In short
- What the rule is
- A category one business makes and keeps records for the prescribed provisions it carries out, or shows an authorised officer another way that it meets them (Standard 3.2.2A clause 12).
- Who it applies to
- Category one businesses, for the activities they actually do. Category two businesses have no records to keep under clause 12.
- What you need to do
- Record each prescribed activity you carry out, keep each record for at least three months, and have them at the premises while you trade.
- What this does not require
- No form, template or frequency is prescribed, and no allergen or hand washing record is required.
What the rule says
Clause 12 of Standard 3.2.2A gives a category one business two routes. It makes and keeps records for the prescribed provisions it carries out, or it demonstrates to the reasonable satisfaction of an authorised officer that it meets them.
Each record is kept for at least three months from the date it was made (clause 12(2)). FSANZ set three months against the incubation period of listeria, so an outbreak investigation can still reach the records.
Records must be available to an authorised officer at the premises whenever the business is operating.
What each record shows, provision by provision:
- receiving: the date, the food, and its temperature or the time taken to deliver it
- storage: the temperature and date, or the total time out of temperature control
- cooking or another step that reduces pathogens: the date and the outcome, such as the cooked temperature
- time out of temperature control: the time to prepare the food and refrigerate it again, or the thawing method, and the date
- cooling: the times and temperatures through cooling, and the date
- reheating to hold hot: the time taken, the temperature reached, and the date
- display: the temperature or the time on display, and the date
- transport: the temperature or the time in transit, and the date
- cleaning and sanitising: the water temperature for heat, the chemical and how and when it is used, or the dishwasher setting the manufacturer recommends
Who it applies to
Category one businesses, which in WA covers most restaurants, cafés, takeaways, caterers and bakeries. A provision only applies if you do the activity, so a kitchen that cooks to order and keeps no leftovers has nothing to record for cooling or reheating.
A business under Standard 3.3.1, such as a hospital, aged care home or childcare centre, keeps records for as long as its food safety program requires. Three months is a minimum, never a reason to delete them sooner.
By sector: Restaurants and Bars, Catering and Events
What it looks like in practice
Any form works: paper sheets, an app, marked invoices, data logger graphs or photographs. FSANZ publishes optional templates in Appendix 8 of Safe Food Australia, and WA links to those rather than publishing its own.
One record may cover several foods. A single cool room reading covers everything in it.
Every record needs the date, the time where it matters, and the food or activity it relates to.
Guidance, not law
Where a record shows something went wrong, guidance recommends noting what you did about it beside the record: the food thrown out, the repair called. That shows the problem was dealt with, not only found.
The demonstration route is harder than it sounds. The business carries the onus, it is judged provision by provision, and an officer who is not satisfied can require records from then on.
Guidance, not law
Records help outside clause 12 too. Section 27 of the Food Act 2008 (WA) gives a due diligence defence, and the business has to prove it took all reasonable precautions. Records made at the time are the practical way to show that.
What you are not required to do
- A particular form or template. None is prescribed.
- A set frequency. How often you record follows how often you do the activity.
- Records from a category two business. It needs a supervisor and trained handlers, and not the evidence tool.
- An allergen record. None is required in Australia.
- Training records for each food handler, unless the business is under Standard 3.3.1. They are recommended rather than required.
Doing it in Hospitality Shield
Every entry in Hospitality Shield carries the name of the person who recorded it and the time. When an officer asks, the venue prints a dated pack for the period they name. Which checks a venue keeps, and how often, is the venue's choice.
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Asked about this rule
How long do we keep food safety records?
At least three months from the date each record was made (Standard 3.2.2A clause 12(2)). A Standard 3.3.1 business keeps them for as long as its program requires.
Can our records be on a tablet or phone?
Yes. No form is prescribed. What matters is that an authorised officer can see them at the premises while the business is operating.
Do we need records if we are category two?
No. Category two does not need the evidence tool, so clause 12 asks for no records. It still needs a supervisor and trained handlers.
Can we show the officer instead of keeping records?
Clause 12(3) allows it, but the onus is on you, it is judged provision by provision, and an officer who is not satisfied can require records from then on.
Sources
- Standard 3.2.2A Food Safety Management Tools, Federal Register of Legislation
- Evidence tool, Food Standards Australia New Zealand
- Safe Food Australia: a guide to the food safety standards, Food Standards Australia New Zealand
- Guide for food businesses on Food Safety Standard 3.2.2A, WA Department of Health
- Food Act 2008 (WA), Western Australian Legislation
General information about the rules in Western Australia. It is not legal advice. Your local government's environmental health officer decides how the rules apply to your premises.