Code of Practice: Processing of Seafood Products Part 1: Overview July 2011 Disclaimer Every effort has been made to ensure the information in this report is accurate. MAF 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. Requests for further copies should be directed to: MAF Information Bureau PO Box 2526 WELLINGTON Telephone: 0800 00 83 33 Facsimile: 04-894 0300 This publication is also available on the MAF food safety website at: www.foodsafety.govt.nz/elibrary/ © Crown Copyright - Ministry of Agriculture and Forestry Ministry of Agriculture and Forestry Code of Practice: Processing of Seafood Products 1 Part 1: Overview Amendment 0 Prelims July 2011 Prelims Amendment 0 July 2011 Contents Page Prelims 2 Review of Code of Practice 3 1 1.1 1.2 1.3 Purpose and Scope of the Code of Practice Parts of the COP Supplementary Information Exclusions 4 4 5 5 2 2.1 2.2 2.3 2.4 Requirements of the Animal Products Act 1999 6 Risk management programmes (Part 2 of the Act) 6 Regulated control schemes (Part 3 of the Act) 6 Exporter controls (Part 5 of the Act) 7 Imposition of authorisations, duties and responsibilities (Part 8 of the Animal Products Act) 7 3 3.1 3.2 Risk Management Programme What is a risk management programme? RMP configurations 3.2.1 Single-business RMP (Sections 12(3) and 12(4) of the Act) 3.2.2 Multi-business RMP (Section 17A of the Act) Contents of a risk management programme 3.3.1 Contents 3.3.2 RMP components 3.3 8 8 8 8 9 9 9 9 4 4.1 4.2 4.3 Development of an RMP based on an Approved Code of Practice Development Evaluation Steps for the development, registration and implementation of an RMP 11 11 11 12 5 Other Legislation 13 6 Sources of Other Information 14 Ministry of Agriculture and Forestry Code of Practice: Processing of Seafood Products 2 Part 1: Overview Amendment 0 Prelims July 2011 Review of Code of Practice This code of practice will be reviewed, as necessary, by the Ministry of Agriculture and Forestry. Suggestions for alterations, deletions or additions to this code of practice, should be sent, together with reasons for the change, any relevant data and contact details of the person making the suggestion, to: Manager (Food Standards) New Zealand Standards Group MAF PO Box 2526 Wellington Telephone: 04 463 2500 Facsimile: 04 463 2643 Ministry of Agriculture and Forestry Code of Practice: Processing of Seafood Products 3 Part 1: Overview Amendment 0 Purpose and Scope of the Code of Practice July 2011 1 Purpose and Scope of the Code of Practice Amendment Number 0 July 2011 This code of practice (COP) has been developed by the New Zealand Seafood Standards Council and the Ministry of Agriculture and Forestry (MAF), in consultation with an industry working group. This COP has been developed to assist seafood operators to meet the requirements of the Animal Products Act 1999 and produce seafood products for human consumption that are safe and suitable for its intended purpose. Guidance is provided for meeting the development, registration and implementation requirements of risk management programmes (RMPs). For operators under the Food Act (Food Safety Programme operators and businesses registered under the Food Hygiene Regulations 1974), this COP provides a good source of guidance. This COP applies to businesses involved in the primary and secondary processing of seafood products for human consumption. Examples of primary seafood products processing include, but are not limited to: heading, gutting, and filleting of fish; shucking, heat shocking, land-based wet storage and depuration of bivalve molluscan shellfish; tubing of squid; and tailing of crustaceans. Examples of secondary seafood products processing include, but are not limited to: acidification, salting, brining, smoking, thermal processing, refrigeration, storage; extraction, drying, blending of powders from fish or shellfish; and addition of non-animal product ingredients to Seafood Products e.g. breading, coating, saucing, assembling. 1.1 PARTS OF THE COP The COP is divided into three parts. Part 1: Overview Part 1 gives an overview of the whole COP and the requirements of the Animal Products Act 1999. It explains the options available to operators for the development of RMPs. It also provides links to other relevant documents published by MAF. Part 2: Good Operating Practice (GOP) Part 2 covers good operating practice and process control. It sets out the regulatory requirements, and acceptable or agreed procedures for meeting the requirements of the Act, particularly the Specifications for Products Intended for Human Consumption. This will assist operators in the development and documentation of supporting systems that form part of RMPs. Ministry of Agriculture and Forestry Code of Practice: Processing of Seafood Products 4 Part 1: Overview Amendment 0 Purpose and Scope of the Code of Practice July 2011 Part 3: HACCP Application, and the Identification of Other Risk Factors and their Controls Part 3 shows how the principles of Hazard Analysis and Critical Control Point (HACCP) can be applied to seafood products processing. It also covers the identification of risk factors and controls related to the wholesomeness and labelling of seafood products. 