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Have management practices been documented to include:
- The organisational structure?
- Roles & responsibilities of staff at the establishment?
- Duty statements for key staff?
- Management review process that ensures all elements of the approved arrangement are formally reviewed on an annual basis? How is it captured and addressed? (eg. Management review meetings, records, agenda items)
Has the management's commitment been documented in a statement/s including a commitment to:
- Food safety including provision of resources?
- Meeting importing country requirements?
- Meeting the requirements of the Rules and Act?
Are there documented procedures available specifying:
- All records or documents made and received by the occupier relevant to meeting the requirements of the legislation are retained for not less than 3 years?
- All variations made to the approved arrangement are recorded when made, and where the variation has the potential to adversely affect compliance with the Rules, compliance with importing country requirements or the fitness for purpose of the food, the variation is not implemented unless it is approved in writing by the Department?
For the relevant legislative references in the Export Control (Milk and Milk Products) Rules 2021, please refer to the department’s, Approved Arrangement Checklist.
Your site must show that management is committed to ensuring that the approved arrangement you have in place is effective by continually verifying and monitoring implementation, and that activities undertaken are in compliance with your documented procedures.
Your ongoing management review may include (but not be limited to) HACCP, importing country requirements, operational hygiene, product standards, structural requirements, trade descriptions, corrective actions, internal audits and any supporting evidence which shows that you are monitoring your records and complying with your obligations under export legislation.
Management review is used as an effective tool to determine if each AA element continues to meet the legislative requirements for export. Having relevant personnel and specific expertise present at these meetings sets the requirements for an effective review process.
As part of your review process, you will need to discuss any key compliance and implementation issues, decisions made and any action taken as a result of these meetings. The outcome of these meetings must be recorded.
All elements of your approved arrangement must be internally audited within each 12-month period and evidence gathered to support the outcome of the audit.
Your organisational chart is a diagram that shows your company's internal structure, detailing the roles and relationships between individuals within a company. These documents will assist your company to define how activities such as task allocation, coordination, and supervision are directed toward achieving your organisational goals and specifically who has responsibility over the various elements of the approved arrangement.
All key roles must have clearly defined position descriptions. The purpose of a position description is to clearly define the tasks being performed by that position, the reason why those tasks are performed, and the manner in which they are performed.
You must ensure that key personnel have undergone appropriate and effective training.
When attempting to become compliant with the requirements of this element, please consider the following;
- Are position descriptions available for all key roles? Are they up to date?
- Have you documented who is responsible for the overall site?
- Is there a signed statement or policy defining their commitment? Have they included their commitment to meeting all relevant legislation? Have they included their commitment to producing a safe food product and to meeting all importing country requirements?
- Do all staff have a copy or are made aware of their position descriptions and responsibilities?
- Is it clear who is responsible for what roles within the organisation and under the approved arrangement? Are reporting lines clear?
- Is role delegation in the case of any absence clear?
- Are personnel appropriately trained and is there a record of this?
- Are management review meetings conducted at least annually or more frequently as required or if there are changes to the organisation or processes? Are all relevant personnel present at the meeting?
- Do you keep records to show who attended meetings and on what date?
- Are fully documented management review minutes available? Are they up to date? Is there evidence that the approved arrangement elements are discussed, met and effective?
- Are adequate resources provided to ensure your business can meet all requirements of the approved arrangement?
- Are any corrective actions required noted and followed up? This could be from any internal audits conducted or from any other non-conformances detected.
- Do you ensure that each document made by the occupier or comes in possession of the occupier that is relevant to the occupier complying with the Act, the Rules, the approved arrangement or a condition of the Arrangement, must be retained for a minimum of 3 years.
- Are any changes to the documented approved arrangement clearly identified in a register or similar system? Does this include all pre-approvals, new processes or exemptions made?
- Do you have evidence that these variations have been approved by the relevant authorities?
- Should legislation or importing country requirements change, is there a review mechanism to ensure these changes are addressed? Are such changes and how you will meet additional requirements discussed at quality meetings or at management review meetings?
The site’s senior management shall demonstrate they are committed to fully comply with the export legislation of the Export Control 2020 and Export Control (Milk and Milk Products) Rules 2021. This may be in the form of a statement.
The proposed arrangement must cover each stage of your manufacturing operations to prepare prescribed milk or milk products at your registered establishment and ensure all importing country requirements are met.
As an export registered establishment, it is expected that you will have systems in place to ensure that all records or documents which are relevant to ensuring you comply with the Export legislation, importing country requirements and your approved arrangement are kept for at least 3 years.
Any changes to your documented approved arrangement must be clearly identified. This may be in a register or by any method which clearly defines all changes made to your approved arrangement. Changes may include any pre-approvals, exemptions or new processes you have in place. This is important as any variation to your approved arrangement may have the potential to affect your compliance with the relevant legislation or the safety of your food product.
Any variation should not be implemented unless it has been given approval by the relevant authority or department.