Standard 3.2.2A frequently asked questions

Find the answers to frequently asked questions about the Food Safety Management Tools - Standard 3.2.2A and how it may apply to your business. 

Background and implementation FAQs

Food Safety Standard 3.2.2A – Food Safety Management Tools came into effect on 8 December 2022 and adds new requirements for all food service, catering, and retail businesses that handle unpackaged, ready-to-eat, potentially hazardous foods.

In June 2018, the Australia and New Zealand Ministerial Forum on Food Regulation found the highest proportion of foodborne illness outbreaks in Australia were from food service and retail businesses.

Food Standards Australia New Zealand (FSANZ) along with Australian states and territories developed Standard 3.2.2A to make sure all food handlers in these sectors have adequate food safety skills and knowledge and use practices that keep food safe.

The new Standard builds on Standard 3.2.2, by strengthening the requirements for skills and knowledge of food handlers and for businesses to demonstrate they are keeping high-risk food safe.

The new Standard became law on 8 December 2022 and has a 12-month transition period for businesses to comply. This means all affected businesses should comply with the Standard by 8 December 2023.

Some investment is likely needed for businesses to meet Standard 3.2.2A. This may include:

  • providing time for food handlers to complete a food safety training course and/or making sure they have the appropriate skills and knowledge
  • paying for a food handler to complete Food Safety Supervisor certification, or employing a certified Food Safety Supervisor
  • developing and/or providing training on processes, records, or other ways to show that the key food safety controls are monitored and managed

For most businesses compliance with the Standard will be monitored by local council Environmental Health Officers (EHOs) or Food Safety Auditors during routine food safety inspections or audits. Extra inspections or audits should not be required.

The penalties for non-compliance with the Food Standards Code are prescribed in the Food Act 2001 under Section 21 Compliance with Food Standards Code. These penalties have not changed since the introduction of the new Standard.

The Standard applies caterers and food service and retail businesses who handle unpackaged, potentially hazardous, ready-to-eat foods and sell or serve them to the consumer. Check below to see if the following activities and businesses are captured by the Standard and if you ares still unsure, contact your Local Council Environmental Health Officer.

A business that makes and delivers meal packs to consumers

No, businesses who deliver meal packs, such as pre-portioned meal ingredients or packaged meals for reheating, are not captured by the Standard because the food they sell is not ready-to-eat or served for immediate consumption.

For example, the food delivered by these businesses usually needs storage/refrigeration, assembly, cooking and/or reheating before being eaten and is often eaten a few days after delivery.

A manufacturer with a retail shop front or food service section

Businesses with dual activities, such as a manufacturer with a retail, food service or catering section, must implement the Food Safety Management Tools in any areas of the business where retail, food service or catering activities take place.

An organisation that provides food for free (e.g. school breakfast program, soup kitchen, meals to the homeless)

No, where food is provided free of charge these activities are not captured under the Food Act 2001 therefore not required to comply with the Food Standards Code, however safe food handling practices are always encouraged where food is prepared for others. See the fact sheet for childcare and educational settings (PDF 229KB) or the fact sheet for charities and not-for-profits (PDF 376KB) for more information.

School canteens and OSHC facilities

Yes, school canteens and OSHC facilities who are selling potentially hazardous foods or providing potentially hazardous food as part of a service are captured by the Standard. See the fact sheet (PDF 229KB) for more information.

A retailer selling packaged high-risk foods

No, the Standard only applies to businesses who handle unpackaged potentially hazardous foods for sale or service to the consumer.

A sporting club that operates a kitchen/canteen/BBQ on training and/or game days

Yes, where the food handling activities are category one or two activities the Standard applies. 

See the fact sheet for charities and not-for-profits (PDF 376KB) for more information on how the Standard can be applied in not-for-profit sporting clubs.

A charitable, community or not for profit organisation

If an organisation makes or handles unpackaged potentially hazardous foods and sells or serves them to a consumer (i.e. they are undertaking category one or category two activities) they must comply with the Standard, even if the food handlers are volunteers. 

See the fact sheet for charities and not-for-profits (PDF 376KB) for more information on how the Standard can be applied in charitable, community and not-for-profit organisations.

The only exemption in the Standard is for food handling activities for or at a fundraising event.

The Standard does not apply to food handling activities for or at a fund raising event. A fund raising event is defined as ‘an event that raises funds solely for a community or charitable cause and not for personal financial gain’ and is generally a once-off or infrequent event that occurs outside of regular operations. Events that would be considered fundraisers include a once off fair or fete, an occasional fundraising BBQ or catered event, or a movie night with fairy floss and popcorn. The intent is that the activity is not a regular occurrence. See the Food Safety Management Tools for not-for-profit organisations fact sheet (PDF 229KB) for more information on the exemption to the Standard.

Contact your local council Environmental Health Officer or visit Safe Food Australia 3.2.2A Food Safety Management Tools (PDF 1145KB) for more information.

Food handler training FAQs

The Standard states that food safety training courses must teach the following topics:

  • Safe food handling including temperature control measures for potentially hazardous food and the temperature danger zone.
  • Food contamination including ways to keep food from becoming contaminated and food allergen management.
  • Cleaning and sanitising food contact surfaces and equipment including correct procedures, using food-grade chemicals, and sanitising using heat.
  • Personal hygiene including obligations for sick employees, handwashing, uniforms and grooming of hair, nails, and skin.

