References

·         Ahl AS and Buntain B 1997, ‘Risk and the food safety chain: animal health, public health and the environment’, Review of Science Technology, 16(1): 322–30.

·         Altekruse SF, Stern NJ, Fields PI and Swerdlow DL 1999 ‘Campylobacter jejuni—an emerging foodborne pathogen’,Emerging Infectious Disease, 5(1): 28–35.

·         Altekruse SF and Swerdlow DL 1996, ‘The changing epidemiology of foodborne diseases’,American Journal of Medical Sciences, 311(1): 23–9.

·         Archer DL and Kvenberg JE 1985, ‘Incidence and cost of foodborne diarrheal disease in the United States’, Journal of Food Protection, 48(10): 887–94.

·         Auckland Healthcare 1998, ‘Food safety advice’,Food Safety Quarterly Report, Dec 1998.

·         Australian Bureau of Statistics 1998, Year Book Australia, Australian Bureau of Statistics, Canberra, 1998.

·         Australian Bureau of Statistics 1996, Food Safety: Tasmania, Australian Bureau of Statistics, Oct 1996; 4344.6.

·         Baird-Parker AC 1990, ‘Foodborne salmonellosis’,Lancet, 336: 1231–35.

·         Bean NH, Goulding JS, Lao C and Angulo FJ 1996, ‘Surveillance for foodborne disease outbreaks United States 1988–92’, Morbidity and Mortality Weekly Report-CDC-Surveillance Summary, 45(5): 1–66.

·         Beuchat LR 1995, ‘Pathogenic microorganisms associated with fresh produce’,Journal of Food Protection, 59: 204–16.

·         BIS Shrapnel 1997, Australian Food Service Market, 5th edition.

·         Bryan FL 1980, ‘Foodborne diseases in the United States associated with meat and poultry’,Journal of Food Protection, 43 (2): 140–50.

·         Bunning VK, Lindsay JA and Archer DL 1997, ‘Chronic health effects of microbial foodborne disease’, World Health Statistic Quarterly, 50(1–2): 51–6.

·         Buzby JC and Roberts T 1997, ‘Guillain-Barré Syndrome increases foodborne disease costs’, Food Safety, Sept 1997: 36–42.

·         Buzby JC, Roberts T, Jordan Lin CT and MacDonald JM 1996, ‘An Economic Research Service Report—Bacterial foodborne disease’,Agricultural Economic Report, Aug 1996: 741.

·         Cartwright RY and Chahed M 1997, ‘Foodborne diseases in travellers’,World Health Statistics Quarterly, 50(1–2): 102–10.

·         Centers for Disease Control and Prevention 1997, ‘Outbreaks ofEscherichia coli0157:H7 infection and cryptosporidiosis associated with drinking unpasteurized apple juice—Connecticut and New York’, October 1996, Morbidity and Mortality Weekly Report, 46: 4-8.

·         Chivell WC 1995, ‘Finding of inquest: inquest into death of Nikki Dearne Robinson’,State Coroner’s Report, Adelaide, South Australia.

·         Clive r DO 1997, ‘Virus transmissio n via food’, World Health Statistics Quarterly, 50(1–2): 90–101.

·         Collins JE 1997, ‘Impact of changing consumer lifestyles on the emergence/reemergence of foodborne pathogens’, Emerging Infectious Diseases, 3(4): 471–9.

·         Corlett DA 1991, ‘A practical approach to HACCP’,Food Safety Management Seminar. ESCAgenetics Corp., 830 Bransten Rd., San Carlos cited by EJ. Rhodehamel ‘Overview of Biological, Chemical and Physical Hazards’ inHACCP Principles and ApplicationsPierson, MD. and Corlett, D.A. Eds AVI 1992

·         Council for Agricultural Science and Technology 1994, ‘Foodborne Pathogens: Risks and Consequences’, CAST, USA.

·         Cowden JM, Wall PG, Evans H, Adak G, Le-Baigue S and Ross D 1995, ‘Outbreaks of foodborne infectious intestinal disease in England and Wales: 1992 and 1993’,Communicable Disease Report Review, 5(8) 109–17.

·         Crerar SK, Dalton CB, Longbottom HM and Kraa E 1996, ‘Foodborne disease: Current trend s and f utur e surveillance needs in Australia’,Medical Journal of Australia, 165(2): 672–75.

·         Department of Workplace Relations and Small Business 1998,Overcooked: A study of food compliance costs for small business, Department of Workplace Relations and Small Business Commonwealth of Australia.

·         del Rosario BA and Beuchat LR 1995, ‘Survival and growth of enterohaemorrhagicEscherichia coli0157:H7 in cantaloupe and watermelon’,Journal of Food Protection, 58: 105–7.

·         Desmarchelier P 1996, ‘Foodborne disease: Emerging problems and solutions’,Medical Journal of Australia, 165(2): 668–71.

·         Djuretic T, Wall PG, Ryan MJ, Evans HS, Adak GK and Cowden JM 1996, ‘General outbreaks of infectious disease in England and Wales 1992 to 1994’,Communicable Disease Report Review, 29: 6(4): 57–63.

·         Doyle MP 1991, ‘Escherichia coliO157: H7 and its significance in foods’, International Journal of Food Microbiology, 12: 289–302.

·         Fairley C, Sinclair M, Hellard M et al 1999, The Water Quality Study—Summary December 1998, http://www.med.monash.edu.au/epidemiology/crc/wqsweb.htm.

·         Food Regulation Review Committee 1998, Food: a growth industry—Report of the Food Regulation Review, Australia New Zealand Food Authority, Commonwealth of Australia.

·         Gerba CP, Rose JB and Haas CN 1996, ‘Sensitive populations: who is at the greatest risk?’International Journal of Food Microbiology, 30(1–2): 113–23.

