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The Australia New Zealand Food Authority (ANZFA) prepared this document with assistance from the Food Safety Program Tools Working Group:
Mr Kerry Bell
Queensland Health Department
Mr Tony Downer
Australian Food and Grocery Council
Ms Tenille Fort
Department of Human Services, Victoria
Ms Catherine Gay
Commonwealth Department of Health and Aged Care
Ms Brigid Hardy
Agriculture, Fisheries and Forestry - Australia
Mr John Hart
Restaurant and Catering Industry Association of Australia
Mr Tony Johnson (Chair)
Australia New Zealand Food Authority
Mr Steven Newton
Metcash Pty Ltd
ANZFA expresses its appreciation of the assistance from these people and acknowledges that the views contained in the document do not necessarily represent their views or the views of their organisations.
This document is intended as a guide only: legal requirements are contained in the Food Standards Code and relevant food legislation and other applicable laws. The information in this document should not be relied upon as legal advice or used as a substitute for legal advice. You should exercise your own skill, care and judgment before relying on this information in any important matter.
What are food safety program tools?
The role and purpose of tools
Style and format
Content and structure of the food safety program tool
Scope of the tool
Purpose and use of the tool
Definitions and glossary of terms
Advice on complying with the Food Acts and Food Safety Standards
State and Territory Food Acts
Food Safety Standard 3.2.1Food Safety Programs
The HACCP Approach
Food Safety Standards 3.1.1, 3.2.2 and 3.2.3
Instructions on how the tool should be used in practice
Useful references and websites
Commonwealth Government organisations
State and Territory Government health departments and other food safety agencies
Appendix: Checklist for tool developers
Australia New Zealand Food Authority
Food and Agriculture Organization of the United Nations
Hazard Analysis and Critical Control Point
World Health Organization
There are four Food Safety Standards in Chapter 3 of theAustralia New Zealand Food Standards Code. All food businesses in Australia are required to comply with three of these standards. They are:
Standard 3.1.1Interpretation and Application
Standard 3.2.2Food Safety Practices and General Requirements
Standard 3.2.3Food Premises and Equipment
The fourth of these standards, Standard 3.2.1Food Safety Programs, is a 'model' standard. It will only apply to food businesses if a State or Territory Government chooses to introduce a requirement for food safety programs for some or all types of food businesses. If a State or Territory does introduce a requirement for food safety programs, it must use this model standard. None of these four Food Safety Standards apply to New Zealand.
Standard 3.2.1 is based upon the internationally accepted 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 (HACCP) system, adopted by the joint WHO/FAO Codex Alimentarius Commission. This standard enables States and Territories to require food businesses to implement a preventative food safety management system - a food safety program. In practice, a food business can demonstrate that this preventative approach has been implemented by demonstrating compliance with Standard 3.2.2 through documentation, record keeping and review.
However, Standard 3.2.1 provides no detail on how to develop and implement a food safety program. For example, it contains no detail on the means of controlling identified hazards, or the amount and type of documentation and record keeping necessary to demonstrate compliance. Consequently, many businesses, particularly small businesses, may require significant guidance and advice to assist them. This guidance can be provided in the form of food safety program tools (templates, guides, guidelines, etc.) that can assist individual businesses to develop and implement their food safety program. For the sake of brevity these food safety program tools are generally referred to as 'tools' in this document.
While some food businesses are required to comply with Standard 3.2.1 and implement a food safety program, many food businesses that are not required to implement a food safety program may choose to do so for their own business purposes.
This framework document is intended to guide the production of practical, easy-to-use tools that can be used by individual food businesses and, in particular, small businesses, whether they are required or choose to implement a food safety program.
This document is intended to facilitate a nationally consistent approach to the production of these tools. It is intended for use by food industry associations, other collective organisations, governments or individuals to develop tools appropriate to the types of food businesses within a food industry sector or sectors. It is not intended for use by individual food businesses.
This document is advisory only and not part of food law.
'Food safety program tools' ('tools' ) are defined as materials such as templates, models, software and printed materials which may be used directly by food businesses through customisation to create their own workable, site-specific food safety programs which meet the requirements of food law, in particular the Food Safety Standards.
