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Regulated control schemes – a cost-effective way to manage some food risks
Regulated control schemes are imposed by the government (through NZFSA, with industry consultation) to manage food-related risks when:
• individual risk management programmes would not be feasible or practicable, or
• it is more efficient for the government to run the programme, or
• it is needed to meet the market access requirements of foreign governments.
There are two types of RCSs, depending on the way they are legislated:
• Regulated control schemes legislated under regulation
• Regulated control schemes issued as a notice under section 60 of the Animal Products Act 1999.
Regulated control schemes legislated under regulation
All manufacturers, both domestic and export, must participate. Some of the requirements are elaborated in more detail in specifications or notices.
• limited processing fishing vessels
• bivalve molluscan shellfish
• contaminant monitoring and surveillance
Regulated control schemes issued as a notice under section 60 of the Animal Products Act 1999
These RCSs are national in scope. However, they apply only to products intended for export. Products for domestic sale only are excluded. These RCSs are set up to manage market access requirements. They are issued after exporters have been notified of the requirements in an overseas market access requirement (OMAR).
• hormonal growth promotant
• control of specified substances
• verification of contaminants in bee products for export
National monitoring and surveillance programmes
In addition to the regulated control schemes, NZFSA runs two national monitoring and surveillance programmes for animal products. One of these is an RCS. The other has the same effect. They are:
• contaminant monitoring and surveillance - for animal products excluding dairy
• national programme for monitoring chemical contaminants and residues in raw milk and dairy products (NCCP dairy).
The purpose of these national programmes is to ensure that the controls in place deliver animal products that comply with the wide range of residue and contaminant limits applied both domestically and internationally. In doing so these programmes reduce or, in many cases, remove any requirement for expensive consignment-by-consignment testing.
The chemical residue and contaminant status of New Zealand foods
Limited processing fishing vessels
This RCS covers requirements for the operation of limited processing fishing vessels that export processed fish material and fish products intended for human consumption, without landing the products into an on-shore fish processor.
‘Limited processing’ includes washing, de-heading, gutting, tubing, tailing, chilling, freezing, storage, package or transport of finfish or shellfish material or product intended for human consumption. It does not include the filleting of finfish.
The key requirements of this RCS are that:
• each limited processing fishing vessel is registered by the NZFSA
• the operator develops an operator documented system for implementing the requirements of the RCS
• a recognised verifier externally verifies this system.
This RCS consists of regulations and associated notices.
Animal Products (Specifications for Limited Processing Fishing Vessels) Notice 2005 [PDF 330 KB]
Regulated control scheme for limited processing fishing vessels: operator guidelines
List of approved limited processing vessels
Bivalve molluscan shellfish
The New Zealand requirements for the growing, harvesting and transport of commercial bivalve molluscan shellfish are covered by the bivalve molluscan shellfish regulated control scheme (BMSRCS).
Bivalve molluscan shellfish (BMS) are not permitted to be harvested until the growing area has undergone a sanitary survey and classification in accordance with the BMSRCS. Once classified, the BMS and seawater in each growing area must be routinely sampled and the results evaluated and summarised annually.
Each BMS harvest operator must:
• be registered with NZFSA
• ensure their respective harvest vessels and vehicles are listed with a unique identifier which is readily visible on the vessel/vehicle
• ensure the vessel/vehicle design, operation, maintenance and sewage disposal, comply with BMSRCS requirements
• ensure that BMS labelling and harvest declarations comply with BMSRCS
• follow harvesting and transport time-temperature protocols.
This RCS consists of regulations and associated notices.
Animal Products (Specifications for Bivalve Molluscan Shellfish) [PDF 338 KB]
Registers and lists – see bivalve molluscan shellfish
Contaminant monitoring and surveillance
The purpose of this RCS is to control chemical contaminants in animal material and animal products, and ensure that the maximum residue limits under the Food Act and maximum permissible levels for export are met. It ensures that NZFSA can demonstrate that the use of veterinary medicines and agricultural compounds are controlled.
This RCS manages contaminant monitoring and surveillance sampling regimes for animal material and animal product, and requirements for laboratories testing samples. It covers live animals, meat and meat products, birds, farmed fish and wild caught fish.
This RCS provides for a number of regulatory interventions, including a surveillance list where suppliers of non-complying product are listed until they supply compliant product.
This is a nationally managed scheme. If you operate a risk management programme (RMP) you are included in the scheme. Authorised samplers will take samples from product at your processing facility.
Monitoring sampling regime
The sampling plan starts on 1 July every year and finishes on 30 June the next year. It outlines the classes of animal material or animal product and the tests to be undertaken. An example is included in schedule one. Please note, as the sampling plan is continuously updated to meet market requirements (both domestic and export), the live version is not shown.
Sampling plan (1 July 2007-30 June 2008) - see page 7
The number of samples tested for each species takes into account the following considerations:
• historical results for that animal class and compound
• requirements of overseas regulatory authorities
• regulatory or registration status of the compound
• husbandry of the species
• regulatory status of the compound in New Zealand and in overseas markets
• numbers of animals processed each year
• changes in use of the compound.
