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Summary of Submissions on the Transition Policy and Related Implementation Discussion Document

3 Executive Summary

Forty eight written submissions were received on the discussion document Transition Policy and Related Implementation. These comprised of:

• 29 government bodies (including Territorial Authorities (TAs) and Public Health Units (PHUs) / District Health Boards (DHBs))

• 7 industry organisations

• 7 business groups

• 3 community groups, clubs, associations, and not-for-profit organisations

• 2 academic or professional bodies

Analysis of submissions revealed that many submitters expressed their views on common issues-based themes rather than responding strictly to the format of the discussion document. NZFSA has proceeded to analyse the submissions around 25 identified issues-based themes.

Submitters in general supported the underlying principles of the proposed regulatory system and recognised the appropriateness of the proposed risk management tools, i.e. the Food Control Plans, National Programmes and Food Handler Guidance.

A clear theme in submitter comments was the perceived lack of clarity and the limited breadth of specific information provided in the discussion document. Submitters were seeking greater detail around such issues as the roles and responsibilities of the regulator, PHUs and TAs. More information was requested on verification and the proposed ISO17020/New Zealand standard; cost recovery; education and training requirements (including who will pay) and the registration process.

While submitters were supportive of the proposed 5-year timeframe for implementation, many expressed concern that the commencement date of the new regime (currently proposed to be 1 July 2008) was too soon. In terms of the various sectors proposed for transition over the 5-year period, specific mention was made regarding the number of businesses expected to transition into the new regime in years 1 and 2. The concern raised by submitters was around the heavy work load for these two years, especially in relation to the food service-general sector currently proposed for year one. Submitters, in addressing this issue, provided alternative views on how these years could be better split to enable the better management of implementation.

The above issues, and others, are discussed further in this paper. In terms of a response to issues raised by submitters, NZFSA will publish a policy position paper in the near future. The policy position paper will provide greater clarity to submitters about the new food regulatory regime and address the various issues that have been raised in the Transition Policy and Related Implementation discussion document.