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Risk management programmes (RMPs)

A risk management programme (RMP) is a written plan designed by an animal product business to manage its biological, chemical and physical hazards. It is based on internationally agreed risk principles of Hazard Analysis and Critical Control Point (HACCP). It ensures that the resulting animal product meets relevant standards and is fit for its intended purpose.

What RMPs mean for manufacturers and exporters

The risk management programme is a key regulatory component of the Animal Products Act 1999. Processors, manufacturers and exporters of animal products need to be familiar with the requirements of the Act.

If you process or manufacture animal products for export you will probably operate an RMP.

If you export animal products but are not the processor or manufacturer, you need to ensure that all processors and manufacturers involved in the production of your product operate an RMP, or other appropriate risk management system. This could be an export approved premise (EAP) or food safety programme (FSP).

For example, if you are exporting mussel patties, the growing, harvesting, transport and primary processing of the mussels, and the manufacture of the mussel patties, must all be carried out according to the requirements of the Animal Products Act 1999.

Export requirements for animal products

Registered risk management programmes- animal products excluding dairy

Registered risk management programmes - dairy

Businesses that need a risk management programme

All primary processors of animal products. For example:

• Mammal, bird (including ostrich and emu) and seafood primary processors

• dairy processors

• most avian egg primary processors

• deer velvet processors

The following secondary processors:

• renderers and blood-drying operations for mammals and birds

• dual operator butchers (butchers dealing in both homekill and regulated meat)

• All secondary processors of animal products intended for human or animal consumption requiring official assurances.

Full list of businesses requiring RMPs - appendix C of the RMP manual

Glossary and acronym definitions – primary and secondary processors

Businesses that don’t need a risk management programme

Some people are exempt from the requirement to have an RMP. For example:

• primary producers of animal products (e.g. sheep and beef farmers)

• dairy processors of dairy products consumed on premises

• certain dairy products that are multi-ingredient foods

• egg producers who have 100 birds or less and sell all eggs direct to the consumer

• primary processors of animal material for purposes other than human or animal consumption (e.g. skinning and shearing)

Full list of businesses not requiring RMPs - appendix D of the RMP manual

5 steps to your RMP

These are the steps that manufacturers need to follow to register as an RMP operator:

Step 1: Developing and validating your RMP
Step 2: Getting your RMP evaluated
Step 3: Getting your RMP assessed and registered by NZFSA
Step 4: Implementing your RMP
Step 5: Getting your RMP externally verified

Step 1: Developing and validating your RMP

There are two main ways to develop your RMP:

• Base your RMP on an NZFSA-approved code of practice (COP) or template.

• Write your own risk management programme by following the RMP manual.

The first way is the simpler and cheaper way to write your RMP.

If there is an approved code of practice or template for your animal product, these documents provide industry-agreed information on how to meet regulatory requirements. Basing your RMP on an approved COP or template:

• ensures you comply with current best practice or acceptable industry practices and procedures

• ensures that you meet the relevant regulatory requirements

• simplifies and reduces the cost of developing and evaluating your RMP.

• means you will not need to validate your RMP or have it evaluated

Codes of practice and templates to base your RMP on

• Codes of practice and Risk management programme templates  

• Codes of practice - for dairy products

Please note that not all of these templates or codes of practice are approved. To ensure you use an approved code of practice or template and qualify for the exemption from evaluation, check the list of approved templates currently available (as of November 2008).

Waiver of the requirement to provide a copy of an independent evaluation report

If there is no approved RMP code of practice or template for your animal product

You will need to work through the RMP manual. The key difference is that because the RMP will be tailored to your business you will need to validate it and have it evaluated by an independent evaluator.

RMP manual - check this to ensure your RMP is complete

Get help putting together your RMP

If you need help writing your RMP you can contact:

• an RMP consultant. You can find them on the internet (limit your search to ‘pages in New Zealand’)

• an evaluator. They may be able to help you develop your RMP or find someone who can. Note that if they help you to document your RMP, you cannot use them as your official evaluator or verifier.
Evaluators - recognised persons list - animal products excluding dairy

Evaluators – recognised persons list –dairy products

• NZFSA Approvals

Validating your RMP

If you are not basing your RMP on an approved template or approved COP, you need to validate your RMP. Validation involves checking each step of your RMP to ensure that it is working effectively to control risks.

Confirmation of validity - section 5 of the RMP manual

Step 2: Getting your RMP evaluated

If you have written your own RMP rather than basing it on an approved template or approved COP, you need to employ an independent evaluator who has been recognised by NZFSA to evaluate your RMP. It is preferable to choose an evaluator who has experience in your type of operation.