1.2 SUPPLEMENTARY INFORMATION In some places, the COP refers to supplementary information. This supplementary information includes: Generic RMP Models; Guide to HACCP Systems in the Seafood Industry; Guidelines for Seafood Recall Programmes; Verification of Cleaning Programmes; Listeria Guideline 1993. 1.3 EXCLUSIONS This code of practice does not apply to the following: 1. Activities covered by the current versions of the RCS and notice which cover all activities involved in growing, harvesting, sorting and transporting bivalve molluscan shellfish for commercial purposes up until the time when the shellfish are received by a wholesaler or retailer or sold direct to the consumer, or undergo primary processing. Please refer to the following links for the required details: Animal Products (Regulated Control Scheme – Bivalve Molluscan Shellfish) Regulations 2006 (Shellfish RCS) (external website) Animal Products (Specifications for Bivalve Molluscan Shellfish) Notice 2006 (330KB PDF) This means that the following activities are excluded from the COP - relaying, temporary storage, and wet storage occurring in a coastal marine area or a land-based aquaculture facility. However, the COP does cover wet storage in a land-based facility or any other forms of primary processing that operate under an RMP. 2. Activities carried out on Limited Processing Fishing Vessels that are covered under the current versions of the RCS, notice and associated operators guidelines. Please refer to the following links for the required details: Animal Products (Regulated Control Scheme-Limited Processing Fishing Vessels) Regulations 2006 (external website) Animal Products (Specifications for Limited Processing Fishing Vessels) Notice 2006 (330KB PDF) Regulated Control Scheme for Limited Processing Fishing Vessels: Operator Guidelines (303KB PDF) The COP has been developed based on New Zealand requirements only and does not cover overseas market access requirements. Exporters must ensure that they meet the overseas market access requirements relevant to their product and intended market. Ministry of Agriculture and Forestry Code of Practice: Processing of Seafood Products 5 Part 1: Overview Amendment 0 Requirements of the Animal Products Act 1999 July 2011 2 Requirements of the Animal Products Act 1999 Amendment 0 July 2011 The Animal Products Act 1999 is New Zealand’s legal framework for the processing of animal products. It establishes a risk management system that requires all animal products traded and used to be “fit for intended purpose”. The Act sets out the duties of the operator and the requirements related to risk management programmes (RMPs), regulated control schemes, and exporter controls. 2.1 RISK MANAGEMENT PROGRAMMES (PART 2 OF THE ACT) All primary processors of seafood products for human or animal consumption are required to have a registered RMP. Secondary processors of seafood products must operate under an RMP except where their operations are covered by the Food Act regime. Although secondary processors of seafood products intended for export to overseas markets are not required to have a registered RMP, an RMP is usually necessary to enable them to comply with overseas market access and official assurance requirements. Operations that constitute primary processing of seafood products are described in clauses 7 and 8 of the current version of the Animal Products (Exemptions and Inclusions) Order. Secondary processing of seafood products includes processes at any stage beyond primary processing. Persons who carry out the operations listed below are exempt from the requirement to have an RMP (see clauses 10 and 11 of the current version of the Animal Products (Exemptions and Inclusions) Order): retail sale of fish if no fish from their operation are exported; both retail and wholesale sale of fish if no fish are exported, provided the operations are covered by a food safety programme under the Food Act 1981; temporary holding, storage, or transport of fish pending their transport to a primary processor; and processing of fish bait, fish berley, chum or ground bait. In addition, no RMP is required for persons operating fishing boats where the fish is not landed in New Zealand nor claimed to be a product of New Zealand. 