The Food Act Regulators Forum met for their final meeting of this year. FARF is a nominated group of co-regulatory organisations from across New Zealand, who provide a wide range of services to food businesses under the Food Act 2014. Here are highlights of interest to registration authorities, evaluators, verifiers and food safety officers:
Practice Notes
Some new Practice Notes are being developed. Practice Notes are guides for co-regulatory partners to develop their own processes for delivering Food Act duties and services for food businesses. They can be relevant for verifiers, food safety officers, and registration authorities – or sometimes all of these.
Here’s what’s currently in the pipeline:
• Shared services between territorial authorities
• How to approach verifying multi-site businesses
• Verification timeframes – how to fit it all in
Registering wholesale businesses
An area we know registration authorities find challenging, is how to register businesses who supply other businesses - when does a food service or retail activity become a wholesale activity?
While no date has yet been set, next year the food control plan - food service and food retail (aka March 2017 version) - will stop being available for new registrations. The Food Act doesn't define ‘wholesale’, and at this stage, we don’t want to define it. Businesses come in many shapes and sizes, and definitions create hard boundaries that are rarely a good fit in the real world. Instead we want to help registration, verification and enforcement staff to be more confident they know what are the important factors to consider, so they can make good decisions.
MPI will soon be publishing guidance on the key things we want you to take in to account, along with some helpful case studies.
Small Businesses & Market Stalls
Small businesses are often naturally very conscious about costs. As more of them transition to the Food Act, we’re hearing concerns about affording the costs they can face. This is especially acute for business sectors that are experiencing food regulation for the first time. You may have seen recent media about small market stall operators in Te Horo, which will not be unique.
The Food Act provides us more ways than ever before to enable businesses to comply. We have started looking at where monitoring and surveillance programmes could provide sufficient assurance so that individual business verification is not required. Also, whether modern wearable technologies could allow for new approaches to verification in some businesses (see the story below).
The Minister for Food Safety has asked MPI to explore other ways to reduce costs, and is interested in how councils have managed markets in the past, and whether any councils are implementing differential fee structures for markets under the new Act. MPI will be writing to councils to ask for some more information. Expect more on this topic over the coming months.
Communication approaches
FARF are keen to improve how all co-regulators communicate with each other. One distinction they think is important, is communicating on operational matters, separately to changes to how operations are carried out. It is important to share information about good operational practices, improving national co-ordination, and new issues that may arise. Decisions and uncertainty about new or changing services are also important, but quite different.
FARF want to make sure there are good ways for both these types of communication to happen, and all those who should be involved, are actively engaged. Thank you to those Territorial Authorities you who took the time to reply to the recent national survey on their implementation experiences, which closed last week. We look forward to sharing the findings with you, and using them to enhance how co-regulators communicate and support each other.
National Outcomes
Led by Judith Robertson from Gisborne District Council, a FARF working group have started considering what would make good National Outcomes for TA functions and duties. It’s still very early days, and there will be ample opportunity for all TAs to get involved next year. National Outcomes will help everyone, from the public to businesses to be more confident the right things are being achieved. At its highest level, the areas discussed so far include:
• Businesses know what they must do
• Businesses can do what they need to do
• Businesses do what they need to do
• Services for businesses are fair and transparent.