4 March Attn: Planning Technician, Level 10, Civic Building Auckland Council Private Bag Auckland Proposed Food Safety Bylaw

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Anissa Allen
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4 March 2013 Cornwall Complex Floor 2, Building 15 Greenlane Clinical Centre Private Bag 92 605 Symonds Street Auckland 1150 New Zealand Telephone: 09-623 4600 Facsimile: 09-623 4633 Attn: Planning

safety bylaw. ARPHS does not like to be heard at any submissions hearing.

1 4 March 2013 Cornwall Complex Floor 2, Building 15 Greenlane Clinical Centre Private Bag Symonds Street Auckland 1150 New Zealand Telephone: Facsimile: Attn: Planning Technician, Level 10, Civic Building Auckland Council Private Bag Auckland 1142 Proposed Food Safety Bylaw Thank you for the opportunity for (ARPHS) to provide a submission on the proposed food safety bylaw. ARPHS does not like to be heard at any submissions hearing. The following submission represents the views of Auckland Regional Public Health Service and does not necessarily reflect the views of the three District Health Boards it serves. Please refer to Appendix 1 for more information on ARPHS. ARPHS understands that all submissions will be available under the Local Government Official Information and Meetings Act 1987, except if grounds set out under the Act apply. The primary contact point for this submission is: Naina Raj Public Health Scientist Intelligence and Planning Private Bag Symonds Street Auckland ext Nainar@adhb.govt.nz Yours sincerely William Rainger Service Manager Dr Simon Baker Acting Clinical Director/Medical Officer of 1

2 Health Executive Summary 1. ARPHS welcomes and is supportive of the proposed Food Hygiene and Safety bylaw to increase the safety of food sold to the public for the purposes of promoting and protecting public health in the Auckland Region. 2. ARPHS recommends that the proposed Food Hygiene and Safety Bylaw be amended as follows: Amend definition of food and readily perishable so it is aligned with the Food Act 1981 Where it is mentioned, New Zealand Food Safety Authority should be changed to Ministry for Primary Industries Extend the requirement for food handlers to be trained in an approved health hygiene course from 50 percent to 100 percent Introduction 3. Rates of foodborne outbreak notifications are usually higher in the Auckland region in comparison to the rest of New Zealand. 1 The causes of foodborne illness include; viruses, bacteria, parasites and toxins. Symptoms can range from mild gastroenteritis to life-threatening neurologic, hepatic and renal complications. Although people from all age groups are susceptible to foodborne illnesses, children, the elderly, those with weakened immune systems and medical comorbidities are at a higher risk. 4. According to Environmental Science and Research Limited (ESR) surveillance reports, 2 the most common contributing factors of foodborne outbreaks involve either contamination of food or time and temperature abuses. Contamination of food usually occurs via an infected food handler or cross-contamination with other food. The most common time and temperature related issues are; undercooking, inadequately reheating previously cooked food, improper storage prior to preparation and improper hot holding. Other factors involve unsafe 1 Environmental Science and Research Limited (ESR) 2 ibid 2

3 sources of food such as; raw food, use of untreated water and contaminated ingredients in food preparation. 5. As a public health unit ARPHS receives notifications and monitors levels of notifiable diseases, such as those linked to foodborne outbreaks in the wider Auckland region. One of ARPHS s functions is investigating disease notifications and taking steps to mitigate risks to the wider population. This can involve, but not limited to; contact tracing, provision of advice to individuals and institutions and liaison with the Ministry for Primary Industries, where the source of infection may be related to food and food hygiene practices. 6. ARPHS does not currently investigate food complaints or conduct food premises investigation work under contract to the Ministry for Primary Industries however, it does have a legislative role under both the Health Act 1956 and the Food Act 1981 which gives the Medical Officer of Health power to inspect and require appropriate information to minimise any negative public health impact of improper sale of food. Specific comments on the document being submitted Clause 5 Interpretation 7. ARPHS notes that in the proposed bylaw there is a slight variance in the definition of food and readily perishable from the Food Act ARPHS recommends that the definitions of both the terms in the bylaw should be aligned to the Food Act 1981 and so should read, Food Without limiting to the definition of Food as prescribed under the Food Act 1981, food means for the purpose of this bylaw anything that is used (p32) Readily perishable food Without limiting to the definition of readily perishable as prescribed under the Food Act 1981 readily perishable food shall mean food for sale that consists (p33) 8. Under food premises on page 32, the New Zealand Food Safety (NZFSA) should be amended to read as the Ministry for Primary Industries. 3

4 Clause 7 Training of staff in food premises 9. Clause 7 (2), the bylaw requires that at least 50 percent of all food handlers employed at the premise at any one time must have passed an approved basic food hygiene course, either before they have commenced work or within three months of commencing. In ARPHS experience, the most common contributors of food contamination occur via an infected handler, or due to unsafe handling practices in food premises. 10. In consideration of the higher risk of foodborne outbreak associated with the food handler, anyone preparing food has a duty to ensure their operations result in the provision of safe and suitable food. Therefore, ARPHS suggests that the 50 percent requirement be extended to 100 percent of food handlers having passed an approved basic food hygiene course over a gradual period of time to minimise these risks. A phased-in approach would assist food establishments with achieving compliance with the bylaw. Attachment 1: Matters to be considered in grading 11. Point 1 under Critical items-the last word rates appears to be a typographical error and should be read as rats. 4

5 Appendix 1 - (ARPHS) provides public health services for the three district health boards (DHBs) in the Auckland region (Auckland, Counties Manukau and Waitemata District Health Boards), with the primary governance mechanism for the Service resting with Auckland District Health Board. ARPHS has a statutory obligation under the New Zealand Public Health and Disability Act 2000 to improve, promote and protect the health of people and communities in the Auckland region. The Medical Officer of Health has an enforcement and regulatory role under the Health Act 1956 and other legislative designations to protect the health of the community. ARPHS primary role is to improve population health. It actively seeks to influence any initiatives or proposals that may affect population health in the Auckland region to maximise their positive impact and minimise possible negative effects on population health. The Auckland region faces a number of public health challenges through changing demographics, increasingly diverse communities, increasing incidence of lifestylerelated health conditions such as obesity and type 2 diabetes, outstanding infrastructure needs, the balancing of transport needs, and the reconciliation of urban design and urban intensification issues. 5

Policy proposals for inclusion in the Food Safety Law Reform Bill

Policy proposals for inclusion in the Food Safety Law Reform Bill Auckland Regional Public Health Service Cornwall Complex Floor 2, Building 15 Greenlane Clinical Centre Private Bag 92 605 Symonds Street Auckland 1150 New Zealand Telephone: 09-623 4600 Facsimile: 09-623