2.2 REGULATED CONTROL SCHEMES (PART 3 OF THE ACT) A regulated control scheme is a scheme developed by the MAF and imposed by the DirectorGeneral to manage risks, where: RMPs would not be feasible or practicable; it is more efficient for the government to run the programme; or it is needed to meet the market access requirements of foreign governments. Ministry of Agriculture and Forestry Code of Practice: Processing of Seafood Products 6 Part 1: Overview Amendment 0 Requirements of the Animal Products Act 1999 July 2011 As noted in Part 1, Section 1.3 of this COP, MAF has developed regulated control schemes for the growing, harvesting, sorting and transporting of bivalve molluscan shellfish and for the control of processing operations carried out on limited processing fishing vessels. 2.3 EXPORTER CONTROLS (PART 5 OF THE ACT) Exporters of Seafood Products must register with MAF. Exporters are responsible for exporting in accordance with the Act and, where appropriate, may be required to meet specified market access requirements of foreign governments that are additional to the New Zealand standard. Export requirements are excluded from this COP. Operators should, however, be aware of these requirements and ensure that their documented systems include procedures and records necessary to demonstrate compliance with all relevant requirements notified in: General Requirements for Export (GREX); and Overseas Market Access Requirements (OMAR). The guide for exporters discusses exporter requirements in more detail: Guide to Exporting Animal Products Including Dairy 2.4 IMPOSITION OF AUTHORISATIONS, DUTIES AND RESPONSIBILITIES (PART 8 OF THE ANIMAL PRODUCTS ACT) The Act provides for MAF’s recognition of agencies and persons to undertake certain functions and activities (e.g. evaluation and external verification) that are important to the management of RMPs. MAF maintains a public register of all recognised agencies and recognised persons, which is available on http://www.foodsafety.govt.nz/. The Act imposes duties on these key persons: operators of RMPs (section 16 of the Act); exporters (section 51 of the Act); recognised agencies (section 106 of the Act); and recognised persons (section 107 of the Act). The Act also provides for appropriate penalties to be applied when an offence occurs. Ministry of Agriculture and Forestry Code of Practice: Processing of Seafood Products 7 Part 1: Overview Amendment 0 Risk Management Programme July 2011 3 Risk Management Programme Amendment 0 July 2011 3.1 WHAT IS A RISK MANAGEMENT PROGRAMME? A risk management programme (RMP) is a documented programme designed to identify and manage hazards and other risk factors in relation to the production and processing of animal material and animal products, in order to ensure that the resulting animal product is fit for intended purpose. The risk factors that must be considered in the development of an RMP are: risks from hazards to human and animal health; risks from false or misleading labelling; and risks to the wholesomeness of animal material or product. An operator’s registered RMP will be “legally binding” so it must be developed and implemented in accordance with relevant New Zealand legislation. MAF does not require overseas market access requirements and commercial quality issues to be part of the RMP. The Risk Management Programme Manual provides comprehensive information on the principles and components of RMPs and provides guidance for their development: Risk Management Programme Manual (638KB PDF) 3.2 RMP CONFIGURATIONS An RMP may be developed for a single business or for multiple businesses. 3.2.1 Single-business RMP (Sections 12(3) and 12(4) of the Act) A single RMP that covers the operations of a single business located in a single site is the simplest form of an RMP and its use is encouraged, whenever applicable. This is likely to be the most suitable RMP configuration for the majority of seafood products processors. A business may decide to have more than one RMP. This may be useful when the operation can be logically and clearly split by product, process or premises. Such an arrangement can give flexibility to the operator in terms of making RMP amendments. It also allows for the suspension or deregistration of one RMP without affecting the other. However, consideration should be given to the practicality and cost of managing more than one RMP within a single business, and how this may affect any market access requirements. Ministry of Agriculture and Forestry Code of Practice: Processing of Seafood Products 8 Part 1: Overview Amendment 0 Risk Management Programme July 2011 3.2.2 Multi-business RMP (Section 17A of the Act) An RMP may apply to more than one business, if the Director-General approves such an arrangement for the particular business. The approval will