Showing food is safe
Under Standard 3.2.2A, from 8 December 2023 food businesses that process potentially hazardous food, and serve it ready-to-eat, must be able to show their food is safe.
This is to ensure businesses are actively monitoring and managing key food safety risks related to food temperature control, food processing, and cleaning and sanitising, which are critical for food safety.
The requirement can be met by maintaining records or demonstrating to authorised officers that the business is safely receiving, storing, processing, displaying and transporting potentially hazardous food, and cleaning and sanitising.
Specific activities relating to the requirements of Food Safety Standard 3.2.2 must be monitored and recorded, including:
- temperature control during food receipt
- storage
- display
- transport
- pathogen reduction during food processing
- minimising time during food processing
- cooling food
- reheating food
- cleaning and sanitising.
These are known as ‘prescribed provisions’. Below are more details on the above requirements for potentially hazardous food, and suggested frequency of monitoring and records that should be kept for each activity.
Receipt
A food business must take all practicable measures to ensure it only accepts on delivery potentially hazardous food at a temperature of:
- 5°C or below; or
- 60°C or above, unless the food business transporting the food demonstrates that the temperature of the food will not adversely affect the microbiological safety of the food due to the time taken to deliver it.
What needs to be shown: The temperature of potentially hazardous food (PHF) when received OR the time arrangement with the supplier showing the food safety has not been adversely affected during food transport.
What needs to be recorded: Date, food received and food temperature OR the time taken to deliver food.
Suggested frequency: Each delivery.
Storage
A food business must, when storing potentially hazardous food, store it under temperature control.
What needs to be shown: The temperature of potentially hazardous food during storage.
What needs to be recorded: The temperature of potentially hazardous food during storage, date.
Suggested frequency: Daily or as often as instructed in a Standard Operating Procedure (SOP).
Display
A food business must, when displaying potentially hazardous food, display it under temperature control.
What needs to be shown: That PHF is displayed at 5°C or below; or 60°C or above, or total time out of temperature control does not exceed 4 hours (2 hr/4 hr rule).
What needs to be recorded: The temperature of PHF on display or the length of time foods are on display, and date. PHF kept out of temperature control for more than 4 hours must be thrown out.
Suggested frequency: Daily or as often as instructed in a Standard Operating Procedure (SOP).
Transport
A food business must, when transporting food, transport potentially hazardous food under temperature control.
What needs to be shown: That PHF is transported at 5°C or below; or 60°C or above, or total time out of temperature control does not exceed 4 hours (2 hr/4 hr rule).
What needs to be recorded: The temperature of PHF transported or the length of time food is transported for, date. PHF kept out of temperature control for more than 4 hours must be thrown out.
Suggested frequency: Daily or as often as instructed in a SOP.
Pathogen reduction during food processing (cooking)
A food business must, when processing food, 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.
What needs to be shown: That pathogen reduction or killing step has been used on potentially hazardous food to achieve safety of the food (destroy pathogens potentially present).
What needs to be recorded: The date and outcome of the pathogen reduction step, for example:
- temperature of cooked food
- pH of acidified/ fermented food
- time and temperature of pasteurised or sous vide food
- water activity (aw) of dried foods.
Suggested frequency: Per batch or as often as instructed in a SOP.
Minimising time during food processing
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 microorganisms in the food is minimised.
What needs to be shown: The time that ready-to-eat PHF is in the temperature danger zone (between 5°C and 60°C) is minimised and does not make the food unsafe.
What needs to be recorded: The time taken to prepare and then re-refrigerate ready-to-eat PHF or the method used to thaw ready-to-eat PHF, and date.
Suggested frequency: Per batch and/or as often as instructed in a SOP.
Cooling food
A food business must, when cooling cooked potentially hazardous food, cool the food:
- within two hours – from 60°C to 21°C; and
- 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.
What needs to be shown: That cooked potentially hazardous food has cooled to prescribed temperatures within the required timeframes.
What needs to be recorded: The time and temperatures of the food during the cooling process, that is, the length of time taken for food to cool from 60°C to 21°C, and the time then taken to cool food from 21°C to 5°C, and date.
Suggested frequency: Per batch and/or as often as instructed in a SOP.
Reheating food
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.
What needs to be shown: That cooked and cooled PHF is reheated rapidly (within 2 hours) to 60°C or above.
What needs to be recorded: The length of time taken to reheat the food and the temperature the food is reheated to, and date.
Suggested frequency: Per batch and/or as often as instructed in a SOP.
Cleaning and sanitising
A food business must ensure the following equipment is in a clean and sanitary condition in the circumstances set out below:
- eating and drinking utensils - immediately before each use; and
- the food contact surfaces of equipment - whenever food that will come into contact with the surface is likely to be contaminated.
What needs to be shown: That eating and drinking utensils and food contact surfaces have been cleaned and sanitised when required.
What needs to be recorded: If using heat, the temperature the water reaches to sanitise the surfaces, contact time and date. If using chemicals, how and when the chemicals are used to sanitise the food contact surfaces, date. If using a commercial dishwasher, the setting recommended by the manufacturer for sanitising.
