Develop a risk management programme

• In this step:

• Decide how to create your RMP
• Decide what your RMP will apply to
• What your RMP must include
• Different ways to structure your RMP
• Contact a validator and verifier

Decide how to create your RMP

There are 3 main ways to create your RMP:

1. Base your RMP on a Ministry for Primary Industries (MPI)-approved template or code of practice (where available).
2. Create your own RMP by following the RMP manual.
3. Convert your food control plan (FCP) to an RMP.

1. Using an MPI-approved RMP template

This is the easiest way to set up an RMP. Templates for specific activities are on the RMP resources page.

Resources for developing your risk management programme

Basing your RMP on an approved code of practice or template will:

• reduce the cost of creating your RMP
• make the process simpler
• ensure you follow best practice or acceptable industry practices and procedures
• ensure you meet any legal requirements
• mean you do not need to get your RMP evaluated.

We recommend using a template if one is available for your activity and it suits your needs. Even if you base your RMP on a template or code of practice, you should still use the RMP manual to ensure your RMP is complete.

2. Create your own RMP

You can write your own custom RMP. For instructions, refer to the RMP manual.

3. Convert an FCP to an RMP

If you have a food control plan (FCP), you can use it as the basis for an RMP. You can use the same risk factors that your FCP contains.

To convert the FCP to an RMP, you need to identify the:

• risks from hazards to animal health (if relevant)
• risks from false or misleading labelling
• risks to the wholesomeness of animal material or product.

You’ll need to get your RMP evaluated by a recognised evaluator.

Get your RMP evaluated (Step 3)

Decide what your RMP will apply to

What your RMP applies to is known as the "scope" of your RMP – what it does and does not include. Your RMP can apply to one or many products, processes, premises, or businesses.

When you're thinking about how you will set up your RMP, make sure you take into account the physical and operational aspects of your business. For example, if you operate a mobile business, or are a transport operator who uses vehicles in their RMP.

Your RMP must include a description of the:

• animal material it covers
• animal products it covers.

In your RMP, you must document:

• all animal materials or products managed under your RMP that are intended for human consumption, animal consumption, and industrial use
• the intended use of the animal material or product
• any specific consumer groups (such as pregnant and older people)
• any relevant regulatory and operator-defined limits
• any waste.

What your RMP must include

In the RMP manual, section 4 (RMP development) has details of what should be included in your RMP, as appropriate to your products and operation. These include:

• operator, business and RMP identification
• management authorities and responsibilities
• scope of the RMP
• animal material and animal product description
• process description
• supporting systems
• application of HACCP (Hazard Analysis and Critical Control Point)
• identification and control of risks to wholesomeness and from false and misleading labelling
• validation
• provision for verification activities and verifier rights
• additional requirements for dual operator butchers.

Applying HACCP

Hazard Analysis and Critical Control Point (HACCP) is an internationally recognised system used to identify, analyse, and control hazards.

This helps to ensure the food you produce is safe to eat. You must apply HACCP principles when you make your food.

Find out about using HACCP in your business

Operator verification

"Operator verification" refers to ongoing checks that you do as an RMP operator. You need to include how you will do operator verification in your RMP. These checks confirm that your RMP:

• meets legal requirements
• follows your documented system
• effectively manages any food safety hazards.

Operator verification activities include:

• internal audits
• reviewing the RMP
• doing reality checks.

Note that operator verification is different to "verifying your RMP" (which is covered in Step 5: Verifying your RMP).

Guidance document: Operator verification [PDF, 873 KB]

Different ways to structure your RMP

You can structure your RMP(s) in different ways. For example, you can:

• use a different RMP for each of your products, processes, premises, or businesses
• use one RMP that covers multiple products, processes, or premises (for example, both dairy and non-dairy animal products)
• use one RMP that covers multiple businesses.

Whatever you choose, you must ensure that your RMPs cover every aspect of the product, process, premises, or business that the RMP applies to.

Section 2.4: RMP configurations in the RMP manual has more information.

Including non-animal product foods in an RMP

RMP businesses have the option to use their RMPs to manage the food safety of non-animal food products. This option would apply most to businesses that use similar processing methods (like transporting, canning, or cold storage) to manufacture animal product foods regulated under the Animal Products Act 1999 and non-animal product foods regulated under the Food Act 2014. The guidance document has more information.

Guidance document: Can I include non-animal product foods in a risk management programme [PDF, 267 KB]

You should also discuss this with your verifier to ensure you have the correct scope of your RMP.