depend on the operator being able to demonstrate that: the programme is appropriate to all businesses or part-businesses that it covers; the registered operator of the programme will have sufficient control, authority and accountability for all matters covered by the programme in relation to the other business or part-business subject to its coverage; and the applicant has obtained the consent or otherwise taken into account the views of any person whose business or part-business is to be covered by the programme. Certain market access requirements, for example European Union (EU) listing requirements, do not allow this RMP configuration to be used. A multi-business RMP is thus unlikely to be a suitable configuration for the majority of Seafood Products processors. 3.3 CONTENTS OF A RISK MANAGEMENT PROGRAMME 3.3.1 Contents The documented RMP must include the following: Good Operating Practice Good Operating Practice (GOP) includes the practices and procedures designed to ensure the consistent production of products that are safe and suitable for their intended purpose, and that meet relevant regulatory requirements. It includes several interacting components such as hygienic practices, process control and quality assurance systems. Operators will usually document GOP in the supporting systems of their RMP. GOP is the foundation for Hazard Analysis and Critical Control Point (HACCP) and RMPs. GOP for the processing of seafood products is discussed in Part 2 of this COP. Application of HACCP principles The operator must apply HACCP principles, as appropriate to the product and process, to ensure a systematic approach to the identification and analysis of hazards and their control. This is covered in Part 3 of the COP. Identification of other risk factors and their controls Other risk factors related to the wholesomeness of the product and risks from misleading labelling must be identified and documented in the RMP, together with control measures for addressing the identified risk factors. These are also covered in Part 3 of the COP. Other RMP requirements Other RMP requirements such as business identification, operator’s details, physical boundaries, and provision for verifiers’ rights must also be documented in the RMP. 3.3.2 RMP components The RMP should include the following components: Operator, business and RMP identification; Ministry of Agriculture and Forestry Code of Practice: Processing of Seafood Products 9 Part 1: Overview Amendment 0 Risk Management Programme July 2011 List of RMP documents; Management authorities and responsibilities; Scope; Animal material and animal product description; Process description; Good Operating Practice; Application of HACCP (identification, analysis and control of hazards to human or animal health); Identification and control of risks to wholesomeness; Identification and control of risks from false and misleading labelling; Identification and competency of responsible persons; Corrective action for unforeseen circumstances; Recall procedures; Validation; Operator verification; Notification requirements; Provision for external verification activities & verifiers’ rights; Document control and requirements for records. Ministry of Agriculture and Forestry Code of Practice: Processing of Seafood Products 10 Part 1: Overview Amendment 0 Development of an RMP based on an Approved Code of Practice July 2011 4 Development of an RMP based on an Approved Code of Practice Amendment 0 July 2011 The Animal Products Amendment Act 2002 allows for an RMP to be based on a COP, a template, or a model if in the view of the Director-General it is valid and appropriate for businesses of that kind. A COP that is deemed as valid and appropriate after an assessment process carried out by MAF will be formally recognised as an “approved code of practice”. A COP is a valuable tool to use in the development of the RMP. Compliance with an approved COP will: ensure that the operator complies with current best practice or acceptable industry practices and procedures; ensure that the operator meets the relevant regulatory requirements; and simplify and reduce the cost of developing and evaluating the RMP. The applicability of the approved COP to the particular business and the degree of the operator’s compliance with the approved COP will influence the development approach, and, in some cases, the evaluation requirements for the RMP. 4.1 DEVELOPMENT The simplest approach for developing an RMP is to base the RMP on relevant generic RMP model(s) that MAF provides for several categories of Seafood Products processing. These models can be found in the Supplementary Information document “Generic RMP Models for the Processing of Seafood”. Operators must customise their RMPs to cover specific