Working as a verifier
Find out how to become a verifier, the training available, and the responsibilities of verifiers under the new Food Act.
Becoming a verifier
If you want to become a verifier, you'll need to apply to become a recognised person or agency.
MPI's Food Verifiers Academy is a central point – a hub – for verifiers to get and exchange:
- guidance on performance expectations.
The focus for verifiers under the new law
The Food Act moves from a one-size-fits-all approach, to one that is risk based. This means that high-risk businesses should have to meet higher standards than lower-risk businesses. It also means that verifiers should focus on what is most important for achieving food safety at each type of business.
The Act focuses on outcomes rather than prescriptive measures. Guidelines for verifiers are aimed at supporting them to use their professional judgement.
The Act encourages businesses to take responsibility for food safety in their business, and we hope that verifiers will play a role in educating businesses about what this means.
Who can verify which risk-based measure?
Template Food Control Plans are mainly verified by councils (territorial authorities). Other risk-based measures (RBMs) can be verified by any appropriately-recognised agency or person. This includes local councils and third party verifiers.
Only local councils can verify template food control plans for businesses that operate exclusively in their council area. This is explained in section 137 of the Food Act.
Use this table to check
The table shows the risk-based measures that have contestable verification and those that can be done only by a territorial authority. When a measure is contestable it means any agency or person that has gained the appropriate recognition can do the verification.
|Custom food control plan||Contestable, subject to gaining appropriate recognition. The agency and/or verifier is required to have ISO 17020 accreditation.|
|Section 39 template food control plan (where a business is in a single territorial authority region and sells primarily directly to consumers)||Only territorial authority verifiers. Recognised under section 137 of the Act.|
|Section 39 template food control plan (where a business is not in a single territorial authority region and/or does not sell primarily directly to consumers)||Contestable subject to gaining appropriate recognition.|
|Section 40 template (where a business uses an industry-generated template approved by MPI)||Contestable subject to gaining appropriate recognition.|
|National programme||Contestable subject to gaining appropriate recognition.|
Steps to complete a verification
Businesses using a third party verifier will need to include a letter from their chosen verifier or agency when they apply for registration.
If a business contacts you, and you want to work with them, provide them with a letter to say you will verify them. You don't need to know an exact date for the first verification.
If you are the registration authority and the verifier, you don't need to provide a letter.
Check business details
Check what type of business you are verifying and what risk-based measure this falls under. If they are operating under a custom food control plan request a copy of the plan from the business.
Find details in the food business Public Register, or your own records. If the business is multi-site, ensure you know what operations each site is responsible for.
You can also find food registration business details in Titiro. This is the online system developed by MPI to assist with verification activities and to capture your verification results. You need to register to use Titiro.
The first verification of a multi-site business must include every site. For subsequent verifications, you can select a sample of sites to verify. You can use the outcome of the sample verifications to determine the outcome for other sites that were not verified and are covered by the same risk-based measure.
Check the business compliance history by reading their previous verification report. The registration authority should let you know of any enforcement activity undertaken between verifications (or you can request this). This should help inform what you focus on during the verification.
Technical expert support
If the business is in a sector you are not familiar with, or uses processes that you do not fully understand, you may need a technical expert's support during the verification.
Schedule a visit
Schedule the initial verification within these timeframes (from when the business registers):
|Risk-based measure||New business||Existing business|
|Custom food control plan||3 months||6 months|
|Template food control plan||6 - 12 weeks||1 year|
|National Programme 1||6 - 12 weeks||1 year|
|National Programme 2||6 - 12 weeks||1 year|
|National Programme 3||6 - 12 weeks||6 months|
For subsequent verifications, schedule according to the verification step in the most recent verification report. If you are taking over verification of an existing business, you should contact the business for a copy of their most recent report.
Schedule a mutually convenient time
Verifiers should give businesses reasonable notice of a verification, and work with them to schedule a mutually convenient time. The appointment should be at a time that allows you to see the business up and running, but also allows the operator and key staff to engage in the verification. So, don't go when the business is closed, or at the busiest time of the day.
Consider the type of business, their previous compliance history, and topics required by MPI.
High-risk businesses have to meet higher standards than lower-risk businesses. You should focus on what is most important for food safety at each type of business.
What's required for a National Programme business may be different from what's required of a Food Control Plan business, even when the same topic is being checked. For example, cleaning is required of all businesses, but sanitising is not. National Programme businesses don't need written procedures.
We have compiled a list of verification topics to help you know what to check when you verify a business.
- Download the verification criteria and topics [XLSX, 42 KB]
- Read verification topics guidance [PDF, 133 KB]
Not all topics need to be included in every verification, but you must include:
- at least one from each verification criterion
- the top 5 food safety factors
- the mandatory topics.
Top 5 food safety factors
MPI has developed the top 5 food safety factors for each type of business that will move to the new law in the first year (between 1 March 2016 and 30 June 2017).
The top 5 food safety factors for the relevant sector should be the key focus of your verification.
- Find the top 5 food safety factors for the relevant sector
- Read more about the top 5 food safety factors [PDF, 118 KB]
You must include all the following mandatory topics:
- Registration/scope of operations
- Improvements and corrective actions
- Traceability, recall and complaints
- Managing unsafe/unsuitable food.
Use your professional judgement
Add to the list of topics to be verified based on the information you gathered in the preparation stage (such as previous verification findings or compliance actions). You should cover enough topics to give you confidence that food will be safe and suitable, and consider covering different topics from the previous visit.
The verification topic mapping documents will help you understand what each topic means.
