Managing High-Risk Food: Prescribed Activities in Standard 3.2.2A

Learn how Standard 3.2.2A impacts food businesses by outlining prescribed activities for handling high-risk, unpackaged food.
September 22, 2023

Standard 3.2.2.A requires Australian food service, catering and retail businesses to implement specific food safety management tools when handling unpackaged, potentially hazardous food that is ready to eat. 

One key aspect of these food safety management tools is the concept of prescribed activities. These activities relate to handling unpackaged, potentially hazardous food, particularly when no further preparation steps are taken, so there is no chance to eliminate pathogens before consumption.

Prescribed activities are identified as high-risk because they involve food that is susceptible to contamination just before consumption. This vulnerability underscores the need for specific measures to be in place to prevent the occurrence of foodborne illnesses.

Defining Prescribed Activities

As per Standard 3.2.2A, a prescribed activity refers to handling unpackaged, potentially hazardous food with specific intentions. These intentions revolve around two crucial scenarios:

Preparation of Ready-to-Eat Food

Prescribed activities encompass handling unpackaged potentially hazardous food to prepare ready-to-eat meals intended for direct consumption by customers, especially in processes where there are no further steps to eliminate pathogens before the food reaches the consumer's plate.

Retail Sale of Ready-to-Eat Food

Additionally, prescribed activities include handling unpackaged potentially hazardous food intended for retail sale in a ready-to-eat form. This pertains to situations where the food is handled, portioned or packaged for sale without undergoing processes to eliminate pathogens.

Significance of Prescribed Activities

The significance of prescribed activities lies in food’s vulnerability to contamination during these activities. Unpackaged potentially hazardous food, which means food items prone to harbour harmful microorganisms, is at a heightened risk of contamination just before consumption. The absence of further processing steps accentuates this risk. Due to these factors, prescribed activities are categorised as high-risk within the context of food safety.

Recognising and addressing prescribed activities is paramount in ensuring the well-being of consumers and compliance with Standard 3.2.2A. Mitigating risk  through appropriate handling, storage, and hygiene practices is essential to prevent foodborne illnesses and contribute to a safer dining experience.

Examples of Prescribed Activities

Prescribed activities can include many daily food-handling activities in food businesses. We compiled a short list of examples so you can better understand the concept of prescribed activities:

  • Temperature control during food transport, receipt, storage or display
  • Pathogen reduction during food processing
  • Minimising time during food processing
  • Cooling and reheating food
  • Cleaning and sanitising

Let’s consider more specific examples.

Picture a busy restaurant where many workers handle unpackaged, potentially hazardous food, including raw ingredients like meats, dairy, eggs, and fresh produce. As per Standard 3.2.2A, the restaurant engages in prescribed activities whenever they handle these unpackaged ingredients to prepare their products: from receiving and storing ingredients to prepping, chopping, cooking, storing and serving.

Since the prepared meals are intended for immediate consumption without further processing, the importance of food safety during prescribed activities becomes crystal clear. Proper handling, storage, cooking, and serving protocols are essential to ensure the food's safety and prevent the spread of foodborne illnesses. 

A different scenario occurs in a supermarket deli section selling ready-to-eat meats, including deli cuts and varieties of cured meats. The supermarket performs prescribed activities by slicing, weighing, and packaging the meats according to customers' preferences or protocols. These activities are considered high-risk due to the nature of the food. The absence of further processing steps means the food's safety hinges on the supermarket's diligent adherence to food safety protocols.

Distinguishing Non-Prescribed Activities

It's important to note that not all food business activities are considered “prescribed activities” by Standard 3.2.2A. While prescribed activities revolve around handling unpackaged, potentially hazardous food for immediate consumption, many other operations do not fall under this category. 

For instance, activities such as selling packaged snacks like nuts and chips or repackaging bulk raw grains to sell in smaller packages do not involve the direct handling of unpackaged, potentially hazardous food. 

These activities, although integral to the food business, are distinct from the high-risk prescribed activities: in the first example, there is no direct handling of unpackaged food, and in the second example, the food requires cooking before it is consumed. 

Understanding these distinctions is essential in comprehending the scope and significance of the prescribed activities outlined in the food safety standards.

Conclusion

Just to recap, in the context of Standard 3.2.2A, prescribed activities involve:

  • Direct handling of unpackaged, potentially hazardous food 
  • Awareness that the food will be consumed immediately without further processing

One significant change brought by Standard 3.2.2A is that any employee who engages in prescribed activities in a food establishment must be trained as a Food Handler, and every food business engaging in prescribed activities must have at least one qualified Food Safety Supervisor. 

Recognising and addressing prescribed activities is paramount in ensuring the well-being of consumers and complying with Standard 3.2.2A. We have compiled an Action Plan and essential information about 3.2.2A compliance so you and your business can continue to provide safe food services and stay on top of the law.