·         Hawkless J 1999,Regulatory Impact Statement, Nationally Uniform Food Safety Standards, John Hawkless Consultants Pty Ltd Report to the Australia New Zealand Food Authority, January 1999.

·         Hennessey TW, Hedberg CW, Slutsker L et al 1996, ‘A National Outbreak ofSalmonellaenteritidisin Ice Cream’, New England Journal of Medicine, 334: 1281–86.

·         Henson S 1996, ‘Consumer willingness to pay for reductions in the risk of food poisoning in the United Kingdom’, Journal of Agricultural Economics, 47(3): 403–20.

·         Herwaldt BL, Ackers ML et al 1997, ‘An outbreak in 1996 of cyclosporiasis associated with imported raspberries’, New England Journal of Medicine, 336(22): 1548–56.

·         Heyhoe and Associates Pty Ltd 1999, Assessing strategies to implement the proposed food safety standards into small business, Repor t to the Australia New Z ealan d Food A uthori ty March 1999.

·         Kaferstein FK 1997, ‘Food safety: A commonly underestimated public health issue’,World Health Statistics Quarterly, 50(1–2): 3–4.

·         KPMG 1998a,Food regulation: current costs to state and local governments, KPMG Management Consulting Pty Ltd Report to the Australia New Zealand Food Authority, October 1998.

·         KPMG 1998b,Costs of implementing proposed food hygiene standards, KPMG Management Consulting Pty Ltd Report to the Australia New Zealand Food Authority October 1998.

·         Landefeld JS and Seskin EP 1982, ‘The economic value of life: Linking theory to practice’,American Journal of Public Health, 72: 555–56.

·         Lewis C 1998, ‘Critical controls for juice safety’,FDA Consumer, Sept—Oct 1998, 16–19.

·         Lindsay JA 1997, ‘Chronic sequelae of foodborne disease’,Emerging Infectious Diseases, 3(4): 443–52.

·         Mayers P and Couture H 1999 ‘Bacterial Foodborne Illness in Canada: The Problem’Canadian Food Inspection Agency Website,http//cfia-acia.agr.ca/english/toc.html.

·         Mayes T 1993, ‘The Application of Management Systems to Food Safety and Quality’,Trends in Food Science and Technology, July, 216.

·         McDowell RM and McElvaine MD 1997, ‘Long-term sequelae to foodborne disease’,Review of Science Technology, 16(2): 337–41.

·         McKay I 1998,Foodsafe—Food Handler Training Program: An Information Paper, Australia New Zealand Food Authority.

·         Meng J and Doyle MP 1997, ‘Emerging issues in microbiological food safety’,Annual Review of Nutrition, 17: 255–75.

·         Monto AS and Koopman JS 1980, ‘The Tecumseh Study: XI Occurrence of acute enteric illness in the community’, American Journal of Epidemiology, 112(3) 323–33.

·         Morton E (ed) 1998 ‘Lawyers feed on outbreaks’Food Protection Report14 (10) 1-2

·         Mulder RWAW 1996, ‘Impact of transport on the incidence of human pathogens in poultry’,World Poultry—Misset.,12(9): 18–19

·         Murray C, Davos D and Karna-Mare M 1995, Australian Salmonella Reference Centre 1995 Annual Report. Institute of Medical and Veterinary Science.

·         Nathan S 1997, ‘Clean and green or just too lean?’,Consuming Interest, 13–17.

·         National Centre for Disease Control 1999, ‘Australia’s notifiable diseases status, 1997’,Communicable Diseases Intelligence, Commonwealth Department of Health and Aged Care.

·         Office of Regulation Review 1995, Enforcing Australia’s food laws—A survey and discussion of the practices of Australia food regulation enforcement agencies, Office of Regulation Review.

·         Palmer S, Houston H, Lervy B, Ribeiro D and Thomas P 1996, ‘Problems in the diagnosis of foodborne infection in general practice’,Epidemiology and Infection, 117(3): 479–84.

·         Parish ME 1998, ‘Coliforms, Escherichia coliand Salmonellaserovars associated with a citrus- processing facility implicated in a salmonellosis outbreak’,Journal of Food Protection, 61(3): 280–4.

·         Pennington Group 1997, Report on the circumstances leading to the 1996 outbreak of infection withE. coli 0157in Central Scotland: The implications for food safety and the lessons to be learned, The Stationery Office, Edinburgh.

·         Reid TMS and Robinson HG 1987, ‘Frozen raspberries and hepatitis A’,Epidemiological Infection, 98: 109–12.

·         Robbins M and McSwane D 1994, ‘Sanitation doesn’t cost, it pays: Is it true and can we prove it?’, Journal of Environmental Health, 57(5): 14–20.

·         Ryan MJ 1997, ‘Outbreaks of infectious intestinal disease in residential institutions in England and Wales’, Journal of Infection, 34(1): 49–54.

·         Smith JL 1998, ‘Foodborne illness in the elderly’,Journal of Food Protection, 61(9): 1229–39.

·         Smith JL and Fratamico PM 1995, ‘Factors provided in the emergence and persistence of foodborne diseases’, Journal of Food Protection, 58: 696–708.

·         Sockett P 199 3, ‘S ocial and economic aspects of foodborne diseas e’,Food Polic y, April: 110–19.

·         Stöhr K and Hoppe B 1995, ‘Human to human transmission ofSalmonellaenteritidis’,Zbl. Hyg.197: 543–51.

·         Stolle A and Sperner B 1997, ‘Viral infections transmitted by food of animal origin: the present situation in the European Union’,Archives of Virology Supplementum, 13: 219–28.

·         Sumner J 1997,The hygiene status of Victorian meat 1993–97: A scientific appraisal, Australian Institute of Food Science and Technology.

·         Sumner JL 1995A Guide to Food Quality AssuranceM&S Food Consultants, Council of Barton College of Technical and Further Education and the Commonwealth of Australia.

·         Swinbank A 1993,The economics of food safety, Butterworth-Heinemann Ltd.

