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

16 Capability and Capacity

Introduction

This section collects together the comments made in relation to the capability and capacity of the various organisations involved in the new regime to successfully implement the transitional arrangements. As such, each of the comments integrates a number of elements from the discussion document and generally frames a concern that the submitter has in relation to the capability and capacity of a particular stakeholder group or groups to implement the transitional proposals.

Overview of Submissions

Seventeen submitters commented on capability and capacity issues. These submitters comprised:

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

• 2 industry organisations

• 2 business groups

• 1 academic or professional body

Summary

Almost all of the submitters in this section expressed concerns in relation to capability and capacity issues. The principal concerns of submitters revolve around the perceived preparedness of TAs to transition to the new regime. The two main concerns are related to the scarcity of qualified staff and the timeframe for implementation. Some submitters highlighted the challenges that will be faced by smaller rural TAs to recruit qualified staff and to resource the transition to the new regime.

Staffing issues

As noted above, submitters expressed considerable concern at the preparedness of TAs and PHUs to transition into the new regime. The number of qualified staff, and funding needed for such staff, are principal factors in this perceived lack of preparedness. One submitter’s comment is indicative of a number:

“Council will invariably need to increase its staffing levels in order to cope with the increased workload that the new regime poses. The workload increase is caused both by the increase in the number of premises coming to council for registration, enforcement and verification, but also due to the increased amount of time required to assist businesses to move to the new regime and increased amount of time to audit a food plan. This increase in staffing levels plus all the other operational costs is likely to result in increased costs to food businesses” .

One large TA estimates that an increase of 40 per cent in the number of food businesses requiring verification will require an additional six fulltime EHOs. The associated costs of

“attaining accreditation, managing and maintaining a register and database, recruitment, training and equipping of staff will require significant addition to the annual budget.”

Several submitters pointed out that many TAs and PHUs are already short staffed and, especially in rural areas, are “struggling with current workloads”.

One submitter, a PHU, commented in particular that,

“the demands on TLAs are much greater under this scheme than in the past. Once again, the smaller TLAs may struggle to keep up with demand. EHOs who work in smaller or rural TLAs are accountable for a wide range of public health duties, including food. It is possible that registration of FCPs would take a lower priority than other core work, for example noise complaints, resource management, drinking water activities and bylaw enforcement”.

Two submitters pointed out that there is a shortage of trained EHOs in New Zealand and also in other countries like Australia, Britain and Ireland and that this must be taken into account when proposing systems that will require more qualified staff across the country. The possibility that some older EHOs may retire rather than retrain for the new regime was also mooted by submitters.

Off-the-Peg Food Control Plan operator capability

Five submitters expressed concern over the short time-frame in which TAs must register operators’ off-the-peg Food Control Plans. One submitter, a TA, noted that off-the-peg Food Control Plan food businesses will get the least regulatory attention but are the ones that will probably need most assistance as they have the least food safety knowledge and will find it hard completing their off-the-peg Food Control Plans to ensure it fits the scope of their business within six months. Given this, a submitter wrote:

“Business will require significant help and training in order to successfully move from the current regulatory regime to the new proposed framework”.

Two regimes operating simultaneously

Several submitters noted that TAs and PHUs will have to operate two separate regimes during the transition period. This will be particularly significant for the first three years of the transition.

One TA notes that there will be “significant implications for administration, database management, and process control” where two systems are operating simultaneously. The submitter goes on to assert that in consequence, “resources at council level will be stretched and council will have to prioritise its workload”. This prioritisation may result in those businesses transitioning into the new regime being given more attention that those operating under the old system.

Recognition of capability and capacity

Two submitters, a business group and a DHB, expressed confidence in the capability and capacity of stakeholders. One of the two comments, however, included the rejoinder that this capability and capacity “will largely depend on the information, training and education provided” by NZFSA and asserted that “it is essential [that the] information be written for the user”.

General concerns

One submitter, an industry organisation, noted that their members currently experience “delays and inaction by the TAs” in getting their risk management tools approved. They are concerned that under the pressure of implementing the new regime, these frustrations will become acute.

One submitter, a TA, echoing the comments of others, noted their concern

“about the additional responsibilities being imposed on local government, without commensurate funding.”