RMP Templates
MPI have issued several Templates for Risk Management Programmes (RMP’s). These are particularly useful in industries where there is a predominance of small operations (eg farms and family businesses) that cannot justify dedicated staff specialising in RMP compliance.
MPI has provided RMP templates for several industry sectors (Eg micro abattoirs, farm dairies and egg producers). However the first RMP templates issued since the recent changes to the animal products regulations and notices are for bee products operators and honey storage.
The new Bee Products RMP template has also expanded on the previous version which was issued in 2005.
Whereas the Initial template provided no supporting systems and covered only honey, beeswax and pollen, the new template:
• includes a section for all supporting systems
• has a series of modules that now also includes: propolis, royal jelly and bee venom
These modules allow the operator to identify the relevant products and identify the processing steps they utilise, and these link to the Hazard Analysis in a streamlined way.
New Bee Products RMP’s
With the revised template, creating a new RMP for export eligible bee products is a significantly easier process compared to the previous system.
However any products & processes outside the scope of the new template (eg honey blended with other ingredients), need to be written by the operator and such documents evaluated prior to registration as a significant amendment.
Alternatively operators may create a custom RMP, noting that these will need to be evaluated prior to registration.
Existing Bee Products Template RMP’s
For Bee Products RMP operators who have been using the 2005 template, there is no compulsion to transfer to the new template. However there is a requirement to update to the new features from the regulatory re-design. These amendments must be completed by 1 November 2023. Such changes are a minor and do not need to be advised to MPI approvals.
The new features relate to the new regulatory tools:
Animal Products Regulations 2021
Animal Products Notice: Production, Supply and Processing
Operators now also have a mandatory requirement to undertake a simulated (or actual) recall within every 12 month period. The simulated recall requirements are more comprehensive that previous “mock recalls”. MPI have provided excellent guidance on simulated recalls.
If operators wish to add new products that are included in the new template to their RMP, then use of the relevant modules will streamline the process as evaluation will not be required for these significant amendments.
Should operators using the 2005 template wish to transition to the new template this is also a minor amendment that does not require notification to MPI approvals.
Use of the new Bee Products RMP template
It should also be noted that the supporting systems are generic, so there are several sections that require further supporting procedures that define how the operator will manage specific activities. Sections likely to need supporting documents include:
F – Design, Construction and Maintenance of Buildings, Facilities and Equipment
Procedures for monitoring conditions of buildings & facilities, the actions taken when undertaking maintenance to prevent product contamination
H – Cleaning and Sanitation
A detailed cleaning programme or schedule for cleaning and sanitizing all areas of the operation
J – Traceability, Inventory and Labelling
A traceability and identification system that allows the tracing of all animal products back one step to the supplier and forward one step to the receiver
Labelling procedures to ensure that labels meet the regulatory requirements (retail & transportation units), and accurately reflect the product contained
L – Calibration
Procedures that identify measuring equipment used to provide critical measurements, the frequency of calibration and by whom
M – Chemical Control
An up-to-date register of all chemical held on the premises
Depending on the operation there may be other areas where additional procedures should be documented.
Methods of record keeping must also be determined by the operator and suitable systems devised to ensure that records for all required monitoring activities are undertaken and kept securely for 4 years. The template identifies the record keeping requirements for each supporting programme. The MPI RMP Operator Resource Toolkit provides record examples that may be used or adapted to meet the operators needs for records.
