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FSANZ Food Standards Code 3.2.2A Food Safety Management Tools

FSANZ addendum Standard 3.2.2A Food Safety Management Tools became mandatory in December 2023.
It is important to note that each state and territory will manage the compliance requirements and implementation arrangements slightly differently so approach your state and territory health department or food authority.

The new food safety management tools are:
  • food safety supervisor (FSS) training
  • food handler training (FHT)
  • evidence to substantiate food safety management of key processes.

The new Food Standards Code 3.2.2A Standard is based on risk assessment for Category 1 and 2 Businesses
Food service businesses (Category 1) that prepare and serve RTE food will be required to implement all three tools, while food retail businesses who only minimally handle unpackaged RTE food (Category 2) will only be required to implement the FSS and FHT requirements.
FSANZ has a decision tree to help businesses determine the correct category. (refer below) 

Some businesses that already have a HACCP food safety program or have documented food safety programs may need to extend the scope of their programs ensuring any outlet that prepares and sells ready to eat, unpackaged, potentially hazardous foods to customers to consume or take away is meeting the requirements. 
Some businesses with an existing food safety program may be exempt or have extensions by the state authority. 

Correct Food system has worked with a number of clients to develop a simple food safety guide and customised simple forms to demonstrate compliance.

Category One businesses

Category 1 Business:
3.2.2A—6 provides that a ‘category one business’ means a food business that:
  • is a caterer or a food service; and
  • processes unpackaged potentially hazardous food into a food that is:
  • potentially hazardous food; and ready-to-eat food
    (would include a bakery that makes its own potentially hazardous food,)
  • a business that makes and then sells ‘ready-to-eat food’ to another business, for example a food business which sells premade sandwiches to a café.
Category 1
must comply with proposed sections
  • 3.2.2A—10 (Food safety training for food handlers engaged in a prescribed activity),
  • 3.2.2A—11 (Supervision of food handlers),
  • 3.2.2A—12 (Substantiating food safety management of prescribed activities) (see below).
Typical category 1 businesses required to abide by these 3 requirements are:
Restuarant's, Caterers, Clubs, Accommodation including hotels, motels and B&B's, Hospitals, Aged Care, Cafes, Mobile Food Vans, delivered meals, cruise boats, training venues.

Category Two businesses

Category 2 Business:
Section 3.2.2A —7 provides that a ‘category two business’ means a food business that offers for retail sale a food that is:
  • potentially hazardous food; and
  • ready-to-eat food;
    and
where that food:
  • was received unpackaged by the food business or was unpackaged by the food business after receipt; and
  • was not made or processed (other than slicing, weighing, repacking, reheating or hot-holding the food) by the food business
Category 1
must comply with proposed sections
  • 3.2.2A—10 (Food safety training for food handlers engaged in a prescribed activity),
  • 3.2.2A—11 (Supervision of food handlers),
Typical category 2 businesses required to abide by these 3 requirements are:
Retail outlets, convenience stores, service stations, factory outlet shops, delicatessens, seafood retailers., some butchers.

3.2.2A 3 Requirements

Requirement 1: Food Safety Training for food handlers  
Section 3.2.2A —10 provides that a food business must ensure that each food handler who engages in a prescribed activity has, before engaging in that activity:
  • completed a food safety training course;
    or
  • skills and knowledge of food safety and hygiene matters commensurate with that specific prescribed activity (can recognise prior learning)
Food safety training includes:
  • safe handling of food; and
  • food contamination; and
  • cleaning and sanitising of food premises and equipment; and
  • personal hygiene
The food safety training course must include all of the listed topics, but specific courses or units are not prescribed. There is prescribed minimum course content that must be included.

Requirement 2 Food Safety Supervision  
Section 3.2.2A —11 provides that the food business must:
  • appoint a food safety supervisor before engaging in a prescribed activity; and
  • ensure that the food safety supervisor is reasonably available to advise and supervise each food handler engaged in that prescribed activity.

Requirement 3 Food Safety Management of Subscribed activities
Category 1 businesses only. 
This requirement does not apply to the handling of food for or at a fund raising event.

Section 3.2.2A —12 sets out requirements related to substantiating the food safety management of prescribed activities (substantiation requirements).
Records:
  • Records kept for a minimum of 3 months from date of activity
  • Alternative compliance with EHOs is possible - by use and training on Standard Operating Procedures and or Physical demonstration of compliance to EHO
  • The prescribed provisions relate to temperature control (during food receipt, storage, cooking/reheating, display and transport for Potentially Hazardous Foods (PHF)), food processing of PHF and cleaning/sanitising.
    Records will be needed to show compliance with clauses from 3.2.2.
    a. subclause 5(3); [on temperature control during food receipt]
    b. paragraph 6(2)(a); [on temperature control during food storage]
    c. paragraph 7(1)(b)(ii); [on pathogen reduction during food processing]
    d. subclause 7(2); [on minimising time during food processing]
    e. subclause 7(3); [on cooling food]
    f. subclause 7(4); [on reheating food]
    g. paragraph 8(5)(a); [on temperature control during food display]
    h. paragraph 10(b); and [on temperature control during food transport]
    i. clause 20. [on cleaning and sanitising​]
  • Safe Food Australia guideline has a useful table on the prescribed activities, information to be recorded, and frequency of record.
  • Records can include completing forms/ templates, electronic records or online forms, photos or videos.
    Alternatively, businesses may choose to have a written instruction sheet or standard operating procedure with staff able to demonstrate the safe handling of food, if requested by a regulatory inspector.
    ​
FSANZ has released some support information
Safe Food Australia - a guide to the Food Safety Standards
FSANZ Infobites Overview 3.2.2A
and information of FSS Food Safety Supervisor Requirements here 
FSANZ Info bites - Training
FSANZ Info bites - evidence/ records 

FSANZ has a template for records that may be useful- Appendix 8 of Safe Food Australia 

The NSW Food Authority also has some useful resources
Standard 3.2.2A - ​Frequently asked questions​ | NSW Food Authority
NSW Food authority forms are also available
 Showing food is safe | NSW Food Authority


Questions ? Resources?  best solution for your business?
Correct Food Systems can assist with a customised food safety induction training manual / record used to train your food handlers.
We have simple food safety compliance record templates and workplace instructions your business can use to substantiate safe food handling of the prescribed activities.  
We can also work with you to develop food safety management procedures within your business.
 
Email your enquiry now to start progressing to meet this new requirement for food service and retail businesses.

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