·         Tauxe RV 1997, ‘Emerging foodborne diseases: an evolving public health challenge’,Emerging Infectious Diseases, 3(4): 425–34.

·         Threlfall J 1998, ‘Update on SalmonellaDT104’, International Association of Milk, Food and Environmental Sanitarians, Annual Meeting, Nashville, USA.

·         Todd ECD 1985, ‘Economic loss from foodborne disease outbreaks associated with foodservice establishments’, Journal of Food Protection, 48(2): 169–80.

·         Todd ECD 1987, ‘Legal liability and its economic impact on the food industry’,Journal of Food Protection, 50(12): 1048–57.

·         Todd ECD 1989, ‘Preliminary estimates of costs of foodborne disease in Canada and costs to reduce salmonellosis’, Journal of Food Protection, 52(8): 586–94.

·         Troutt HF and Osburn BI 1997, ‘Meat from dairy cows: possible microbiological hazards and risks’, Review of Science Technology, 16(2): 405–14.

·         United States General Accounting Office 1996,Food safety—Information on foodborne illnesses, Resources, Community, and Economic Development Division.

·         United States Department of Health and Human Services 1998,FoodNet: 1997 surveillance results, Center for Disease Control and Prevention.

·         Vanderlinde PB, Shay B and Murray J 1998, ‘Microbiological quality of Australian beef carcass meat and frozen bulk packed beef’,Journal of Food Protection, 61(4): 437–43.

·         Venables L 1997,Formulating and Implementing Food Safety Programs in Small Business—The VDA Experience, Victorian Dairy Industry Authority.

·         Viscusi WK 1993, ‘The value of risks to life and health’,Journal of Economic Literature, 31: 1912–46.

·         Veitch MGK and Hogg GG 1997, ‘Must it have been something I ate?’,Australian and New Zealand Journal of Public Health, 21(1): 7–8.

·         Vought KJ and Tatini SR 1998, ‘Salmonella enteritidiscontamination of ice cream associated with a 1994 multistate outbreak’,Journal of Food Protection, 61(1): 5–10.

·         Wang GT, Zhao T and Doyle MP 1996, ‘Fate of enterohaemorrhagicEscherichia coli0157 on bovine faeces’,Applied and Environmental Microbiology, 62: 2567–70.

·         World Food Chemical News 1999, ‘HACCP has greatly reduced threat ofSalmonella— Un ited States Department of Agriculture announce s’, CRC Press February 1999 5 (21) 11–12.

·         World Health Organization 1997, ‘Foodborne diseases—Possibly 350 times more frequent than reported’, World Health Statistics Quarterly, Aug: 50.


Appendix 1: Assumptions used by John Hawkless to derive costs of proposed food safety standards to business

These words have been taken from Hawkless (1999).

Costs—quantitative: all businesses

This section addresses the quantitative costs of the proposed food safety standards. The uncertainty associated with costing accuracy is discussed. Where possible, dollar values of costs are given. The specific impact on small business is also separately discussed and, where possible, quantified.

General

In the sections below we have indicated indicative costs for compliance with the Standards based on certain assumptions, in terms of:

• notification,

• staff training,

• recall,

• development of food safety programs,

• auditing, and

• record keeping.

Business costs of notification

As mentioned, ANZFA asked us to separately identify the costs to business of notification. We have assumed that the simple act of notification of a new business or the change in scope of an existing business would take 0.5 person-days. This assumption is based on the inclusion of time to identify requirements from Environmental Health Officers, obtain the necessary forms, complete the forms and lodge them.

This is a worst case example of a person who has newly entered the industry without prior knowledge of notification requirements. For large businesses and small businesses with prior management possessing experience the costs may be less. If we assume an average adult wage of $105 per day, then the notification cost required by Standard 3.2.1 is assumed to be $50 per business.

The total cost to 131,510 food industry businesses to notify initially is thus $6,575,500.

It has been stated that the turnover in the café and restaurant businesses is very high and may approach 80 per cent per annum in some areas. If we assume a 20 per cent per annum turnover rate then the notification costs for those new businesses entering the industry will be $1,315,100 per annum.

As noted earlier, some costs imposed by the proposed Food Safety Standard are being borne now in the States and Territories that have notification/registration requirements for food businesses. Thus the above costs of Option 2 will be less when expressed as costsincrementalto Option 1. The extent of this reduction inincremental costs is now estimated.

The following table summarises the extent to which governments require registration of food businesses . From this summary an assessme nt of the current costs of n otificatio n is made.

Table 1.1 Current State registration requirements

State/Territory

Registration requirements

New South Wales

No general registration except some high risk industries such as oyster, dairy produce, meat processing

Victoria

Registration is compulsory

Queensland

Registration mandatory

South Australia

No general registration except for some high risk industries such as, dairy produce, meat processing

Western Australia

Registration is compulsory for restaurants and small good only

Tasmania

No general registration except for some high risk industries such as, dairy produce, meat processing

Northern Territory

Registration is compulsory for restaurants

Australian Capital Territory

Registration is compulsory

It will be seen from the above table that the situation varies widely at present from one State/Territory to the next and that exact quantification of the proportion of businesses subject to registration now cannot be exactly determined. For the purposes of this Impact Statement we have assumed that some 50 per cent of the costs imposed by the proposed Standards is already being borne by Australian food business. Thus we have taken 50 per cent of the costs above as theincrementalcosts that will be borne by food business from notification. That is, theincremental cost to 131,510 food industry businesses to notify initially is $3,287,750.

Costs of food safety training

This section of the Impact Statement attempts to assess the likely impact on business of training costs on food industry managers and supervisors. No data is available as to the extent to which competencies already exist and there are a range of possible training programs that could be used to raise competency levels in those who do not have existing knowledge of food hygiene. Also, the competency needs of managers may be greater than those of employees and thus a range of training programs may be needed for various responsibility levels. It should also be noted that, where an individual already possesses adequate industry experience, no training will be required.

