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Summary of Submissions on the Review of Requirements for the Transport and some Storage of Animal Materials and Products

3 Summary of submissions

Twelve submissions were received on the NZFSA proposals. The affiliations of the submitters were as follows:

Of the total submissions received, seven supported option 3 (NZFSA preferred option), two supported two options in the following order of preference - option 2 and status quo, and three did not state any preference.

Four out of the twelve submissions commented only on the preferred option and supported it. One submission commented on two options, the status quo and the preferred option, and supported the latter. Three submissions commented on all three options. Of these, one supported the preferred option and two expressed a preference for two options, ranking a modified option 2 first, followed by a modified option 1. The proposed modifications were to include solutions to the anomalous treatment of dairy products and products for animal consumption into option 2; the development of a Code of Practice and a template RMP for option 1.

Of the seven submissions that supported option 3, one offered unqualified support. The other six submitters raised general queries.

3.1 Matters raised by submitters

The submitters raised the following operational matters:

• compliance cost of operating under an RCS

• consideration of Vehicle Docking Facility type provision for transhipping export dairy

• RCS making provisions for the temporary storage of animal products, (eg when ambient animal products are transhipped and are temporarily held in un-registered premises while loads are consolidated)

• requirements for listing and verification should be at the minimum necessary level

• clarification about the scope of the RCS (storage at animal material depots and transport prior to primary processing

• concern that the RCS may result in additional tasks for drivers

• request for further dialogue with NZFSA about the content of the RCS.

3.2 NZFSA preliminary response

NZFSA’s Standards Group is responsible for the development of the RCS. The Group will address the issues raised by the submitters and will engage in dialogue with the transport industry during the development of the RCS. The coordinator of the RCS development can be contacted on this email address: Greg.Zemke-Smith@nzfsa.govt.nz

¹ The total number of the expressed support for each option exceeds by two the total number of submissions. This is caused by two separate submissions supporting two options each.