Why use a Risk Management Programme (RMP)?

“All” New Zealand food Businesses must operate according to the regulatory requirements of the Food Act or Animal Products Act. Certain primary and secondary processors of animal products must operate a Risk Management Programme (including for some non-food animal products), whilst other operators may instead choose to operate under the Food Act.

Generally if exporting animal materials or products to overseas countries where Official Assurances are required (eg Health Certificates, or Export Certificates), then an RMP is generally required.

For many operators using the MPI “Food Safety Rules” tool will indicate whether an RMP is required.

If you’ve completed this tool and had an in interview with MPI to confirm the outcome is a Risk Management Programme (RMP), then the development phase begins.

The normal process for operating a RMP is as follows:

Document the RMP (the main focus of this issue)
Have your RMP evaluated (generally not required for those operating only a Template RMP)
Register your RMP with MPI
Operate your RMP
Have your RMP verified

For people establishing a new animal products business the process of establishing a RMP can be daunting. For those in sectors where there is no industry Template RMP, it’s even more complex. Understanding the RMP requirements is important both for developing the documentation but also to ensure that the buildings, facilities and equipment are fit for purpose.

Expensive mistakes can be avoided by gaining a good understanding of the requirements early on. eg prior to investing capital in equipment that is not of hygienic design, or committing to a multi-year lease for a facility that needs significant refurbishment to meet the required hygiene criteria.

Although MPI has numerous documents to assist with this process, if you are new to RMP’s, finding guidance to all the parts required can be challenging – after all you don’t know what you don’t know. Please get in touch if you would like some help.

For any new RMP – even if you are using a template, the best place to start is: MPI Guidance Document: Risk Management Programme Manual. (RMP Manual)

For most businesses there are 3 or 4 key aspects of the RMP:

Information about the Operator and Scope of the Operation
Supporting Programmes (also known as Prerequisite programmes and Good Operating Practice)
HACCP
Validation

The RMP Manual provides a lot of detail about numbers 1 & 4 above, but less about Supporting Programmes and HACCP. However I would suggest additional resources are utilised to assist with all aspects of establishing a new RMP.

RMP Templates:

Several Industry sectors have RMP Templates that have been developed by MPI in conjunction with industry bodies to assist the membership meet the regulatory requirements primarily drawn from the following:

By their nature the templates must be somewhat generic, so tend to cover simpler operations, such as transport and industry sectors generally comprising small operations where there is limited capacity for dedicated Food Safety / Compliance resources.

RMP Templates that have been recently revised to align with current regulatory instruments include:

Bee Products
Storage and Transport Operators
Farm Dairies and Dairy Products
Dual Operator Butchers & Micro Abattoirs
Poultry (meat, eggs & breeding)

These Templates cover most of the RMP requirements for specified activities. However it should be noted that businesses using templates will need to:

complete details throughout the template
develop records to meet the monitoring and operator verification requirements
create procedures to detail how specific tasks are done (eg cleaning, inventory control and lot identification procedures)
document any activities not included in the RMP template and have these evaluated
carry out validation for processes that require it

Each supporting programme in the templates states the types of records that need to be kept, and any associated procedures that should be written by the operator.

Templates, (along with other useful resources) can be found on the following Web Page under RMP Templates and Models:

Custom RMP’s:

If there is no suitable RMP template for your business a custom RMP will need to be created. Custom RMP’s must be evaluated prior to registration. This evaluation process is necessary to ensure that it meets the legislative requirements. MPI Recognised evaluators must be engaged for this work.

The following Web Page references RMP templates and Industry Operational Codes which are a good source of information.

RMP Supporting Programmes:

Supporting programmes must cover your business activities from reception materials to dispatch of product, meet the regulatory requirements so that the products processed are fit for their intended purpose. Section 4.11.1 of the RMP Manual provides a list of the types of items that should be covered by supporting systems. Templates from similar industries may be useful starting point for developing your own supporting programmes.

Hazard Analysis and Critical Control Point (HACCP):

If a template is unavailable, you will need to carry out the Hazard Analysis and Critical Control Point. This is a system to systematically identify significant Food Safety Hazards and implement procedures to manage them.

Evaluation of all inputs, and process steps is required to determine the significant hazards and identify control measures for them. Hazards include:

Biological: Pathogens such as bacteria, and protozoa. The specific pathogen must be identified in relation to the specific process step, or input. Eg Giardia in water supplies, Campylobacter in chicken, and the control required will be specific to the species of concern
Chemical: Includes biotoxins (eg in shellfish), allergens, heavy metals and other environmental toxins, drug residues, spray residues, and food additives
Physical: Objects that may be harmful including fish bones that might become a choking hazard, or glass fragments that may cause physical damage

HACCP relies upon Good Operating Practice (GOP), typically in the form of documented supporting programmes, and monitoring systems. Any Food Safety Risks that cannot be suitably managed by these supporting programmes, are deemed Critical Control Points (CCP’s). Not all businesses require CCP’s.

Resources for developing HACCP plans include

RMP Validation:

Certain processing activities require validation – to ensure that certain of your process will result in the required outcome each time. This applies to those using RMP Templates, and those creating a Custom RMP.

To find out whether any of your processes require validation, check: RMP Manual, Appendix D: Procedures and processes requiring validation.

The following typically require validation:

Operator supplied water
Pasteurisation / heat treatment to achieve food safety outcomes (eg hot smoking etc)
Fermentation
Acidification
Drying / concentration

Exporting Animal Products:

Whether or not you utilise a template, or develop a custom RMP, if you are also exporting you may also need to:

Understand the requirements of the countries to which you wish to Export your products (OMARS) – which may influence the content of the RMP
Seek listing to supply certain products to some countries
Register with MPI to use the Certification tool (eg Ecert)
Receive and dispatch all animal products for which official assurances may be required using the certification system *
Register as an Exporter
Develop a documented programme describing how you are going to meet the “Official Assurances requirements”

* MPI is currently reviewing the Animal Products Official Assurances Requirements and changes will be rolled out over 2024 and 2025

Call or email me if you require any assistance with you RMP requirements.

Creating a Documented Risk Management Programme (RMP)