Is Your Food Business Category One or Two Under Standard 3.2.2A?

Understand Standard 3.2.2A rules to ensure compliance, whether in category one or category two.
June 8, 2023

Navigating the complexities of food safety regulations is essential for every food business, and understanding the classification of your business under Food Safety Standard 3.2.2A can significantly impact your operations and compliance requirements.
Let’s delve into the differences between category one and category two businesses, as outlined under Australia's Food Safety Standard 3.2.2A, to help you understand what each entails and how these classifications could affect your business.

What is Food Safety Standard 3.2.2A?

Standard 3.2.2A is a mandatory update to the Australia New Zealand Food Standards Code, effective December 2022. It applies to Australian food businesses categorised as “one” or “two,” introducing stricter guidelines in three key areas: Food Handler training, food safety supervision, and record-keeping.

Training for Food Handlers is now more comprehensive, and businesses must designate at least one qualified Food Safety Supervisor. Record-keeping, especially for category one businesses, is also more stringent. Category one businesses face more rigorous regulations and must comply with all three food safety management tools, while category two businesses have slightly more relaxed rules. 

The standard coexists with state or territory laws, making it crucial for businesses to understand and comply with both.

Category One Businesses: Key Characteristics

Food businesses that fall under category one under the updated standard have a few key traits:

  • Category one businesses are involved in the direct handling of food that could be exposed to contamination before serving. This typically includes caterers and food service businesses.
  • These businesses process unpackaged, potentially hazardous food. In other words, they convert raw materials into finished food products that could pose a safety risk if improperly handled.
  • The food produced is ready-to-eat and potentially hazardous, requiring stringent safety measures to prevent contamination.
  • The food is then served to consumers for immediate consumption, often in a dine-in setting and possibly via delivery or take-out.

Category one businesses include, but are not limited to:

  • Restaurants
  • Caterers
  • Takeaway outlets
  • Bakeries

Implications for Compliance

Due to the high-risk nature of their operations, category one businesses must maintain detailed records. These records facilitate both compliance verification and ongoing food safety assessment. Training and supervision requirements are rigorous, reflecting the elevated risks associated with these types of businesses.

What is a Food Safety Record?

In Australia's new Food Safety Standard 3.2.2A, "prescribed activities" refer to the handling and managing of unpackaged, potentially hazardous foods. These can include the preparation of meals ready for immediate consumption or the retail sale of ready-to-eat items.

Businesses mandated to keep records under this standard must document these prescribed activities. Such documentation is intended to validate a range of concerns, for instance, ensuring that hazardous food items are maintained at safe temperatures. Each record should be dated and, when relevant, time-stamped, along with a detailed description of the food or activity involved.

A record can be any form of documented information that provides evidence of adherence to the Food Safety Program. Records can include:

  • Temperature logs for storage units
  • Cleaning and sanitisation schedules
  • Details about raw material suppliers
  • Employee training documentation
  • Customer complaints or incident reports
  • Invoice notes
  • Photos and video footage

Be aware that a record may cover multiple prescribed activities. For instance, the temperature log for a refrigeration unit could serve as a record for various types of potentially hazardous foods stored inside. Meticulous record-keeping – and keeping those records for at least three months – is not just a regulatory requirement but a crucial element in affirming a business's commitment to food safety.

Category Two Businesses: Key Characteristics

Let’s move on to the qualities of a category two business under Standard 3.2.2A:

Unlike category one businesses that process food, category two businesses handle unpackaged food but do not produce or process it.

These businesses still offer ready-to-eat, potentially hazardous food to consumers but don't engage in the full spectrum of food preparation.

Category two businesses either receive unpackaged food from suppliers or unpackage food themselves.
Food processing activities are limited to slicing, repacking, or hot-holding without minimal intervention.
Category two businesses include, but are not limited to:

  • Convenience stores
  • Service stations
  • Delicatessens
  • Market stalls

Implications for Compliance

While category two businesses also have strict guidelines to follow under Food Safety Standard 3.2.2A, their requirements are less stringent than those for category one businesses, reflecting the lower levels of associated risks. Record-keeping, although important, is optional for category two businesses.

Comparative Analysis

Here's a few of the differences:

  • Category one businesses usually carry a higher level of risk due to the nature of their food handling and processing.
  • Category one businesses must maintain detailed records for compliance and food safety verification, while category two businesses may have slightly less stringent record-keeping requirements.
  • Category one businesses may be subject to more frequent and rigorous inspections due to their higher risk profile.

Know Your Category

Understanding whether your business falls under category one or category two as per Food Safety Standard 3.2.2A is crucial for ensuring you meet all compliance requirements. Failing to adhere to the guidelines can result not only in legal repercussions but can also severely damage your brand's reputation.

Knowledge of your category will enable you to implement the proper safety measures, train your staff adequately, and maintain the required records, thus ensuring consumer safety and business sustainability.

Regardless of your category, training is vital. The Australian Institute of Food Safety offers online, fully compliant Food Handler and Food Safety Supervisor courses to get your team up to speed.