Thus, certain assumptions have been made below simply to give the reader an indication of the order of magnitude of the costs likely to be incurred.These costs should not be taken as authoritative cost estimates.

We have taken the Heyhoe (1999) estimate of $150 per manager as an appropriate cost for hygiene training. The assumptions are made that 50 per cent of managerial staff in current and new businesses will already have adequate competency and that turnover of new businesses to the industry is 20 per cent per annum. Therefore, the total food hygiene training costs in 131,510 businesses will be $9,863,250 initially, together with ongoing costs to train new managers of $1,972,650 per annum in the 26,302 businesses that are new.

Costs of recall recording

We have assumed that ANZFA would provide, free of charge, guidelines outlining the expected recall procedures. In consultation with ANZFA, we have assumed that recall would only be required of the manufacturing/ processing segment of the food industry. It would not be feasible for retailers to maintain useful recall records.

We have also assumed that the act of recording sufficient information so as to permit effective recall when foodborne illness outbreak occurs would take 0.5 p erson-hours per day. T his assumption is based on the inclusion of the time to record the date of manufacture of goods including name, quantity, expiry date, batch number and customer name.

If we assume an average adult wage of $105 per day, then the food recall recording cost required by Standard 3.2.1 is assumed to be $7 per business per day. The total cost to 4,247 food industry businesses is thus $29,729 per day or $10,851,085 per year assuming 365 days per year trading.

Costs of developing and drafting written food safety plans

The costs of developing and writing a food safety plan will vary significantly depending on:

1 The extent to which a business already has a quality management system (QMS) and the extent to which food safety is integrated into that quality management system.

2 Obviously the costs of extending an existing QMS to the food safety area will be less when a QMS already exists than where a company must build its food safety QMS from a zero base.

3 The size of the business in terms of staff numbers.

A large business is more likely to have a QMS in place and thus the incremental costs of developing a food safety program will be less in proportion to many parameters including product volume, staff numbers and turnover.

4 Risk: The range and nature of the food(s) being prepared.

Some foods present a greater risk of foodborne illness than do others.

5 Risk: The nature of the business.

In general, food manufacturing and processing industries will present a greater risk than retail due to the larger number of persons potentially placed at risk by a single breakdown in food safety management.

Aimed at a specific product or process line a HACCP program can take six to eight meetings each of two to three hours. Development of the program is stated to involve significant operational involvement and is not just a paper exercise (Mayes 1993).

The Victorian Dairy Industry Authority has estimated that the costs of implementing a HACCP program and a food safety program for a small manufacturer will be initial set up costs of $5,000 to $6,000 plus $2,000 per annum for auditing and ongoing training (Venables 1997). Victorian meat companies have spent $10 million in workplace training, in constructing training centres, employing training officers and in contracts with local TAFE Colleges over the period 1994–97 (Sumner 1997).

It is acknowledged, however, that significant expenditure has already occurred in developing food safety programs in the Australian food industry. In economic terms this is a ‘sunk cost’ and not a cost that can be taken into consideration in assessing the impact of Standard 3.2.1 in the future.

In addition, it is stated elsewhere that most large industry members are introducing food safety programs not because they anticipate it is to be mandated by governments by adopting Standard 3.2.1 but because it is seen by them to be to their competitive advantage to follow industry norms.

Thus, for the purpose of Option 2, we may assume it is only small business that will bear the cost of food safety programs in Standard 3.2.1. We further assume small business will have available guidelines, introduced by the food industry or government, that they can use to develop food safety programs. Thus it will be necessary for small business managers to only assess their own business in light of the guidelines and draft a food safety program specific to their own enterprise.

As an example, theFoodSafeFood Handler Food Safety Training Program in Western Australia demonstrates that a simple food safety program can be developed by small business for only a small time and cost commitment.

We have assessed that workload of developing food safety programs as comprising two person-days for each small business, a cost of $210. If a program likeFoodSafe orFoodSafe+is purchased, at a cost of $60 or $120, then the labour cost to develop programs will be less but we have assumed the total cost of labour will be of the same order, that is, $210.

Based on the assumption that there are 125,805 small businesses in Australia and that none currently have such programs the costs of developing food safety programs will be $26,419,050.

If we further assume an annual turnover of small business of 20 per cent per annum, then new food safety programs each year will cost $5,283,810.

Costs of auditing

For those food businesses already operating under HACCP, this Option may pose few additional costs so far as application of the Standards is concerned and thus the costs may be low for those businesses, incremental to Option 1. The major uncertainty for these businesses is the cost of auditing food safety programs.

For example, McDonald’s is typical of many large restaurant/café chains and has its own internal system of auditing compliance with its own HACCP-based food safety programs.

There are a number of alternative approaches regulators may take in a case such as that. Government may require an additional régime of external auditing in which case significant additional costs may be incurred.

Alternatively, an initial external audit of such companies’ systems may be undertaken to show compliance, by those companies, with the letter and spirit of Standard 3.2.1. In which case reports, from those companies’ internal audit procedures to the regulators, may be acceptable, or there may be a reduction in the frequency of audits. In the latter case the incremental costs of applying the Standard to those companies may be negligible.

The costs of applying HACCP to other largebusinesses that do not have HACCP-based food safety programs are uncertain. It is important to note, however, that even those large business that do not have HACCP-based food safety programs are in the process of implementing them. This is not just due to the need to comply with the proposed Food Safety Standard, but is in light of business acceptance that quality management systems are necessary to be able to compete with their competitors in terms of product quality and cost.

Thus, it is primarily the desire to increase or maintain competitive advantage that is driving large businesses to so act. In such cases the costs of implementing the Standard incrementalto the status quo option, Option 1, for large businesses may be close to zero. See ‘Auditing’ below for costs of auditing to small businesses.

