Navigating Australia's Food Safety Standard 3.2.2A: A Guide for Businesses

Let's address these questions to help you better understand your obligations.

Who is Subject to Standard 3.2.2A?

The standard is applicable to Australian food businesses classified as either 'category one' or 'category two,' regardless of their size, location, or type of operation—whether permanent, temporary, fixed, or mobile. 

Essentially, these businesses manage unpackaged, ready-to-eat, and potentially hazardous food just before it reaches the consumer. The activities involved in this handling are inherently risky in terms of food safety and have been associated with outbreaks of foodborne illnesses both in Australia and internationally. 

Some examples of businesses affected by Standard 3.2.2A are:

• Restaurants, cafes, and bars
• Hotels or casinos with food services and buffet restaurants
• Supermarkets and grocery stores
• Mobile food units and takeaway facilities
• Hospitals, aged care, and childcare facilities
• Petrol stations
• Prisons

It’s important to note that if your business is only involved in manufacturing or wholesale of food, or is charity-based, you're generally exempt.

Understanding Business Categories

Standard 3.2.2A categorises food businesses into two primary groups:

Category One Businesses:
These businesses engage directly in food service and handle unpackaged, potentially hazardous foods to prepare ready-to-eat foods. Due to their extensive high-risk food handling, category one businesses are subject to more strict regulations. Category one businesses may need to implement all three tools: training Food Handlers, appointing at least one Food Safety Supervisor to oversee those Food Handlers, and ensuring proper records are created and kept on hand for at least three months. 

Category Two Businesses:
These establishments offer ready-to-eat, potentially hazardous foods, but usually have limited food processing activities, like slicing or repacking. They fall under a different set of rules than category one. Category two establishments must also have trained Food Handlers and a Food Safety Supervisor, but the rules on record-keeping that apply to them are only those set out by their particular state or territory.

Prior to the introduction of Standard 3.2.2A, most states and territories already had categories for food businesses, as well as compliance requirements dependent on that category. In most cases this hasn’t changed – so if you own or manage a food business, it’s important to know the category at both a state and federal level, and the compliance requirements for each.

Immediate Steps for Compliance

Training Food Handlers:
All staff involved in food handling activities must undergo training in food safety. Check if their existing certifications are current and if they have sufficient knowledge on essential topics in safe handling of food, including:

• Safe food handling
• Food contamination
• Cleaning and sanitising of food premises and equipment
• Personal hygiene

The requirements for Food Handler training under Standard 3.2.2A are much stricter and more comprehensive than ever before. For this reason, Food Handler training completed previously may not be sufficient. For example, traditional Food Handler training under the nationally recognised training framework did not include training on allergen handling; however, this is now a necessity under the new standard. The Australian Institute of Food Safety has updated all Food Handler training to meet the requirements of both nationally recognised training legislation and Standard 3.2.2A.

Appointing a Food Safety Supervisor:
Both category one and category two businesses need to designate at least one qualified Food Safety Supervisor. An FSS (Food Safety Supervisor) is required to have official certification within the last five years to ensure that their relevant skills and knowledge, especially when dealing with high-risk food, is up to date. Food Safety Supervisors should be proficient in identifying, preventing, and fixing food safety issues. They also need to make sure Food Handlers are keeping records. 

* Victoria has extended the deadline to December 2028 for existing Food Safety Supervisors to renew their certification.

Food Safety Supervisor training is a brand-new requirement in some states and territories including Western Australia, the Northern Territory, South Australia and Tasmania.

It’s also industry-specific (the industries covered are hospitality, retail, health and community, and food processing) so it’s essential to ensure that supervisors are enrolled into the correct course.

Furthermore, certain states have additional requirements for Food Safety Supervisors –  such as in New South Wales. The New South Wales Food Authority requires Food Safety Supervisors to have additional skills and knowledge in egg safety, allergen management and more. The Australian Institute of Food Safety is fully compliant with NSW requirements and issues certificates on behalf of the NSW Food Authority.

A key point to remember is that prior to the introduction of Standard 3.2.2A, Food Safety Supervisor certificates did not expire in most states and territories – now these certificates must be renewed every five years.

Record-Keeping:
Some states or territories in Australia already require food businesses to keep records. With Food Safety Standard 3.2.2A, those state or territory regulations still apply, but category one businesses under 3.2.2A must also keep meticulous records of prescribed food handling activities, such as temperature monitoring and sanitisation schedules. Read about what constitutes a record in this article.