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Proposed regulatory framework for unpasteurised milk products

9 Implementation of the framework for unpasteurised milk products

9.1 Familiarisation for industry, importers and third parties

9.1.1 Guidance material

NZFSA proposes to provide guidance to industry operators, importers, third party agencies and other interested parties to assist them to become familiar with the processes for manufacturing and importing unpasteurised milk products.

Guidance materials will be developed and made available to stakeholders to assist them to understand any relevant technical requirements, and these materials would include:

• information about the technical requirements for raw milk products, including the content of the proposed Animal Products (Raw Milk Products Specifications) Notice 2009;

• validation – guidance on the evidence and supporting information that will be required from operators if they are undertaking studies to validate their programmes in order to help determine whether their products can be classified as ‘unpasteurised milk products’ or ‘raw milk products’;

• qualifications and training that may be available to manufacturers of unpasteurised milk products and other interested parties;

• the process for development, evaluation (where required), registration, auditing and verification of risk based management plans for unpasteurised and raw milk products; and

• information for importers on the process to be followed when importing such products.

NZFSA would welcome feedback on any other forms of material that may be useful.

9.1.2 Workshops

During the consultation period for this paper, NZFSA will undertake workshops in Auckland, Hamilton and Christchurch for all stakeholders with an interest in unpasteurised milk and raw milk processing, including people who intend to manufacture such products, importers, evaluators and verifiers of RMPs, auditors of FSPs, and staff from public health units.

The workshops will provide an opportunity for stakeholders to become familiar with, and to discuss, the proposal outlined in this paper. The workshops will be timed to ensure that, following attendance, stakeholders have sufficient time to make a written submission on the discussion paper prior to the consultation period closing. Participants will also be able to request that comments they make at the workshops are included in the summary of submissions.

Stakeholders will be asked to indicate which workshop they wish to attend by a set date to allow time for arrangements to be made.

Providing this proposal progresses, NZFSA will also provide training workshops for attendance by auditors of FSPs, evaluators and verifiers of RMPs, the NZFSA Compliance and Investigation Group, staff from public health units and accreditation bodies. These would occur once the technical and legal requirements relating to this proposal have been finalised.

9.2 Costs

Costs incurred in the process of manufacturing, importing or exporting unpasteurised and raw milk products will need to be met by the operator concerned. Such costs may for example be incurred when assessing intrinsic characteristics and/or processes in order to determine the regulatory requirements that will apply; developing and obtaining registration or approval of an RMP or FSP for unpasteurised or raw milk products; getting RMPs or FSPs evaluated, verified or audited; and seeking registration as an exporter.

In future when NZFSA provides services related to unpasteurised and raw milk products at the request of an operator of an RMP or FSP, or any other processor or person, NZFSA will charge at the appropriate hourly rate as prescribed in regulations under the relevant legislation, plus the costs of any actual and reasonable expenses incurred. For example, NZFSA currently recovers for the time applied to dairy approvals at a rate of $137.25 inclusive of GST per hour.

The work that NZFSA could be requested to undertake by operators could include: assessing data provided in conjunction with an application to register a RMP or approve a FSP and determining the regulatory requirements that would apply (for example by making a determination using the results of a validation study). Where possible and appropriate, NZFSA will work over time to train third parties to undertake tasks associated with the assessment of unpasteurised milk product processes.

NZFSA would welcome comment from submitters about the costs which they may incur when satisfying the regulatory requirements described in this paper.

9.3 Risk communication and consumer education

Implementing the outcomes of this proposal would also involve communicating the right messages to the right consumer audiences in a timely way.

NZFSA’s current risk communication strategies for vulnerable consumers, and for the limited range of unpasteurised milk products that are currently available, are described in sections 5.2.1. and 5.2.2. above. In light of the market research survey into the effectiveness of NZFSA’s previous unpasteurised milk products education campaign (referred to as raw milk products) and the public’s level of awareness of the hazards that may be associated with some unpasteurised milk products, the strategy for unpasteurised milk products is now being updated.

New initiatives to reach affected people are being added. These include working with government and non-government groups to inform their members/constituency about unpasteurised milk products. Proposals include providing website information or links to targeted information; supplying copy for publications on food safety issues, and making presentations or supplying brochures for their meetings or resource centres. NZFSA’s consumer resources will also be updated to ensure they use terminology that consumers understand.

NZFSA’s risk communications strategy for unpasteurised milk products will continue to evolve as the outcomes of the proposal are finalised. The objective will be to ensure not only that all sectors of industry have the information they need to meet their legal obligations, but also that consumers are made aware of any hazards associated with unpasteurised milk products.