Domestic Food Review Update

1
Domestic Food Review Update

• Glen NealAssistant Director
• (Food Service, Sale Import)
• NZ Standards Group

Carole InksterDirector (Policy) Policy Group
2
Background

• Commenced in 2003
• Purpose ensure New Zealand has a food programme
  that applies across the board and will deliver on
  promote safe suitable food into the future

3
Background

• Largely completed Policy development phase
• Entering Legislation and Implementation
  phases
• New Food Act by 2008
• Complete implementation by 2013

4
Status of Policy

• Government agreed to NZFSA proceeding to
  legislation in late 2006
• Transition policy being analysed (almost 50
  submissions received)

5
Recap on Policy

• Principles to underpin legislation
• minimising costs
• regulatory model (see diag in brochure/papers)
• basis for regulatory controls
• persons taking responsibility
• consistent requirements
• seamless/coherent programme
• facilitate trade

6
Recap on Policy

• Tools
• Food Control Plans
• Off-the-Peg
• Custom-made
• National Programmes
• for all or part of FCP
• Food Handler Guidance
• prepared by NZFSA/TAs
• educational

Supported by information, guidance, codes of
practice, templates, models etc
7
Recap on Policy

• Local Government roles
• Local Government to be shop front for food
  businesses
• Continue registration function but will include
  most premises currently exempt under FHRs
• Replace inspection with verification
• Exclusive area for verification will include
• Off-the-Peg Food Control Plans
• Businesses limited to one jurisdiction
• Business sells direct to the consumer
• Limited community reach

8
Food Bill and Regulations etc

• Drafting instructions for Bill provided to
  Parliamentary Counsel Dec 06
• Awaiting first draft
• Legislative priority proceed to Select
  Committee
• Awaiting first draft
• Continue to aim for passage in 2007
• Replacement FHRs Food (Safety) Regs in draft
  Food Regulations

9
Food Bill

• 9 Parts proposed
• Introduction
• definitions, commencement, etc
• Imported Food
• FCPs and CoPs
• National Programmes
• Food Standards and specifications
• Recognised agencies and persons
• TAs
• roles, guidelines, voluntary transfer of
  functions, etc
• Approvals, cost recovery, offences, penalties,
  etc
• Miscellaneous
• records, right of review, consultation,
  regulations, notices, etc

10
Food Regulations

• 6 Parts proposed
• Food standards
• Premises, facilities, equipment and essential
  services
• Lighting, ventilation, etc
• Operational standards
• Hygiene of processing environment, training, etc
• Identification, labelling and record keeping
• Primary producers
• Miscellaneous
• Offences, etc
• Schedule 1 Specification for operator supply of
  clean water

11
Implementation

• Implementation Timing
• Over five years commencing on
• 1 July 2008

12
Implementation - Verification

• Key elements from NZFSA VA
• Operates across New Zealand
• Provides mandated verification export
  certification services to companies operating
  under the Animal Products Act 1999
• Verifies around 1,000 RMPs meat, seafood, eggs,
  DOBs, pharmaceuticals, some dairy, petfood, honey
  etc
• Verifies non-RMP operations animal material
  depots, scientific material operators, fishing
  vessels, wharves etc

13
Implementation - Verification

• Accredited to ISO 17020 plus meet other
  requirements of a Recognised Agency set by NZFSA
• Structure 9 teams across New Zealand
• The Agency is responsible for assessing
  individuals against competencies for proposed
  functions
• Puts forward applications for recognition of each
  individual for verification or evaluation as
  applicable

14
Implementation - Verification

• Verification operates on Performance Basis (PBV)
• Poor performers get more frequent visits good
  performers get less
• NZFSA has a policy statement for APA verification
  that includes
• Frequency of verification
• Minimum requirements for verification visits
• Reporting requirements
• Rights of appeal
• Stepping rules

15
Implementation - Verification

• Implementation of PBV
• Established National Verification System
• Established VA Online to track compliance
  nationally
• Communicated with industry
• Clearly outlined steps to be followed for poor
  performers
• Initial verification designed to facilitate change

16
Implementation - Verification

• Strategies for implementation
• Consistency of verification
• Predictability of cost
• Relationship building and management
• Information management
• Up skilling VA and industry
• Close liaison with standard setter to assist
  with practical development of standards

17
Implementation - Verification

• Strategies for implementation
• Establish team sector coordinators (conduct
  verification visits to ensure verifiers from
  teams are calibrated)
• Establish a dispute procedure
• Develop maximum timeframes for verification
• Agree with sector on specified scope each
  verification visit
• Use standardised verification tools e.g.
  checklists and report templates

