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Approval for the Risk Management Programme (RMP) Template for Farm Dairies – Export Eligible Milk

4th September 2007

I, Carol Barnao, Director (Export Standards), approve the Risk Management Programme (RMP) Template for Farm Dairies – Export Eligible Milk dated August 2007 in its entirety, in accordance with section 12 (3A) of the Animal Products Act, for the purpose of making the determination that the Risk Management Programme (RMP) Template for Farm Dairies – Export Eligible Milk is valid and appropriate for the businesses of the kind described in the Statement of Application.

Statement of Application

The application of the Risk Management Programme (RMP) Template for Farm Dairies – Export Eligible Milk is limited to businesses of the kind that are farm dairies involved in, on farm milk harvesting and storage activities, and supplying milk intended for further processing that includes a defined heat treatment.

Without limiting the application, this approval covers the harvesting and storage of raw milk, including colostrum, intended for further processing into dairy products for the domestic market or for export.

Signed at Wellington this 4^th day of September 2007.

[ Signed ]

Carol Barnao, Director (Export Standards)
New Zealand Food Safety Authority
(Acting under delegated authority)

1. Background

1. Despite the general requirement that a risk management programme is tailored to the individual business concerned, section 12 (3A) of the Animal Products Act (the Act) allows for a risk management programme for a particular business, or part of a business, to be based on a template, a model, or a code of practice, if in the view of the Director-General the template, model or code of practice is valid and appropriate for businesses of that kind.

2. The NZFSA has published the Animal Products Act 1999 – Approval of Templates, Models, Codes of Practice Statement of Policy to clarify the application of section 12 (3A) of the Act and provide the procedural arrangements for assessing and approving a template, model or code of practice.

3. The NZFSA has developed a Risk Management Programme (RMP) Template for farm dairies supplying milk intended for either the domestic market or for export referred to as the ‘Risk Management Programme (RMP) Template for Farm Dairies – Export Eligible Milk’. The version approved is dated August 2007.

2. Justification

1. The following aspects have been considered in making this approval:-

a. The Risk Management Programme (RMP) Template for Farm Dairies – Export Eligible Milk incorporates regulatory requirements that are applicable for the kind of business concerned;

b. The Risk Management Programme (RMP) Template for Farm Dairies – Export Eligible Milk incorporates Good Operating Practice, the application of HACCP principles, other RMP components, and requirements of DPC2 Farm Dairies, Animal Products (Dairy) Approved Criteria that are appropriate for the kind of business concerned;

c. The Risk Management Programme (RMP) Template for Farm Dairies – Export Eligible Milk makes appropriate identification of regulatory requirements distinct from strongly recommended practice distinct from helpful information, and as relevant, an indication of what this distinction means in terms of application to a business; and

d. The Risk Management Programme (RMP) Template for Farm Dairies – Export Eligible Milk is practical, achievable and appropriate for the kind of businesses concerned.

2. The Risk Management Programme (RMP) Template for Farm Dairies – Export Eligible Milk meets criteria (a), (b) and (d) above. Of note, the Risk Management Programme (RMP) Template for Farm Dairies – Export Eligible Milk was trialled by both small farm dairy operators as well as a new multi-business RMP operator. Feedback received from this trial and from other consultation processes was incorporated into the Risk Management Programme (RMP) Template for Farm Dairies – Export Eligible Milk.

3. In regard to the identification of regulatory requirements, recommended practice and guidance material, it is noted that the Risk Management Programme (RMP) Template for Farm Dairies – Export Eligible Milk has clearly identified the regulatory requirements in each section of attachment, however allowances for specific businesses to tailor relevant parts of the Export Eligible Milk to their particular operation are clearly identified and as such it is considered that the business application is clear.

4. Market specific export requirements may apply to the farm dairy activities over and above those set out in the Risk Management Programme (RMP) Template for Farm Dairies - Export Eligible Milk. Such export requirements must also be met if the milk is intended to be eligible for those markets.

3. Disclaimer

1. Considerable effort has been made to ensure that the information provided in the Risk Management Programme (RMP) Template for Farm Dairies – Export Eligible Milk is accurate, up to date, and otherwise adequate in all respects. Nevertheless, this RMP template is approved STRICTLY on the basis that the Crown, the New Zealand Food Safety Authority, its statutory officers, employees, agents, and all other persons involved with the writing, editing, approval or publication of, or any other kind of work in connection with the Risk Management Programme (RMP) Template for Farm Dairies – Export Eligible Milk:

a. Disclaim any and all responsibility for any inaccuracy, error, omission, or any other kind of inadequacy, deficiency, or flaw in, or in relation to, the Risk Management Programme (RMP) Template for Farm Dairies – Export Eligible Milk; and

b. Without limiting a) above, fully exclude any and all liability of any kind, on the part of any and all of them, to any person or entity that applies the Risk Management Programme (RMP) Template for Farm Dairies – Export Eligible Milk.