Record keeping

The initial figures provided by Hawkless (1999) were amended in light of further work undertaken by Heyhoe and Associates. The cost of record keeping was estimated to be $730 per small business per year.

Cost impact on small business

Small Business Definition

The definition of ‘small business’ used in this document is the one adopted by the Department of Workplace Relations and Small Business, that is:

A ‘small business’ is one that, in the ‘manufacturing’ sector, employs less than 100 people and, in the ‘services’ sector, employs less than 20 people.

It will be noted that the total number of ‘small businesses’ is 125,805.

Notification

As mentioned, for the purposes of this Impact Statement, we have assumed that some 50 per cent of the costs imposed by the proposed Standards is already being borne by Australian food business. Thus we have taken 50 per cent of the costs of $50 from Section 0 above as the incremental costs that will be borne by food business from notification. That is, theincrementalcost to 125,805 food industry small businesses to notify initially is $3,145,125.

If we assume a 20 per cent per annum turnover rate then the notification costs for those new businesses entering the industry will be $629,025 per annum.

Training

We have taken the Heyhoe (1999) estimate of $150 per manager as an appropriate cost for hygiene training. Based on the assumptions that 50 per cent of staff will already have adequate competency and that turnover of new staff to the industry is 20 per cent per annum, the total food safety training costs in 125,805 small businesses will be $9,435,375 initially, together with ongoing costs to train new entrants of $1,887,075.

Costs of recall recording

For small business in the manufacturing/process sector we have assumed that businesses employing nine persons or less would absorb these costs without additional staff. Thus the number of small businesses incurring recall cost at $7 per business per day are 1,452 with a total cost of $3,709,860.

Costs of developing and drafting written food safety programs

Food safety programs costs at $210 per business (two person-days per business to develop a safety program at $105 per person-day) for 125,805 businesses is $26,419,050 with annual costs of $5,283,810 per annum. This annual cost assumes a 20 per cent business turnover per year.

Auditing

Heyhoe (1999) has estimated that an audit of a small business would take an average of 2.5 hours which, at $100 per hour, would cost $125.00. If two such audits were undertaken per year then the total cost would be $250 per business per year.

Assuming we have 125,805 small businesses then the costs of audit would be $31,451,250 per year.

Record keeping

The initial figures provided by Hawkless (1999) were amended in light of further work undertaken by Heyhoe and Associates. The cost of record keeping was estimated to be $730 per small business per year.


Appendix 2: Food Safety Standards

These draft standards may undergo minor changes before their adoption by ANZFSC.

Standard 3.1.1Interpretation and Application

Purpose

This Standard sets out the interpretation and application provisions that apply to the three other food safety standards: Standard 3.2.1 (Food Safety Programs), Standard 3.2.2 (Food Safety Practices and General Requirements) and Standard 3.2.3 (Food Premises and Equipment). The objective of the food safety standards is to ensure that only safe and suitable food is sold in Australia.

Contents

1 Interpretation

2 Application of the Food Safety Standards

3 Application of Standard 3.2.1 (Food Safety Programs)

4 Recognition of equivalent arrangements

5 Application of Standard 3.2.2 (Food Safety Practices and General Requirements) and Standard 3.2.3 (Food Premises and Equipment)

6 Low risk food businesses within the primary industry sector

7 Compliance

Schedule 1 — Recognised equivalent arrangements

Schedule 2 — Classes of low risk primary industry food businesses

Clauses

1 Interpretation

In this Chapter

authorised officermeans a person appointed as an authorised officer under the Act;

cleanmeans clean to touch and free of extraneous visible matter and objectionable odour;

contaminant means any biological or chemical agent, foreign matter, or other substances that may compromise food safety or suitability;

contaminationmeans the introduction or occurrence of a contaminant in food;

equipmentmeans a machine, instrument, apparatus, utensil or appliance, other than a single-use item, used or intended to be used in or in connection with food handling and includes any equipment used or intended to be used to clean food premises or equipment;

food means a substance, whether processed, partly-processed or raw, intended for or represented as being for, human consumption and includes drink, chewing gum and any substance used in the preparation, production, manufacture or treatment of food, but does not include substances declared in the Food Standards Code not to be food and therapeutic goods within the meaning of theTherapeutic Goods Act 1989(Cth);

food businessmeans a business carrying on food handling for sale or selling food;

food handlermeans a person who directly engages in food handling for a food business;

food handlingincludes convey, cook, decorate, deliver, display, distribute, manufacture, pack, prepare, preserve, process, produce, receive, serve, store, transport, or treat food;

food handling operationmeans any activity involving food handling;

food premisesmeans any premises (including land, vehicles, parts of structures, tents, stalls and other temporary structures, boats, pontoons and any other place declared by the relevant authority to be premises under the Act) kept or used for handling food for sale, regardless of whether those premises are owned by the proprietor, including premises used principally as a private dwelling, but does not include food vending machines or vehicles used only to transport food;

food safety standardsmeans Standards 3.1.1, 3.2.1, 3.2.2 and 3.2.3 in Chapter 3 of the Code;

hazardmeans a biological, chemical or physical agent in, or condition of, food that has the potential to cause an adverse health effect in humans;

pests include birds, rodents, insects and arachnids;

proprietor means, in relation to a food business, or an article that is on or at a food premises — the owner of the food business, or, where the owner is not the occupier of the food premises of the food business, the person in charge of the food premises;

safemeans, in relation to food, food that is not likely to cause harm to a person who consumes the food when it is prepared, stored and consumed according to its reasonable intended use;

sale includes:

(a) to sell;

(b) sell for resale;

(c) intend for sale;

(d) offer, or expose for sale;

(e) agree or attempt to sell;

(f) receive, keep or have in possession for sale;

(g) cause or permit to be sold or offered or exposed for sale;

(h) send forward for sale or deliver for sale;

(i) provide a sample;

(j) barter;

(k) provide under a contract of services;

