Introducing Standard 3.2.2A: Food safety management tools

Affected businesses in Australia need to meet a new food safety standard in the Australia New Zealand Food Standards Code (the Code) from 8 December 2023.

Standard 3.2.2A (the Standard) is a new food safety standard for food service and retail businesses that aims to improve food safety and support consumer confidence.

There are three food safety management tools in the Standard:

Tool 1: food handler training

Tool 2: food safety supervisor (FSS)

Tool 3: substantiation of critical food safety controls.

For information on the new standard, an introduction video is available.

To read Standard 3.2.2A directly, go to page 208 of the Safe Food Australia 4th edition.

Affected businesses

The Standard applies to food business who are defined as a category one or category two business in the Code. Victorian food businesses are not classified into categories but classes (classes 1,2,3A, 3, and 4); the guidance that follows on Standard 3.2.2A interprets the Standard for Victorian food businesses.

For more about which class 2 businesses are required to have an FSP go to Frequently asked questions about the food classification and regulatory changes.

You can download a copy of Introduction of new Standard 3.2.2A: Frequently asked questions in the More Information section below.

Tool 1: Food handler training

The Standard requires that food handlers who handle high-risk foods complete a food safety training course in, or be able to show they understand, safe handling of food, food contamination, cleaning and sanitising equipment, and personal hygiene.

Food handlers can show food regulators and businesses that they have food safety skills and knowledge in the same way they already show they’re meeting the existing skills and knowledge requirements, and/or by showing a certificate of completion from a food safety training course.

Note: under Standard 3.2.2 all food handlers, regardless of their food handling activities, need to have food safety skills and knowledge in line with the work that they do.

Food business must make sure their food handlers have adequate skills and knowledge before they start working with high-risk foods.

The Standard states that food safety training courses or a business’ in-house training must teach the following food safety 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 demonstrate to the food 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 the Standard 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.

Who is considered a food handler?

A food handler is a person who directly engages in the handling of food, or who handles surfaces likely to be into contact with food (such as crockery, utensils, cooking equipment and surfaces) 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.

Where can staff access, or how can businesses provide food safety training courses?

DoFoodSafely is a free, online food handler training platform provided by the Department of Health Victoria and supported by Queensland, South Australia, Tasmania, Northern Territory and ACT Health Departments. It covers the Standard’s required course content and is available in eight community languages. Once the DoFoodSafely assessment test is successfully completed (with a score of 90 per cent or higher), food handlers 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, and 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.

How often is food safety training required?

There is no set timeframe for food handler training refreshers; businesses must make sure that their food handlers have up-to-date food safety skills and knowledge.

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

Do businesses need to keep a record of staff training?

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.

Tool 2: Food safety supervisors

The supervision of food handlers requires businesses to appoint a qualified FSS who is available to oversee the day-to-day food handling operations, help food handlers to handle food safely, and make sure food safety risks are managed.

The Standard requires that a business’ FSS must have achieved certification within the previous five years.

In Victoria, an exemption will apply for FSSs who received their certification prior to 8 December 2023 and will give them five years from 8 December 2023 to re-certify; that is, they must re-certify by 8 December 2028. For anyone first certifying as an FSS from 8 December 2023 onwards, their qualification is valid for five years.

For more information on the requirements for certifying as a food safety supervisor go to our food safety supervisor page. For a complete list of registered training organisations (RTOs) that offer the FSS skill sets/units nationally, search the course unit names or codes on the Training.gov.au website.

Tool 3: Substantiation of critical food safety controls

Class 1 and class 2 food businesses with a standard or non-standard food safety program (FSP) are exempted from the Standard in relation to Tool 3: Substantiation of critical food safety controls. This is because the controls required under the Standard are covered by their FSP.

For class 2 businesses without an FSP, you will need to be able to substantiate your critical food safety controls to your local council authorised officer.

Class 3A have been exempted from Tool 3.

What is meant by ‘substantiation’?

Substantiation of key food safety controls means businesses must show they are meeting the ‘prescribed provisions’, which are the existing food safety standards in the Code for temperature control, food processing, and cleaning and sanitising.

Food businesses must show that they are meeting the prescribed provisions by keeping a record or by demonstrating compliance to their food safety regulator, in the same way they already show regulators they’re meeting these existing food safety standards.

What does this mean for my business?

Class 2 food businesses that are not required to have an FSP can show how they manage key food safety controls by keeping written or electronic records, making a note on invoices, taking photos, having written, standard operating procedures, and/or demonstrating their compliance by walking and talking through their critical food safety control processes with their food safety regulator. For some businesses it may be a mix of all of these; for others a demonstration to a council officer of how the business ensures the proscribed provisions are handled, or with the provision of the business’ written procedures that staff follow.

Class 1 and class 2 food business with an FSP are exempt from Tool 3 as they already keep records to demonstrate compliance with the proscribed provisions and must continue to do so. They are also exempt from Tool 2 for five years if their FSS is certified prior to 8 December 2023 but are required implement Tool 1: Food handler training.

Class 3 and class 4 food businesses are exempt from the Standard, although they must ensure that food handlers have the relevant skills for work that they do in a food business.

Substantiation resources

The Department has developed a guide for food businesses on substantiation called A recipe for food safety: A food safety management tool for food businesses, along with four supporting animations. The guidance document and animations have been designed to assist class 2 food service and food retailers who are exempt from having an FSP with the substantiation of their critical food safety controls. The four videos below outline three simple steps to substantiation.

More information

More information is available at FSANZ on substantiation of critical food safety controls.