All food handlers, including volunteers, who handle unpackaged potentially hazardous foods must complete a food safety training course, or be able to show appropriate food safety skills and knowledge. If food handlers can show the business and authorised officers that they understand and apply safe food handling practices, a training course may not be required.

If a person is new to the food industry, or to the types of food handling taking place at the business, they should complete a food safety training course to make sure they have appropriate skills and knowledge before handling high-risk foods.

Staff in the business who don’t handle unpackaged potentially hazardous foods, such as people working at the checkout or loading dock at a supermarket, or bar staff who only serve drinks, are not required to complete a food safety training course. However, under the existing requirements of Standard 3.2.2, staff must still have food safety skills and knowledge in line with the work they do, so completion of a food safety training course is recommended.

A food handler is a person who directly engages in the handling of food, or who handles surfaces likely to come into contact with food, for a food business. Therefore, anyone who is working or volunteering in a food business, even at ad hoc times, is considered a food handler. Businesses need to ensure all food handlers have adequate skills and knowledge in food safety and hygiene in line with the work that they do.

SA Health endorses the free, online food safety training platform DoFoodSafely that covers the required course content and is available in multiple languages. Once DoFoodSafely is completed, food handlers will receive a certificate that they can show to business owners and authorised officers.

Food safety training courses can also be accessed through other online platforms, some local councils, vocational training providers. Training can also be developed and delivered by the food business, or training from another food business where an employee worked previously may be acceptable. Training can be delivered in-house, externally, online and/or in person.

There is no set timeframe for food safety training refreshers, but businesses need to make sure their food handlers have up to date food safety skills and knowledge.

It is recommended that businesses schedule regular food safety training refreshers for their staff and/or update staff when processes, foods, equipment or chemicals change.

Most businesses are not required to keep a record of staff training, however it is recommended that businesses keep staff training records to easily demonstrate to authorised officers they have met the requirements of the food handler training.

If your business already has a food safety program under Standard 3.3.1, then nothing will change and you will need to continue to keep staff training records.

Food safety supervision FAQs

To be eligible to be a Food Safety Supervisor (FSS), food handlers must have completed at least one of the following skill sets within the last five years:

These units can be delivered as stand-alone short courses or within longer Vocational Education & Training (VET) courses.

Food Safety Supervisor certification can only be gained from a Registered Training Organisation (RTO).

Some VET courses contain the FSS skill sets/units meaning if a food handler has completed a VET course in the food, hospitality, retail or community and health care sector they may have already completed the FSS units.

If someone has completed a VET course and are unsure whether they have completed the FSS units, they can check their study transcript or with their training provider.

Current courses containing the two Food Safety Supervision Skill Set units include:

Current courses containing the Handle food safely in a retail environment unit include:

The current course containing the three units for the Food safety supervision skill set - for community services and health industries is:

The SA Health website contains a list of Registered Training Organisations (RTOs) who offer FSS certification either online or face to face in SA.

A complete list of RTOs that offer the FSS skill sets/units across Australia is available on the training.gov.au website by searching the course unit names or codes.

Yes.

Yes, the Standard requires the food handler to have gained certification as Food Safety Supervisor through a Registered Training Organisation within the last five years.

Yes. Under the Standard FSS certification must be completed at least every five years. Some RTOs may offer re-certification, otherwise the person will need to complete FSS certification course again.

Course unit names and requirements can be updated from time to time. If superseded units were completed within the last 5 years, they will still be recognised, and the person can be a FSS.

If the superseded units were completed more than 5 years ago, the new units, or re-certification under the new units, will need to be completed.

Yes, an academic transcript will suffice as evidence of having completed the required units of competency.

Under clause 11 of Standard 3.2.2A the 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.

While a sole operator would not need to supervise any other food handlers, if they are undertaking prescribed activities they still need to appoint a Food Safety Supervisor. This aims to make sure the business or sole operator has the skills and knowledge to handle food safely.

If a Food Safety Supervisor is absent for 30 days or less then you don’t need to appoint a replacement Food Safety Supervisor but you should ensure that appropriate processes & procedures are in place e.g. having a written guide for staff to use.

Where a Food Safety Supervisor is absent for more than 30 days a replacement food safety supervisor needs to be appointed.

The FSS only needs to be reasonably available when the handling of unpackaged potentially hazardous foods (prescribed activities) is taking place. This means being onsite for majority of the time to oversee the prescribed activities, and when not onsite being otherwise contactable and having procedures in place.

FSS’s need to be reasonably available (mostly onsite) when prescribed activities are taking place, and at other times must be contactable via phone or email.

Managing prescribed provisions FAQs

The prescribed provisions are key food safety requirements that businesses must control to make sure the food they sell is safe. For potentially hazardous foods, category one businesses must show that they:

A business can demonstrate they are meeting the prescribed provisions a number of ways including:

  • writing on templates
  • recording electronically
  • writing invoices
  • keeping photos or videos
  • having written instruction sheets or procedures
  • walking and talking through the process with the food regulator.

If your business already has a food safety program under Standard 3.3.1, then nothing will change as you will already be keeping records to demonstrate compliance and must continue to do so.

Record keeping templates are available from various sources including Food Standards Australia New Zealand template examples (DOCX 93KB) and in the records section of the SA Health Food Safety Program Template: Food Service to Vulnerable Persons (DOCX 767KB). Templates may also be available from your local council Environmental Health Department. Businesses can develop their own or adapt and amend existing templates to suit their needs.

No, businesses who are required to implement a food safety program under Standard 3.3.1 must continue to keep their records as they usually do.