"P" & "T" Registrations

[Dave A]

I have had a number of queries relating to the status of "T" registrations, particularly in respect of food safety audits.

This is my understanding of where we stand:

The issue of T registrations first came up about a year ago as a result of the change in Registrars. We had to defend a member of the Association against an accusation that T registrations were not lawful.

The T system was implimented by agreement under Mr. E. Wolmarans. The current Registrar has stated that he is unhappy with the system, and it is currently being revised. It was agreed that the existing system would remain in force until the new regulations (being contemplated at the time) are implimented.

This is a process that has taken a year to date (I regret the wheels of government grind a trifle slow), and in fact our negotiations with the Department of Agriculture around the new regulations were only finalised at a meeting on the 21st February 2006. There is still a little while to go before the new regulations take effect as, apart from the need to be published, they rely heavily on unit standards which are currently being held up in the SAQA process, which in turn will delay implimentation.

Accordingly, the "status quo" remains and T registrations are still considered acceptable for the time being.

Just to clarify the direction the new regulations are taking; the requirements for P registrations are being brought into line with the current standards for T registrations. Accordingly, a T registration should not be considered sub-standard at this point.

[Me2]

Is there anything in writing that shows that the T registration are accepted by HACCP auditors? What is the status quo re the T registration above?

Regards
mark Enslin

[Dave A]

Consider for a moment the varying standards between HACCP auditors on rodent control, particularly placement of rodent bait stations.

Even if one auditor put in writing a position on "T" registrations, it does not mean that all would endorse it! In fact, probably the opposite. Better they focus on GMPs; that is what produces the results (no contamination).

The regulatory "confusion" is on the verge of being cleared up anyway. The new regs were supposed to be published last week, but with true bureaucratic efficiency.... Maybe this week... or next week...

From there, a clear course forward should be developed during Pestbiz.

[Me2]

Part of the problem with the T registration and HACCP auditors is that the Pest Industry themselves are shooting the qualification down. We all know and understand that there is always an erosion of personel from the larger companies. In essence the people migrating are the P qualified indiviuals that the smaller company absorb. This in effect means that whilst the smaller company has enough P qualified people to cover all bases, the larger company does not. Hence the larger companies need to use the T system in order to maintain the momentum. Here is where the problem arises because the company with excess capacity wants the contracts and therefore starts or fuels the fire of confusion. And in certain instances has created the abhorrence of T registered individuals with the Auditors at large.

It is a classic case of acting in own interests as oposed to the upliftment and sustainability of our industry.

Mark Enslin

[Dave A]

It is a classic case of acting in own interests as oposed to the upliftment and sustainability of our industry.

Mark Enslin

In a nutshell - our biggest challenge.

Acting totally out of personal interest can damage the industry. This is aggrevated when folk act literally with no thought of the downstream consequences past today.

It is important to uplift the industry - because this uplifts your business along with it.

Good to have you on board, Mark.