Is our food safety system as robust as we think it is? And are we better served by the public or private sector? Last week I blogged about my issues getting the mobile cowshed evaluated by inspectors. The way the food safety system works, is the government agency via The Ministry of Primary Industries (MPI) set the food standards. When a company sets up a food business, the verification services are provided by the private sector. In New Zealand we have AsureQuality, which is a state owned enterprise, but it operates as a for profit business. There seems to be only two other providers, Eurofins & SGS in NZ who can offer dairy evaluation services. The problem I have struck is there are not enough staff within these three businesses to evaluate and verify my business. Lack of food safety specialists I've spoken to quite a few people in MPI, AsureQuality & Eurofins over the last few months. They all say that the demand for their services have boomed in the last 2 years. The Fonterra botulism issue has absorbed a lot of manpower, but there is also a large number of new dairy businesses starting or expanding. There are a number of large dairy processors expanding, like Fonterra's Edendale & Darfield plants. But there is also a number of new factories (many backed by Chinese money) popping up across the country. There is also a boom in the numbers of small producers like myself setting up. As an aside; I found it interesting that there are only 3 people in New Zealand who can assess dairy heat treatment facilities. The same person who assesses massive milk powder plants is also the guy who assesses my 300 litre/day pasteuriser. All these things combined have meant that the demand for their services has increased dramatically. Why not just employ more people? They are trying to, the problem is these roles are quite specialised, they can't just put an ad in the paper. I've noticed almost all of the people I have dealt with, from food safety consultants, evaluators and assessors all seem to be over 50 years old. These people have been in the industry for over 30 years. Many are on the verge of retirement. Where are the young people? It seems they don't stick around. One person commented
"we used to employ graduates, but they all seemed to leave after 1-1.5 years. The problem is it takes us 2 years to train a graduate to the point where they can operate unsupervised."
I haven't received my bill yet for my pasteuriser inspection, but I believe the hourly rate that I pay for the time the inspector is travelling is $90/hour. While they are inspecting and writing the report, the hourly rate is over $130. Upon hearing the rates they charge, I thought there must be some serious money to be made in dairy verification. Yes there is, but at the same time no there isn't. It appears that for some companies, dairy verification services are just too hard to provide. I've come across at least one company that no longer does dairy evaluation because their evaluator left and its just too hard to replace them. Private sector vs public sector This has got me thinking, is New Zealand's food safety system best served by the private sector? My reason for asking this is. A private company needs to make a profit. If a company employs a verifier and spends considerable resources training them, they want to be sure there's enough work for them so the new employee can pay for themselves. It appears to me that these companies take a "wait and see" approach before committing to employing more staff. This make perfect sense to any business person.
Meanwhile, the countries food businesses are being held up by a bottleneck in the form of insufficient number of inspectors & other services. What about the public sector? Well, MPI is able to conduct evaluations, but
"we don't want to be seen to be competing with the private sector".
Before MPI will step in they need to be sure that none of the private sector providers are able to provide the services. In my case, MPI have said they will step in & evaluate my RMP because the private sector businesses are unable to do it. I wonder how larger export businesses are faring? I'm sure I'm not the only one battling these sorts of delays? Efficiency vs Resilience This has got me thinking. We always hear about companies and departments focusing on efficiency. But maybe it's in the best interests of the country to have some inefficient departments. The more efficient you become the less resilient you are. An efficient department is one where the minimum number of people are meeting the required standards. But as soon as something unexpected happens like botulism. You find yourself stretched and it takes time to catch up. It appears to me that the combination of Fonterra's botulism scare and the ever increasing demands of our export partners is stretching our food safety system. I have no hard facts to prove this, but my little experience with the food safety system makes me wonder if our system is really as strong as we think it is. Maybe its best to have MPI overstaffed a bit, with the experienced staff investing in training the next generation of food safety professionals. Even if they can't justify bringing these new staff on at the moment. The payback may be in 10 years time.
