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The chemical residue and contaminant status of New Zealand foods

The regulatory model

The current government approach to regulating the food chain comprises a regulator (primarily but not exclusively NZFSA), an approved verifier, who undertakes verification activities on behalf of the regulator, and the regulated party, who can be any food producer, processor, seller or importer.

Regulator

As the primary food regulator for New Zealand, NZFSA administers Acts, develops standards, provides scientific and policy advice that contributes to food standards, monitors conformance and reviews legislation to ensure it is effective.

Food Standards Australia and New Zealand (FSANZ) is a bi-national independent statutory authority that develops food standards for composition, labelling and contaminants (including microbiological limits) that apply to all foods produced or imported for sale in Australia and New Zealand. FSANZ works in partnership with Australia’s commonwealth, state and territory governments and the New Zealand government.

In New Zealand, the Environmental Risk Management Authority (ERMA) is responsible (under the Hazardous Substances and New Organisms Act 1996) for imposing controls that limit human exposure to a wide range of substances (including agricultural compounds and veterinary medicines) to ensure public health and environmental safety. Oral exposure to hazardous substances is within the scope of the Act although direct food management is not. While there is an overlap between ERMA and NZFSA, the two authorities manage different risks and collectively provide the necessary regulatory control. In particular, ERMA sets a human exposure limit where one is required.

Within NZFSA the Compliance and Investigation Group (CIG) investigates breaches of those Acts that come under the jurisdiction of NZFSA – it acts as the ‘eyes and ears’ of NZFSA. CIG carries out compliance audits in the export sector and the domestic food area, as well as assisting with overseas audits of New Zealand’s food processing systems.

The Animal Products Act 1999 establishes a risk management system that requires all animal products traded and used to be fit for their intended purpose. The risk management system includes the following types of controls:

• Risk Management Programmes (RMPs) – these are individually designed and implemented by operators, and evaluated and verified by persons recognised by NZFSA and belonging to recognised agencies

• Regulated Control Schemes (RCSs) – these manage risks on a national basis when processor-based RMPs would not be feasible, practicable, efficient or economical

• Standards – the APA provides for regulations and specifications (including manuals) to amplify and/or clarify requirements under the Act

• Export controls – NZFSA issues export requirements that are either generic or market specific in nature, monitors compliance with those requirements and issues official assurances to facilitate trade.

Risk management programmes

A key control for many dairy and meat product processors is the Risk Management Programme, which is developed by operators for a specific operation to manage known biological, chemical and physical hazards. The RMP must apply Hazard Analysis and Critical Control Point (HACCP) principles, identifying the systems of control, and demonstrating that they are effective.

Each RMP is independently evaluated and verified to show that the operation complies with regulatory requirements, covers the scope of the operation, is technically sound, and will minimise and manage food safety and suitability risks.

The RMP needs to include:

• the business name and name of the person who is ultimately responsible for the programme

• the scope of the business, its products and their intended use

• any hazards identified in animal material, animal product and processes, and how these hazards will be managed

• a system of record keeping

• how the RMP will be verified by an independent, recognised agency.

All RMPs need to be registered with NZFSA and then verified on an ongoing basis. This checks that the business is following the RMP and that the RMP continues to deliver product that is fit for intended purpose.

Recognised Agencies and Recognised Persons

Verification of RMPs and official assurances is an activity provided for under the Animal Products Act (APA). Both the agency and the individual persons must be recognised by NZFSA to undertake verification activities.

NZFSA’s Verification Agency (VA) is a Recognised Agency for providing verification and official assurance services for animal products, animal material and certification of live animals or germplasm being exported from New Zealand. It is responsible for confirming compliance with all technical and market access requirements relating to animal product premises (eg: export and domestic slaughter premises, processing premises, cold stores, canneries and by-product premises). It employs veterinarians to inspect animals, ensure animal welfare protocols are followed and provides export certification for certain animal products.

VA is audited annually by International Accreditation New Zealand and is accredited to ISO 17020.

Third-party agencies can also act as verifiers for NZFSA if they meet the criteria for recognition under the APA. AsureQuality is a Recognised Agency for verification of RMPs under the APA. It employs more than 400 inspectors and auditors who also provide independent auditing, inspection and testing services to the food and agricultural sectors in the Southern Hemisphere.

Under the Food Act 1981, auditing (verification) of food safety programmes is provided by third-party agencies such as AsureQuality, Society Generale Surveillance (SGS), IMS and certain Territorial Authorities that are approved by the Chief Executive of NZFSA. An individual person may also be an agency.

Industry or ‘regulated parties’

In terms of the regulatory model a ‘person’ can be any food producer, processor, seller or importer. It is the responsibility of ‘persons’ in the industry to apply NZFSA-approved risk management plans that identify, assess and manage hazards and other risk factors. These plans ensure that food products will be safe and suitable for consumers.

Use of agricultural compounds and veterinary medicines

Agricultural compounds are chemicals (including veterinary medicines) used in the production of primary produce (farmed plants or animals). They are also used by home gardeners, and for the health of domestic animals such as cats and dogs.

Agricultural compounds can be natural or synthetic and include veterinary medicines, fertilisers and pesticides (fungicides, herbicides and insecticides). Farmers following either conventional or organic methods of production can use approved chemicals to control pests and weeds, treat their animals, and improve soil fertility (amongst other things).

Control of residues and contaminants starts with control of the chemicals that may be used.

