Understanding Standard 3.2.2A and the New Food Safety Management Tools for Australian Food Businesses

In the food industry, it’s crucial to stay updated with the latest regulations. The latest amendment to the Australia New Zealand Food Standards—Standard 3.2.2A—is a pivotal addition that every food business owner in Australia should be aware of.

An Overview of Standard 3.2.2A

Standard 3.2.2A Food Safety Management Tools has been in effect since 8 December 2022.

Prior to this update, New South Wales, Victoria, Queensland, and the Australian Capital Territory, had individualised requirements for food handling and record-keeping. The recent shift marks a significant alignment in food safety standards, ensuring a more unified approach across the nation. Regions like Western Australia, South Australia, Tasmania, and the Northern Territory, which previously operated under limited requirements, must now adhere to this comprehensive standard.

Business Categories under Standard 3.2.2A

Businesses are categorised into two groups based on their operations:

• Category One: This category comprises businesses handling unpackaged, ready-to-eat food that could be hazardous. Examples include:
  • Restaurants, pubs, and cafes.
  • Supermarkets with ready-to-eat sections.
  • Catering services and takeaway outlets.
  • Medical and childcare institutions.
• Category Two: These are establishments selling ready-to-eat, potentially hazardous foods that were not prepared on-site, with a few exceptions. Examples are delis, market stalls, and some service stations.

The Three Pillars of Standard 3.2.2A

At the heart of this update are three essential tools designed to improve food safety:

Food Handler Training

A comprehensive approach to food safety, this tool prioritises proper training for those in direct contact with food. Based on Clause 10 of the standard, the objective is clear:

Criteria for Food Handlers

Before engaging in high-risk activities, a food handler must either:

1. Have completed a nationally recognised food safety training course, or
2. Possess skills and knowledge of food safety and hygiene in line with the specific high-risk activity.

Scope of Training

This training must focus on:

1. Safe food handling, especially temperature control and the temperature danger zone.
2. Prevention strategies for food contamination like managing allergens, separating raw and cooked foods, and using separate utensils and chopping boards.
3. Proper cleaning and sanitising of premises and equipment, focusing on the right procedures and food-safe chemicals.
4. Personal hygiene, such as protocols for ill employees, hand-washing, and proper grooming.

Intended Outcome

The aim is to ensure food handlers have the skills to handle potentially hazardous foods safely—those that can support the growth of pathogenic microorganisms. Emphasis is on activities affecting the safety of ready-to-eat, potentially hazardous foods and the importance of strict controls. Key areas include temperature maintenance, contamination prevention, proper sanitising methods, and personal hygiene—all crucial for reducing food-borne illness risks.

Recognition of Prior Learning

Recognising prior learning in food handlers is allowed. This might be from competency-based food safety training, in-house education, or induction from another business. Relevant past experience in the food industry should also be acknowledged.

Additional Consideration for Business Owners

Even if not directly handling food, business owners and managers should consider undergoing food safety training. It promotes a strong food safety culture and aids in understanding and mitigating potential risks.

Food Safety Supervision

Standard 3.2.2A emphasises the importance of proper supervision for food handlers. Clause 11 elaborates on the vital role that a Food Safety Supervisor (FSS) plays in this:

Appointment and Accessibility

• Both Category One and Category Two businesses are mandated to appoint a certified FSS.
• It is essential that the FSS remains “reasonably available” to guide and oversee food handlers involved in prescribed activities.
• The primary objective is to ensure food, especially high-risk and ready-to-eat food, remains safe. The right FSS, equipped with the necessary skills and authority, can effectively oversee food handlers, ensuring a safe food environment.

Certification and Validation

• An FSS must have acquired formal certification within the preceding five years. This ensures that they possess up-to-date and consistent skills and knowledge, particularly in handling high-risk foods.
• The FSS must have the authority and capability to identify, avoid, and rectify food safety issues.
• Importantly, the FSS should be actively engaged in food handling and present at the business site.
• The FSS certification is valid for five years.

Role Definition

• The primary duty of the FSS is to ensure that the business meets food safety standards. They can achieve this through staff training, updating operational procedures, and reviewing food handling practices and the premises.

Being Effective and Available

• For the FSS to be effective, they should ideally be on-site, especially when handling high-risk unpackaged foods. If not on-site, they should be easily reachable, especially if there are set procedures.

Record Management

As per Standard 3.2.2 guidelines, Category One businesses must have an ‘evidence tool’. This is crucial to ensure these businesses strictly adhere to food safety management for their prescribed activities.