(l) supply or have available for supply;

(m) already sold or supplied;

(n) provide for analysis; and

(o) authorise, direct, cause, suffer or permit any of the above acts;

single-use itemmeans an instrument, apparatus, utensil or other thing intended by the manufacturer to only be used once in connection with food handling, and includes disposable gloves;

single fund raising eventmeans an event that is held by a community or charitable organisation:

(a) not more than once every three months;

(b) for a community or charitable purpose; and

(c) at which only food that is of low risk to public health is sold;

suitable means, in relation to food, food that:

(a) is not damaged, decomposed, deteriorated or perished or does not contain a damaged, decomposed, deteriorated or perished substance, having regard to its reasonable intended use;

(b) does not contain any biological or chemical agent, or other matter or substance, that is foreign to the nature of the food except for any matter or substance permitted by the Food Standards Code; and

(c) is not the product of a diseased part of an animal or one that has died otherwise than by slaughter;

the Actmeans the legislation relating to food that is enacted by a State or Territory in accordance with the Agreement between the Commonwealth of Australia, the States, the Northern Territory of Australia and the Australian Capital Territory in relation to the implementation of nationally uniform Food Acts;

the Councilmeans the Council of Commonwealth, State and Territory Ministers that was established in 1986 by agreement between the Commonwealth, the States and the Northern Territory as continued in existence under the name Australia New Zealand Food Standards Council by agreement between the Commonwealth of Australia the States and the Northern Territory of Australia and the Australian Capital Territory;

the primary industry sectormeans that sector of industry that conducts the steps in the food supply chain relating to primary produce or seafood up to and including harvesting, or an equivalent step such as fishing or milking, or that conducts food handling at meat or dairy premises;

In the definition of ‘primary industry sector’ -

dairy premisesmeans non-retail premises used for milk processing or distribution, including dairy factories;

meat premisesmeans non-retail premises used for slaughtering, processing or distributing meat;

primary producemeans any of the following that are intended for human consumption:

(a) animals;

(b) plants; and

(c) other substances or organisms, harvested, collected, extracted or processed;

seafoodmeans any of the following that are intended for human consumption:

(a) marine, estuarine or freshwater fish or other aquatic animal life;

(b) aquatic plants; and

(c) any other aquatic organisms; and other substances; and

the relevant authorityis the State or Territory agency responsible for the overall enforcement and administration of the Act.

Editorial note

Terms that are defined in this Standard are terms that are used only in this Standard or in more than one food safety standard. Terms that are used in only one of the other food safety standards are defined in the standard in which they are used.

Some of the definitions are the same as proposed definitions for the nationally uniform Food Acts. They will continue to appear in the standards for ease of reference but may change once the definitions for those Acts are finalised.

2 Application of the Food Safety Standards

Standards 3.2.1 (Food Safety Programs), Standards 3.2.2 (Food Safety Practices and General Requirements) and Standard 3.2.3 (Food Premises and Equipment) apply in accordance with this Standard to food businesses and food premises in Australia and not in New Zealand.

Editorial note

‘single fund raising event’ is defined in Standard 3.1.1.

A Code of Practice is to be developed by the Australia New Zealand Food Authority Advisory Committee to provide guidance in relation to the preparation of foods for single fund raising events and for more regular fundraising events.

In the interim, organisations are encouraged to advise the relevant authority of their events, as the relevant authority will be able to provide them with guidance concerning:

• the types of low risk foods that may be sold at such events; and

• the preparation of foods at residential premises.

 

3 Application of Standard 3.2.1 (Food Safety Programs)

(1) Subject to subclause (2) of this clause and Clause 6 of this Standard, Standard 3.2.1 applies to all food businesses that are determined by the relevant authority under the Act to be within a category listed in Column 1 of the Table below from the commencement date listed opposite in Column 2 of the Table.

(2) A food business that is a community or charitable organisation does not have to prepare a food safety program in accordance with Standard 3.2.1 in relation to a single fund raising event.

TABLE

Column 1

Column 2

Priority category of food business

Commencement date

 

 

Editorial note

The categories of food business that are not within the primary industry sector shall be determined in accordance with the ANZFA Priority Classification System for Food Businesses. The categories of food business within the primary industry sector may be determined in accordance with the proposed classification system for food businesses within that sector.

It is intended that Standard 3.2.1 (Food Safety Programs and General Requirements) will be declared to apply by ANZFSC to food businesses in accordance with the following timetable:

High priority businesses - 2 years from gazettal

Medium priority businesses - 4 years from gazettal

Low priority businesses - 6 years from gazettal

Under the Act, the relevant authority or its delegate may determine the particular category to which an individual food business belongs. The ANZFA Priority Classification System for Food Businesses shall be used to determine this for food businesses that are not within the primary industry sector, and for food retailing, food service and substantial transformation operations conducted by food businesses that also operate within the primary industry sector.

It is proposed that a classification system for food businesses within the primary industry sector, yet to be developed, will be used to determine the particular category to which individual food businesses within the primary industry sector belong.

After ANZFSC has declared Standard 3.2.1 applies to low priority businesses, subclause 3 of this Standard may be amended to ensure that all remaining food businesses will have to comply with Standard 3.2.1 unless they are specifically exempted from compliance.

4 Recognition of equivalent arrangements for Standard 3.2.1

(1) Food businesses within the primary industry sector that are regulated by, or have implemented, recognised equivalent arrangements are deemed to comply with Standard 3.2.1.

(2) For the purposes of this clause, ‘recognised equivalent arrangements’ are:

(a) mandatory legislation that includes independent audit of the food handling operations of the food business; or

(b) audited industry based or market driven programs that include independent audit of the food handling operations of the food business,

that are listed in Schedule 1.

(3) Recognised equivalent arrangements may only be listed in Schedule 1 if they meet the outcomes of the Food Safety Standards and have been recognised as meeting these outcomes by the Council.

