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

6 Food Control Plans

Introduction

The principal risk management tool in the new food regime is the Food Control Plan which may be achieved through either an off-the-peg Food Control Plan or a custom-made Food Control Plan. The discussion document provides a basic description of the off-the-peg Food Control Plan and custom-made Food Control Plan models, and provides lists of the kinds of food business operations that will be regulated with them.

Overview of Submissions

Fifteen written submissions commented in relation to specific Food Control Plan issues. These comprised of:

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

• 3 business groups

• 1 academic or professional body

Summary

In general, submitters supported the Food Control Plan as a risk management tool and especially supported NZFSA’s undertaking to provide off-the-peg Food Control Plan templates to food operators at no charge. Submitters suggested that NZFSA consult relevant industry sectors in the development of off-the-peg Food Control Plans to both ensure the practicality of each off-the-peg Food Control Plan and to prepare the sector for the requirements that will be expected of them when operating an off-the-peg Food Control Plan.

Off the Peg Food Control Plans: application and scope

The principal concerns expressed by submitters were around the provision of more detailed information in regard to Food Control Plans and their application to specific sectors. A few submitters suggested that the scope of off-the-peg Food Control Plans will be too narrow to properly apply to various sectors. For example, a business group suggested:

“..that the diversity of this sector [fresh salad manufacturers] is such that an 'Off the Peg' solution may be unworkable and, anyway, that most fresh salad manufacturers have, or are developing, custom-made plans”.

Another business group asked why, based on current numbers, a retail butcher that handles ready to eat meat is not being provided with an off-the-peg Food Control Plan. Most retail butchers at least handle (if not also manufacture to some extent) ready to eat meat, so why just have the raw meat component covered with an off-the-peg Food Control Plan. It was suggested that the scope needs to be extended for ease of implementation by butchers.

A concern from a third business group was that off-the-peg Food Control Plans may limit the application of traditional processing methods in ‘artisan’ food manufacture.

One TA asked why distributors and transporters need to devise a custom-made Food Control Plan when, as an industry, what they do is reasonably standardised.¹

Off the Peg Food Control Plans: design and provision

Concern was expressed at the huge range of businesses in the Food Service Sector proposed to be regulated using off-the-peg Food Control Plans. This sector is described in the submission of one large TA:

“This is a very diverse group in terms of the type of food operations being carried out, premises size and structure, and ethnic background. Language barriers also prevail in this sector, common languages include Mandarin, Cantonese, Korean, Thai, Vietnamese, Cambodian, and Hindu. Some of the Pacific Island language speakers also struggle with written instruction or advice in English, including Fijian, Tongan, and Samoan communities.”

One submitter, an academic/professional body also noted that the culture change required to move to a Food Control Plan (FCP) system is significant and that:

“It is likely that many, if not most, businesses will fail to either: fully implement an FCP; complete monitoring requirements; or operate outside the scope of their FCP.”

It was therefore suggested that it is important for off-the-peg Food Control Plans to be as simply written as possible for the user.

Another concern raised by a government submitter was over future intellectual property rights if an off-the-peg Food Control Plan is designed by and for a new industry. The submitter asked whether the creators of the off-the-peg Food Control Plan retain rights over the plan that they develop, or will such plans become publicly available and distributed by NZFSA.

¹ Proposal in paper was that distributors and transporters would have an off-the-peg Food Control Plan devised for them