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Proposed Animal Products Regulated Control Schemes for Transport, and Wharf Handling of Export Products

To the Stakeholder

In June 2009 NZFSA issued a transport discussion document. NZFSA consulted with affected businesses on would be the most suitable regulatory framework for transport and handling of animal products for export with official assurances (export certification). The proposed regulated control schemes (RCS) are NZFSA’s preferred option as envisaged in the discussion document. Responses to the discussion paper generally agreed with NZFSA’s preferred option. NZFSA intends to implement two RCSs:

• An RCS for transport of animal products (for human or animal consumption) intended for export with official assurances (export certificates).

• An RCS for wharf handling of animal products being exported with official assurances.

The Animal Products Act 1999 (the Act) requires the following activities to occur within registered risk management programmes (RMPs):

• primary processing of animal products, for human or animal consumption, and

• secondary processing of animal product for human or animal consumption intended for export with official assurances

Under the Act transport and wharf handling come under the definition of secondary processing for non-dairy animal products, and primary processing for dairy products. The Act also contains provisions for any primary or secondary process to occur under a RCS in place of an RMP. A RCS can be put in place when it is a more practical and feasible options compared to a RMP, or where it is more economically efficient than requiring each individual business to register a RMP.

NZFSA consultation through the abovementioned discussion document identified RCSs for both transport and wharf handling as the preferred options primarily on the grounds of economic efficiency*.

Who is covered by the proposed RCSs?

NZFSA intends for the transport RCS to cover all forms of animal products transport within New Zealand: road, rail, sea, air. Transport that is already covered by RMP (e.g. transport of fish in RMP or limited processing vessel RCS) will not be captured by the RCS. Transport that is not primary or secondary processing is outside the scope of the RCS (e.g. transport of animals to slaughter premises, transport of fish caught on inshore fishing vessels for delivery to a land based fish processing factory). Transport on the vessel that is being used for taking the animal product to the importing country is not covered by the transport RCS.

NZFSA intends for the wharf RCS to apply to all ports that are loading animal products onto exporting vessels. The RCS will also encompass container terminals and other facilities remote from the port side that hold loaded containers awaiting delivery to the port.

What animal products are covered by the RCSs?

The RCSs will apply to animal products for human or animal consumption, intended for export with official assurances. The RCS will not apply to animal products not for human or animal consumption (e.g. hides, skins, wool, game trophies). It will not apply to animal products intended for consumption in New Zealand. It will not apply to animal products intended for export without official assurances.

Official assurances normally come in the form of export certificates for each consignment of animal product. However, in some cases an animal product may be covered by another type of official assurance, e.g. dairy products for which a product registration certificate is issued periodically (every 2 or 3 years) but consignment based export certificates are not issued. The RCS covers products exported under all forms of official assurance, not just consignment based export certification.

You are invited to make submissions on the amendment by:

5.00pm, Friday 16 October, 2009.

Submitters are asked to include the following information with their submission:

• The title of the discussion document;

• The name and title of the submitter;

• Name of organisation where applicable;

• Submitters address and contact details (phone, fax and e-mail if available); and

• The title and number of the clause(s) commented on where appropriate.

Submissions or queries should be addressed to:

Robyn Scully
Coordinator (Administration)

Standards
NZFSA
P.O. Box 2835
Wellington

Alternatively responses can be emailed to:
robyn.scully@nzfsa.govt.nz

All submissions are subject to the Official Information Act 1982. Therefore if you consider that all or part of your submission is commercially sensitive or should be treated as confidential, please state this clearly when making your submission.

Yours sincerely,

(Signed)

Greg Zemke-Smith
Senior Programme Manager (Animal Products)

*NZFSA recognises that individual circumstances may mean the RCS is not the most economically efficient option for a particular business. For this reason RMPs will still be available for those businesses