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Proposed Changes to RMP Evaluation
Does the Evaluation System Need to be Tampered With?
The NZ Food Safety Authority (NZFSA) has released a discussion paper outlining proposed changes to the way that risk management programmes are evaluated.
I will summarise the main points below and you can also download the full document from here.
NZFSA believe there are problems with the current evaluation system.
The main problem is believed to be the low number of evaluators – 36 in total and only 13 from “private” companies.
Of these, some are restricted to the industry that they can work in and others are not prepared to travel.
The reason for the low number of evaluators is throught to be due to:
- the trend towards using codes of practices (COPs), which dispense with the need for evaluation. COPs have reduced costs for industry operators, but they have caused the evaluation market to shrink and have made it more difficult for evaluators to develop or maintain a business in the market.
- the largely one-off, non-repeatable nature of evaluation.
- the reluctance, or failure, of some industry operators to pay for evaluation.
As a result, some industry operators are experiencing difficulty finding evaluators.
NZFSA also has concerns about the quality and consistency of the work undertaken by some evaluators. And they have difficulties when addressing problems with non-performing evaluators under the current system.
NZFSA are Proposing to Manage ALL Evaluations
NZFSA propose to: - set the competency and performance criteria for evaluators (they do this now)
- negotiate the terms of engagement with evaluators
- allocate work to evaluators
- monitor the outcome of evaluations
- take responsibility for payment of evaluators
NZFSA also propose to:
- set parameters for the scope of evaluation
- develop and administer a panel list of suppliers for evaluation
- allocate evaluation work according to transparent criteria
- monitor the delivery and quality of the evaluation service provided to industry
- collect payment from industry
- reimburse evaluators
Other points to note include:
The Verification Agency (VA), which already evaluates a limited number of plans will, if necessary, make evaluators available. It is expected this would occur if no other evaluator is available, or if the VA has particularly relevant expertise that is not readily available from other sources.
Allocation of evaluators to companies will be done by NZFSA (although input by companies for preferred evaluators would be possible)
Charges would be on an hourly rate rather than a set fee (fee setting criteria are yet to be determined).
Start date for the proposed change is July 2009.
Comments on the Proposal are due 17 December
I know this is late notice but hopefully you will have seen the notifications from NZFSA and have already given it some thought. I will be completing a submission on behalf of the Cold Storage Association on Monday 17 December. You can send your comments to me for inclusion in this submission. Alternatively you can make your own submission. Please contact me if you are interested in either of these options.
Some points to consider include:
Where companies use the Code of Practice for Cold and Dry Stores as the basis of their RMP, evaluation is not required. Therefore this proposal is of no relevance.
Companies that choose to have their RMP evaluated may lose the flexibility to select their evaluator.
Cost implications are not at all clear at this stage.
Nothing in the proposal will fix the current problem of a shortage of evaluators. It could reduce numbers even more.
Evaluators themselves are unlikely to support this proposal.
Thanks for your input,
Rachel Harvie
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