For the purposes of this document, tools donotinclude services such as direct input by consultants expert in the field of food safety.
The principal purpose of tools is to provide sector-specific information that will help individual food businesses within a food industry sector to develop and implement their own food safety program.
A tool should provide an individual food business with:
· simple, practical 'how-to-do-it' guidance on producing safe food and complying with the Food Safety Standards;
· the flexibility to manage the business's own processes to suit its individual situation;
· an instruction process for the owner/manager and staff, which explains how to implement a food safety program;
· generally accepted practices and procedures specific to the food industry sector;
· a means to minimise the costs of implementing a food safety program; and
· a source of information to address the needs of the business owner/manager.
While a range of organisations, including governments, and individuals can develop food safety program tools, industry associations or groups are in the best position to take responsibility for the development of tools appropriate to the needs of businesses within their sector.
Where practicable, tools should be national in their application and be developed with this perspective in mind. The development process should be consultative and involve a representative section of the relevant food industry sector, including small business. Agencies that will be required to enforce the Food Safety Standards should be offered the opportunity for involvement in the development process.
Tool developers should make themselves aware of the differences between State and Territory Food Acts and, in particular, the application of Standard 3.2.1 in the different jurisdictions. (Note: All State and Territory Food Acts are in the process of being reviewed. Developers should ensure they are aware of changes to relevant legislation .)
Tools should allow for flexible food safety programs consistent with the needs of businesses within the sector. For example, simple food safety programs should be sufficient for many small and low-risk businesses, provided that they address all of the core elements of a food safety program (required in Standard 3.2.1).
A tool should be easy to customise into the operations of individual food businesses. This is an important aspect for tool developers to consider in the development process. It is strongly recommended that tool developers conduct trials of their tool to determine its user friendliness, practicality and ease of customisation by businesses. Trials will allow modifications and improvements, if needed, to the tool before it is made generally available.
ANZFA is happy to assist tool developers with the development of sector-specific tools. For example, ANZFA is willing to advise on the development and content of tools and also to provide comment during the development process.
Tool developers wanting to seek advice, or to obtain further information, are invited to contact:
The Food Safety Program
PO Box 7186
CANBERRA MC ACT 2610
Phone: +61 2 6271 2224
This framework document is not intended to provide detailed instructions on the content of tools. However, the following sections are intended to assist tool developers by providing a framework for the development of tools that are consistent in their content, structure, style and utility.
Tools should be limited to providing businesses with advice on the minimum effective measures to comply with food law. However, it is acknowledged that some tool developers may consider it desirable to include guidance to businesses on other matters, such as product quality attributes, industry best practice, good manufacturing practices (GMP) or other current practices within the sector above minimum requirements. In these cases, the tool should distinguish between guidance on complying with food law and guidance related to product quality or other matters.
The Appendix to this document contains a checklist on the content and other attributes of food safety program tools. It is provided so that tool developers can quickly check that the individual requirements of the Food Safety Standards and other desirable attributes have been included or considered during the development process of their food safety program tool.
Tools should be drafted in plain-language style and be as concise, simple and user-friendly as possible.
It is desirable for tools to be drafted using a modular structure. This will allow businesses to use the modules or sections that apply to their business and discard modules that do not apply to their activities and processes.
Tools may be presented in different formats, including electronic, as determined by the tool developer.
To improve consistency across industry sectors and jurisdictions, the food safety program tool should reflect the content and structure outlined in the following sections.
This section of the tool should include the contact details of the developer. It should also include a description of back-up resources available to help businesses use the tool.
It should be made clear that the tool itself is not mandatory. It is an aid for businesses in developing and implementing a food safety program and complying with legislative requirements.
The tool should refer to other relevant documents, including the Food Safety Standards.
In this section, clearly describe the operational scope of the tool for the specific food industry sector and/or list in appropriate detail the types of food businesses to which the tool is targeted.
Set out the purpose of the tool and explain how it should be correctly used.
The tool should include a list of appropriate definitions, including relevant terms that are specific to, and broadly used within, the particular industry sector. These terms should be defined in plain language and may be clarified using examples. (Note: definitions included in the tool should not differ from those in the Food Safety Standards and Food Acts).