5 Application of Standard 3.2.2 (Food Safety Practices and General Requirements) and Standard 3.2.3 (Food Premises and Equipment)

(1) Subject to subclause (2) and Clause 6, Standards 3.2.2 and 3.2.3 apply to all food businesses in Australia.

(2) In relation to a food business operating within the primary industry sector, Standards 3.2.2 and 3.2.3 will not apply except in relation to the following food handling operations if they are conducted by the food business:

(a) food retailing operations;

(b) food service operations; and

(c) substantial transformation operations.

(3) In subclause (2), ‘substantial transformation operations’ means activities by which food undergoes a fundamental change in its form, appearance or nature such that the food existing after the change is new and different food from that existing before the change.

Editorial note

It is intended that all the requirements of Standards 3.2.2 and 3.2.3 except the notification and competency requirements will commence six months from gazettal of those standards. The notification and competency requirements may commence within 18 months after gazettal.

 

6 Low risk food businesses within the primary industry sector

(1) None of the food safety standards apply to food businesses in a class of food business that is listed in Schedule 2.

(2) A class of food business may be listed in Schedule 2 only if it is a class of food business within the primary industry sector and the food handling operations of food businesses within that class have been assessed as being of low risk to public health by the Council.

Editorial note

ANZFSC will determine the classes of low risk primary industry food businesses for the purposes of subclause 6(2). In doing so, it will take into consideration recommendations by ARMCANZ.

While low risk businesses in the primary industry sector will not have to meet the requirements of the Food Safety Standards, a review of this approach will be undertaken in 2002 and advice put to ANZFSC on whether to continue or vary this approach.

7 Compliance

The proprietor of a food business is responsible for the compliance by the food business with all the requirements of the Food Safety Standards except those in Subdivision 1 of Division 4 of Standard 3.2.2 (Food Safety Practices and General Requirements). Food handlers are responsible for their own compliance with the requirements of that Subdivision.

SCHEDULE 1

Recognised equivalent arrangements

SCHEDULE 2

Classes of low risk primary industry food businesse s

Standard 3.2.1Food Safety Programs

Purpose

This standard is based upon the principle that food safety is best ensured through the identification and control of hazards in the production, manufacturing and handling of food as described in the Hazard Analysis and Critical Control Point System, or HACCP, adopted by the joint WHO/FAO Codex Alimentarius Commission, rather than relying on end product standards alone. The standard requires each food business to implement a food safety program based upon the HACCP concepts. The food safety program is to be implemented and reviewed by the food business, and is subject to periodic audit by a suitably qualified food safety auditor.

Contents

Division 1 - Interpretation and application

1 Interpretation

2 Application

Division 2 - Food safety programs

3 General food safety program requirements

4 Auditing and review requirements

5 Food safety programs

Division 1 - Interpretation and application

1 Interpretation

In this Standard -

food safety auditormeans a person approved as an auditor for the purposes of the Act; and

food safety programmeans a food safety program that satisfies the requirements of clause 5.

2 Application of this Standard

This Standard applies to all food businesses and food premises in Australia in accordance with Standard 3.1.1 (Interpretation and Application).

Division 2 - Food safety programs

3 General food safety program requirements

A food business must:

(a) systematically examine all of its food handling operations in order to identify any hazards;

(b) if one or more hazards exist, develop and implement a food safety program to control the hazard or hazards;

(c) set out the food safety program in a written document; and

(d) comply with the food safety program.

4 Auditing and review requirements

A food business must:

(a) retain records demonstrating all action taken in relation to, or in compliance with, the food safety program for use by a food safety auditor;

(b) ensure the food safety program is regularly audited by a food safety auditor; and

(c) regularly review the contents of its food safety program to ensure its adequacy, and, in any event, review it for that purpose at least once a year.

Editorial note

An ‘auditor’ is a person who has been approved by the relevant authority under the Food Act as a person competent to audit the relevant class of food business.

ANZFA is facilitating the development of food safety auditor approval criteria for auditors of various classes of food businesses in conjunction with the States and Territories.

The appropriate frequency of audit of a food safety program may be determined in accordance with ANZFA’s Priority Classification System.

5 Food safety programs

A food safety program must:

(a) systematically identify and analyse the hazards in all food handling operations of the food business;

(b) identify where, in a food handling operation, each potential hazard can be controlled and the means of control;

(c) provide for the systematic supervision and monitoring of those controls;

(d) provide for appropriate corrective action when a hazard is found not to be under control;

(e) provide for the regular review of the program by the food business to ensure its adequacy; and

(f) provide that appropriate records are made and kept by the food business to facilitate the maintenance of an adequate food safety program.

Standard 3.2.2 Food Safety Practices and General Requirements

Purpose

This standard sets out specific requirements for food businesses and food handlers that, if complied with, will ensure food does not become unsafe or unsuitable.

The standard specifies process control requirements to be satisfied at each step of the food handling process. Some requirements relate to the receipt, storage, processing, display, packaging, distribution disposal and recall of food. Other requirements relate to the training of food handlers, and their health and hygiene, as well as the cleaning, sanitising, and maintenance of premises and equipment.

