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  • Writer's pictureGraham Henrickson

Food Safety – What Australian Childcare Providers Need to Know



Here’s a simple explanation of the rules and laws on food safety that apply to Australian childcare providers.



Australia’s Food Safety Standards & State/Territory Food Safety Laws

The Australia New Zealand Food Standards Code was born from an agreement between the federal, state and territory governments in the late 1980’s. It saw the establishment of the Food Standards Australia New Zealand (FSANZ) as the national authority. The Australia Food Standards Code places tighter controls on those environments where the most vulnerable members of society face the greatest risk from food contamination and food borne disease. These are aged-care facilities, hospitals, certain types of catering firms and childcare centres.


While it sets the standards, it’s the responsibility of the states and territories to pass them into law and enforce them. For example, in Queensland it’s called the Food Act (2006), in Victoria it’s the Food Act (1984) and in South Australia it’s the Food Act (2001). Legislation in each state/territory of Australia mirrors the Australia New Zealand Food Standards Code and defines the roles and responsibilities of the state health department and local Councils in managing the state’s food safety regulatory system.


The legal obligations that apply to childcare centres across the country include:

  • While there are some exceptions, as a general rule - childcare operators that supply food must have a food business license.

  • Childcare providers with a food business license must also have an accredited Food Safety Program.

Of greater significance (because it applied equally to childcare centres with a food business license and to this without) is the requirement that all staff who handle food must have the necessary food safety knowledge & skills to perform their duties safely.


The national code and therefore the law in each state and territory defines a food handler as anyone involved in the making, cooking, preparing, serving, packing, displaying, storing, or the delivery of food as well and anyone who cleans equipment, surfaces, utensils, or cutlery.


Put simply, it means anyone with direct contact with food in the supply chain must have the appropriate knowledge and skills in food safety for the job. Failure to comply comes with hefty penalties, and the high risk of reputational damage.


While the Food Standards Code provides guidance for food businesses on the skills and knowledge requirement of Food Safety Standard 3.2.2 (Food Safety Practices and General Requirements) it doesn’t specify how this must be done. Instead, it leaves this up to each individual business to find its own solution. This could be through on-the-job training or a more formal approach. Formal online food safety training has emerged as the most popular – largely because it’s easier to implement, cost-effective and provides the necessary proof of compliance if required. But you’ll be hard pressed to find a company that offers a solution specific to childcare. Most follow a ‘one-size-fits-all’ approach.



Food Safety Programs & Food Safety Auditors

As mentioned, the laws in each state and territory mirror the Australian Food Standards Code, placing the primary authority for food safety with local Councils. They are the heavy lifters with responsibility for approving food business license applications and Food Safety Programs as well as performance monitoring, inspections, investigations, and enforcement.


Food Safety Programs must be accredited by local Council and the Program must be reviewed by an Approved Food Safety Auditor before it can be submitted to Council. If all the requirements have been met, the approved Auditor will issue a Notice of Written Advice that must accompany the submission to Council. Once accredited by Council, the business is subject to formal onsite Food Safety Audits based on a schedule decided by local Council. The first being within 6 months of accreditation and their purpose is to assess if the business has deviated from the accredited program. The business must engage an Approved Food Safety Auditor to conduct these onsite audits.



The HACCP Approach & Food Safety Programs

To be accredited, a Food Safety Program must satisfy a list of legal requirements. These are largely based on what is called the HACCP System. Originated in the 1950’s as a solution to ensure American Astronauts on the Appollo Missions would have safe food to eat, it has since become the global gold standard for food safety and was adopted by FSANZ for the preparation of accredited Food Safety Programs.


Rather than ‘after the fact’ HACCP is a proactive approach based on prevention and risk analysis. It is a system to identify, control and eliminate the 3 categories of food safety hazards.

  1. Biological hazards – e.g., salmonella and E. coli

  2. Physical hazards – e.g., glass, metal, and plastic

  3. Chemical hazards – e.g., cleaning products, pesticides, and excessive additives


HACCP is an acronym for:

Hazard Analysis of Critical Control Points


In simple terms HACCP works by examining each step of the food production process to identify where things are most likely to go wrong (HAZARD ANALYSIS). These are called - CRITICAL CONTROL POINTS. With the Critical Control Points identified – systems and procedures can then be implemented to minimise the risk of failure.


Food Safety Programs are usually prepared by the business owner themselves and they are free to create their own as long as they meet the criteria. To make this easier, there are a number of excellent templates and step-by-step guides freely available on the internet including an 86-page tool developed by Queensland Health.


Some business owners prefer to engage a Food Safety Auditor to complete this exercise. If so, then a different Food Safety Auditor is required to prepare the Notice of Written Advice for Council and conduct the onsite audits.



The Australian Children's Education & Care Quality Authority (ACECQA)

As well as Food Safety laws, childcare centres are subject to a separate national regulatory authority that specifically applies to childcare and child education services - the National Quality Framework (NQF) as administrated by the ACECQA. Quality Area 2 of the NQF deals with food safety and all registered childcare centres are assessed and monitored against a strict set of criteria that includes the requirements for specific food safety policies and procedures.


The results of these assessments are published, so parents can make an informed decision regarding the education and care of their children.


For Online Food Safety Training developed exclusively for Australian Childcare Centres visit www.fsea.au

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