COVID-19 – Audits of establishments preparing and/or storing dairy, eggs, fish and prepared meat products for export – Arrangements and Response (2020-08)
Date of issue: 27 March 2020
Date of effect: 27 March 2020
The department has received a number of inquiries about how it is approaching its staffing, regulatory and operational obligations in relation to audits of export establishments and the risks posed by the COVID-19 outbreak.
This notice is to advise that the department is monitoring the rapidly changing circumstances while working to protect staff, clients and on-going access to our international markets.
This notice covers dairy, eggs, fish and processed meat registered establishments. Further advice will be provided regarding audit and listing for food and other goods (non-prescribed goods), and for approved certifying organisations (organic exports).
Audits of establishments registered to prepare and/or store food for export
The ability of the department to certify products for export is underpinned by our audit processes. A number of our key trading partners have mandatory requirements for the department, as the competent authority, to certify that food for export has been produced in compliance with their requirements.
While the department is preparing alternative audit procedures for some activities, at this time department officers are able to travel and on-site audits will continue. Where an establishment is continuing to process, prepare, pack and or store product for export, it is important that auditors continue to have access to premises to assist them to continue to perform their regulatory functions under legislation.
Auditors requiring access to the premise include authorised officers of the department, state regulatory authorities undertaking audits on the departments’ behalf and approved third party auditors will require access to the premises.
You are encouraged at this time to regard your scheduled audit by the department as verification of the effectiveness of your approved arrangement in ensuring legislative requirements are continuing to be met during a period of rapid change. This includes verification of the effectiveness of any new procedures that establishments may need to implement to ensure business continuity. This may include sourcing new suppliers and changing operations due to reduced staff numbers.
While it is acknowledged that some establishments have implemented changed requirements for visitors, be advised that our officers and approved auditors are performing a mandatory regulatory function which provides assurance that your establishment and operations are meeting legislative requirements. A failure to provide assistance or access is grounds for suspension of the establishments approved arrangement.
Position on auditors and other certifying bodies accessing facilities
Auditor compliance with the health and safety requirements at third party premises will continue, including where reasonably practical, any new or enhanced screening procedures that have been introduced.
Similarly it is expected that all auditors and staff of third-party organisations will continue to comply with existing regulatory requirements for health and hygiene at food plants and will not present for work if they are sick, have a communicable disease, or are otherwise feeling unwell.
Where it is an importing country requirement for the consignment to be accompanied by a halal certificate, the Approved Islamic Organisation (AIO) may require access to the premises. An AIO refused access would be unable to assess an establishment’s conformance with halal procedures; an official mark may not be applied to the Halal product where the approved arrangement designates that the AIO must apply the official mark; and the Halal product cannot be certified or a Halal certificate issued.
Impact of COVID-19 on Departmental workforce
There has not been a significant impact on the department’s workforce at this point in time.
The department has active business continuity and contingency plans in place and will activate these should circumstances require. These plans are aimed at ensuring that export certification can continue, with all critical functions being supported.
In the event of travel limitations being experienced by departmental staff, the department will endeavour to ensure that audits will continue to be conducted. This may (depending on the nature of the product, production method and target market) include remote audits by a review of documentation required to be maintained under establishments’ existing approved arrangements, and other verification as necessary to manage identified risks.
Remote audit obligations
If you are advised by the department that your next scheduled audit will be undertaken remotely, please be reminded that you are under the same obligation to provide assistance and the documents requested within the timeframes specified by the auditor as you would be at a site audit. A failure to do so is grounds to suspend an approved arrangement.
Establishments export operations
Audit will not be required if your establishment has or intends to cease export operations.
If you have ceased or intend to cease export operations for a period, you are requested to advise the department in writing and specify the period during which you will not be operational so that audits will not be scheduled.
A cessation of operation means during the period you have specified, the establishment will not be receiving, preparing or dispatching products for export.
If you intend to provide food or services to the domestic market during the period you have specified, you are advised to contact your state regulatory authority for additional information.
In the event that your establishment is ceasing export operations, please advise the department by e-mail: Dairyeggsfish@awe.gov.au
On receiving your advice, additional detail will be provided of requirements for recommencement of your export operations
If you require additional information, please contact: Dairyeggsfish@awe.gov.au