Approved arrangements for fish export establishments
The Department of Agriculture, Water and the Environment manages requirements for the approved arrangement (AA) that an establishment must have in place to be export registered.
An AA is a documented food safety management system, which describes how an establishment manages food safety and traceability.
Your AA must document how your establishment will comply with:
When applying to become an export registered establishment, you will need to submit your proposed AA to us for assessment and approval. Once we approve the arrangement, your establishment can become export registered.
All export registered establishments, including vessels involved in preparing, handling and storing prescribed fish and fish products destined for human consumption, must have an AA.
Minimum requirements for an approved arrangement
An AA documents the procedures, controls and records used to ensure that all fish and fish products prepared or stored by the establishment meets the Export Control (Fish and Fish Products) Rules 2021 and importing country requirements.
In the Export Control Rules, particular types of requirements are grouped together in schedules:
- export documentation
- identification, tracing systems, integrity and transfer
- management of food safety and suitability
- operational hygiene
- product standards
- structural requirements
- trade description
Most establishments document their AA to correspond with these schedules.
Checklists are available for anyone interested in becoming an export registered establishment. These documents explain each of the schedule topics in more detail and should be read in conjunction with the Export Control Rules.
Key elements to a well-managed system
Elements of AAs which are regularly raised as non-compliant during importing country reviews and departmental audits include:
An effective internal audit program
- An internal audit program must identify each element to be audited, schedule for conducting audits, individuals responsible for conducting audits, training of individuals, corrective action for non-compliance and links to management review. Suitable evidence to support the activities being undertaken must be documented.
Verification of good manufacturing practices and housekeeping programs
- Cleaning and hygiene programs must be regularly verified as effective. The standard of the establishment must reflect acceptable standards. Evidence to support cleaning and hygiene programs must be documented.
Accurate and up to date Hazard Analysis Critical Control Point (HACCP) programs
- HACCP plans must be reviewed by the establishment as part of the annual verification and validation program. This process must be supported by a risk assessment. Records should provide evidence the required elements were reviewed and document any changes made and the individuals who participated in the process and evidence to support the thoroughness of the review.
An effective maintenance program (including preventative maintenance)
- The structure of the establishment must be up to acceptable standards and be supported by an effective preventative program. The corrective action/maintenance system must keep accurate records of all equipment and facilities requiring maintenance and document actions taken/planned activity.
An effective corrective action program
- The corrective action program must include all internal and external non-compliances. The program must assign responsibility, risk assessment relative to food safety, time frame for completion, monitoring to confirm effective corrective action taken, links to the review of cause of any non-compliance, escalation in the event of non-close out of non-compliance and links to export eligibility and management review.
Identification of importing country requirements and export eligibility
- Export eligibility must be stated in the declaration of compliance and transfer document. The AA must identify the markets the establishment currently or intends to export to and how export eligibility for each market is verified. For instance, through product testing, ingredient sourcing conditions and labelling.
In addition to the testing regime required to meet general export requirements, the AA must also document any testing required to meet specific country requirements where they exist, in particular:
- the nature of the products to be tested
- the source of water used in the establishment
- testing parameters for each of the different products being manufactured and exported
- testing parameters required, relevant to the water source (chemical, physical and microbiological)
- location points of the water to be tested
- who will take the samples and what training they have to support this activity (product and water sampling)
- the frequency of testing
- evidence of annual test results from the local water authority (if applicable)
- triggers/limits for corrective action
- corrective action when limits are exceeded
- where testing is conducted e.g. in-house or external National Association of Testing Authorities (NATA) accredited laboratory
- what test methods are being used to conduct the specific tests
- how non-eligible product is identified in the system and excluded from either the European Union (EU) (if applicable) or exports in general
- if you are an EU listed manufacturer, the declarations of compliance and transfer declarations must include a statement about EU eligibility or otherwise
- notification to the State Regulatory Authority (SRA) of any:
- pathogen detected in product
- issue affecting export eligibility
- how ongoing compliance is covered through your internal audit and verification program.
When an establishment requests to become export registered, they must have a completed AA available for assessment. This will include:
- in-office assessment of the application
- on-site assessment.
Once the registration process has commenced, we will review the AA to ensure it addresses all requirements of export legislation.
See our charging guidelines for fees applied to this service.
All export registered establishments are subject to ongoing audits at a frequency based on risk and compliance.
New AAs are subject to audit of the physical location of the establishment and the AA working in practice.
On-site audits are conducted to verify:
- controls identified in the AA are working in practice
- compliance with export legislation and applicable country requirements.
We will check your establishment’s AA against each of the schedule topics in export legislation at least once a year.
Check our audit guidelines for more detail.