Suggested frequency: Daily or as often as instructed in a SOP.
What is a record?
A ‘record’ means a document or object in any form (including electronic) that is kept for the information it contains or that can be obtained from it. Records could include, for example:
- writing or other entries on paper or electronic templates
- written instructions that have been verified to achieve food safety outcomes (for example, a validated recipe or standard operating procedure (SOP)
- notes on invoices, such as a receipt temperature
- data logger information in a graph
- photos or video footage
- information recorded in any other way that allows for the required information to be captured and kept for the required amount of time.
A single record might cover more than one activity or food – for example, a record of the coolroom temperature used to store all potentially hazardous foods.
Records need to be available to an authorised officer on request. So, records should be available at the business at any time the business is operating (not in an inaccessible drawer or inaccessible computer file).
Record timeframes
The records should be made on each day the business is receiving, storing, processing, displaying and transporting potentially hazardous food, and cleaning and sanitising. Information recorded should include the date (and time, if appropriate) the record was made and which food or activity it relates to.
Where a food business is required to keep a record, that record must be kept for at least 3 months.
It might be useful to keep records for longer to track activities over time and look for trends or potential issues (for example, signs that a bain marie needs servicing/replacing, or a food handler is not recording enough details). The 3-month minimum was designed to assist in foodborne illness outbreaks, as it is based on the incubation period of listeria bacteria, a significant pathogen in foodborne illness.
Record keeping examples
- Receiving food at safe temperature
The business must show how it knows the food was received at an appropriate temperature. So, the record needs to show what the food was, when it was received and the temperature of the food when it was received.
- Storing food at safe temperature
A food business has a coolroom and upright refrigerator to store potentially hazardous foods. There is a bottle of water in each unit, the food handlers use a probe thermometer to check the temperature of the water in each unit each day. The temperature is recorded on a sheet which is kept for 3 months.
The Standard offers flexibility in how a business can show that key risks are being adequately managed. The record requirement does not apply to a food business that can demonstrate to the reasonable satisfaction of an authorised officer that the business has safely received, stored, processed, displayed and transported potentially hazardous food, and cleaned and sanitised.
For example, they may be able to show their food is safe by:
- physically demonstrating an activity, such as sanitising a piece of equipment, or measuring the temperature of food
- training staff on a standard operating procedure and talking/walking through that procedure with an authorised officer.
If an authorised officer believes the business is not adequately managing a critical activity, they may require the business to keep records.
Examples
The following are examples of managing food safety using a standard operating procedure.
- Keeping potentially hazardous food safe using time
A shop makes sandwiches from salad and meat ingredients displayed in a refrigerated cabinet. They wrap the sandwiches and place them on top of the display cabinet, ready to sell in the lunch time rush. The standard procedure is to make sure the sandwiches are sold within 4 hours of preparation (validated as per the 2-hour/4-hour rule). At the 4-hour time point, any remaining sandwiches are disposed of. Using this method, staff know the potentially hazardous food they serve is safe for customers to eat. They will also be able to explain to an authorised officer the usual time the sandwiches are placed on the counter, and by what time any unsold sandwiches are disposed of (as soon as the food has been out of refrigeration for 4 hours).
- Transporting potentially hazardous food safely using time
A takeaway shop decides to deliver hot takeaway meals using time as a control, rather than temperature. The shop cooks the meals, puts them in an insulated bag and gives them to the delivery driver within 10 minutes of cooking. The meals are only delivered within 5 kilometres of the shop (no more than 20 minutes by car). The business has a map showing the 5km delivery radius. All delivery drivers and those collecting phone orders are aware of this process and follow it for every order. In this way the business can be sure all potentially hazardous food is safely delivered within 30 minutes of cooking. If an authorised officer requests, the business can show the map and explain how staff follow the timeline from ordering to delivery.
- Cleaning and sanitising procedure
A food business does not have a dishwasher for cleaning and sanitising, so all food contact surfaces are cleaned and sanitised using detergent, water and a food-grade chemical sanitiser. The business already has an established validated procedure for cleaning and sanitising using chemicals, which all staff doing the cleaning and sanitising are aware of, but this procedure is not documented. The business writes down their procedure, laminates it and places it in the dishwashing area. The procedure includes what needs to be cleaned and sanitised and when, what chemicals are to be used and how much (manufacturer's instructions on chemicals are to be followed), and the steps for cleaning and sanitising. The Food Safety Supervisor runs a session for all existing staff to reinforce the procedure, and all new staff are also trained in this procedure as part of their induction.
The following templates are available to help businesses record food temperatures and their cleaning and sanitising activities:
- Supplier details (PDF, 148 KB)
- Food receipt (PDF, 111 KB)
- Cooling food (PDF, 112 KB)
- Temperature record sheet for food display (PDF, 142 KB)
- Log for 2-hour/4-hour rule (PDF, 113 KB)
- Cleaning and sanitising procedure (PDF, 109 KB)
- Cleaning and sanitising record (PDF, 135 KB)
Download all template examples for record keeping: