Do You Need to Retrain Staff to Comply With Standard 3.2.2A?

September 11, 2023 Read Time icon 4 min read

The food industry is a fast-paced sector where one small mistake can have significant consequences—and this makes food safety practices crucial. One of the guidelines shaping the industry in Australia is Food Safety Standard 3.2.2A. This standard introduces specific requirements that businesses must follow, especially new ones regarding staff training. 

Standard 3.2.2A has been in place since December 2022, and its enforcement is overseen by the local government. The penalties for not complying with the Food Standards Code vary depending on the severity of the violation, as well as the state or territory the business is operating in. These penalties can include fines, suspension or cancellation of a food business licence. This is why it is vital to ensure your business is 3.2.2A-compliant as soon as possible.

Food businesses need to ensure staff are always trained and their certificates are current, since food safety incidents resulting from non-compliance can result in damage to your business’s brand and reputation, a loss of customers, and the potential for legal action by affected consumers. Local health authorities also ensure compliance with food safety training requirements during inspections.

Read more to learn what your business needs to do to comply with the new standard.

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It’s important to note that some states and territories already had mandatory food safety training requirements prior to the introduction of Standard 3.2.2A. The new standard doesn’t replace the previous state and territory requirements, but rather is additional to them. This means that food businesses must continue to comply with any existing state or territory legislation, as well as the requirements of Standard 3.2.2A.

Food Safety Standard 3.2.2A: What Is It?

Standard 3.2.2A builds on the existing food safety guidelines of Standard 3.2.2. It targets Australian businesses in the food service, catering, and retail industries that deal with unpackaged food that is both ready-to-eat and potentially hazardous. Depending on their specific food handling procedures, these businesses are mandated to use either two or three additional food safety management tools, beyond their current Chapter 3 responsibilities.

Food Handlers: Training Requirements

Food Handlers involved in high-risk activities must meet specific training requirements under Standard 3.2.2A. This standard dictates that any Food Handler engaged in a particular activity must either:

  • Have completed a food safety training course, or
  • Possess the relevant skills and knowledge in food safety and hygiene specific to that activity.

These rules apply to both category one and category two businesses. For more information on category one and category two businesses, read our article that expands on the distinctions and requirements.


As for what constitutes a food safety training course, the standard specifies that it must cover four key areas:

It's essential that all Food Handlers complete a course that includes these topics before engaging in activities involving high-risk foods.

It’s key to note that many traditional Food Handler courses have not covered all of the above topics as they weren’t mandated under nationally training requirements. For example, allergen management was previously only required knowledge for Food Safety Supervisors. This means that many Food Handlers in Australia need to undergo further training. The Food Handler course provided by the Australian Institute of Food Safety complies with both nationally recognised standards as well as Standard 3.2.2A.

If an authorised officer finds that a Food Handler's skills and knowledge are lacking, further training could be mandated. Even if business owners or managers do not directly handle food, it's advisable for them to undergo food safety training. This contributes to cultivating a strong food safety culture within the establishment and helps in understanding and mitigating risks to the business.


Food Safety Supervisors: A Must-Have for Every Business

Another critical aspect of the new standard is the requirement for businesses to appoint at least one Food Safety Supervisor. This was already a requirement in some states and territories; however, Standard 3.2.2A has some additional requirements.

To remain compliant with updated food safety standards, Food Safety Supervisors (FSS) are now required to have completed a valid Food Safety Supervisor course within the last five years. This requirement ensures that FSSs have the most up-to-date knowledge and skills in food safety and hygiene, which is crucial for supervising Food Handlers, particularly those involved in high-risk activities.

A Food Safety Supervisor is responsible for:

  • Monitoring Compliance: They need to monitor and verify that all food safety practices are followed correctly.
  • Ensuring Food Handlers Follow Record-Keeping Protocols: Keeping records of all food safety activities, including staff training, is a must.
  • Being Accessible: The Food Safety Supervisor must be readily available to address food safety issues and concerns, either in person or through digital communication.

Food Safety Supervisor training is industry specific (retail, hospitality, health and community and food processing industries are recognised), and some states and territories such as New South Wales have special requirements for this training outside of the Standard 3.2.2A requirements. 

The Australian Institute of Food Safety offers Food Safety Supervisor training for all industries and is accepted across all Australian states and territories.


Why is Compliance Crucial?

Starting in 2023, local government agencies will be responsible for enforcing the new standard. Penalties for failing to comply with the Food Standards Code can differ, taking into account factors like:

  • Seriousness of the violation
  • Regulations specific to the state or territory where the business operates

Potential consequences can range from:

  • Fines
  • Suspension of your food business licence
  • Complete revocation of your food business licence

Non-compliance can have additional impacts on your business, such as:

  • Harm to your brand and reputation
  • Loss of customer loyalty
  • Risk of facing legal action from consumers who are affected

Train Staff Right Away

Food safety is everyone's business—from the newest hire to the owner. With the updated Food Safety Standard 3.2.2A already in place, businesses have a responsibility to act now by assessing staff training and ensuring that they have the documentation to show every food handling employee is qualified. Schedule a free consultation with a Compliance Officer to understand what your business needs and how to get started. 

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