Risk management programmes for egg processing food safety
If your food business produces eggs, or you're a secondary processor exporting with an official assurance, you are likely to need a risk management programme (RMP).
The Animal Products Act 1999 (APA) requires most primary processors of eggs to have a registered and independently verified risk management programme (RMP) before trading any eggs.
Primary processing includes harvesting, "candling", grading and packing whole shell eggs. Candling is the assessment of eggs for freshness, fertility, or defects by use of light, electronic means, or any other commercially accepted means. In practical terms, this means the RMP must apply from the layer farm (where the harvesting occurs) through to the packhouse (where the candling occurs).
Secondary processors (those who break eggs and make egg products) who require official assurances for export are also required to have an RMP. Secondary processors may choose to operate under an RMP rather than under a registered food control plan (FCP) under the Food Act 2014.
Purpose of RMPs
An RMP covers good operating practice and manages the following hazards and other risk factors:
- hazards to human health (consumers)
- hazards to animal health (where eggs are used for pet food or animal feed)
- risks to wholesomeness (anything that is offensive or unexpected in that type of product)
- risks from false or misleading labelling.
Exemption from RMP requirement
Some smaller egg producers may be eligible for an exemption from having an RMP (clause 11F of the Animal Products (Exemptions and Inclusions) Order 2000). However, exemption from the RMP requirement does not exempt you from any other legal requirements.
You qualify for this exemption if you:
- produce eggs for sale for human or animal consumption from 100 female birds or fewer (all species included) and
- sell all eggs intended for human or animal consumption direct to the consumer or end-user and
- do not sell any eggs to any person for further sale (such as a cafe, shop, or other third parties).
Female bird count
All your female birds on the laying farm are counted as part of the 100 birds, regardless of their age, location, whether or not they are currently in lay, and whether or not eggs are the main reason for keeping the birds. The only exceptions would be for female birds whose eggs are clearly never meant for consumption, such as pet budgies or birds specifically grown for meat production.
If you have clearly separated rearing and laying farms, then you may count only those female birds on the laying farm (so long as all birds on the rearing farm are clearly young birds not yet in lay).
If more than one egg producer shares a property (for example, a husband and wife), each would be allowed to have 100 female birds only if they could show that their operations are separate (throughout harvesting and packing). It would not be acceptable to run or house the birds together.
You will not always know what people use your eggs for, but if you're selling to another business of any type, it is highly likely the exemption will not apply. If you know that the purchaser on-sells the eggs or uses them to prepare food that is sold to someone else, then you cannot sell to that person and claim the exemption.
You must sell the eggs yourself. This is normally done at the laying farm, a farmers' market, or by delivering the eggs yourself to the consumer. You cannot have someone else sell your eggs for you at farmers' markets (or any other places) and claim the exemption.
You need to be able to show you meet the requirements for the exemption. This can be done by having a physical count of the female birds, and by having a mechanism, such as a conspicuous notice, to notify your customers that eggs are only for sale to the final consumer and are not allowed to be on-sold or used to make other foods that are then sold.
How to get your RMP
This guidance document helps businesses to develop their RMP or Food Control Plan (FCP)
Guidance Document: Egg Pulping for RMPs and FCPs [PDF, 710 KB]
You are responsible for developing your RMP. To simplify the job, use our "fill in the blanks" RMP template and guidelines.
You can write your own RMP, so long as all relevant legislation is met and the programme is shown to be effective. Refer to our step-by-step guidance and list of consultants who have experience in developing RMPs:
Another source of useful information is the Technical Annex of a generic code of practice for egg production, produced by MPI and the Egg Producers Federation:
Technical Annex [PDF, 959 KB]
Having your RMP evaluated
Once you have completed your RMP, you may have to get it evaluated by a recognised evaluator.
If it is fully based on our RMP template for eggs – that is, you haven't altered the pre-written parts of the template except as recommended by MPI, then evaluation is not required.
Read the legal basis for waiving this requirement:
If you have changed the template or written your own RMP, evaluation is required. You must hire an RMP evaluator to do this.
Choose an RMP evaluator:
Register your RMP
The next step is to apply for registration of the RMP using Application Form AP4 (with or without an evaluation report, depending on whether it's needed). Use Form AP49 to identify the scope of your RMP.
MPI will assess the application and register the RMP if you are considered a "fit and proper" person (mainly by having no previous convictions for fraud, dishonesty, or mismanagement) and the RMP meets requirements.
Verify your RMP
Once the RMP is registered, you must get it checked by an MPI-recognised verifier to ensure the RMP has been implemented effectively. Further verification visits will be done annually, or more frequently if needed.
If you're unsure whether you or someone else should have an RMP, contact us:
- Email: firstname.lastname@example.org
Other APA requirements for egg producers
Part 4 of the APA allows for the setting of Animal Product Standards and Specifications. These define the criteria that must be met for particular animal products to be treated as fit for their intended purpose.
In the current Animal Products Notice: Specifications for Products Intended for Human Consumption, all the general sections at the front are relevant and Part 9 relates specifically to egg production and processing: