If you own or manage a food business, you are probably aware that a new, stricter food standard will come into effect on December 8, 2023: Standard 3.2.2A - Food Safety Management Tools.
This standard classifies food-handling businesses into several categories with increased food safety requirements. Depending on their activities and category, Australian food-related businesses will have to implement two or three food safety management tools on top of their existing Chapter 3 obligations.
You must have many questions, such as:
Let’s tackle those questions one by one.
The standard applies to the vast majority of food service and food retail businesses, such as:
There are a few exceptions, though. The standard does NOT apply to food handling businesses or situations such as:
Does your business handle potentially hazardous or unpackaged food? How much will the new standard affect you? Let’s start by finding out which category you fall into.
Standard 3.2.2A says that a category one business:
The main gist is that category one businesses handle food directly, so it may be exposed to contamination before it is served.
If this doesn’t sound like your business, let’s take a look at category 2. Standard 3.2.2A says that a category 2 business:
Standard 3.2.2A is called “Food Safety Management Tools” because it is about enforcing three specific tools for all applicable food handling businesses, according to their category.
Let’s go over the tools now. The Food Safety Management tools that Standard 3.2.2A is now making a requirement for many businesses like yours are:
The standard’s exact wording is:
All food handlers undertaking prescribed activities must have completed a food safety training course or have appropriate skills and knowledge.
This means that if Standard 3.2.2A applies to your business, then every employee who handles high-risk food needs to either have completed a Food Handler course or have proven their knowledge and experience on this or a previous job.
The standard is very specific about the required skills and knowledge, and not just any course will do.
An approved course should cover, at the very least: safe handling of food, food contamination, cleaning and sanitising of food premises and equipment, and personal hygiene. The best way to make sure these are covered is by taking a nationally recognised Food Handler Certification Course.
One thing to keep in mind about members of staff who have not completed a course: if an authorised officer is not convinced that a food handler has the necessary knowledge and skills, they may request that said food handler go through some training.
FSANZ also recommends that business owners and managers also consider taking Food Handler training even if they don’t handle food, so they can better understand and mitigate risks.
First, let’s see what the standard says:
The intended outcome is that food handlers in category one and two food businesses are adequately supervised by a trained and competent supervisor.
Note that this applies to both categories in the standard, which means every Australian business in the food service, catering and retail sectors, that handles unpackaged, potentially hazardous food that is ready to eat.
Is your business included in Standard 3.2.2A? Then you will need to appoint a trained Food Safety Supervisor before handling any high-risk foods. You are probably already conducting business every day, and you may wonder what the standard means by ”before”. Remember that the standard will come into effect on December 8, 2023, so you will have to make sure your business is fully compliant before that date.
If you already have a trained Food Safety Supervisor, make sure their certificate is still valid - FSANZ requires food Safety Supervisors to refresh their training every 5 years, so their knowledge and skills are up-to-date and relevant. And just like with Food Handler training, Food Safety Supervisor training must be provided by a registered or accredited training organisation.
The final food safety management tool is only required for category one businesses, so if it applies to your business this is what you need to do according to the Standard:
Records or other evidence to substantiate that specific activities are being properly
managed (prescribed provisions of Standard 3.2.2, listed in clause 12).
First, let’s look at what the standard says:
The food business must make a record that substantiates any matter that the prescribed provisions require in relation to that prescribed activity.
This wording may seem confusing, but we will translate it for you. This requirement for Category 1 businesses (those that handle or process high-risk food that will be served or sold for consumption) means they must keep track of several parameters in a reliable format, such as paper or digital documents, photos or video. You must be able to produce this documentation whenever it is requested by the authorities.
Some of the parameters you may need to record include:
Every business is different, and as you just saw, Standard 3.2.2A has different requirements for different types of food-related activities. Still, this checklist is a good place to start:
Compliance with Food Safety Standard 3.2.2A is typically monitored and enforced by local or national food safety authorities. These authorities conduct regular inspections, review food safety records and ensure that food businesses adhere to the standards set in the regulation.
If a business fails to comply, it may face penalties such as fines, mandatory training or even closure until compliance is achieved. For detailed enforcement mechanisms specific to your locality, you may need to consult local government websites or food safety authorities.
The specific penalties for non-compliance with Food Safety Standard 3.2.2A can vary based on jurisdiction but generally include fines, orders to rectify the non-compliance, temporary suspension of business operations or even permanent closure for severe violations.
Some regions may also impose legal proceedings against the food business owners or managers. For detailed information on penalties applicable in your area, it's best to consult with the local authorities.
As a Registered Training Organisation (RTO), the Australian Institute of Food Safety is able to offer specific training programs and resources to help food businesses comply with Standard 3.2.2A.
As always, we are here to help you and your business. Contact us if you want to take advantage of our business solutions or if you need any more information!
If you want to learn more about Standard 3.2.2A - visit our dedicated 3.2.2A Information Page here.