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

5 Consultation and Evidence Gathering

Introduction

The Transition Policy and Related Implementation Paper went out for public consultation in October 2006, on the back of a number of other DFR public discussion documents. Submissions on this, the most recent DFR paper, closed 9 February 2007.

Prior to and throughout the design of the new food regime, NZFSA has gathered scientific evidence for the Risk Ranking Model. Other aspects of the regime, including roles and responsibilities have also required public consultation.

This section discusses feedback from submitters regarding consultation and evidence gathering.

Overview of submissions

Seven written submissions included comments on consultation and evidence gathering. These comprised submissions from:

• 3 government bodies (including TAs, PHUs and DHBs)

• 1 Industry organisation

• 2 business groups

• 1 community group

Summary

Submissions on consultation and evidence gathering were mixed, as summarised below.

Approval of process

An industry organisation and a community group expressed appreciation and support for work undertaken by NZFSA to engage industry. For example:

“The consultation processes put in place by the Authority on the review have been very comprehensive”.

The submitter then goes on to say that NZFSA’s industry interface work has:

“..done much not only to explain the proposals to New Zealand retail businesses but also to mitigate potential concerns about compliance costs that potentially could flow from the policy review”.

Concerns

Four submitters (two government bodies and two business groups) expressed disapproval over the consultation and evidence gathering undertaken for the DFR Transition Policy and Related Implementation discussion document.

A submission from one business group strongly expressed concern that they perceived there had been a lack of consultation over provisions for TA exclusivity in verifying off-the-peg Food Control Plans:

“This was not part of any earlier consultation document and now has been introduced as a fait accompli. There have been meetings with TA’s around this point which clearly show this is not an option but an item on which a decision has been made. It is far from clear why such a fundamental change should occur in the middle of a process of consultation, without any fair process of consultation. There certainly have been no reasons put forward in public as to why this has come about or why there needs to be such a decision made”.

Another submitter expressed disapproval over the consultation and evidence gathering used in the Risk Ranking System to determine the risk posed by food sectors, saying:

“Data to confirm the food borne component of enteric diseases does not yet exist, until such time as the current ESR study has been completed. It therefore follows that any opinions relating to risk cannot meaningful reflect values for the various sectors that NZFSA has identified. Personal opinion can therefore only reflect a perception of the possibility of risk, it cannot indicate the actual levels of risk”.

One submitter questioned NZFSA’s consultation and evidence gathering, by asking:

“Has there been enough consultation with the actual manufacturer's & retailers to ensure the scope [off-the-peg Food Control Plans] is wide enough for each industry?”

Another submitter recommended that close liaison be maintained with the food retail sector so that off-the-peg Food Control Plans continue to meet their needs:

“In this way the potentially embarrassing Approved Supplier programmes - developed because of perceived failings in the current regulatory food assurance scheme - will cease. In fact, it is suggested that the end of these programmes be regarded as an indicator of the successful/credible introduction of 'Off the Peg' programmes”.