Food Safety Standard 3.2.2a Food Safety Management Tools is being implemented into the law on December 8, 2023, as an addendum to the previous standard 3.2.2, Food Safety Requirements. It is intended to standardise the requirements for Food Safety Supervisors, Food Handlers and introduce requirements for Substantiation of Critical Food Safety Controls across all states. This new law affects all businesses in food service, catering, and retail sectors that handle unpackaged, potentially hazardous food that is ready to eat. This includes restaurants, cafes, food stalls, retail businesses and more.
The first thing food businesses must be aware of when understanding Standard 3.2.2a is what the three Food Safety Management Tools are, which businesses they apply to, and how they need to be implemented. The three tools are Food Safety Supervisor, Food Hander Training, and Substantiation of Critical food Safety Controls.
Under Standard 3.2.2a is it required that both category 1 and 2 businesses must employ a fully qualified Food Safety Supervisor that is either on-site during operating hours, or reasonably contactable during this time. They must have received Food Safety Supervisor Training delivered by a registered training organisation (RTO) such as QMS Audits and have received a statement of attainment with the correct units of competency for their business sector (Retail, Hospitality, etc.) to demonstrate appropriate food safety knowledge. Often, local food authorities will require that this certificate is kept on-site and can even offer penalties to businesses that cannot produce one when requested by an inspector.
To ensure that their skills are up to date and relevant, Food Safety Supervisors must have received their certification within the past 5 years, and therefore must renew their training if this timeframe is exceeded. It is also necessary that the person nominated for a Food Safety Supervisor role has previous experience regularly handling food, as their responsibilities include managing and supervising the safe handling of food within the business.
The second Food Safety Management Tool is Food Handler Training. Again, it is required that both category 1 and 2 businesses ensure Food Handlers have received adequate food handling training and have the capacity to safely handle high risk ready to eat foods. A Food Handler in this case refers to any employee that is involved in handling or preparing hazardous or potentially hazardous foods that are to be sold on the premises. It is also required by this standard that Food Handlers have adequate supervision by a competent and trained supervisor, which is why this tool is always implemented alongside the first Food Safety Management Tool, Food Safety Supervisor.
To meet Standard 3.2.2a, Food Handler Training must at minimum cover personal hygiene of Food Handlers, cleaning and sanitation, safe handling of food and types of food contamination. To meet Standard 3.2.2a, Food Handler Training must at minimum cover personal hygiene of Food Handlers, cleaning and sanitation, safe handling of food and types of food contamination.
Substantiation of Critical Food Safety Controls is the final Food Safety Management Tool which only applies to higher risk category 1 food businesses. This tool is intended to ensure category 1 businesses are actively managing food safety risks such as cleaning and sanitation, food processing, and temperature control. In online resources this tool is normally referred to as the ‘evidence tool’. This is because the requirement states that businesses must make sure to maintain physical records of prescribed activities and be able to demonstrate that standard 3.2.2a requirements are being met to authorised officers during these activities.
The Standard defines prescribed activities as any handling of potentially hazardous food by employees of the food business that is used in the preparation of ready-to-eat food that is either intended for consumption on site by the customer or for retail sale by the business. Businesses are required to maintain evidence that they are monitoring and managing these activities because they are categorised as high-risk.
Throughout the Standard there are many mentions to either category 1 or category 2 food businesses. It is therefore important to be able to know which category your food business falls into to understand what Food Safety Management Tools need to be implemented. Category 1 businesses are defined as the most high-risk food businesses such as caterers and food services where food is prepared for consumption on-site. Examples include restaurants, canteens or even hospitals.
Category 2 businesses may include retail businesses such as delicatessens, market stalls, supermarkets with delis, service stations, convenience stores and other food retailers. If you are struggling to determine which category your business falls into, there is a useful decision tree provided in the Standard as an attachment that can help clarify. Of these three tools, category 1 businesses are the required to implement all three, and category 2 businesses are only required to employ an on-site Food Safety Supervisor and ensure training for Food Handlers.
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