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28 October 1999
The new Animal Products Act will deliver food safety assurances, advance New
Zealand's export competitiveness and potentially save the country millions per annum.
The Act, which in most part commences on November 1, covers the production and
processing of all animal products unless otherwise specified.
It will directly affect a wide range of New Zealanders such as processors of animal
products, farmers, homekill operators, exporters, and recreational hunters.
It will affect all other New Zealanders by ensuring animal products are free from
diseases, defects and contaminants of concern. This is considered vital to the health and
well being of consumers on both the domestic and international market.
Internationally, consumer confidence was shaken following headlines of breakdowns in
the food safety system - BSE in Britain and E.coli outbreaks in Japan, Australia, Scotland
and the United States. These highly visible episodes lead to widespread moves
internationally and in New Zealand, to revise food safety regulations. In New Zealand
these were a factor in the development of the Animal Products Act.
The Animal Products Act will eventually repeal the Meat Act 1981 and the Apiaries Act
regime. The Meat Act in particular was considered outdated, inconsistent and unduly
prescriptive, and industries felt constrained by it.
The Animal Products Act 1999 will be implemented over a three-year transitional period
– until 31 October 2002. During this time the two former Acts will operate in
parallel except in a three key areas - export provisions, cost recovery and homekill
– which come into force from day one (1 November 1999). The transitional provisions
are contained in the Animal Products (Ancillary and Transitional Provisions) Act.
Government and the Risk Management System
The Animal Products Act will reduce the Government's involvement at the
operational level of the business and puts the responsibility for risk management on
Government's new role focuses on managing a risk management system within which it
sets risk management outcomes for businesses to meet, rather than prescribing how industry
should deliver safe animal products. Industry operator's must develop and implement
their own risk management programmes tailored to meet their own specific needs.
All primary processors of animal material and secondary processors of animal products
which are not food, and 'dual operator' butchers must develop and implement risk
management programmes, which manage known biological, chemical and physical hazards
involved in processing animal products.
The risk management programme must reflect current knowledge regarding food risk
management and include Hazard Analysis and Critical Control Point (HACCP) principles (i.e.
that the animal products are safe and healthy for consumption by humans and animals). The
risk management programme must be able to demonstrate that the business is effective in
delivering animal products that meet the operational systems and product standards.
As these programmes are specifically tailored, those businesses that already have
specially tailored quality assurance programmes in place are likely to enjoy significant
cost savings because many of the quality assurance aspects will satisfy risk management
programme requirements. Many businesses already operating under both the Food Hygiene
Regulations of the Food Act and the Meat Act will now be able to operate under their
elected regime and not be required to meet both sets of concurrent requirements. Risk
management programmes are equivalent to food safety programmes under the Food Act.
To reduce implementation costs further, the new Act facilitates the establishment by
different industry groups of 'generic template' risk management programmes that
businesses could adapt to their particular operations. Much of industry is already
acquainted with HACCP principles and the philosophy of food safety risk management, so it
will not be a new concept for them.
Risk management compliance also brings with it a reduction in the number of
verification requirements for businesses. The implementation of the Act's risk
management system will involve an investment by Government and industry, but the down
stream benefits are estimated to bring a saving. It's believed that the cost of not
moving to a risk management programme would be an increased hampering of market access.
Risk management programmes must be registered with the Ministry of Agriculture and
Forestry after being evaluated by an independent person whom is accredited by the
Ministry. Key information within the risk management programmes (other than that, which is
commercially sensitive) will be held on a public register.
The final date for having risk management programmes in place is 31 October 2002 but
earlier adoption is being strongly encouraged. As well as setting risk management
outcomes, MAF will maintain an overview of the whole risk management system.
For exporters of animal products, the new Act no longer requires mandatory export
certification, which is currently required for meat and fish products under the Meat Act
Currently we have a 'one size fits all' system within which meat product
exporters have to meet the requirements of the most stringent overseas market, regardless
of whether they are exporting to that country or not.
Under the Animal Products Act, official Government assurance will be given - usually in
the form of certificates – when they are required by importing countries to ensure
our producers consistently meet overseas market requirements.
All businesses producing animal material and products for human and animal consumption
intending to export must register with MAF within six months of the Act's
commencement. MAF will continue to provide New Zealand exporters with information covering
overseas market access requirements.
Homekill, recreational catch and dual operators
From November 1, homekill and recreational catch activities will be covered by the Act
when legal requirements for homekill operators are formalised.
The Act preserves the right of animal owners, actively engaged in the day to day
maintenance of their animals, to slaughter and consume their own meat. It also allows for
service providers to offer a slaughter and butchering service. Homekill and recreational
catch service providers have six months (until April 2000) to be listed with MAF so they
can be contacted by MAF for any reason such as informing them of legal changes and be
subject to inventory controls.
The law remains the same as in the previous legislation in regards to how the homekill
product must be used or consumed. Homekill can only be slaughtered for the use of the
farmer or the animal's owner, their family or household and those workers living on
the farm. In essence, those privy to, or involved in how the slaughtered animal was
The homekill must take place on either the animal owner's property or the service
provider's premises. It remains an offence to sell or trade homekill meat because it
is uninspected. All meat for sale must be inspected.
Hunters who kill game can have the game processed by a recreational catch service
provider as long as it is for the hunter, their family, or members of the hunting
party's own use or consumption.
The Act officially recognises retail butchers dealing in regulated animal product
handling homekill product simultaneously as 'dual operator butchers'.
These dual operator butchers will be required to have risk management programmes in
place which make a separation between the regulated meat trade and the homekill service.
This is to provide greater food safety assurances to our trading partners.
Dual operator butchers will need to be listed with MAF as service operators by 30 April
2000. In mid-2000 the same operators will be required to register a risk management