18
Implementation - Verification

• Focus of initial visits on capacity building with
  industry
• Clear bottom lines relating to food safety
  established
• Initial training of team sector coordinator and
  industry representatives
• Manage information via sector specific web pages
• For future annual reviews from verification
  activities
• Annual refresher training and calibration

19
Transition Update

• Submissions on discussion paper closed 9 February
  07
• Summary nearing completion
• Analysis underway

20
Transition Recap

• Discussion paper covered following
• Why have a transition
• When will businesses be affected
• What about Food Safety Programmes
• And Risk Management Programmes, Wine Standard
  Management Programmes
• Food Handler Guidance
• Update on roles and responsibilities
• QAs

21
Transition Recap

• Food sectors proposed - Year one

22
Transition Recap

• Food sectors proposed Year Two

23
Transition Recap

• Food sectors proposed Year Two (cont)

24
Transition Update

• Main themes raised in submissions
• Response to purpose direction of DFR
• Year 1 of transition (too many businesses at
  once)
• Transition of particular sectors
• Education training
• TA capability capacity
• TA Area of exclusivity for verification
• Small businesses

25
Transition Update

• Main themes raised in submissions (cont)
• Clarity on role of PHUs
• Cost of new regime who pays?
• ISO17020/NZFSA standard
• Compliance
• Define Fit and Proper Person
• Relationship to other legislation risk
  management tools
• FCPs, Food Handler Guidance National Programmes
  

26
Transition Update

• Proposals for Year One
• Have General Food Service category running over
  two years
• How to split category
• Dine in or Take out
• Liquor licensed or not licensed
• When does year one start
• Best estimate 1 July 2008
• When is final registration date etc

27
Trials and Training

• Overview of
• Off the Peg Food Control Plan Trials for
• Corner Dairies
• Foodservice
• DFR Implementation Project
• Training and Education

28
Background

• 2002 Work with PHU to develop Mini-mart
  template
• 2004 Template shown to sample of Corner dairy
  operators identify support
• 2006 Template (OTP FCP) trial test the
  proposal

29
Trial objectives and opportunities

• Introduce small business to a template FCP
• Involve TAs in delivering OTP FCP concept
• Measure outcomes by independent parties

30
Trial objectives and opportunities

• How small businesses respond to the concept
• Impact on the business
• Implications for TAs
• Time inputs needed
• Effectiveness/relevance of documents
• Impact on food safety/suitability
• Issues arising

31
Trial format and method

• 11 EHOs, 7 TAs
• Independent Auditor
• Market Researcher

32
Trial format and method

• Workshop
• introduce TAs/EHOs to OTP FCP docs and mission
• Identify participants
• Representative sample of sector as far as
  possible
• Volunteers
• Pre-trial audit by Independent Auditor
• Food safety practices implemented
• Extent of documentation
• OTP FCP introduced to dairies by EHOs

33
Trial format and method

• 1 month in participant interviews with Market
  Researcher
• Understanding of trial, documents, likes,
  dislikes issues, early experiences
• 3 months business as usual
• End-of-trial audit
• Level of documentation, understanding
• Changes to practices
• Participant and EHO interviews
• Longer-term usage/involvement, time implications,
  changes to ideas

34
Findings - Auditor

• Pre-trial
• Limited evidence of systems
• One premises - signed-off cleaning schedule
• Three premises - reasonable temperature
• records
• Need for documentation questioned by many
  participants

35
Findings - Auditor

• Most businesses a husband-and-wife team some
  family help
• At least one person at each had hygiene training
• Significant proportion of sector have English as
  a second language
• Unfamiliar with quality management systems

36
Findings Auditor

• End of Trial
• Varying levels of completing documentation
• Some improvements to implementation noted -
• Storage of ice-cream scoops Provision of
  single-use towels
• Cleaning Pie-warming activities
• Diary used to varying degrees but popular
• However issues with
• Thermometers/calibration
• Need for Suppliers lists

37
Findings Market Research

• Our business has increased by one-third since we
  cleaned up the shop and made a strong commitment
  to cleaning and good food handling. It started
  before the trial. The lady at the Council told us
  that things needed to be done differently in
  future and she was right. It did help out
  business. This plan we are using in the trial is
  just a follow-on to that.

38
Findings Market Research

• Its bollocks. Im not using that every day. I
  did it for a week, that was enough. Im not
  interested. It requires too much documentation.

