist you to meet the legislative requirements.

http://www.nzfsa.govt.nz/dairy/publications/guidelines/index.htm

2.5 HACCP Plans

RMPs are based on the application of HACCP principles. NZFSA developed HACCP guidance and generic HACCP plans to assist meat and seafood operators. These documents are available at http://www.nzfsa.govt.nz/animalproducts/haccp/index.htm.

For the dairy sector, HACCP guidance is available at: http://www.nzfsa.govt.nz/dairy/publications/guidelines/d110-guide.pdf

HACCP plans for products intended for human consumption only address hazards to human health. You must ensure that hazards to animal health and other risk factors (i.e. risks to false or misleading labelling, wholesomeness) are also addressed in your RMP, where appropriate.

Exporters must consider the impact of overseas market access requirements that relate to their HACCP plans (e.g. mandated Critical Control Points (CCPs)) when a plan is incorporated into an RMP. For certain markets such as the US, the components of the HACCP plan need to be easily identified so that this is clear to any overseas reviewers.

2.6 Generic RMP Models

Generic RMP models have been produced by NZFSA, in consultation with various industry working groups. The models show how the principles of HACCP can be applied and how RMP components could be written for various processes including:

• slaughter and dressing, and cutting and boning operations for cattle, farmed deer, sheep and bobby calves

• processing of half-shell mussels

• processing of hot smoked mussel meat

• processing of oysters

• processing of finfish.

These models are not complete RMPs. If used, you must tailor your RMP to your specific products, processes and premises.

In general, generic RMP models are based on New Zealand requirements only. However, some RMP models do incorporate overseas market access requirements for specific countries. This usually happens when a significant number of processors export to the same country. In such cases the RMP model clearly identifies the market access requirements to differentiate them from New Zealand requirements.

2.7 Existing Procedures

You may have access to documented food control or QA systems that meet customer requirements, e.g. ISO 9001. It is likely that relevant parts of these documented systems can be incorporated into the RMP by reference where the meet and do not conflict with any regulatory requierments. You must ensure that RMP components that are not covered by these systems are added to complete your RMP.

2.8 Peer-Reviewed Scientific Information

You may use scientific literature published in reputable journals (i.e. peer reviewed and appropriately referenced) as a basis for establishing or justifying certain procedures and criteria used in your RMP. The use of this type of information is only appropriate if the conditions or variables considered in the scientific study are applicable to the process(es) covered by the RMP.

2.9 Predictive Models

You can use predictive models to establish product and process parameters. A predictive model is a computer-based software programme that considers the various factors affecting a particular reaction, operation or activity, e.g. growth or decline of foodborne microorganisms in food; chemical deterioration.

These models are valuable tools to support hazard analyses, develop critical limits and to evaluate the relative severity of problems caused by process deviations. They may also be used to predict the effectiveness of corrective actions. They should not be used in isolation from other resources but as an additional tool. Parameters used in predictive models should match process parameters, otherwise estimates are likely to be misleading.

An example of a predictive model commonly used in the New Zealand meat industry is the model for estimating Process Hygiene Index (PHI). This model provides an approximation of the potential bacterial growth that can occur during the cooling of meat products from slaughter until the meat has cooled to 7°C.

2.10 Approved Food Safety Programmes

(Section 32 of the Animal Products Act)

You may use an approved FSP as a basis for an RMP but it will need to be revised to ensure RMP requirements that are not covered by the FSP are met. This includes the identification of risk factors other than hazards to human health, i.e:

• risks from hazards to animal health (where relevant)

• risks from false or misleading labelling

• risks to the wholesomeness of animal material or animal product.