129 The two main options that have been considered in this review are to retain NZFSA as part of MAF or to separate NZFSA into a stand-alone organisation. The existing SAB arrangements give rise to accountability issues that are more complex than is normal for departments. The complexities involved create some risks in terms of undermining effective accountability and have the potential to create some tensions between the parties involved. Accordingly, there is a higher than normal onus on the key individuals within the SAB and the "parent" department to make the relationship work.
130 Notwithstanding the risks posed by the SAB model, there are strong reasons for retaining NZFSA as part of MAF because of the need for close links, and the existence of considerable synergy, between the agencies.
- International trade is a fundamental part of NZ's economic health. Traditional barriers to trade are being replaced by those which focus on biosecurity, food safety, environmental and animal welfare issues. There needs to be close co-ordination between NZFSA and MAF (including, in particular, Biosecurity NZ) because of the need to maintain a consistent and principled approach to the design and application of the regulatory regime and a consistent voice when representing NZ in international fora.
- A large part of NZFSA's work involves providing assurances to trading partners. Its main focus is on animal products, but in order to provide assurances in respect of these, it relies upon assurances from Bioseciurity NZ regarding the health status of NZ's livestock.
- The two agencies collaborate, at a day-to-day level, on a wide range of trade and regulatory issues.
- NZFSA makes a direct contribution to three of the four high-level outcomes described in MAF's Statement of Intent.
- The nature of the work undertaken by NZFSA and Biosecurity NZ has common scientific and risk-based underpinnings and this is reflected in the composition of staff within NZFSA and Biosecurity NZ.
- Good regulatory design and application needs to be based on a blend of technical and policy perspectives.
- The effectiveness of response in the event of biosecurity incursion or food safety risk depends on close integration between MAF, Biosecuirity NZ and NZFSA.
- In general, across government there is a desire for greater collaboration and horizontal integration across agencies reflecting concerns that the relatively fragmented nature of the public sector can hinder achievement of Government's desired outcomes.
131 The option of establishing NZFSA as a stand-alone agency has the potential to weaken these links and, therefore, diminish, rather than enhance, the achievement of desired outcomes. Moreover, establishing NZFSA on a stand-alone basis could involve significant costs both in an ongoing sense (potentially in the region of $5 million per annum) and in a transitional sense. There is potential for one-off capital (mainly IT) related costs of around $6 million. While the option of a stand-alone entity does offer clearer and simpler accountabilities, the benefits of this are very unlikely to outweigh the fiscal costs involved let alone the costs through losing the benefits of close integration outlined above.
132 Consideration has been given to making NZFSA a division of MAF rather than continuing as a SAB. This would also help to address the accountability tensions while retaining the advantages of close integration. However, this option is not recommended at this stage. There are some advantages in maintaining a degree of separate identity for NZFSA in terms of providing focus and building on the considerable success already achieved by NZFSA since its establishment. Furthermore, from an external stakeholder perspective, retaining NZFSA as a SAB implies no disruption or change.
133 Accordingly, the review concludes with a preference in favour of retaining the SAB model for NZFSA. This is tempered, however, by the need for the parties involved to address some underlying relationship issues by focusing on enhancing the formal and informal mechanisms that need to be in place to foster effective working relationships. This is discussed further in the next section.