Using one RMP for both dairy and non-dairy products

You can use one RMP to cover both dairy processing and other animal product processing. It will need to meet the requirements for both areas. However, you may need to use separate evaluators and verifiers for each type of processing. Most verifiers and evaluators are recognised for either one or the other, so they may not be able to do both. This is likely to increase your costs.

Risk management programmes for farm dairies

Dairy risk management programme templates

Contact a validator and verifier

You'll need a validator and verifier for Steps 3, 4, and 5 (validation, registration, and verification). To register your RMP, you will need a letter from a verification agency confirming they have agreed to regularly verify your RMP.

We suggest that you contact a validator and verifier early, in case there is a wait time. You can search for validators and verifiers on our public register, or see Step 3 (validation) or Step 5 (verification) for more information.

MPI public register of recognised persons, agencies, and laboratories

• In this step:

• Check your RMP
• Validate your RMP

Check your RMP

Once you've created a new RMP (or amended an existing one), you need to do a check to ensure that it has all the required information.

For a custom RMP, check to make sure that:

• the RMP documentation is complete and meets all relevant legal requirements
• your premises and equipment will meet your RMP requirements and other legal requirements
• the RMP can consistently produce animal material or animal product that is fit for its intended purpose.

If you are using a template, code, or industry manual, check that you have:

• written any procedures you are required to have
• a way to make the records you are required to make
• calibrated any equipment that needs to be calibrated.

Find out about amending an RMP and significant amendments

Validate your RMP

Validation is the process of collecting evidence that shows your RMP can consistently produce food that is safe and suitable and meets requirements.

It's particularly important to give evidence that your RMP is meeting:

• the regulatory limits (for example, fish at 4ºC)
• your operator-defined limits.

To help write your validation report, you can use the resources, guidance, and other information found on our RMP resources page

You should also read our guidance document  What is 'Validation'? [PDF, 249 KB]

Validation protocols

If there's not enough evidence to prove that the RMP is effective before you submit your registration, you may need to develop a protocol for validation. This is a plan describing:

• what evidence you will collect
• how you will collect it
• the timeframe it will take you to collect the evidence
• what you will do with any animal material or animal product produced in this timeframe.

Section 5 (checks and validation) in the RMP manual has more about these protocols.

Risk management programme manual for animal product processing [PDF, 2.1 MB]

Validation requirements after your RMP is registered

If you have registered your RMP without validating all of it, you must:

• follow the protocol and any conditions (like timeframes to complete the validation work) imposed by MPI for registration
• collect evidence over that timeframe.

If you use a template, code, or industry manual to create your RMP

If you use one of these to create your RMP, you'll generally only need to show that you're consistently following the requirements in the template, code, or industry manual.

• In this step:

• Do you need to get your RMP evaluated?
• Find a recognised RMP evaluator
• What happens during evaluation

Do you need to get your RMP evaluated?

When you apply to register your RMP, you might need to provide MPI an independent evaluation report.

See Section 6 (evaluation) in the RMP manual and our guidance document for more information.

Risk management programme manual for animal product processing [PDF, 2.1 MB]

Guidance document: Evaluation manual for evaluating risk management programmes which do not cover dairy products [PDF, 732 KB]

When your RMP needs to be evaluated

You'll need to get your RMP evaluated if you:

• created your RMP without using a template, or
• used a consultant, or
• are converting an FCP to an RMP.

When your RMP does not need to be evaluated

You do not need to get your RMP evaluated if you used an MPI-approved RMP template. However, if you change any sections in that template, then these sections must be evaluated. This will ensure that the processes and activities are still suitable.

Talk to your contracted verifier about any changes you're making to an RMP template.

Find a recognised RMP evaluator

To choose an evaluator from MPI's recognised persons list:

• go to the register (link below)
• in the "Recognition Function" field, select "RMP Evaluation"
• in the "Activity" field, select the activity that fits most closely with what you're doing
• select the "Search Person" button
• when you've found an evaluator, select the link in the "Person Recognition ID" column.

MPI public register of recognised persons, agencies, and laboratories

If you want to narrow your search, you can try typing in a location. Try a town, city, or region.

Try to choose someone with experience in your type of operation. Some processes and activities (like dairy heat treatment and canning) require evaluators that are endorsed for that activity.

You can't use the same person to develop your RMP and evaluate your RMP, as this would be a conflict of interest.

You're responsible for any costs associated with an evaluation.

What happens during evaluation?

