The Pathway for Manufacturers is Made Smoother

And with that MPI changes the registration process for higher risk manufacturers. If you were needing a Custom Food Control Plan this means you.

Higher risk manufacturers are defined as businesses that manufacture or process;

• Meat, dairy or wholesale baked products,
• Ready to eat meals, or;
• Non shelf stable products.

Anyone who has been through the process of developing a custom FCP knows first hand how time consuming and expensive the experience was. We have seen the impact this has had on smaller New Zealand food manufacturers. Across the country we have talked to;

• New manufacturers finding it too expensive and complicated to get started.
• Small manufacturers struggling to transfer to the new system. Some of these businesses felt they had no other choice but to close after many years of trade.
• Existing food businesses being discouraged from expanding into manufacturing their products for wholesale.

For many the cost of compliance has been too restrictive. Last week all of this changed.

MPI has responded to the plea to make the path to compliance cheaper and less cumbersome. Essentially, they have created more pre-evaluated templates that cover a wider scope of operations. In the majority of cases this eliminates the need to put your plan through the evaluation process.

But what does this mean for your business?

If you are starting a high-risk manufacturing business then you are still required to build a food control plan, implement systems for validation and record keeping, get registered and get verified. However, this process, without the evaluation stage, will now take less time to work through and save you several thousand dollars.

Although MPI have developed a wide range of new templates you do still need to ‘customise’ them to meet your needs. The plan becomes completely bespoke for you by only including the specific areas your business requires and none of the ones it doesn’t. Below I have answered five key questions about the new and improved Custom Food Control Plan development process.

A Custom Food Control Plan tells the story of what your business does. It is a written plan that outlines;

1. What happens,
2. When it happens,
3. Who does what,
4. How problems are solved.

There are four main areas that need to be addressed when building your Food Control Plan:

Yes. You are required to be able to show your verifier that you understand the whole production process and any hazards associated with it.

3. What is a HACCP plan?

A HACCP plan is your hazard analysis, critical control points identification and management plan. It includes the biological, chemical and physical conditions that can cause finished product to be unsafe as well as the validated measures you will take to reduce those risks.

A HACCP plan can be tricky. Any critical limits must be related back to Schedule 27 – Microbiological Limits for Foods of the Australia New Zealand Food Standards Code. I would advise seeking professional advice on this.

In short – no. The new templates are an overall guide to how you are managing your food business and keeping what you produce safe. However, you are also required to demonstrate, or prove, how you are managing these processes.

Depending on what you are manufacturing and what hazards have been identified in your HACCP plans you will need to develop the following;

a. Testing Procedures: If you are manufacturing products for retail or wholesale you may need to put in place some testing procedures. These could include;

• Water Activity testing for dried products.
• Environmental hygiene testing.
• Product safety testing.
• Shelf-life and end of shelf-life testing.

b. Record Keeping: You will need to put in place a record keeping system that adequately covers all areas outlined in your bespoke plan. There are many records that will need to be kept, some of these will be unique to your business but some are required by all businesses across New Zealand such as;

• Maintenance planning and ongoing monitoring.
• Cleaning planning and ongoing record.
• Staff training.
• Fridge temperatures.
• Cooking and cooling food records.
• Supplier and Receiving goods records.

You have options when it comes to how you keep your records. You can take a traditional pen, paper and clipboard approach, or if you prefer, an online, paperfree food business management system such as FCP Log is now considered completely compliant under the Food Act 2014.

c. Product Recall Procedure: Plan out how your business will;

• Know when a recall is required.
• Will manage the recall process.
• Review processes to ensure the recall does not happen again.

d. Labelling Requirements: If you are manufacturing products for retail sale you will need to layout what will be on your labels. It is essential this is in-line with the Food Labelling guidelines set out by MPI. You can find more detail on food labelling here.

Yes you can. MPI has developed an online tool that allows you to put together your own template. From there you can customise it to your own needs, develop your HACCP plans and additional systems and processes, develop and implement your record keeping system and complete the registration process.

It is important to be aware that even with templates available the development of your custom food control plan is complicated. If it is not developed correctly it will slow down the process of getting registered and therefore delay your ability to trade. Getting professional advice is advisable as it will ensure everything is done correctly right from the start, after all, the quicker you get started the quicker you can sell your products!

If you would like to discuss anything raised in this article I would love to hear from you! Please flick me an email on anna@foodcontrolplans.co.nz, message me on Facebook or click below to book in a 15 minute chat with me.