Evidence Tool & Category One Businesses

1. Only Category One businesses are required to use the evidence tool.
2. These businesses must provide records or alternative forms of proof to authorised officers, demonstrating compliance with specific requirements. These pertain to receiving, storing, processing, displaying, and transporting potentially hazardous food, alongside cleaning and sanitising.
3. The aim is to ensure that these businesses rigorously monitor and address major food safety risks, with a focus on food temperature, processing, and cleaning/sanitising.

Clause 12 & Record Keeping

1. Under 3.2.2A—12, businesses involved in prescribed activities need to maintain records demonstrating the management of food safety risks.
2. ‘Prescribed provisions’ include the guidelines for keeping food at safe temperatures, as well as cleaning and sanitising. These provisions directly influence the safety of ready-to-eat, potentially hazardous foods.
3. The mandate applies universally to all Category One food businesses.

Understanding ‘Record’

1. A record is any documentation or object kept for informational purposes, including written notes, electronic templates, standard operating procedures, photographs, video footage, or any other method that captures required data.
2. One record can encompass multiple prescribed activities or foods.
3. Such records must always be accessible to both authorised officers and business personnel.

Prescribed Details & Retention

1. The purpose of these records is to confirm key matters, like ensuring hazardous foods are maintained at safe temperatures.
2. Records must be made each day the business is engaged in prescribed activities. They should include the date (and time if needed) of their creation and specifics about the food or activity.
3. As per 3.2.2A—12 (2), a record, once made, must be retained for a minimum of three months. This three-month period is particularly significant given the incubation period of the listeria bacteria, a major contributor to food-borne diseases.

Flexibility & Adaptability

1. Subclause 3.2.2A—12 (3) offers flexibility in demonstrating risk management. Businesses can use physical demonstrations or train staff using standard operating procedures.
2. Businesses should refer to guidance from their state/territory regulators for clearer insights.
3. Ultimately, it’s the business’s responsibility to provide evidence of compliance to authorised officers.

Specific Prescribed Provisions

1. Outlined in 3.2.2A—12 (4), these provisions define the standards for various aspects, from temperature control during food storage and receipt to pathogen reduction, food processing time, and cleaning/sanitising.
2. Ensuring the adherence to these guidelines is crucial as mismanagement can lead to unsafe food conditions.

Corrective Measures

If a record highlights an issue, like food stored at an unsafe temperature, the business must take immediate action. The corrective steps, whether discarding the food or repairing equipment, must be documented.

 

Clarifying Key Terms

Potentially Hazardous Food

Foods that require specific treatment to inhibit bacterial growth or toxin production, such as dairy, seafood, salads, cooked grains, and protein-rich items like quiches and soy products.

Ready to Eat Food

These are foods ready for consumption as sold, without any further cooking or processing. As they do not undergo additional heat treatment before eating, they’re susceptible to bacterial growth. Examples include sandwiches, salads, cold meat platters, and select desserts.

Prescribed Activities

For businesses in Category One, documenting certain practices is crucial to uphold food safety. These practices include:

• Monitoring Temperature: Constantly checking and recording temperatures during various stages like storage, cooking, and display to ensure food safety.
• Ensuring Pathogen Reduction: Applying measures and methods to significantly decrease harmful pathogens in food, ensuring its safe consumption.
• Proper Food Cooling and Reheating: Adhering to standardised cooling and reheating practices that prevent bacterial growth.
• Rigorous Cleaning and Sanitising Protocols: Implementing thorough cleaning and sanitising processes to eliminate potential food contaminants and maintaining a sterile environment.

Compliance and Penalties

Starting in 2023, local governments will intensively monitor compliance with this standard. Non-adherence can result in penalties, ranging from fines to license cancellations, depending on the violation’s seriousness.

 

Steps Towards Compliance

1. Training: Ensure that all Food Handlers undergo necessary training through approved programs.
2. Safety Supervisors: Appoint a trained supervisor to oversee and ensure compliance with food safety standards.
3. Record Keeping: For Category One businesses, maintaining records of the prescribed activities is essential.

 

Further Reading

For a deeper understanding, consider consulting the following resources:

• Standard 3.2.2 Food Safety Practices and General Requirements
• Standard 3.2.2A Food Safety Management Tools​

Staying informed and compliant protects both your business and the health of your customers. Make sure you’re aligned with the latest in food safety standards.