Contents

Division 1 - Interpretation and application

1 Interpretation

2 Application of this Standard

Division 2 - General requirements

3 Food handling competencies

4 Notification

Division 3 - Food handling controls

5 Food receival

6 Food storage

7 Food processing

8 Food display

9 Food packaging

10 Food transportation

11 Food disposal

12 Food recall

Division 4 - Health and hygiene requirements

Subdivision 1 - Requirements for food handlers

13 Health of food handlers

14 Hygiene of food handlers

Subdivision 2 - Requirements for food businesses

15 Health of food handlers

16 Hygiene of food handlers

17 General duties of food businesses

Division 5 - Cleaning, sanitising and maintenance

18 Cleanliness

19 Cleaning and sanitising of specific equipment

20 Maintenance

Division 6 - Miscellaneous

21 Temperature measuring devices

22 Single use items

23 Animals and pests

Clauses

Division 1 - Interpretation and application

1 Interpretation

In this Standard, unless the contrary intention appears

demonstrates means demonstrates to the reasonable satisfaction of an authorised officer that the temperature and any heating or cooling process used will not adversely affect the microbiological safety of the food – this may be established by means such as:

(a) a food safety program that complies with Standard 3.2.1;

(b) documented sound scientific evidence; or

(c) written guidelines based on sound scientific evidence that are recognised by the relevant food industry;

environmental conditionsmeans conditions under which certain food may be required to be stored including temperature, humidity, lighting conditions and atmosphere;

food-borne diseasemeans a disease that is likely to be transmitted through contamination of food;

potentially hazardous foodmeans food that has to be kept at certain temperatures to minimise the growth of any pathogenic microorganisms that may be present in the food and to prevent the formation of toxins in the food;

process, in relation to food, means activity conducted to prepare food for sale including chopping, cooking, drying, fermenting, heating, pasteurising, thawing and washing, or a combination of these activities;

ready-to-eat foodmeans food that is ordinarily consumed in the same state as that in which it is sold and does not include nuts in the shell and whole, raw fruits and vegetables;

temperature controlmeans maintaining food at a temperature of:

(a) 5°C, or below 5°C if this is necessary to minimise the growth of infectious or toxigenic micro-organisms in the food so that the microbiological safety of the food will not be adversely affected for the time the food is at that temperature; or

(b) 60°C or above; or

(c) another temperature if the food business demonstrates that maintenance of the food at this temperature for the period of time for which it will be so maintained, will not adversely affect the microbiological safety of the food.

2 Application of this Standard

All food businesses must comply with all the requirements of this standard except the requirements in Subdivision 1 of Division 4. Food handlers are responsible for their own compliance with the requirements of that Subdivision.

Division 2 - General requirements

3 Food handling competencies

(1) Persons undertaking or supervising food handling operations must have:

(a) skills in food safety and food hygiene matters; and

(b) knowledge of food safety and food hygiene matters,

commensurate with their work activities.

(2) Subclause (1) does not apply to persons undertaking food handling operations for a single fundraising event.

Editorial note

single fund raising event’ is defined in Standard 3.1.1.

4 Notification

(1) The proprietor of a food business must, before commencing any food handling operations at food premises, notify the relevant authority of:

(a) the name and address of the proprietor;

(b) the nature of the food business; and

(c) the location of all food premises used by the food business.

(2) When complying with subclause (1), the proprietor must answer all questions asked by the relevant authority in relation to the matters listed in subclause (1), whether in a form prescribed under the Act or otherwise.

(3) The proprietor must notify the relevant authority of any change to the information provided under subclause (1) before the change to the information occurs.

(4) A food business that exists at the time of the commencement of this Standard must provide the relevant authority with the information specified in subclause (1) within three months of the commencement of this Standard.

(5) This clause does not apply to a food business that is a charity or community organisation in relation to a single fund raising event.

Division 3 - Food handling controls

5 Food receival

(1) A food business must take all reasonable measures to ensure it only accepts food that is protected from the likelihood of contamination.

(2) A food business must provide, to the reasonable satisfaction of an authorised officer upon request, the following information relating to food it has accepted:

(a) the name and business address in Australia of the vendor, manufacturer or packer or, in the case of food imported into Australia, the name and business address in Australia of the importer; and

(b) the prescribed name or, if there is no prescribed name, an appropriate designation of the food.

(3) A food business must, when receiving potentially hazardous food, take all reasonable measures to ensure it only accepts potentially hazardous food that is at a temperature of:

(a) 5°C or below; or

(b) 60°C or above,

unless the food business transporting the food demonstrates that the temperature of the food, having regard to the time taken to transport the food, will not adversely affect the microbiological safety of the food.

6 Food storage

(1) A food business must, when storing food, store the food in such a way that:

(a) it is protected from the likelihood of contamination; and

(b) the environmental conditions under which it is stored will not adversely affect the safety and suitability of the food.

(2) A food business must, when storing potentially hazardous food, store it under temperature control.

7 Food processing

(1) A food business must:

(a) take all reasonable measures to process only safe and suitable food; and

(b) when processing food:

(i) take all necessary steps to prevent the likelihood of food being contaminated; and

(ii) where a process step is needed to reduce to safe levels any pathogens that may be present in the food use a process step that is reasonably known to achieve the microbiological safety of the food.

Editorial note:

The definition of ‘safe’ , in relation to food, is ‘food that is not likely to cause harm to a person who consumes the food when it is prepared , stored and consumed according to its reasonable intended use ’ (emphasis added). This means, for example, that raw meat can be considered safe for use during processing as it is intended to be cooked before consumption.

(2) A food business must, when processing potentially hazardous food that is not undergoing a pathogen control step, ensure that the time the food remains at temperatures that permit the growth of infectious or toxigenic micro-organisms in the food is minimised.

(3) A food business must, when cooling cooked potentially hazardous food, cool the food:

(a) within two hours — from 60°C to 21°C; and

(b) within a further four hours from 21°C to 5°C,

unless the food business demonstrates that the cooling process used will not adversely affect the microbiological safety of the food.

(4) A food business must, when reheating previously cooked and cooled potentially hazardous food to hold it hot, use a heat process that rapidly heats the food to a temperature of 60°C or above, unless the food business demonstrates that the heating process used will not adversely affect the microbiological safety of the food.

8 Food display

(1) A food business must, when displaying food, take all reasonable measures to protect the food from the likelihood of contamination.

(2) A food business must, when displaying unpackaged ready-to-eat food for self-service:

(a) ensure the service of the food is supervised so that any food that is contaminated by a customer or is likely to have been so contaminated is removed from display without delay;

(b) provide separate serving utensils for each f