The programme results are reported annually on the NZFSA website.
National Chemical Residue Programme 2006/2007 (Food Focus August 2008)
This scheme consists of regulations and associated specifications and notices.
Animal Products (Contaminant Specifications) Notice 2008 [PDF 229 KB]
Hormonal growth promotants
A hormonal growth promotant (HGP) is any veterinary medicine that contains either natural or synthetic hormones and is sold for the purpose of increasing the muscle tone, growth rate, weight gain or feed efficiency of animals.
The use of HGPs is covered by the hormonal growth promotant regulated control scheme under the Animal Products (Regulated Control Scheme-Hormonal Growth Promotants) Notice 2009.
The purpose of this scheme is to control the use and management of HGPs implanted in animals so that specific market access requirements can be met. The European Union (EU) and a number of other countries ban HGP-treated animal products. So any use of HGPs requires a tracking and documentation system that gives a very high level of certainty that HGP-treated animal products are not exported to these markets. New Zealand is regularly and extensively audited by the EU. It is therefore essential that the HGP scheme is able to maintain the credibility of traceability, verification and certification.
What this means for exporters
As part of the HGP scheme, animals treated with hormonal growth promotants are required, under the Animal Products Act, to be identified from the time of implantation, until slaughter and processing. If hormonal growth promotants have been used there are a number of obligations that must be met if you wish to export to markets that ban the use of HGPs. From 1 August 2009 the cost of the scheme will largely be borne by farmers who use HGPs.
Animal Products (Regulated Control Scheme - Hormonal Growth Promotants) Notice 2009 (effective from 1 August 2009) [PDF 115 KB]
Control of specified substances
This RCS prohibits the use of specified substances in food-producing animals. The current prohibited substance are17ß-oestradiol and its esters. Its use is prohibited in cattle, sheep, goats, deer, emu and ostriches.
There are 3 main reasons for this:
• they are not widely used
• their use brings limited economic gain
• the cost of implementing a scheme to track the animals for their entire life is prohibitive.
What this means for exporters
There are no special requirements on small exporters, other than those set out in the OMAR. The primary producer bears most of the costs.
Animal Products (Control of Specified Substances) Specifications Notice [PDF 59 KB]
Verification of contaminants in bee products for export
The prime purpose of this scheme is to enable NZFSA to verify the absence or presence, extent, and distribution of contaminants in bee products for export in order to ensure there is compliance with the overseas market access requirements.
This scheme:
• is operated by NZFSA
• sets out the residue limits
• provides for the issue of a sampling regime from which a confidential sampling plan is developed and also a surveillance list. Samples are usually taken at a risk management programme (RMP) premises. However, the scheme allows for sampling from any point in the production of specified bee products.
This scheme does not apply to producers and processors who sell on the domestic market only.
What this means for exporters
The cost of administering the regulated control scheme only is a fixed amount per risk management plan (RMP) holder and is not tiered by value or volume exported although this possibility is not ruled out in the future. It is currently set at $ 319.50 for the sampling and testing and $258 for the RMP activities undertaken by NZFSA.
Animal Products (Regulated Control Scheme - Verification of Contaminants in Bee Products for Export) Notice 2008 [PDF 110 KB]
National programme for monitoring chemical contaminants and residues in raw milk and dairy products (NCCP dairy)
The NCCP, while issued as a regulation, provides the same outcome as a regulated control scheme.
The Dairy Industry National Residue Monitoring Programme is operated as a regulation issued under the Animal Product Act 1999.
The monitoring and surveillance programme is designed to audit the effectiveness of the regulatory controls in place for ensuring:
• chemical residues in dairy products do not pose a threat to human health
• good agricultural practices are being followed
• all relevant importing country requirements will be met.
Raw milk and raw colostrum samples are taken at the farm dairy prior to any consolidation or dilution. Final dairy products are sampled at the factory. Operators of risk management programmes (RMPs) that cover milk harvesting at farm dairies are required to advise NZFSA of the farms covered by their RMP. These farms are then eligible for supply and available for selection for sampling.
Monitoring sampling regime
The types of chemicals analysed, the number of samples to be analysed, and the sampling pattern have been determined following consideration of factors relevant to New Zealand farming practices.
Factors taken into consideration in the design of the programme include:
• historical monitoring results
• residue and toxicological potential of the substance
• potential for misuse or abuse
• extent and pattern of use within New Zealand
• previous residue non-compliance
• persistence in the environment
• intelligence gathering (both formal and informal)
• advice from other competent authorities.
National Programme for Monitoring Chemical Contaminants and Residues in Raw Milk and Dairy Products (NCCP) – see table 4
Results for 2006/07 are outlined in this table:
Dairy National Chemical Contaminants Programme 2006/07 [PDF 15 KB]
For further information:
Related links
Specifications/Notices - Regulated Control Schemes
Contact
Please include your geographical region so we can direct your enquiry to the correct person.
export.animalproducts@nzfsa.govt.nz
Last updated 13 May 2009
New Zealand Food Safety Authority
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PO Box 2835
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NEW ZEALAND
Phone: +64 4 894 2500
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