products, processes and premises. Businesses whose products and processes are not fully covered by the approved COP, or who have decided to apply procedures and/or processing parameters that differ significantly from those given in the COP, must be able to demonstrate that any alternative procedures or parameters can consistently and effectively meet all relevant regulatory requirements and produce products that are safe and suitable for their purpose. To demonstrate the effectiveness of such alternative procedures the operator may be required to collect evidence (e.g. data from testing or trials, published scientific information, report from an expert) for assessment by the recognised evaluator or MAF. 4.2 EVALUATION Seafood products RMPs, whether they are based on the approved seafood COP or include procedures that vary from the COP, must be evaluated by an independent, recognised evaluator to confirm the adequacy of the RMP. Evaluation will involve a desk-top audit of the documented RMP and an on-site visit of the premises, and must be complete before the RMP can be registered. Ministry of Agriculture and Forestry Code of Practice: Processing of Seafood Products 11 Part 1: Overview Amendment 0 Development of an RMP based on an Approved Code of Practice July 2011 4.3 STEPS FOR THE DEVELOPMENT, REGISTRATION AND IMPLEMENTATION OF AN RMP The steps for the development, registration and implementation of an RMP are summarised in Figure 1. When developing their RMP, operators may incorporate parts of the COP by reference, provided the parts referenced reflect the actual activities / processes that take place within the business. Figure 1: Steps for the development, registration and implementation of an RMP Development Operator develops RMP based on the COP OR Operator develops own RMP Operator confirms effectiveness of any alternative procedures/parameters, and validates the RMP Operator writes to recognised verifying agency requesting letter to confirm the agency’s agreement to provide verification services for the RMP Evaluation Operator contracts an evaluator Recognised evaluator carries out evaluation, prepares report and recommends RMP for registration Registration Operator submits to MAF the documents required for registration including RMP or RMP outline, application form and fee MAF assesses and registers the RMP application Implementation Operator notifies recognised verifying agency of RMP commencement Operator implements the RMP, including operator verification Recognised verifier provides external verification Operator applies for registration of any significant amendment* * Significant amendments will require evaluation prior to registration – for information on significant amendments refer to Appendix G of the Risk Management Programme Manual: Risk Management Programme Manual (638KB PDF) Ministry of Agriculture and Forestry Code of Practice: Processing of Seafood Products 12 Part 1: Overview Amendment 0 Other Legislation July 2011 5 Other Legislation Amendment 0 July 2011 This COP will help seafood products operators to meet the requirements of the Animal Products Act 1999. Operators are responsible for ensuring that they are familiar and comply with all other relevant legislation. Operators should not rely solely on this COP to provide them with information on the legal requirements under other legislation. Legislation that is likely to be relevant to seafood operators includes, but is not limited to, the following Acts and their associated regulations and specifications: Animal Products Act 1999; Animal Products (Ancillary and Transitional Provisions Act) 1999; Agricultural Compounds and Veterinary Medicines Act 1997; Biosecurity Act 1993; Commerce Act 1986; Consumer Guarantees Act 1993; Fair Trading Act 1986; Food Act 1981; Hazardous Substances and New Organisms Act 1996; Resource Management Act 1991; Health and Safety in Employment Act 1992; Fisheries Act 1993. Ministry of Agriculture and Forestry Code of Practice: Processing of Seafood Products 13 Part 1: Overview Amendment 0 Sources of Other Information July 2011 6 Sources of Other Information Amendment 0 July 2011 Information specific to seafood products is available on the seafood part of the MAF food safety website: Seafood Other information about the Animal Products Act 1999 and RMPs can be obtained through the animal products part of the MAF (food safety) website or the risk management part of the MAF (food safety) website: Animal Products – General Risk Management Programmes (RMPs) The new food safety section of the MAF website also provides useful information. Food Safety Ministry of Agriculture and Forestry Code of Practice: Processing of Seafood Products 14 Part 1: Overview
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