New Food Safety Standard –What Does it Mean for Hotels?

OWEN WEBB - AHA|SA WORKPLACE RELATIONS MANAGER

A new food safety standard in the Australia New Zealand Food Standards Code has been developed and, in this article, we look in depth at the new standard and what hotels need to do to ensure they comply.

STANDARD 3.2.2A – FOOD SAFETY MANAGEMENT TOOLS

South Australian food businesses need to comply with the Food Act 2001 (SA) and the Australia New Zealand Food Standards Code. There are six national food safety standards under the Food Standards Code which includes a recently developed and approved code, Standard 3.2.2A – Food Safety Management Tools (Standards 3.2.2A).

Standard 3.2.2A commenced on 8 December 2022 and it places new obligations on food businesses in Australia that handle unpackaged, ready to eat, and potentially hazardous foods.

Under the Standard, businesses will need to comply with either two or three new food safety management tools depending upon the level of risk to the business. The three management tools include:

• Food handler training;

• The appointment of a certified food safety supervisor; and

• Substantiation of critical food safety controls (evidence).

Category one businesses (e.g. hotels, restaurants, bakeries, fast food outlets) will need to comply with all three management tools, while category two businesses (e.g. supermarkets, service stations, delis) only need to comply with food handler training and the appointment of a food safety supervisor.

There is a 12 month transitional period to ensure that businesses implement these new management tools before 8 December 2023.

CATEGORY ONE BUSINESSES

Category one businesses are considered higher risk under Standard 3.2.2A, because they deal with unpackaged potentially hazardous food that is made into ready-to-eat food which is served to customers. Hotels are included as category one businesses and therefore they need to ensure they have implemented all three food safety management tools by 8 December 2023.

FOOD HANDLER TRAINING

Hotels need to ensure that all food handlers in their business who engage in a prescribed activity has, before engaging in that activity:

(a) Completed a food safety training course; or

(b) Have demonstrated skills and knowledge of food safety and hygiene matters commensurate with that prescribed activity.

For the purposes of Standard 3.2.2A a prescribed activity is the handling by the food business of any unpackaged potentially hazardous food that:

(a) is used in the preparation of ready-to-eat food to be served to a consumer; or

(b) is ready-to-eat food intended for retail sale by that business.

In terms of food safety training courses, a food handling training course means training in food safety that includes training in each of the following:

(a) safe handling of food; and

(b) food contamination; and

(c) cleaning and sanitising of food premises and equipment; and

(d) personal hygiene.

There is a free online food safety course that is supported by SA Health called DoFoodSafely (dofoodsafely.health.vic.gov.au) that food handlers can undertake.

In relation to demonstrated skills and knowledge of food safety and hygiene matters for a food handler, Hotels will be able to show demonstrated skills and knowledge where a food handler has undertaken prior learning from a previous food safety training course including food safety units from a certificate in commercial cookery for example. Hotels will also be able to recognise such demonstrated skills and knowledge where a food handler has prior experience in the food industry.

It’s recommended that Hotels keep a record of any training that food handlers complete.

Under the Standard, businesses will need to comply with either two or three new food safety management tools depending upon the level of risk to the business.

FOOD SAFETY SUPERVISOR

Hotels will also need to ensure that they:

(a) appoint a food safety supervisor before engaging in a prescribed activity; and

(b) ensure that the food safety supervisor is reasonably available to advise and supervise each food handler engaged in that prescribed activity.

A food safety supervisor is defined under Standard 3.2.2A as a person who:

(a) holds a food safety supervisor certificate that has been issued within the immediately preceding period of 5 years; and

(b) has the authority and ability to manage and give direction on the safe handling of food.

A food safety supervisor certificate means a certification as a food safety supervisor by a registered training organisation or an organisation recognised by the relevant authority under the applicable Act.

The required national units of competency under the food safety supervisor course are – Use hygienic practices for food safety and participate in safe food handling practices The food safety certificate is valid for 5 years and a refresher will need to be undertaken every 5 years.

It is recommended that hotels ensure that more than one employee is appointed as a food safety supervisor to ensure that appropriate supervision of food handling practices is always maintained when trading.

SUBSTANTIATION OF CRITICAL FOOD SAFETY CONTROLS ( EVIDENCE )

Hotels will need to ensure that they maintain records or can demonstrate by other appropriate means that they are safely managing the risks associated with handling unpackaged potentially hazardous food.

A Hotel will need to maintain evidence that they are safely receiving, storing, processing, displaying and transporting potentially hazardous food, and for cleaning and sanitising. Records can be kept in a variety of different forms including written or electronic templates, standard operating procedures, notes on invoices, photos and video footage. Records need to be maintained every day that the business is operating and need to include the date and time the record was made. Records need to be maintained for at least 3 months and they need to be readily accessible so that they can be produced if inspected by the relevant health authorities.

Examples of the type of records that would need to be maintained in a Hotel environment include; records of cool room and freezer temperatures, records of procedures for safe receipt of goods, cooking and reheating temperature logs, records of procedures for safe storage of foods, procedures for personal hygiene and handwashing for food handlers.

OBLIGATIONS FOR BUSINESS

Prior to 8 December 2023, hotels need to ensure that they are compliant with the new Food Safety Standard 3.2.2A and compliance will be achieved by:

• Ensuring that all those who handle food have either completed a food safety training course or have records that can demonstrate that a food handler has the skills and knowledge of food safety and hygiene practices (e.g. copy of any certifications obtained, prior work experiences, previous in house training).

• Ensuring that they appoint an appropriate number of food safety supervisors who in the preceding period of 5 years have undertaken a food safety supervisor course or have documented evidence of having completed the units of competency required in the food safety supervisor course (e.g. Certificate 3 in Commercial Cookery).

• Ensuring they can substantiate their food safety management practices by maintaining appropriate records (which are kept for at least 3 months) for safely receiving, storing, processing, displaying and transporting potentially hazardous food, and for cleaning and sanitising.

The AHA|SA currently has a food safety fundamentals package in the members section of the AHA|SA website which contains a range of food safety information and templates that members can use. The website also contains information of the new Standard 3.2.2A and website links for other resources and training providers.