RMP Verification

changes to implementation & monitoring of rmps

The New Zealand Food Safety Authority introduced changes to the way Dairy RMPs are to be implemented and monitored from 1 July 2009. The changes will affect operators who require NZFSA Official Assurances.

If you are an operator that processes, stores and/or transports export eligible product which requires official assurances (including dairy materials intended to be used in the manufacture of export eligible product), then the notice will apply to you.
There are market exemptions for which an NZFSA export certificate is not required.

Operators are encouraged to contact NZFSA for details or refer to Section 3 of the Notice.

Verification Frequency

This is determined by the Verification Programme applied to an RMP.  Frequencies are documented in DPC3 or the AP (Export Verification) Notice 2009.  The Export Verification Notice (EVP) applies to all RMPs where product is required to be eligible for export with official assurances and came into effect on 1 July 2009.
Verification frequencies are determined by the Recognised Agency based on operators performance and are reviewed following each verification audit or following occurrence of a critical non-compliance.

Verification Frequencies under EVP

The verification frequency of an operator under the EVP is determined by the Performance Based Verification (PBV) step assigned to the RMP Operator.  These PBV steps and the requirements for changing steps are documented in the Animal Products Export Verification Programme Schedules 1, 2 & 3.

Each location (or site) under an RMP is assigned a PBV step and needs to be audited at the frequency determined by this step.  Farm Dairy RMPs are assigned a single PBV step.

New operators must commence on the initial PBV Step appropriate for their business and progress to the ceiling frequency as per the steps in Schedules 1-3 in the Animal Products Export Verification Programme.

The verification frequency under the Export Verification Notice is determined based on the audit outcome and the assigned PBV Step. Each audit will be assigned an outcome of Acceptable or Unacceptable, defined and clarified in the Export Verification Notice and Programme as:

• Acceptable outcome means the verifier is satisfied:

(a) that the operator is substantially complying with all applicable regulatory requirements, and

(b) where there have been any departures from those requirements, that the operators corrective actions have been, or are, appropriate and effective”

• Unacceptable outcome means the verifier has determined that the operator is not in substantial compliance with all applicable regulatory requirements.

Verification Frequencies under DPC3

For RMP Operators  not operating under the Export Verification Notice the verification frequencies are assigned in accordance with the criteria in DPC 3 Table A9.1.  A frequency determination is made at the conclusion of each verification and stated in the RMP Verification report. 

Frequencies may also be reviewed following identification of issues with the Operator performance, or on request of an RMP Operator. 

Export Verification Audit Types

Scheduled audits

Audits which occur at the frequency determined by the assigned PBV step.  The date of the Scheduled audit is the date by which an audit needs to be completed.  This date is used to determine the date for the next Scheduled audit (Scheduled Audit + PBV Step Audit Frequency).

To ensure randomness in the system the Export Verification Programme requires that a minimum of 1/5 audits is Unscheduled and 1/2 Unscheduled audits (or 1/10 scheduled audits) are Unannounced.

Unscheduled or Unannounced

Audit occurs prior to the Scheduled audit date and replaces all or part of the Scheduled verification audit.  An Unscheduled or Unannounced audit does not affect the date of the next Scheduled verification audit.

An Unscheduled audit is planned and communicated to the site in the same method as a Scheduled audit.  An Unscheduled verification may also be completed to follow-up non-conformances on-site.

An Unannounced audit has little or no prior notice to the Operator but not more than 2 days notice.  The scope of an Unannounced audit does not need to be notified in advance of the audit.