- Verification topics and mapping to template food control plan [PDF, 168 KB]
- Mapping verification topics to the template food control plan – for businesses on a deemed plan [PDF, 168 KB]
- Find out about working with businesses on deemed plans
You can also find verification topic information in Titiro. This is the online system provided by MPI to assist with verification activities and to capture your verification results. Titiro provides you with descriptive text on each topic as you verify, and also indicates which topics are considered mandatory or 'top 5'. You need to register to use Titiro.
Let the business owner or staff know who you are and why you are there (even if you arranged the appointment with them). Set expectations for the verification. Let them know what you will be checking and what will happen if you identify something that must be changed or fixed.
Explain when you need to report your findings to a food safety officer (escalation). If you are also an officer, explain what will happen if you need to switch from a verifier to an officer role. Present your warrant if switching to an officer role.
During the first verification, you should explain:
- that they are operating under a new regime, and what changes to expect
- the appeals and complaints procedure.
If relevant, discuss follow-up to any issues that were identified at the previous audit. You should also find out whether they have made any changes to their operation or key personnel since the last audit. Tailor your approach according to the level of experience the business has with the verification process.
Look through their Food Control Plan, if they have one, or check any written procedures they are using. Note, those businesses on a National Programme do not have to have written procedures. In many cases you can complete this part of the verification before your visit.
Check they're following procedures and keeping records
To make sure they're doing what they say they are, you should:
- talk to management and staff to make sure there is a consistent understanding of how things should be done
- observe what people actually do
- check equipment and the environment, where these are important for the safety and suitability of the food
- ask to see the records required by the food control plan or national programme regulations.
Remember that the purpose of verification is to 'check the truth'. Use a combination of all of the above (what you see and what you hear) to learn whether the food business is taking the right steps to produce safe and suitable food. We are looking for 'safe and suitable food' rather than just compliance.
Use your professional judgement. Based on what you see on site, you can add topics to the scope of verification if you think necessary to confirm the business is doing what is needed.
Decide on outcomes
For each verification topic covered, decide on an outcome. Is the business:
- critically non-compliant
Each topic outcome has a specific meaning, as outlined in this document:
- Verification topic outcomes [PDF, 92 KB]
You'll need to say if any corrective actions are needed. Then determine the overall outcome of the verification – either acceptable or unacceptable.
Using Titiro to enter your verification results
When using Titiro to enter your verification results, either manually or from a file, the system will automatically calculate a score for you using MPI's verification scoring matrix. Based on that score, it will also calculate a suggested outcome which you can override. The purpose of the scoring matrix and the suggested outcome are to help us better calibrate verification outcomes nationally. So if you override an outcome, you may wish to review why, and whether you need to adjust how you apply topics and outcomes.
At the end of the verification visit
Let the business know what they are doing well, as well as discussing any areas they need to improve.
- say if any corrective actions are needed (required for every non-compliant outcome and may be required for non-conforming outcomes).
- agree on a plan to address the issues, including setting reasonable timeframes. Typically the plan should be agreed within 48 hours.
Do not instruct the business what they must do to correct any problems. Instead, help them to work through some options for corrective actions. Let them decide which corrective action is best for them.
If the business disagrees with anything, remind them of the dispute process.
Finally, tell the business when you'll next visit.
Deciding on the frequency of visits
The timing of the next verification will be based on the risk-based measure, the current frequency, and the outcome of the verification.
Use our verification frequency guidance to help decide which verification step a business should be on, and when their next verification will be due.
- Verification frequency guidance [PDF, 290 KB]
When using Titiro, the system will calculate a proposed next verification date for you, once you've determined the outcome and performance-based verification (PBV) step.
Use the template
You can use MPI's verification report template to report on verification results.
- Download the verification report template [PDF, 224 KB]
The report should contain:
- the name of the verification agency or verifier
- the name of the operator or registered importer
- the name and address of the food business or registered importer
- a summary of the verification activities undertaken
- the outcome of the verification
- any recommendations concerning corrective actions (see regulations 103 and 104)
- if applicable, any aspects of an unacceptable outcome that have triggered an increase in verification frequency
- the verification step they have been placed on and the proposed date of the next verification, noting that this does not prevent an unscheduled verification.
Find out more
Escalation to enforcement
You must inform the relevant registration authority of unacceptable outcomes or critical non-compliances. Where MPI is the registration authority, please report critical non-compliances straight away. A critical non-compliance is one that is likely to pose an immediate threat to people's health. To report a critical non-compliance, contact MPI Food Compliance at firstname.lastname@example.org or call 0800 00 83 33. All other unacceptable outcomes can be reported via your regular monthly reporting of verification data.
The following non-compliances should also trigger an escalation from verification to enforcement. If you work for the registration authority, discuss with a warranted food safety officer or take action yourself (if you are a warranted food safety officer). Food safety officers will assess whether an offence has been committed and what action is needed.
- Failure to be verified – for example, a business won't provide the necessary paperwork when you are doing a verification.
- Recurring issues – the same non-compliance seen several times, or ongoing non-compliance across a range of issues leading to a loss in confidence in the operation. For example, a business repeatedly fails to prove that they are meeting critical control point requirements (such as poultry being cooked to 75 degrees Celsius) because their record-keeping is not up-to-date).
Follow-up on corrective actions
Check that the business has taken effective corrective action within an acceptable period of time. Evidence of completing a corrective action can usually be sent by email or post, but for serious non-compliances, you may need to check at the business premises.
Note: A follow-up visit to confirm corrective action is part of the original verification – it is not a new verification.
Record results in Titiro
Verification results must be recorded in Titiro, our system for capturing and reporting on verifications and enforcement outcomes.
You can either enter the results of a verification directly, using the online form, or you can choose to upload your verification results in bulk.
You must supply Titiro with the verification data of all verifications carried out under the Food Act 2014.