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

18 Education and Training

Introduction

Training to meet the requirements of Food Control Plans and National Programmes will be the responsibility of individual businesses, most likely with the support of an industry training organisation. The food regulatory regime will provide competency requirements for some individuals subject to Food Control Plans and National Programmes and for those ‘persons’ performing certain activities.

The focus will be on establishing competency requirements, not the prescription of training. Competency requirements will be identified and developed with training providers, the food industry and in parallel with the development of sector specific tools if appropriate.

NZFSA has identified the need for a coordinated approach to achieving competencies during the implementation process.

This section discusses feedback from submitters regarding Education and Training.

Overview of submissions

31 written submissions included comments on education and training, comprising submissions from:

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

• 4 Industry organisations

• 3 business groups

• 1 community group

• 1 academic or professional body.

Summary

In general, most submissions supported proposals for the setting of national competency requirements, and that such training is the responsibility of individual businesses, with the support of industry organisations. However, twelve submitters expressed concern regarding the provision to and receptiveness of food businesses, EHOs and HPOs to the training that is necessary for the implementation phase of the DFR. For example one Industry organisation commented:

“We believe that the package of proposals that have now been endorsed by the Government are in general terms realistic, practical and understandable, but, at the same time, we recommend funding be made available for adequate industry training and education during the transition period to ensure that all aspects of the new regime are understood not only by New Zealand businesses but also by individual consumers”.

It was also suggested by a number of submitters that new legislation should back the requirement for formal accredited training of food handlers, including, where appropriate, the endorsement of relevant NZQA unit standards.

The three general areas of concern within the summary are: the need for clarification; industry obstacles; and TA training issues.

Need for clarification

A number of submitters questioned whether training institutions, for both specialist auditors as well as EHOs, will be able to gear up in anticipation of increased demand given that details on the competency requirements are yet to be communicated. Similarly, TAs, PHUs and food businesses are unable to commence training unless they know what the required competencies are (similar issues exist with Accreditation). Many submitters asked about the resourcing and provision of such training with TAs and PHUs/DHBs already starting the process of setting budgets and annual plans for the 2007/2008 year. One submitter, a PHU, wrote that without accurate information they:

“…will not be able to budget for any additional education to occur by this 1 July 2008 when it is not know what will be required”.

Another TA commented in regard to industry training and asked:

“Will the training/competency be time limited i.e. Require refresher training/assessments, if so at what interval? What is proposed to happen in regards to individuals currently holding a ‘Food Hygiene Certificate?”.

Industry obstacles

Implementation is also dependent on industry being willing and able to undergo training. One government submitter noted that at

“present not all food handlers have to have formal food safety training as this is entirely dictated by local council by-laws and there is not a national standard”.

It was also noted by many submitters that food safety knowledge within off-the-peg Food Control Plan sectors can be minimal. Moreover, a business group submitter stated that another:

“..problem is that most organisations do not wish to invest any money in food safety training unless it is 100% subsidized. And, of course, nearly all employers think that they are personally the best trainers in the world”.

A government body stated that:

“There may be some impact on small one or two person businesses where taking time out for training may incur a loss of income. We believe that this could also affect businesses in rural areas who may not have access to the training opportunities that are available in larger urban centres”.

A TA also commented that the fact that food safety training may be new to staff in currently unregulated sectors, such as kitchens run by the Departments of Defence and Corrections, as well as boarding schools, is also an obstacle.

A large TA asserted that establishing competency requirements rather than prescribed training may result in a drop in the number of businesses investing in appropriate training of their food handling staff. Leaving the legislation with a competency focus will move the burden of proof onto the regulator to prove that the food handler is or is not competent, rather than the food operator to prove that their staff are adequately trained.

On submitter, an industry organisation, addressed the issue of ITO capability and capacity in providing training for ‘persons’ and others involved in food manufacture and retail to meet the requirements of the new food regulatory system. The submitter suggested that funding for ITOs may be necessary to enable them to meet demand.

TA training issues

Implementation is also dependent on TAs being willing and able to undergo training. A business group expressed concern over TAs entering the training arena without being qualified (ie with no national certificate or assessor qualification to NZQA 4098). The same submitter also commented that TA trainers may divert custom from qualified training establishments.

A different business group commented that there is currently little or no auditing experience within most TAs, and training inexperienced EHOs to perform verification will not lead to effective verification systems overnight. Lack of TA experience in other areas represents additional obstacles. A TA commented that:

“Most TLA's have had no involvement with food borne illness investigations, so an upskilling of EHO's will be required for this.”

An academic/professional body also noted that enforcement of off-the-peg Food Control Plan businesses’ compliance with labelling and suitability standards in the Food Standards Code is another new role for which TAs will require significant training and resources.

When considering these training needs and obstacles, a TA noted that the amount of training time required for EHOs needs to be adequately assessed by IANZ, and approved by NZFSA.

Suggestions for training and education

Many submitters made recommendations regarding training and education, making it clear that TA staff need to be trained as verifiers before the transition process commences. One TA suggested that all food handlers should be trained, given instructions and supervised commensurate with their duties (with supervisors/managers trained to a higher level). It was also suggested by a few government submitters that training requirements be included in the new Food Bill and associated legislation.

It was suggested that training should be a requirement for Food Control Plan verification and that NZFSA should develop training requirements in conjunction with industry, the education sector and other agencies. A large TA strongly supported training requirements being mandated nationally, with reference made to NZQA unit standards where appropriate. Also, a DHB suggested that provision be made for training via correspondence courses.

With regard to funding, a number of government bodies suggested NZFSA should fund training tools for all stakeholders and provide training for each region, assisting TAs with training costs (one TA believes that training verifiers will cost approximately $4,000 per officer). It was noted that a precedent has already been set with the Building Act for central government to provide training to TAs in order for them to meet new accreditation requirements imposed by legislation.

Another suggestion from a PHU was that appropriately skilled PHU staff should work across TA boundaries to ensure a more coordinated and consistent approach to training that enables effective targeting of groups not traditionally regulated by TAs, such as rest homes and childcare centres (the Technical Advisors Programme model that operates under the Ministry of Health's water programme is an example).