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Operational Guideline: Development of a Dairy RMP from a PSP
May 2005
Important Disclaimer
Every effort has been made to ensure the information in this report is accurate.
NZFSA does not accept any responsibility or liability whatsoever for any error of fact, omission, interpretation or opinion that may be present, however it may have occurred.
What is the purpose of this guideline?
This guideline is designed to assist Dairy Product Safety Programme (PSP) holders & Third Party Agencies (TPA’s) in the conversion of a PSP into a Risk Management Programme (RMP) that meets the requirements of the Animal Products Act 1999 and associated legislation. It may also be of use to TPA’S when assessing compliance of an RMP.
What is included in this guideline?
This is an NZFSA Dairy and Plant Products Group operational guideline. It provides a checklist for assessing the areas within a Product Safety Programme (PSP) that may or will require change in order to comply with requirements under the Animal Products Act including the Animal Products (Dairy Risk Management Programme) Specification.
What are the desired outcomes?
It is expected that after reading this guideline Product Safety Programme (PSP) holders will be more able to identify the required amendments to develop an RMP from a (PSP).
Notes for the User
1. Sections of the RMP Specification which do not correspond to requirements of D101.2 and are substantially new requirements are shown as “NEW REQUIREMENT”.
2. Many of the “technical requirements” (e.g. Labelling, Housekeeping, Pathogen and Pest Management) that are currently contained within D101.2 will be transferred to the consolidated Criteria Documents. Where this occurs such requirements will not change without the normal stakeholder consultation process. Accordingly such requirements of D101.2 have not been included in this guideline.
3. This Guideline has been designed to assist dairy processors and other interested parties in the transition from PSP to RMP requirements. It should not however be seen as a substitute for knowledge of the RMP Specification and associated legislation.
These definitions must be read in conjunction with the interpretations in the Dairy Industry Act 1952 and the Dairy Industry Regulations 1990.
NZFSA Food: Dairy & Plant Products Group definitions of terms can be found in their “Glossary of Terms,” available on the Dairy & Plants website (www.nzfsa.govt.nz/Dairy/).
Change unlikely to be required: There is no significant change and it is anticipated that most previously approved Product Safety Programmes should be compliant in this area.
Review: There has been some change in this area and whilst it is anticipated most Product Safety Programmes will be compliant, all Product Safety Programme holders should check on the specific content.
Change Required: There is significant change and it is anticipated that that previously approved Product Safety Programmes will not be compliant in this area.
Note: The PSP to RMP Guidance material is based upon the generic requirements, and any individual PSP’s may contain additional detail inconsistent with the new requirements.
For more information:
Contact:
Dianne Schumacher
Programme Manager Manufacturing - RMP
NZFSA: Dairy & Plant Products Group
Phone: 04 463 2659 or 06 762 8701
Mobile: 021 724 862
Fax: 04 474 4196
Email: dianne.schumacher@nzfsa.govt.nz
Or
Tony Rumney
Programme Manager Primary Production and Residues
NZFSA: Dairy & Plant Products Group
Phone: 04 463 2658
Mobile: 021 672 389
Fax: 04 474 4196
Email: tony.rumney@nzfsa.govt.nz
PSP Requirements (D101.2 Product Safety Programmes) |
RMP Requirement (Dairy Risk Management Programme Specification) |
Changes to PSP |
1. PSP coverage |
[The requirement of APA (Dairy) Regulations] |
Change unlikely to be required |
2. Management of PSPs |
||
2.1 Development of PSPs |
||
2.2 Management of approved PSPs |
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2.2.1 Review |
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2.2.2 Revision/Variation |
Section 15.0 Documentation and Record Keeping Requirements Section 15.1 (a-e) Section 15.2 |
Review Recommended |
3. PSP access and communication |
Section 15.0 Documentation and Record Keeping Requirements Section 15.1 (f) Section 15.2 |
|
| Section 15 Documentation and Record Keeping Requirements Section 15.4 Section 15.5 |
Changes required (PSP may need updating) | |
4. Content of PSPs |
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4.1.1 Scope |
Section 6.0 (a) (b) Dairy material and Dairy product description | |
| Section 5.0 Boundaries of a Risk Management Programme Section 5.1 |