When I decided to actually build the mobile cowshed & process my own milk, I knew that the regulatory requirements would be the hardest part. New Zealand trades on our food safety reputation. We need to protect that reputation. I'm aware that even small scale producers have the potential to put our whole reputation at risk too. With this in mind, I delved into all the regulations that a mobile cowshed would have to meet. The regulations for the farm dairy side of things are in a document named NZCP1. People wanting to process milk will also need to know all the requirements of DCP1, DCP2, DCP3 & DCP4. There is also the "Heat Treatment Code of Practice" & the "Operational Guideline: Dairy Heat Treatment" documents that need to be followed. After wading through those documents, I had almost lost the will to live. But I somehow managed to get through the "Operational Guideline: Dairy HACCP plans" & "Operational Guideline: Dairy Processing Premises" as well. An important point is, if someone wanted to use a mobile cowshed to supply a dairy company, they would only need to comply with NZCP1. Over the last 2 years I've tried to design a mobile system which I think will meet all these requirements. I met with a number of people in AsureQuality & I had an experienced food safety consultant look over my plans. This was to ensure that what I had planned to build will meet the regulations. But you never really know how it will go until you actually try. So I just had to bite the bullet & do it. Risk Management Programmes Anyone wanting to milk cows need to operate under a risk management programme (RMP) that is registered with the Ministry of Primary Industries (MPI). For example, all Fonterra farmers operate under Fonterra's RMP. Fonterra outline these requirements in their suppliers handbook. As I am my own dairy company I need to have my own RMP for the farm dairy & an RMP for milk processing. MPI provide template RMP's on their website. The templates are essentially a "fill in the boxes" document.
I submitted my template RMP's to the Ministry of Primary Industries and waited. Eventually the Ministry of Primary Industries responded to my risk management programme application with the following:
"Construction of yard and races – photos show gates directly onto the paddock. The requirement is for a concrete or similar impervious yard, and the mobile milking trailer would need to be sited on a concrete pad."
"Our opinion is that a mobile milking unit such as you propose are likely to not meet the requirements. Some modifications to your unit may be required such as having it permanently located or alternatively re-locatable to pre-approved sites where suitable facilities such as a concrete pad,........."
A concrete pad, kind of defeats the purpose of the mobile system. If we take a look at the requirements of NZCP1.
NZCP1 6.1 Floors, Yard Surfaces and Races
All the floors of a farm dairy (i.e. in the milking, milk receiving, and milk storage areas, yards and associated storerooms and offices) must be made of concrete or a similar impervious material. These floors and yards must be uniformly graded, be able to be readily cleaned after every milking, and have a fall to allow drainage to approved outlet points.
The intent of "impervious material" floors, "readily cleaned" & "have a fall to allow drainage" is to ensure that effluent and waste water is not flooding all over the place & causing a smelly health & environmental hazard. I have designed the system to ensure that all effluent, waste water & wash water is contained within the cowshed and drained to a single point where it is spread with a sprinkler. But we obviously don't have a concrete holding yard, which the code requires. Instead of a concrete holding yard I am proposing an alternative method of ensuring waiting cows do not create an environmental & health risk. Basicly I milk a small herd of cows and we move after every milking. So the cows are not waiting in the same area day after day and making a mess. We also ensure that the cows waiting to be milked do not wait more than 30 minutes. We also ensure the cows wait on new grass, this way they graze happily while they wait. These measures combined ensure very little effluent is produced & we will meet the intentions of the regulations. I'm confident that the mobile system will meet the requirements, it just a matter of getting it through the official channels & that is what is taking the time. MPI have said:
"For alternatives to be considered a RMP would need to be developed specific to the nature of operations and these must be evaluated by an MPI recognised dairy evaluator then submitted to MPI for registration"
It's important to note the difference between an evaluator, verifier & an assessor. I have already had the cowshed approved by an dairy assessor, these are the same people who conduct dairy shed inspections on dairy farms. But I need an evaluator who seems to be the next level up from an assessor.
The problem is getting a "dairy evaluator" to inspect my cowshed & RMP. There simply is not enough people to conduct the work. Everyone in this field is flat out busy. I can't even get these guys to answer emails or return phone calls. These evaluators are the same people who inspect the major dairy companies & I suppose I'm at the bottom of the pecking order. Anyway, I had anticipated MPI may respond with the requirement for a specific RMP. So I had spent the previous 4 months writing a custom RMP (consisting of over 7,000 words) that would cover both the farm dairy & the milk processing operations.
I would have submitted my custom RMP immediately, but I'm waiting for an approved evaluator to inspect the system & a verifier to inspect my pasteuriser. Meanwhile, I'm milking my cows and spending money and going broke very quickly! I can't sell my milk until MPI approve my RMP. I can see a scenario where I submit everything again to MPI and they take their 20 days to respond, where by they ask a few further questions and then promptly close for Christmas!