The evaluator confirms that the RMP does indeed cover the operations, and, as written, will deliver product that is fit for its intended purpose. They do this by reviewing your documentation, and, in some cases, reviewing your operations or observing practice.

The evaluator prepares a report, which you need to include as part of your application for registration of your RMP with NZFSA. Full details of how to apply are in the RMP manual.

Evaluation - section 6 of the RMP manual

Evaluators - recognised persons list - animal products excluding dairy

Evaluators – recognised persons list –dairy products

After you have written your RMP

You will need to contract a recognised verifying agency, who will confirm in writing that they are willing to verify the RMP. You include this confirmation with your application.

The main verifying agencies by product are outlined in the table below:

Product	Verifier
Meat and seafood	NZFSAVA(NZFSA verification agency
Dairy	AsureQuality, SGS, NZFSAVA (limited operation)
Honey	AsureQuality and NZFSAVA

Recognised verification agencies for animal products excluding dairy
Recognised verification agencies for dairy

Steps 3, 4 and 5 - registration, implementation and verification

NZFSA will assess your application and if it is approved you will be added to the register. Now it is up to you to ensure the processes are carried out in accordance with your registered RMP, that all the risk management activities are working effectively, and that records are kept. The verifying agency will visit and audit your records regularly to confirm that your RMP continues to deliver product that is fit for purpose.

Application for registration – Section 7 of the RMP manual

Operating the RMP – section 8 of the RMP manual

External verification – section 8.3 of the RMP manual

Duties of operators of risk management programmes (RMPs)

Once you have registered as an operator of an RMP, you must comply with the duties laid out under the Animal Products Act 1999. These include:

• ensuring that their your risk management programme and operations comply with the Act

• adequately implementing and resourcing all operations

• ensuring that all operations under the risk management programme are within the capability and capacity of the premises or place, facilities, equipment, and staff to deliver animal product that is fit for purpose

• giving verifiers such freedom and access as needed to carry out their functions and activities

• notifying the NZFSA if you change your recognised verifying agency.

Operator’s duties – section 8.2 of the RMP manual

RMPs and related risk management programmes

If you already have a food safety programme, or if you need to be registered as both an export approved premises and an RMP operator, here’s what you need to do.

Converting a food safety programme (FSP) to a RMP

If you are currently operating under an approved FSP you may use it as the basis for an RMP as many of the risks have been identified and are already being managed.

Your FSP will need to be revised to meet all the requirements of an RMP. This includes the identification of risk factors other than hazards to human health:

• risks from hazards to animal health (where relevant)

• risks from false or misleading labelling

• risks to the wholesomeness of animal material or product.

The other key difference is the need for an evaluation to be undertaken by a recognised evaluator.

An RMP can cover you as an export approved premises (EAP)

If you have an RMP that covers the activities required to operate under an export approved premises (EAP) then you are covered as an EAP. If not, you have 2 options:

1. amend the scope of your RMP, or

2. get a separate EAP listing for the activities required

For example, you have a slaughter operation that produces hides and skins. The hides and skins collection can be covered by either:

• the RMP (for slaughter for human consumption) or

• a separate EAP listing obtained for the hides and skins operation.

Contact NZFSA Approvals for further advice

Risk management programme configurations

A risk management programme may be configured in various ways.

You can have a separate RMP for each of your products, processes, premises or businesses. You can have a RMP that covers a number of products, processes, places or premises. You can have a single RMP that covers multiple businesses.

Whatever arrangement you choose, you must ensure that there is a risk management programme for every aspect of the operation that requires one.

RMP configurations – section 2.6 of the RMP manual

Implications of RMP configuration for market access overseas

If you have a single RMP covering more than one site or more than one business, this may cause problems if you are also intending to export and country listings are required. For example, European Union listings are limited to a single site. If you are planning to export with a multi-site/multi-business risk management programme, contact NZFSA first to discuss the implications.

Contact NZFSA Approvals for further advice

An RMP can cover both dairy and other animal product processing

The RMP will need to meet the requirements for both dairy and other animal products. As the verifiers and evaluators are often recognised for either one or the other, they may not have the competencies to evaluate both. In this case you will need to use separate evaluators and verifiers for each component. This is likely to increase your costs. Alternatively look for an evaluator or verifier that can cover both dairy and animal products.

Changes to your RMP

You may amend or surrender your RMP, or NZFSA may suspend or deregister your RMP.

Amendments to the RMP – section 8.4 of the RMP manual

Ceasing registration of an RMP – section 9 of the RMP manual (covers surrender, suspension and deregistration of the RMP)

More about RMPs

RMP manual - check this to ensure your RMP is complete

Risk management programme page – everything to do with RMPs, including manuals and guides, legislation, codes of practice, registers and lists.

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