One of the many tasks NZFSA performs is ensuring the use of agricultural chemicals and veterinary medicines does not cause a breach of food residue standards. NZFSA ensures users of these products have sufficient information to apply them appropriately and safely. This gives farmers confidence that the compounds and medicines they use are safe for consumers of their stock and their crops.

Knowing the levels of residues in foods ‘as produced’ (at harvest) allows NZFSA to take appropriate action where and when it is required. For example, if unexpected residues were found, there could be new or amended controls on foods or on the use of agricultural compounds, increased monitoring, or additional consumer information.

Agricultural compounds and veterinary medicines are used to control agricultural pests and animal diseases. Because New Zealand is a relatively small country, the bulk of these compounds and medicines are imported ready-made. A small proportion are manufactured locally from imported ingredients. Their use is controlled by NZFSA to protect consumer health and meet market requirements. The Agricultural Compounds & Veterinary Medicines Group at NZFSA is responsible for the registration of agricultural compounds and veterinary medicines, and monitoring their importation, manufacture, sale and use In New Zealand.

Registration can be refused for a trade-name product if the risks as set out in the ACVM Act cannot by managed. To manage these risks, conditions of registration can be placed on the product covering areas in the manufacture, distribution and sale, and use of it. The label content, including instructions on how to use the product correctly and the withholding periods, is also approved by NZFSA.

Before an agricultural compound or veterinary medicine can be sold or used in New Zealand it must be first registered under the ACVM Act 1997. This involves the assessment of information relating to the product’s chemistry including both the compound and its formulation, animal or plant safety, its efficacy and its residue profile in animals and plants.

Part of this assessment includes the review of residues in food producing animals or crops and setting a withholding period based on good agricultural/veterinary practice. A withholding period is the time between last application of the product and harvest/slaughter/collection of the produce. Based on this a maximum residue limit may be established under the Food Act 1981.

Acceptable residue levels

New Zealand’s reputation as a world leader in food safety assurance systems does not automatically give exporters access to world markets. Our food not only has to be proven safe at home but it also has to meet legal requirements for many overseas markets.

NZFSA’s market access reputation is protected by monitoring programmes that demonstrate compliance with standards. Our aim is to align standards or have our trading partners accept that our New Zealand systems – based on sound science and a risk-based approach – deliver results that meet their requirements.

Overseas market access requirements (known as importing country requirements in the case of dairy product exports) are not driven by NZFSA, they are driven by individual governments and may differ widely from country to country.

NZFSA has official assurance programmes for animal products (these include meat, game, seafood, egg, dairy and bee products), organic products and wine. These set out legislative and export requirements relating to those products.

All imported and domestically produced food sold in New Zealand (except for food imported from Australia) must comply with the New Zealand (Maximum Residue Limits of Agricultural Compounds) Food Standards (the MRL Standards). Food imported from Australia is covered under the Trans-Tasman Mutual Recognition Arrangement and the joint Food Standards Code.

Under the MRL Standards, agricultural compound residues in food must comply with the specific MRLs listed in the MRL Standard (including the ‘default’ MRL of 0.1mg/kg for compounds where no specific MRL is listed), or if the food is imported, it may comply with the Codex Alimentarius MRLs.

Codex Alimentarius is an international food standards code developed by the Codex Alimentarius Commission (CAC). The CAC is an international food standards agency that was established jointly by the Food and Agriculture Organization of the United Nations (FAO) and the World Health Organization (WHO) in 1963. The CAC develops standards for use by all member nations. Codex standards are designed to protect the health of consumers and promote fair practices in food trade.

New Zealand has had significant input in gaining recognition for the application of risk analysis principles to Codex standards-setting and decision-making. New Zealand chairs the key Codex Committees on Meat Hygiene and Milk and Milk Products, and participates in several Codex ‘horizontal’ committees, including those on Food Hygiene, Food Additives, Pesticide Residues, Food Labelling, Residues of Veterinary Drugs, and Methods for Analysis and Sampling. This leadership is helping us shape the international standards that serve as a framework for our global trade.

Maximum residue limits

Residues of an agricultural compound in food must be no higher than the MRL for that chemical. The MRL is the highest concentration of residue allowed in food crops or animal products at harvest or sale and is legally enforceable. A residue found at or below the MRL indicates that the farmer or grower has followed requirements and used the compound properly. This is sometimes referred to as following ‘good agricultural practice’.

MRLs are not safety limits, although they are set below levels known to have any adverse health effect. MRLs are set to ensure that, at harvest or slaughter, the chemical will have achieved the desired effect and the resulting residue is as low as possible. Adherence to MRLS is effected by specifying a withholding period which is the period that must elapse between the application of a chemical product to an animal or plant and when the animal is slaughtered or the animal or plant product harvested. An MRL also takes into account any other relevant breakdown or metabolism of chemicals in the plant or animal, as well as the residue of the agricultural compound itself.

Good agricultural practice

All exporting countries need to pay due diligence in the field of food safety and quality assurance, as cemented by Codex Alimentarius and the ‘farm to fork’ approach. A stringent quality assurance system covers many aspects of fruit and vegetable growing, starting with the choice of production sites, soil preparation, agricultural inputs and harvesting, and ending at storage requirements and transport. This system is generally guided by ‘good agricultural practice’ (GAP), a term used to describe the safe uses of a chemical under actual conditions necessary for effective use. Regulators around the world use GAP as part of their management of pesticides and veterinary medicines.