If you handle or work with food in any way in Australia, it is crucial to be aware of the amendments to the Australia New Zealand Food Standards Code, particularly the inclusion of Food Safety Standard 3.2.2A, enacted into law in December 2022. This is not a pending regulation – it’s already been passed and will be enforced in 2023. With this in mind, you need to take immediate action.
The Critical Nature of Standard 3.2.2A
The introduction of Standard 3.2.2A is a significant shift, expanding your obligations previously defined by Standard 3.2.2 of the Australian Food Safety Standards. Complying with these new stipulations is not optional; it is a legal requirement.
The updated standard prescribes the implementation of certain food safety management tools in every food business. This system uses three key instruments: mandatory Food Handler training, expanded food safety supervision, and robust record management. Whether you need to use all three of these tools depends on whether your business falls under category one or two.
Also, it's crucial to recognise that this new standard doesn't replace existing state or territory legislation and requirements; rather, it functions alongside them. This means businesses must adhere to their state or territory legislation and the newly introduced Standard 3.2.2A.
Questions Often Raised by Business Owners
As you get to know the specifics of Standard 3.2.2A, a range of questions may come to mind:
- Does this new standard impact my business?
- What category does my business fall into as per the new standard?
- Will my Food Handlers and Food Safety Supervisors need additional training?
- What immediate measures should I take for compliance?
In the following sections, we'll answer these questions to clarify your new responsibilities under this standard.
Applying Standard 3.2.2A
Standard 3.2.2A applies to Australian food businesses that fall under category one or category two, regardless of their size, location, or whether they are permanent or temporary. These businesses typically deal with unpackaged, ready-to-eat, and potentially dangerous foods right before customers consume them. This type of food handling is risky and has been connected to foodborne illness outbreaks in Australia and worldwide.
The standard affects a broad range of businesses, such as restaurants, grocery stores, and mobile food units.
Businesses impacted by Standard 3.2.2A encompass a wide variety, including but not limited to:
- Restaurants, cafes, and bars
- Hotels, casinos providing food services, and buffet eateries
- Supermarkets and grocery outlets
- Mobile food units and takeaway restaurants
- Healthcare institutions like hospitals, aged care facilities, and childcare centres
- Petrol filling stations
- Correctional facilities
If your business solely deals with the manufacturing or wholesale distribution of food or operates on a charity basis, you are generally exempt from this standard.
Categorisation of Businesses under Standard 3.2.2A
The standard differentiates food businesses into two primary categories:
3.2.2A Category One
These are establishments directly involved in food service and engage in handling unpackaged, potentially hazardous foods to prepare them for immediate consumption. Due to their food handling activities' extensive and high-risk nature, businesses in this category are subjected to more stringent regulations. Specifically, category one businesses must use all three tools: training of Food Handlers, appointment of at least one Food Safety Supervisor, and meticulous record-keeping, which should be kept for at least three months.
3.2.2A Category Two
These food businesses also offer ready-to-eat, potentially hazardous foods but are usually limited to less complex food-processing tasks like slicing or repacking. As a result, they are subject to a different set of guidelines compared to category one businesses. Category two establishments must still have trained Food Handlers and a designated Food Safety Supervisor. Still, their record-keeping requirements are only determined by the rules set by their respective state or territory.
Immediate Actions for Ensuring Compliance
Food Handler Training
Every staff member involved in food handling must undergo specialised training in food safety to comply with the new standard. It's vital to ensure that their existing certifications are up to date and cover the newly mandated topics in food safety, which include:
- Methods of safe food handling
- Identifying and mitigating food contamination risks
- Cleaning and sanitising food areas and equipment
- Practising personal hygiene
The training requisites under Standard 3.2.2A are notably more extensive and strict than prior guidelines. Existing Food Handler certifications might be insufficient, which will mean further training.
Designation of a Food Safety Supervisor
Both category one and category two businesses must appoint at least one qualified Food Safety Supervisor. Supervisors must be available at all times, so more than one may be required to cover long shifts, illnesses, or multiple locations. This person should have official certification issued within the last five years to ensure up-to-date expertise, especially regarding high-risk foods. Their role includes identifying and fixing food safety issues and overseeing the Food Handlers' record-keeping activities.
Food businesses in some Australian states or territories have existing record-keeping obligations, which are still valid. However, under the new Standard 3.2.2A, category one businesses must also maintain meticulous records of specific food handling activities, such as temperature logs and sanitisation schedules. These records must be kept for a minimum of three months.
A Compliance Checklist
- Identify Your Business Category: Determine whether your business falls under Standard 3.2.2A and identify your corresponding category.
- Assess Staff Training: Evaluate the existing qualifications of your employees to identify who requires immediate training or re-certification. Remember, compliance with the new training guidelines is a focal point during inspection visits.
Appoint Food Safety Supervisors: Ensure that you have a sufficient number of qualified Food Safety Supervisors whose certifications are current.
- Establish Record-Keeping Protocols: For category one businesses, develop a comprehensive list of records to be maintained and train Food Handlers in record creation and management.
By diligently adhering to Food Safety Standard 3.2.2A, you are not only fulfilling your legal obligations but also reinforcing your commitment to ensuring food safety and safeguarding public health. One of the best ways to comply with the standard is by enrolling staff in a Food Handler or Food Safety Supervisor course offered by the Australian Institute of Food Safety (AIFS). These courses are fully compliant with both state/territory laws, as well as federal food safety regulations. Contact one of our knowledgeable support staff to learn more.