In New Zealand a Manufacturer is defined as the place where food is being:
- Manufactured
- Prepared
- Packed
- Stored
- Made and sold to other businesses.
Whether you are starting a brand new company or expanding your existing food business into manufacturing and processing you will need to make sure you have the right plan and registration for your business.
Do I need a Custom Food Control Plan?
It is the risk rating of what you are manufacturing that determines whether you are able to register with your local Council as a National Programme or whether you will need to have a Custom FCP developed, evaluated and registered with MPI.
As a general rule you will require a Custom FCP if you are manufacturing for retail sale any of the following:
- Dairy products
- Meat products
- Non shelf-stable products
- Ready heat-and-eat meals
What is the Process?
Having a Custom FCP registered with MPI is quite a different process from registering with the Council under a template FCP or a National Programme. The key difference is that there are no pre-evaluated plan templates available for you to use.
After you have completed building your Custom FCP you are required to have it evaluated by an MPI accredited evaluator. This is a stage that is not required when registering with your local Council and can prove to be an expensive and time consuming process.
The full process from building your plan to registering it with MPI can take a few months to complete so it is important to get started early. Check out the video below for what the full process looks like.
What is a Custom Food Control Plan?
A Custom Food Control Plan tells the story of what your business does. It is a written plan that outlines the rules your business follows to produce safe food. The overall plan will include;
- What happens
- When it happens
- Who does what
- How problems are solved.
1. Your Plan:
This is the full blueprint for your business and will contain ALL of your processes and procedures you follow. Don't forget these three key elements to include:
a) Food Labelling:
Packaged food needs to be labelled according to regulations. Don't forget to include; the common name or description of the food, the net weight, volume or number of contents, nutritional information, the business trading name and address and a date mark being a ‘best before’, ‘use by’, or ‘packed on’ date mark. Take care over the wording of any claims you make as the use of certain words have special constraints. For more details read Food Labelling in New Zealand - The Basics Explained.
b) Recall Procedures:
It is important when building your plan to assume that a food safety issue may arise with your products and plan ahead. These systems and plans must be tested atleast yearly, sometimes twice yearly if you are wanting to supply supermarkets.
c) Pest Control:
This is a system that prevents the infestation of pests. Reacting when there is a problem is not enough. Establishing a regular pest control programme with a registered pest control company are highly recommended.
2. HACCP:
Your Hazard Analysis and Critical Control Point (HACCP) planning is the system used to identify and manage the significant food safety hazards and ensure food safety for your business. HACCP principles are applied throughout all stages of the food chain and therefore require analysis at each stage, including but not limited to;
a) Food Preparation and Cooking Processes:
This section covers how you protect your product from contamination and spoilage throughout the entire process of preparation and cooking.
b) Critical Control Points:
Once your hazards have been identified you will need to determine the Critical limits using the MPI hazard database.
c) Storage & Transport Systems:
Food safety responsibilities continue throughout the storage and transport process. How are risks being reduced? Include this in your plan.
3. Record Keeping:
The records you keep demonstrate that your Custom FCP is being implemented and your procedures followed everyday. Think about whether an online system or a traditional paper based system is right for you. Don't forget to include the following;
a) Cleaning & Maintenance Records:
This will prove that your facility, equipment and untensils are clean, sanitised and well maintained. Don't forget to check the maintenance compounds database during the
planning stage.
b) Validation & Verification:
The validation is the scientific evidence your processes are safe and the verification is the ongoing monitoring of those processes to prove they continue to be safe. Both systems need to be planned, evaluated and recorded as a part of your Custom FCP.
c) Staff Training:
All staff must be trained in all areas of food handling and safe practice. A training record must be signed by you and your staff. Your verifier will also check this as part of your grading.
4. Facilities:
It is important you lay out clearly to your evaluator that your facility is adequately set up for providing safe and high quality products. Of course - you do need to practise what you preach!
a) Physical Layout of Space:
Is there enough room for all processes to be carried out safely? Can product flow safely and logically through the business? Can cleaning and maintenance be carried out easily and effectively?
b) Floors, Walls & Ceiling:
Surfaces must be durable, smooth, clean and free of damage. Make sure floors and relevant surfaces are sealed for water tightness.
c) Lighting & Ventilation:
Can all staff work comfortably in the space? Can cleaning and maintenance be carried out without shadow and glare being an issue? Do your cooking areas have mechanical ventilation?
Building a Custom Food Control Plan can be a complicated and time consuming process. Getting things wrong or missing out important infromation can slow down the process of getting you evaluated and legally trading which can not only be frustrating but incredibly expensive. It is always best to seek professional advice early in the process to ensure you get it right the first time. After all - getting your product out on the shelves and sold is whats most important!
If you would like to have a chat about your own Custom FCP or anything else raised in this article please get in touch! Click below to book a time for me to call you or flick me an email on anna@foodcontrolplans.co.nz.
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