All Australian businesses that handle food intended for sale or sell food in Australia are required to comply with State and Territory Food (or Health) Acts (Note: 'sell' is defined in the Food (or Health) Acts). This legislation generally does not apply to 'primary food production' activities. Consequently, businesses, such as farms, that engage in primary food production are not required to comply with the Food Safety Standards unless they engage in any process involving the substantial transformation of food or the sale or service of food directly to the public. Additionally, in most jurisdictions, the Food Safety Standards do not apply to businesses regulated by any other food production legislation, for example State and Territory Meat or Dairy Acts.
There are also some exemptions for community and charity fundraising events in relation to the skills and knowledge requirement in Standard 3.2.2 and in relation to food safety programs.
The Food Safety Standards do not apply to food businesses in New Zealand.
Tool developers should provide advice in their tool on the application of the Food Safety Standards to businesses within the sector and jurisdictions concerned.
In this section the tool should:
· inform businesses of their obligation to comply with the State and Territory Food (or Health) Acts;
· advise businesses within the sector on the application of the Food Safety Standards; and
· advise businesses that other laws and regulations may apply to them. For example, other aspects of the Food Standards Code, such as labelling requirements, may apply and businesses that export food must comply with the Australian Quarantine and Inspection Service (AQIS) Export Food Orders.
The tool should provide guidance on developing and implementing a food safety program that is consistent with Standard 3.2.1. This approach will assist businesses required to comply with Standard 3.2.1, as well as those businesses that may choose to implement a food safety program for other reasons.
Standard 3.2.1 requires a food business to systematically examine its food handling operations in order to identify potential food safety hazards that may reasonably be expected to occur. Where one or more food safety hazards have been identified, the business must develop and implement a written food safety program which it must retain at its premises. The food business must comply with its food safety program and ensure that it is audited by an approved food safety auditor, at the applicable audit frequency. The food business must also conduct a review of the food safety program, at least annually, to ensure its adequacy. Tool developers seeking further information on the food safety audit system are advised to refer to the ANZFA website and State and Territory health agency websites.
In this section the tool should:
· describe the steps necessary to develop and implement an effective food safety program that will assist individual businesses to demonstrate due diligence. Illustrative examples from the industry sector may be given;
· provide advice on the types of businesses, if any, in the different jurisdictions that have a mandatory requirement for a food safety program, and the timeframe for implementation;
· where available, include information on applicable audit frequency and the contact person to arrange an audit; and
· make clear that the food safety hazards and critical steps associated with the operations of individual food businesses cannotallbe addressed in the tool. The final responsibility for the development of a food safety program that appropriately addresses all the food safety hazards associated with a food business remains with that business.
Standard 3.2.1 defines a food safety program that contains six core elements, listed below. Each of these must be addressed in the tool. However, tool developers may be flexible in the manner that the food safety program and its core elements are addressed.
Hazard identification:systematically identify the potential hazards that may be reasonably expected to occur in all food-handling operations of the food business.
Many hazards are generic for businesses within a particular food industry sector. These hazards should be described in tools for that sector. In addition to generic hazards, each food business has unique features that may alter a hazard or introduce new hazards. These are referred to as site-specific hazards.
In this section the tool should:
· describe the generic microbiological, chemical and physical hazards that can occur during every stage of the food-handling operations typical for businesses in the sector; and
· describe a process that businesses can use to identify site-specific food safety hazards. These can often be removed once identified. (Examples from the sector should be provided.)
Hazard control:identify where, in a food-handling operation, each identified hazard can be controlled and the means of control.
The tool should advise on the means of control for identified generic food safety hazards and where the hazards can be controlled.
It should include advice on limits (referred to as critical limits in HACCP) for the controls. Limits can be obtained from a number of sources including research, reference books, papers from technical journals, codes of practice and legislation. For example, there are temperature control limits in Standard 3.2.2.
Tool developers should validate critical limits and include appropriate validation information in the tool. However, validation is not necessary for limits that are part of food law.
Monitoring:provide for the systematic monitoring of the controls.
The tool should provide information on the regular measurement and observation for each of the controls. This may include designating responsibility for, and frequency of, monitoring.
Corrective action:provide for appropriate corrective action when a hazard (or hazards) is found not to be under control.