Change required (physical boundary required to be specified) | |
4.1.2 Roles and responsibilities (a) The accountable person |
Section 13.0 Identities of responsible persons | Review recommended (may require additional designations – depending on PSP content) NOTE Ensure that TPA is compliant with RMP Specification Section 26.0 |
4.1.5 Control of operations (a) Identification and traceability (b) Incoming goods : Commentary (c) Dairy raw materials (d) Non-conforming dairy produce (e) Pest management |
Section 8.0 Actions when outcomes not met Section 8.1 Section 12.0 Procedures Section 25.0 Recall |
Change unlikely to be required Review recommended to ensure recall procedures are documented |
4.1.6 Records |
Section 16.0 Monitoring, corrective action and operator verification records Section 16.1 (a) Section 16.2 Section 16.3 Section 16.1 (b)(c) Section 16.4 |
Review recommended Change required (4 yrs storage) Review Recommended |
4.1.7 Reporting |
Section 16.5 | Change unlikely to be required |
4.1.8 References |
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4.1.9 Importing country requirements |
(Not a requirement of the RMP Specification) | |
4.1.10 Assessment of the PSP A Validation of the PSP B Review of the PSP C Revision of the PSP |
Section 17.0 Validation Section 18.0 Obtaining an evaluation report Section 19.0 Evaluator endorsement of risk management programme Section 28.0 Director-General review of the risk management programme
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Review recommended Review recommended (as required by condition) |
| NEW REQUIREMENT Section 14.0 Verifiers’ freedom and access to carry out verification functions |
Change required ( to documentation within the RMP) | |
| 4.2 Operation of farm dairies | Section 9.0 Describing the process or operation
Section 11.0 Control of Hazards |
Change unlikely to be required Review recommended (ensure monitoring activities are documented) |
| NEW REQUIREMENT Section 10.0 Identification and analysis of hazards
|
Change required (Raw milk acceptance criteria may already partially provide this) | |
| 4.2.3 Farm dairy assessment | ||
| 4.3 Storage of raw milk and dairy raw materials | Section 9.0 Describing the process or operation Section 11.1(a) Control of Hazards |
Change unlikely to be required Review recommended (ensure monitoring activities are documented) |
| 4.3.2 Control of operations A Produce safety and HACCP |
Section 10.0 Identification and analysis of hazards Section 11.1/11.2 Control of Hazards |
Change unlikely to be required
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| 4.4 Transport of raw milk and dairy raw materials | Section 9.0 Describing the process or operation
Section 11.1 Control of Hazards |
Change unlikely to be required Review recommended to ensure monitoring activities are documented |
| 4.4.2 Control of operations A Produce safety and HACCP |
Section 10.0 Identification and analysis of hazards Section 11.2 Control of Hazards |
Change unlikely to be required Review recommended to ensure control limits are contained in HACCP plan |
| 4.5 Manufacturing | Section 9.0 Describing the process or operation Section 11.1 Control of hazards |
Change unlikely to be required Review recommended to ensure monitoring activities are documented |
| 4.5.2 Control of operations A Product safety and HACCP |
Section 10.0 Identification and analysis of hazards Section 11.2 Control of Hazards |
Change unlikely to be required Review recommended to ensure control limits are contained in HACCP plan |
| 4.6 Produce storage | Section 9.0 Describing the process or operation
Section 11.1 Control of Hazards |
Change unlikely to be required Review recommended to ensure monitoring activities are documented |
| 4.6.2 Control of operations A HACCP and product safety |
Section 10.0 Identification and analysis of hazards Section 11.2 Control of Hazards |
Change unlikely to be required Review recommended to ensure control limits contained in HACCP plan |
| 4.7 Produce transport | Section 9.0 Describing the process or operation
Section 11.1 Control of Hazards |
Change unlikely to be required Review recommended to ensure monitoring activities are documented |
| 4.7.2 Control of operations A HACCP and product safety |
Section 10.0 Identification and analysis of hazards Section 11.2 Control of Hazards |
Change unlikely to be required Review recommended to ensure control limits contained in HACCP plans |
| NEW REQUIREMENTS Section 7.0 Fitness for purpose Section 11.1(b) Control of Hazards Section 24.0 New Hazards |
Change required |
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