Decoding Record-Keeping in Food Safety Standard 3.2.2A

Keeping track of records is more than just paperwork; it's vital in keeping food safe. In Australia, the new Food Safety Standard 3.2.2A ensures this by requiring detailed records. We'll cover what this standard means, what counts as a record, who needs to keep them, and for how long.

Importantly, Standard 3.2.2A is to be applied alongside existing state or territory legislation, and does not replace it. Therefore if you’re already maintaining records under your local legislation you shouldn’t stop. And the length of time to maintain records should be whichever is longer between Standard 3.2.2A and your local legislation.

What Activities Should Be Recorded?

In Standard 3.2.2A, "prescribed activities" are the handling and management of unpackaged, potentially hazardous foods. These activities involve either the preparation of such foods for meals that are immediately ready for consumption, or their retail sale in a state that's ready to eat. For food businesses that must keep records under the new standard, the records are made to document any prescribed activities. 

Documentation that validates various concerns—for example, to confirm that potentially hazardous food is maintained at safe temperatures—should be generated daily when the business is involved in prescribed activities. Each entry should specify the date, and if relevant, the time it was recorded, along with a description of the food or activity.

For example, if the “matter” to be substantiated is ensuring that potentially hazardous foods are received at temperatures either below or equal to 5°C, or above or equal to 60°C, the business must provide evidence demonstrating that the food arrived at these specific temperatures. So, the record should include details such as the type of food received, the time it was received, and its temperature upon arrival.

What Qualifies as a Record Under Standard 3.2.2A?

Under the new Food Safety Standard 3.2.2A, a record is defined as any documented information that can provide evidence of compliance with the Food Safety Program. Records can range from written logs to digital files, and according to Standard 3.2.2A they must include but are not limited to:

• Temperature monitoring logs for storage units and cooking equipment
• Cleaning and sanitation schedules
• Records of raw materials, including supplier details
• Employee training documentation
• Customer complaints and incident reports
• Notes on invoices (e.g. a receipt temperature)
• Photos or video footage
• Written instructions that have been verified to archive food safety outcomes

One record can cover multiple prescribed activities, for example, documenting the temperature of a cool room that stores various types of potentially hazardous food. The key aspect is that these records must be accurate, easily accessible, and interpretable. They should be available for internal reviews and external audits to ascertain the effectiveness of the Food Safety Program.

Who Must Keep Records: Category One or Category Two Businesses?

Under Standard 3.2.2A, record-keeping requirements are aimed explicitly at category one businesses. These are businesses involved in high-risk food handling activities, including producing, preparing, and selling perishable items like meat, dairy, and seafood for their immediate consumption as ready-to-eat food. The standard is stringent about these businesses maintaining thorough records to demonstrate their adherence to food safety guidelines.

Category two businesses, considered lower risk—such as those dealing with pre-packaged goods or minimally handling high-risk foods—are not explicitly required by Standard 3.2.2A to maintain food safety records. However, these businesses are still recommended to keep basic records for internal management and any state or territory requirements.

Unsure of which category your business is under Standard 3.2.2A. Click here to learn more.

How Long Do Records Need to Be Retained?

According to Standard 3.2.2A, category one businesses are required to keep food safety records for a minimum of three months to help in investigations of foodborne illness outbreaks. While this is the standard requirement, it could be useful to retain these records for an extended period to track trends or spot emerging issues. Additionally, some states and territories mandate a longer record-keeping duration than what the standard specifies.

For businesses required to keep records, the three-month period starts from the date of the last entry in the record. Businesses that handle high-risk foods may also be subjected to longer retention periods based on local regulations or specific industry guidelines. You’re likely already meeting the state and territory requirements where you operate, but be sure to check your local jurisdiction’s requirements to understand exactly what applies to you. 

It's essential to observe these timelines diligently. Not keeping records for the required time can lead to fines and other penalties.

Why is Record-Keeping Crucial?

Having well-maintained records can serve several essential functions:

• Compliance: Records prove your business's compliance with food safety standards, which is vital during audits or inspections.
• Accountability: They help identify food safety issues such as improper preparation and storage, enabling quick corrective action to be performed.
• Transparency: Records ensure a transparent system is in place, which builds trust with customers and stakeholders.
• Risk Mitigation: In the event of a food safety incident, records can be vital evidence to determine the source and extent of the issue.

Make Record-Keeping Simple

Record-keeping is a non-negotiable aspect of food safety management, especially for category one businesses under Food Safety Standard 3.2.2A. These businesses must maintain extensive records ranging from temperature logs to sanitation schedules. Don’t forget: these records must be kept for at least three months to comply with the standard.

To assist businesses with meeting record-keeping requirements, a set of templates is provided by the Australian Institute of Food Safety with each enrolment into nationally recognised Food Safety Supervisor or Food Handler training.

To get further assistance in understanding record-keeping requirements under Standard 3.2.2A, the Australian Institute of Food Safety has a team of Compliance Officers ready to assist. Get a free consultation now.