On 8 December 2023 new requirements for food safety management, including the training of frontline food handlers, come into force. While for most fuel retailers there will be no change to their current, above requirement operations, it is vital that all operators understand the nuance of the requirements and ensure that any in-house or externally provided training is up to the new standard and that any certifications, licences and system templates are updated.
What has changed?
“There is a lot of talk about the changes but the practical impact for fuel retail businesses is, for the most part minimal. A new layer has been added to the Food Safety requirements that places a specific framework of outcomes on the training that food handlers in certain businesses must receive”, explains ACAPMA’s Elisha Radwanowski.
The changes to the Standards include a requirement to train all staff at some businesses, not just the food handlers as well as minor inspector access and record keeping changes.
Food Handler Training changes
The change that is drawing the most attention is the insertion of the Standard 3.2.2A training requirements for certain food service staff. Standard 3.2.2A places a requirement on catering and food service businesses to ensure all of their staff have received appropriate Food Handler training.
This differs from the longstanding Standard 3.2.2 Div 2 Cl 3.1.a which requires only that those staff that are handling food have completed appropriate training.
The insertion of Standard 3.2.2A places new requirements on some food service businesses when it comes to the training of staff that may not have previously been considered ‘food handlers’ such as those that only serve food, or clean tables etc.
The requirements apply depending on the nature of the risk that the food service business is classed as having, based on the ‘hazardous nature’ of the food handled and stored.
“What is important to note here is that the difference is that existing requirements were to train staff who handled food, and now, for certain businesses, all staff have to be trained. In the context of a fuel retail businesses, it is extremely rare that a staff member would not already be considered a food handler under the existing requirements, so they should already be trained. So, there is no real change here”, added Elisha.
If a business is selling potentiality hazardous, unpackaged, ready to eat food, then they will need to ensure they can demonstrate that all staff on site have received appropriate food handler training under the changes.
If they are retailing food, even if it is packaged, there is still the requirement to ensure that all staff who actually handle food have received appropriate food handler training under the existing requirements.
“This discussion usually leads to questions of what is appropriate training? Contrary to some implications from training providers, the training given to the food handlers can be deliver in-house or through an external training provider”.
“You can train your staff yourself – you just have to ensure that you have provided appropriate information, tested the understanding and have the detailed records to show an inspector”, said Elisha.
ACAPMA’s online training
ACAPMAs gold standard frontline staff training for console operators, the Petroleum Convenience Compliance (PCC) course includes a module on food safety – Food Safety for Food Handlers.
This module was developed to the highest standards and has been reviewed annually to ensure ongoing compliance and meets the ‘new’ requirements in Food Safety Standard 3.2.2a as well as the longstanding existing requirements in Food Safety Standard 3.2.2 Div 2 Cl 3.1.a.
The module is fully mapped, and outcomes displayed on both the learning outcome sheet and the certificate of completion learners receive.
“The PCC was designed to the highest standard and so the changes mean that the module continues to exceed the requirements”, outlined Elisha.
For more on the PCC and its included Food Handlers course, see acapma.com.au/our-services/training/fuel-convenience-retail-training-solutions/.
Food Safety Supervisor
The existing requirement for food businesses to have a Food Safety Supervisor have not changed.
Each food business must have completed a nationally recognised and accredited Food Safety Supervisor course within the last five years.
The Food Safety Supervisor must be a person who works on site and is reasonably available to site workers to advise on food safety issues and incidents. Reasonably Available, according to Safe Food Australia, means ‘can be easily contacted (e.g. by phone)’.
“The requirement for a Food Safety Supervisor to implement and oversee food safety systems onsite has been a live one in the fuel retail industry for a long time. There have been recent State based changes that have removed the capacity, in some States, for a Food Safety Supervisor to supervise multiple locations, which leads to a need to ensure there is a qualified Food Safety Supervisor for each site”, explains Elisha.
The Food Safety Supervisor is responsible for implementing the Food Safety System on site, instructing staff on safe operations, reviewing records and engaging with inspectors.
A Food Safety Supervisor must be able to provide an inspector with food safety records, including temperature checks, training records and copies of their own Supervisor Certificate on request.
“The ACAPMA Food Safety Supervisor course is a nationally accredited compliant course that has been contextualised to the fuel retail industry”, notes Elisha.
The course is completed primarily online with observation on site, allowing for efficient recognition of supervisor’s skills.
For more on the ACAPMA Food Safety Supervisor course, see acapma.com.au/wp-content/uploads/2022/08/ACAPMA-Training-Brochure-%E2%80%93-Food-Safety.pdf.
Food Safety System
It is a requirement that all food businesses have, implement and follow a Food Safety System.
“What a good Food Safety System should be changes depending on the offering and operations of the business. There are minimums that any food business will need to be able to demonstrate to an inspector, such as the correct documentation of vendor information, checking of incoming stock, storage of stock and temperature checking through storage, cooking and holding phases”, explains Elisha.
“There are also requirements around the management of allergens, contamination, pests and addressing complaints or recalls. A Food Safety System documents the businesses approach and compliance to all of these”, she adds.
ACAPMA members will be able to access the updated Food Safety System Guide and Templates from mid-October with the release of the 2023/2024 Guide Pack.
Additional considerations
“It is important to note that Food Safety is one of those areas that national, State and Council requirements overlap and interact. It is vital that businesses explore and understand the licencing, registration, inspection and design requirements that apply to each particular site based on these unique interactions, because while the Food Safety Standard is a common thread, it is far from the whole of the requirements that apply to fuel retail businesses when it comes to food compliance”, concludes Elisha.
More information
- General Food Safety Standard Information
foodstandards.gov.au/foodsafety/standards/Pages/Food-Safety-Standards-(Chapter-3).aspx. - Overview on the Standard
foodstandards.gov.au/foodsafety/standards/Pages/Food-Safety-Standards-(Chapter-3).aspx. - Food Standard 3.2.2A Appropriate Training Inclusions – Food Handlers
foodstandards.gov.au/foodsafety/standards/Documents/Std%20322A%20-%20FHT%20Final.pdf. - Food Standard 3.2.2A Training and Responsibilities – Food Safety Supervisor
foodstandards.gov.au/foodsafety/standards/Documents/Std%20322A%20-%20FSS%20Final.pdf.
Here to help
ACAPMA members are reminded that the ACAPMA Employment Professionals are available to assist with employment, safety and training compliance. For more information, email employment@acapma.com.au.
HR Highlights are things to consider, implement and watch out for in your business. They are provided as general advice, and you should seek further advice on your situation by emailing employment@acapma.com.au, it’s free for members.
ACAPMA membership is affordable at only $860 per year for a single site and valuable with sites gaining HR and IR advice support and representation as well as a raft of other benefits and discounts.
Elisha Radwanowski BCom (HRM & IR)
ACAPMA
Source: acapmag.com.au/2023/10/food-safety-understanding-the-new-requirements/.
