Understanding Food Safety Standard 3.2.2A: What's Your Business Category?

Does your business serve or prepare food? Then you absolutely need to be aware of Food Safety Standard 3.2.2A. This important regulation ensures the food you offer is safe for consumption. 

As part of the overarching food safety guidelines for Australia and New Zealand, this standard classifies businesses as either a "category one" or "category two" establishment. 

Businesses are categorised differently based on the type of food handling activities they engage in. Knowing your category is essential for following the appropriate safety measures and complying with the standard.

What is a Prescribed Activity?

Before we dive into business categories, it's important to understand what "prescribed activities" mean in the context of Standard 3.2.2A. Prescribed activities involve the handling of unpackaged, potentially hazardous food by a food business, either for preparing ready-to-eat meals or for retail sale in a ready-to-eat state.

Take, for example, a restaurant that prepares meals with unpackaged, potentially hazardous ingredients like raw meat and vegetables. These operations fall under prescribed activities because they involve making and serving meals that are ready to eat. Such activities carry high risk because the unpackaged foods are vulnerable to contamination right before consumption. Food Handlers often come into direct contact with these items, and there are no subsequent steps to kill any pathogens that might be present.

Managing these risks is crucial and involves maintaining the food at safe temperatures at all stages—receiving, storing, processing, transporting, and displaying. It also means taking steps to minimise the risk of contamination from poor hygiene or faulty equipment.

On the other hand, activities that don't involve unpackaged, potentially hazardous food are considered non-prescribed. For instance, a bistro that prepares meals but also sells alcohol and pre-packaged snacks like nuts and chips doesn't count the handling of these items as prescribed activities.

Businesses engaged in prescribed activities are classified as either category one or category two, depending on the specific nature of their operations.

What is a Category One Business?

A category one business refers to catering or food service operations that handle unpackaged, potentially hazardous food to make it ready for immediate consumption. 

Following preparation, these dishes are served directly to consumers. Due to the direct handling of high-risk food, there is a risk of contamination by harmful microorganisms or other hazardous elements before the food reaches the consumer.

Examples of Category One Businesses 

• A dine-in restaurant that makes and serves salads and cooked meats on-site.
• A bakery that produces and sells items like custard tarts and quiches for on-site and off-site consumption.
• A takeaway shop that cooks and offers hot chicken, salads, and other fast foods for off-site eating.
• A caterer that prepares sandwich platters in a central kitchen for delivery to offices and events.
• A training centre that includes buffet meals in their training fees, cooking and serving them to participants on-site.
• Hospitals, childcare centres, and aged care facilities that prepare and serve meals to their residents or guests.

Category one businesses need to have three key food safety tools in place: an appointed Food Safety Supervisor, mandatory training for Food Handlers, and detailed records must be made and kept on hand for at least three months. The purpose of records is to show that the food handled by your business is safe. To find out more about record-keeping under Standard 3.2.2A, consult our article on the subject. 

What is a Category Two Business?

In the context of this Standard, a category two business refers to a food establishment that retails food which is both potentially hazardous and ready-to-eat. This food either arrives at the business unpackaged or is unpacked by the business after receiving it. Moreover, the business does not create or process this food, except for activities such as slicing, weighing, repacking, reheating, or hot-holding.

Examples of Category Two Food Businesses

• A supermarket deli that unpackages bulk-bought salads, displays them chilled, and portions them for customers. The salads are ready-to-eat and potentially hazardous but not prepared on-site.
• A service station that heats and serves unpackaged pies and pastries from a local bakery. If these items were sold in their original packaging, the station would be exempt from certain standards.

As with category one businesses, those under category two need properly trained Food Handlers and at least one appointed and readily available Food Safety Supervisor. The difference is that category two businesses do not need to maintain specific records to comply with this new standard. They may, however, need to keep records under their state or territory law. 

Both Categories Require Food Handler Training

Businesses in both category one and category two must make sure that every Food Handler involved in handling unpackaged, potentially hazardous, ready-to-eat food has required skills and knowledge related to:

• Safe food handling practices
• Avoid food contamination
• Cleaning and sanitising the premises and equipment
• Personal hygiene best practices

Standard 3.2.2A breaks down these requirements into more detail. The key thing to note is that traditional Food Handler training did not cover all the required topics – for example, allergen management training. For this reason, most Food Handlers need to attain additional skills and knowledge to comply with the new standard. Food Handler training offered by the Australian Institute of Food Safety meets nationally recognised training standards and is also compliant with all aspects of Standard 3.2.2A. 

Food Safety Supervisor Training is Also Required

Food Safety Supervisor training is a new requirement in Western Australia, South Australia, Tasmania and the Northern Territory. Food businesses in these regions must ensure that Food Safety Supervisors have completed nationally recognised training for their specific industry delivered by a Registered Training Organisation.

Other states and territories have new requirements too. Previously in most states and territories there was no expiry date for Food Safety Supervisor training. Under Standard 3.2.2A, Food Safety Supervisors must be trained every five years, which means that many existing Food Safety Supervisors must renew their training.

Furthermore, the new standard exists alongside existing state and territory legislation and does not replace it. So if the state or territory where you work has special requirements for Food Safety Supervisor training, you must adhere to these too. A good example of this is New South Wales where there are additional training requirements, and the training must be delivered by a designated Registered Training Organisation such as the Australian Institute of Food Safety.

What About My Category in my State or Territory?

You may already be familiar with your category under your existing state or territory legislation. As mentioned above, Standard 3.2.2A exists alongside existing legislation but does not replace it. So it is likely that you will have two separate categories you need to know and understand. For example, you may be category one under Standard 3.2.2A and need to follow rules for category one businesses under that legislation. But you may be category three under state legislation and need to follow the rules for that category under state legislation.

It’s hoped that in the future, state, territory and federal categories will be aligned and streamlined, but there are currently no announcements about this at a state or federal level.

If you’re not sure whether your business falls under category one or two under Standard 3.2.2A, the Australian Institute of Food Safety can help. Book a free consultation with one of our Compliance Advisors to learn more.