39
Perceived changes to operations

• 12 Corner dairy owners (41) acknowledged
• operational changes as result of OTP FCP
• I now wrap ice cream cones with tissue.
• I do more frequent cleaning, I dont put off
  tasks until tomorrow.
• Our checking procedures are more regular and
  less random.
• We now heat pies before we put them in the pie
  warmer.
• We now rinse the milk shake machine.

40
Summary - Dairies

• Corner dairies liked simplicity of documents,
  content, diary
• Start of trial few systems (3 premises) End of
  trial 50 completed some/all documentation 75
  implementing, or had introduced, GOP 80
  prepared to continue with Plan
• Spectrum in approach to trial identified
  progressive, partially convinced, unenlightened
• Further simplification sought
• Colour and pictures

41
Summary - EHOs

• First sight of OTP FCP by EHOs cautious
  optimism
• Support to dairies identified as critical to
  success
• Time resource issue
• Training/support need for EHO competence and in
  delivery
• Good documents
• Information/guidance for consistency
• Good lines of communication
• No Surprises
• Issues with language/cultural barriers
• Motivation of operators

42
Next

• Evaluate ideas presented by trial
• Incorporate suggested changes
• Recognise differences in complexities of
  individual businesses
• Identify levels of data/monitoring appropriate to
  operation
• Training devise/provide/make available to
  deliver OTP FCP concept

43
Next

• TA resources to enable multi-regime registration
• Training resources for business
• Support and guidance
• Time - for understanding incorporation as
  function

44
FCP Pilots General Food Service

• Initiative commenced 2005
• Steering group of HANZ, RANZ and NZFSA plus the
  Accor hotel chain
• Pilot of Safer Food Better Business pack from
  UKFSA in 2006

45
Food service trial

• 2007 Trial underway
• OTP-FCP adapted from UK SFBB other models
  from around world and across NZ
• 14 TAs and 5 PHUs
• Auckland, Hawkes Bay, Wellington
• Christchurch, Otago and Southland
• Chefs Association and Sports Clubs (SCANZ) also
  interested

46
Trial objectives

• Determine the suitability of the draft OTP-FCP
• Test suitability of audit tool
• Identify likely implementation resource needs

47
Foodservice trial

• 30 50 independent restaurant/cafes
• Pre and post trial assessments
• EHOs as coaches
• PHUs as assessors
• Final report due 1 July 2007

48
DFR Implementation Project - Training

• In a world of change, learners will inherit the
  earth, while the learned shall find themselves
  perfectly suited for a world that no longer
  exists.

Eric Hoffer, Ordeal of Change
49
DFR Proposals

• Build on basic education in food safety
  suitability in New Zealand education system and
  that contributed by Foodsafe Freddie
• NZFSA will encourage voluntary training schemes
  for people involved in food handling
• Mandatory recognition of competencies for some
  people and businesses subject to FCPs
• No training requirement for those covered by Food
  Handler Guidance

50
DFR Consultation summary

• Should all require minimum training? Yes say most
• Mandated nationally where required, or by TAs?
  Nationally
• Should effectiveness mechanisms be developed?
  Dont rely on FBI use competency assessment and
  tests
• How should we reach small business and ESL?
  Signs, pictures, translate training material,
  multi-lingual trainers

51
DFR Consultation Summary

• Accessible and affordable to community/voluntary
  sector? Night classes, web-based training,
  polytechnics
• Demonstrated competencies or mandated
  training/qualifications?
• Should we regulate competency of consultants?
  Most said yes to deliver training
• Incentives (fee rebates, endorsement), Funding
  (mixed views), training of regulators required

52
Project approach

• Proposed project phases
• Health Protection Officers (first)
• Environmental Health Officers (next)
• Food sector (soon after)
• Individual requirements for verification
  (auditors)
• Training providers (ensure capacity)
• NZFSA competencies link to HR strategy

53
Project approach

• Identify current frameworks competency
  requirements
• Identify existing capability and capacity
  baselines
• Identify gaps
• Propose how these will be met by
• Health Protection Officers March 2007
• Environmental Health Officers July 2007
• Third Party Agents July 2007
• Food Industry December 2007

54
Process

• 1 Roles confirmed
• 2 Draft competencies to underpin roles and
  tasks
• 3 Consult and modify proposed competencies
• 4 Skills gap analysis
• 5 Develop proposals for delivering competency
  gaps

55
Implementation Complete

• 30 June 2013