Recent food safety changes may leave food businesses non-compliant

By Paul Sharpe

Significant changes in food safety regulations on Friday, 8 December, might have left many food businesses on the wrong side of compliance and susceptible to problems. The new Standard 3.2.2.A outlining three additional requirements for food businesses across all states and territories in Australia that must be considered.

From Friday last week, businesses selling unpackaged, potentially hazardous, ready-to-eat food, must ensure that their food handlers have the appropriate skills and knowledge in food safety and hygiene as outlined under Standard 3.2.2A of the Code. 

On top of this, all cafés, restaurants, and retail food outlets also need to appoint a ‘Food Safety Supervisor’ (FSS) if the food they prepare and serve is ready-to-eat (needs temperature control), and is not sold and served in the supplier's original package. In addition, the designated FSS must be contactable at all hours the business is open – something many restaurants have not considered. In other changes, food businesses must also keep the appropriate records that they are managing the standards set out in 3.2.2.

Where many restaurants may get caught out is that the food supervisor must be accredited and that they must be contactable all through the hours of work. For many QSR and franchise businesses, this will be a challenge for late night and early morning opening, and even more difficult for businesses open 24 hours. Take a bakery, for example. They often start at 3AM and finish late, so a trained and designated Food Safety Supervisor must be someone to be contactable between 3AM and perhaps 8PM, which is a big ask. 

Another aspect of the changes that require consideration is the units of competencies that have also been upgraded. Qualifications of the Food Safety Supervisor must have been completed within the last five years so many FSSs are going to be expiring soon. All businesses should be considering who they are in their business and if their training is to date.

Compliance risk

Compliance is a bugbear of any business and something that can never be ignored. With the recent Standard 3.2.2. A change comes with a host of additional compliance considerations and the reporting of adhering to the new standards will be of increased focus. Now, having all your compliance documents in one place is more important than ever. No matter what changes you make to your training, if you can’t prove them, then the health authority will not see them having occurred and therefore compliant. 

Storing your records in a centralised location online is always best. This way a food business can produce the reports when needed and demonstrate the training levels each employee has reached. Health authorities will certainly be proactively reaching out over the coming months and years.

Franchises must pay special attention
When it comes to franchise businesses, until now many franchisors relied on their franchisees to know and comply with their respective state’s regulations. Previously each state had their own rules and ways of enforcing those rules, but now all states and territories must comply, so it should be the franchisor who takes control of this. By using an operating platform with online training, standardised guidance across the franchise can be implemented by the franchisor. This way the franchisor can ensure all franchisees are compliant.

By the franchisor owning this there is far less likelihood of confusion by the franchisees, on what is often quite a complex amount of online reading into which regulations apply to them and which don’t. Courses can be recommended to the franchisees for ease of understanding. With a proper compliance and content strategy the franchisees can then focus on what's important in their business, which is their people, and delivering great customer services and products, rather than worrying about compliance.

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