National Chemical Contaminants Programme

Purpose and aims

NCCP is a statistically based programme designed to confirm that the control of chemical residues in milk and dairy products is appropriate and effective. It assures the safety, wholesomeness, and truth of labelling of milk and dairy products for both domestic and export markets.

The programme is authorised under the Animal Products Regulations 2021 Part 8 Regulated control scheme: monitoring and surveillance.

Read the Animal Products Regulations 2021 Part 8 – NZ Legislation

NCCP verifies the contaminant control system – it is not a primary control measure. It enables MPI to:

• assess the effectiveness of the New Zealand regulatory programme in preventing the risk of contamination – from milk production to the final dairy product
• generate information on chemical contaminants in dairy production and processing to enable the industry and MPI to negotiate access to export markets and mitigate risk to trade
• undertake, where necessary, surveillance testing of dairy material or processors that pose a higher risk than normal
• provide assurances to destination countries where dairy products are being exported.

History and background

The NCCP in its current form was developed in consultation with the New Zealand dairy industry and moved under MPI’s full administrative control in 2002. However, monitoring under the programme dates back to 1997. The programme has been effective in confirming that dairy products are free of chemical residues at levels that could pose a threat to human health or to international trade. The programme has also helped to identify emerging trends and enabled appropriate steps to be taken to mitigate risk.

With over 95% of milk produced in New Zealand exported to more than 150 countries around the world, the integrity of New Zealand’s dairy products is absolutely critical to the dairy industry and to the New Zealand economy.

What gets tested

NCCP focuses primarily on random monitoring of raw milk and directed surveillance, particularly of colostrum. To facilitate exports of dairy products, New Zealand tests a wide range of substances that are of domestic or international interest, as well as parameters of high importance to specific destination countries. For compounds of higher importance, this is done irrespective of whether there is any evidence or likelihood that those substances are being used or abused.

New Zealand farming practices help to determine the types of chemicals and the number of samples to be analysed. Dairy products are subject to periodic surveillance or surveys. From time to time, other materials with the potential to carry over into milk and dairy products, such as animal feeds, are also screened.

Data collection and analysis

Data for NCCP is collected in 3 ways:

• random monitoring
• directed surveillance, which targets substances and practices that pose a higher risk
• surveys, which focus on materials or compounds for which little or no historic data exists.

Random monitoring

Dairy farms and manufactured dairy products are chosen at random throughout the dairy season to be part of the sampling regime. Manufacturers and milk suppliers are not given advance notice of being sampled.

A minimum of 50 raw milk samples are taken from each farm’s bulk-milk tank on 6 occasions each dairy season. Additional samples are collected over the winter and early spring period when most farms are dry. Milk is sampled from the farm's bulk-milk tank, which is continuously agitated. The samples are collected in pre-coded bottles, which are secured with tamper-evident seals. They are then sent to the laboratory for testing. Each season, a selection of finished dairy products are also sampled.

Samples are collected by trained, independent samplers operating under contract and in accordance with formal competency criteria set by MPI.

Directed surveillance

The surveillance component of NCCP is designed to investigate and, if necessary, control the movement of dairy material, which might pose a higher risk. This is based on the risk profile of the material for particular chemical hazards.

Directed sampling, or targeted sampling, is done on the basis of:

• the risk associated with the compound and its use
• the existing level of control
• the likelihood of non-compliance based on information available to MPI, such as reports, instances of non-compliance, audits, and investigations.

Because the sampling is undertaken in response to the risk profile associated with a particular hazard, it is purposely biased.

Surveys

Surveys are a tool to fill knowledge gaps. They are typically a one-off exercise to look at a specific combination of compound and the target material. Potential exposure, such as current or historic use, or environmental considerations are taken into account. Surveys may monitor more than dairy material – for example, animal feeds.

How data is used and reported

Samplers and laboratories report all sample and test result information to MPI, and all results are screened to ensure they conform. A summary of all results from random monitoring and targeted surveillance activities are published for each dairy season. These include comparisons with Action Limits. In addition, sampling plans are published in advance, setting out the expected range of samples and compounds intended to be monitored. These plans are adapted to take account of information that emerges during the course of the season.

Browse NCCP summary reports and sampling plans:

NCCP sampling plans and summary reports

Action Limits

Action Limits are established for all parameters tested under the NCCP. As well as meeting the maximum limits set by New Zealand and Codex, products must also meet the maximum limits set by each destination market. NCCP manages this by establishing an Action Limit. These Action Limits represent the lowest allowable limit applied by New Zealand, Codex, and destination markets. For some parameters, no limits have been established. In such cases, NCCP may apply an Action Limit based on reasonable expectations.

Test results that exceed Action Limits

If any Action Limits are exceeded, then a formal response is initiated. This includes notification to affected parties, for example dairy companies, and, in some situations, reporting to recognised agencies. The affected dairy product is also withdrawn from trade, pending the outcome of the investigation. Exceeding an Action Limit does not automatically mean that the material sampled was non-conforming. Consideration must first be given to the intended market and to the point in the process that the material was sampled before this can be confirmed. 

For findings that are 'out of character', a similar investigation occurs but no trade restriction is applied to the dairy product. Findings from unexpected results help to inform the programme and are taken into consideration when developing the sampling plan for the next season.

Continuous improvement

Because NCCP identifies when and why controls in the dairy industry may not be working, MPI uses information from NCCP in periodic reviews of standards, specifications, and guidance. When controls fail, regulatory actions aim to motivate those parties responsible – not only the individual farmer or the factory directly impacted. By working in concert, effective management and control of the issue is restored, often without the need for additional regulatory intervention.

Who to contact

If you have questions about NCCP, email info@mpi.govt.nz