Food Control Plans and National Programme holders:
Do you understand what activities your Scope of Operations allows you to do?
Under the Food Act 2014 legislation, most food businesses in New Zealand must operate a registered Food Control Plan or National Programme. The Food Act focuses on the food production processes used by each food business, and places more stringent food safety requirements and checks on higher risk processes.
The Scope of Operations includes the types of activities your food business performs. It also includes the products you make or sell, how ingredients are sourced or supplied, how products are processed, and how they are sold under each sector.
Ensure that the food you produce, and the activities you perform are registered in your Scope of Operations under a Food Control Plan or National Programme.
National Programmes are a set of food safety rules that low to medium risk food businesses need to comply with in New Zealand. There are three levels of National Programmes. The type of businesses that operate under each level is determined by their level of food safety risk and the processes they use in manufacturing.
National Programme 1 – applies to food businesses such as:
- Transporters or Distributors of food products
- Horticultural food producers and packhouses
- Retailers of pre-packaged, manufactured ice cream and iced confectionery
National Programme 2 – applies to food businesses such as:
- Bread bakeries
- Manufacturers of jam, chips and confectionery, sauces and spreads
National Programme 3 – applies to businesses such as:
- Brewers and Distillers
- Food additive manufacturers
- Fruit drinks and Flour manufacturers
Food Control Plans
Food Control Plans are used by those higher-risk businesses operating under the Food Act 2014. A Food Control Plan tells a business operator what needs to be done, and when to manage associated risks, but only for the processes listed in the approved Scope of Operations. Templates are available that most businesses can use to document the controls needed for the processes used. For those businesses using a Template Food Control Plan, The HACCP (Hazard Analysis and Critical Control Points) Plan has been developed for you by the Ministry for Primary Industries.
More complex businesses, with higher risk processes will need a Custom Food Control Plan. A HACCP Plan will be needed for each of the processes used in your business. Produco are specialists in creating HACCP Plans for your business. We accurately assess and will design an effective programme that meets your specific business requirements.
Adding New Processes or Changing What You Manufacture?
Before making changes to your current registered food business, you need to make sure your existing Food Control Plan or National Programme covers the new activity. If you make a significant change to your business after it has been registered, you’ll need to notify the correct authorities. A significant change is classified as:
- Change of person who runs the business
- The type of food you make or processes you use (Scope of Operations)
- Your Verification agency
- Change of Address of the site/s you operate from
If you’re registered with your local council, notify them of the changes. If your registered with MPI, complete the form Changes to a food business subject to a National Programme.
Examples of Changes that Require Updates to your Scope of Operations
A dairy operates a registered National Programme 1 selling pre-packaged ice-creams, wants to start selling ice-cream in a cone, where they scoop the ice-cream. Because they will be handling unpackaged food, they need to change their registration to a National Programme 3 before they start selling this product.
A cafe has a registered template Food Control Plan for selling ready-to-eat food directly to customers. They reheat food from the chilled cabinet and serve it to dine-in customers. They want to start selling food in takeaway containers for customers to heat themselves at home. These may be classed as ready-meals but they are not ready-to-eat meals because they need to be stored at the correct temperatures and re-heated properly to manage the food safety risks associated. Depending on how these are sold, the ready-meals may also require a label that complies with the Food Standards Code. Their Food Control Plan will need to be updated to include this new, higher-risk activity.
If new activity is identified by your verifier that is outside your Scope of Operations, this can result in a non-conformance at audit time, and increased verification frequency along with an increase in the associated compliance costs. You may also be required to conduct a recall of all product manufactured outside your Scope of Operations due to a lack of process control.