The tool should advise on corrective action necessary to bring a particular control point back under control before it leads to a safety hazard. Advice should also be given on what action is necessary to prevent the situation from recurring.
Review:provide for the regular review of the program by the food business to ensure its adequacy.
Review consists of the activities undertaken to prove the ongoing effectiveness of a food safety program. The tool should include information on the type of review activities recommended, how often they should be undertaken, events that may trigger a review and how to record and use the results.
Record keeping:provide for appropriate records to be made and kept by the food business demonstrating action taken in relation to, or in compliance with, the food safety program.
The tool should provide information on the amount and type of record keeping required by a food business to show that its food safety program is effective. This will depend upon the needs and the complexity of the food businesses for which the tool is intended and the resources available to them.
The food safety program core elements are consistent with the seven principles of the HACCP system (FAO, 1997). This can be downloaded from the FAO website at www.fao.org/docrep/w6419e/w6419e00.htm ). The tool may refer to and use the Codex HACCP system principles to satisfy the food safety program requirement.
However, tool developers may choose to address the food safety program requirement without reference to HACCP, if this approach is considered preferable for the needs of the food businesses within the sector concerned.
In tools that use the Codex HACCP system principles, include:
· a 'master' or 'generic' HACCP plan that is appropriate for businesses within the sector;
· information and advice on the application of the seven HACCP system principles and, preferably, also on the initial five steps in the application of the HACCP system; and
· include information on support programs applicable for typical businesses within the food industry sector concerned.
These standards apply to all food businesses in Australia but not in New Zealand.
The food safety program tool should provide guidance on compliance with all of the requirements of Standards 3.1.1, 3.2.2 and 3.2.3 applicable to businesses within the food industry sector concerned, within the context of a food safety program.
ANZFA has publishedSafe Food Australia: A Guide to the Food Safety Standards. This publication has been prepared to assist with the interpretation of these three standards. It explains the intent behind each of the requirements of these standards. Tool developers may find it helpful to use appropriate parts ofSafe Food Australiain their tool, or refer businesses to it. It is recommended that tool developers use th is framework document in conjunction with the Food Safety Standards andSafe Food Australia.
There are some requirements in Standards 3.2.2 and 3.2.3 that are qualified by the phrase 'unless the food business demonstrates' . This term has been included to allow businesses to demonstrate that an alternative system they may have in place will not adversely affect the safety of the food. This is usually achieved by the business implementing a food safety program. Tool developers should consider the issue of alternative practices for typical businesses within the sector and, where appropriate, include suitable advice. Any alternative practices suggested must be validated.
Additional guidance on compliance with Standard 3.2.3 can be found in a proposed Australian Standard -Design, Construction and Fit out of Food Premises. The purpose of the standard is to assist architects, food business proprietors and others involved in designing and fitting out new food premises and altering existing food premises. Tool developers may find it helpful to use this Australian Standard in developing their tool. Alternatively, the tool may refer businesses to this Australian Standard.
It is desirable for tool developers to include a list of appropriate organisations and agencies that may assist food businesses in complying with the standards.
If considered desirable, the tool may include a list of suitable references for additional advice to food businesses on particular areas of concern, for example training packages and codes of practice.
Tool developers should provide instructions on how the tool is best used in practice by individual food businesses. This advice should include the appropriate practical steps for businesses to customise the tool to create and implement their own specific food safety program. These steps are listed below and are suitable for most food industry sectors.
Tool developers should advise businesses to:
· study and understand the instructions, support materials and/or training to help customisation of the tool and to seek assistance as required;
· customise the tool document to create the business's 'own food safety program';
· seek a check of the appropriateness of the customised food safety program before it is implemented, for example local government Environmental Health Officers. (Although this is a useful step, in practice, it may not be possible in many situations);
· train food handlers in the specific tasks and processes that they are responsible for (from the food safety program). Food handlers should also be trained in health and hygiene, if needed;
· implement the procedures, monitoring and review as described in the food safety program; and
· arrange to have the food safety program audited as required by State/Territory law (if there is no mandatory requirement for a food safety program the business may or may not choose to have its food safety program audited).
State and territory government health departments and other food safety agencies