The evaluator will check that your RMP:

• covers all your operations
• meets all legal requirements
• will produce product that is safe, suitable, and truthfully labelled.

The evaluator will review:

• your documentation
• your operations and work procedures.

In most cases, this will involve a visit to your site.

You'll need to fix any issues that the evaluator finds. The evaluator won't provide solutions to the issues. This is because they must be impartial and independent.

RMP evaluation report

If the evaluator finds no issues with your RMP, they will:

• endorse your RMP outline
• prepare an evaluation report.

The report will propose any conditions that MPI should apply when your RMP gets registered.

You need to include the report as part of your application to register your RMP with MPI.

Reports are valid for 6 months

The evaluation report is only valid for 6 months. You should apply to register your RMP as soon as possible after evaluation. You’ll need to get evaluated again if 6 months pass.

• In this step:

• How to apply to register your RMP
• Registering an RMP that covers multiple businesses
• Registering before you've validated all of your RMP
• Next steps

Your RMP must be registered with MPI before you start producing food for trade.

How to apply to register your RMP

Complete application form AP4.

Application form AP4: Registration of risk management programme [PDF, 305 KB]

When you apply to register, you need to include:

• a copy of your RMP
• a letter from a verification agency that confirms it will be providing verification services
• a report from an independent evaluator if this is an application for a custom RMP
• completed application form AP4
• application fee
• any other required documents.

Email your application to approvals@mpi.govt.nz

Or post to:

MPI Approvals
PO Box 2526
Wellington 6140.

After you apply

We'll let you know the outcome. Our application process chart shows the review process and timeframes.

RMP application process – New or amended RMP [PDF, 221 KB]

For an RMP application to be considered at MPI's Monday pre-screen, it must be submitted by 10am on the previous Friday.

Registering an RMP that covers multiple businesses

If you're registering an RMP that covers multiple businesses, the process is almost the same as for an RMP covering one business. If your RMP will cover multiple businesses, you must also provide MPI with written evidence that the RMP operator:

• will have sufficient control, authority, and accountability for all matters covered by the programme in relation to the businesses
• has got consent of any person whose business is covered by the RMP (or has taken their views into account).

Registering before you've validated all of your RMP

Sometimes, only parts of your RMP will be validated when you register. The other parts will be validated after registration. If this happens, you'll need to develop a plan before you register that shows how you'll ensure the rest gets validated.

See Section 6.4 (validation after registration) in the RMP manual for more information.

We can approve your application if you have a plan to complete the rest of the validation after registering. You must:

• complete the validation following your plan
• give a validation report to the recognised evaluator covering the work you did, and any significant amendments that you made to your RMP after the work you did.

The evaluator will evaluate the validation report and any significant amendments you made. A significant amendment is a specific type of change that you make to your RMP.

Find out more about updating or changing an RMP

The recognised evaluator will prepare the final evaluation report when they're satisfied that validation is complete. Send this report to MPI, along with any endorsed RMP amendments.

Next steps

Once your RMP is registered with MPI, you can start producing food for trade.

You need to make sure that:

• your business processes meet the conditions of your RMP
• all the risk management activities are working
• records are being kept.

Your verification agency will visit and verify your records regularly. This will confirm that your RMP is continuing to deliver product that is safe, suitable, and truthfully labelled.

After registering your RMP, you must get it checked regularly by an MPI-recognised verifier. This will ensure you're meeting legal requirements. How often your operation is verified depends on your level of compliance with:

• the registered RMP
• any relevant OMARs.

If your operation complies with the RMP, you'll need verification less often. Visits are needed more often if your RMP isn't compliant, or if you export product.

Additional verification frequencies differ depending on what products you are making. Refer to the Operational Code: Verification [PDF, 508 KB]

Find a recognised RMP verifier

To choose a verifier from MPI's recognised persons list:

• go to the register (link below)
• in the "Recognition Function" field, select "RMP Verification"
• in the "Activity" field, select the activity that fits most closely with what you're doing
• select the "Search Agency" button
• when you've found a verifier, select the link in the "Recognition ID" column.

MPI public register of recognised persons, agencies, and laboratories

The verification agency must confirm in writing that they will verify your RMP on an ongoing basis. Include their confirmation letter with your application.

Your first verification visit will usually happen within 1 to 6 months of registering your RMP. This will depend on the type of animal product you make or process.

You're responsible for:

• making sure verification happens before the deadline
• paying for the verification visit.

Verification requirements for RMPs

The following documents prescribe the verification requirements in detail: