In short
- What the rule is
- Standard 3.2.2A adds three tools to the existing food safety rules: a certified food safety supervisor, trained food handlers, and for category one businesses a way to show that key activities are done safely.
- Who it applies to
- Food service, catering and some retail businesses that handle unpackaged, potentially hazardous food that is ready to eat. Most WA cafés, restaurants, pubs and caterers are category one.
- What you need to do
- Appoint a supervisor, make sure every handler is trained or skilled before they start, and if you are category one, keep records of the prescribed activities you carry out or be able to show the officer another way.
- What this does not require
- It does not require a written food safety program, a third party audit, an allergen record, a certificate for every handler, or any set frequency of checks.
What the rule says
Standard 3.2.2A, Food Safety Management Tools, started on 8 December 2023 on one date across Australia. There was no staged rollout by size or type of business. It adds to Standard 3.2.2 and Standard 3.2.3 rather than replacing them, so the existing rules on temperatures, cleaning and premises still apply in full.
- Food safety supervisor (clause 11). Appointed before the business carries out a prescribed activity, and reasonably available to advise and supervise while it happens. Their certificate must have been issued within the previous five years.
- Food handler training (clause 10). Before they first carry out a prescribed activity, every food handler has either completed a food safety training course or has skills and knowledge that match the work.
- Substantiation, often called the evidence tool (clause 12). A category one business makes and keeps records for the prescribed provisions it carries out, or demonstrates to the reasonable satisfaction of an authorised officer that it meets them.
Records made under clause 12 are kept for three months from the date each one was made (clause 12(2)). Three months is a minimum, not a limit.
In Western Australia, regulation 7 of the Food Regulations 2009 (WA), made under the Food Act 2008 (WA), adopts the Code as in force from time to time, and the Act makes failing to comply with it an offence. A change to the Code therefore applies in WA without any separate state amendment.
Who it applies to
The standard reaches food service businesses, caterers and some retailers that handle unpackaged potentially hazardous food that is ready to eat. Which tools apply depends on the business's category.
Category one covers businesses that make that food themselves. WA Health's guide gives restaurants, cafés, takeaway shops, caterers, bakeries, mobile vendors, hospitals and childcare centres as examples. Category two covers retailers that sell such food without making it, such as a shop that only slices, weighs, repacks, reheats or hot holds food it bought in.
Fundraising events are exempt (clause 3(2)).
By sector: Restaurants and Bars, Cafés and Bakeries
What it looks like in practice
In a typical café it looks like this: one or more named supervisors with a current certificate, a short induction for each new starter before their first shift in prep or on the pass, and the habit of recording fridge temperatures, deliveries and cleaning.
Clause 12(4) lists nine prescribed provisions. For each one you carry out, a category one business keeps a record or can show the officer another way:
- receiving potentially hazardous food
- storing it
- cooking or another step that reduces pathogens
- keeping time out of temperature control short, including thawing
- cooling cooked food
- reheating food to hold it hot
- displaying it
- transporting it
- cleaning and sanitising
A provision only matters if you do the activity. A kitchen that cooks to order and throws out leftovers has nothing to record for cooling or reheating.
No form is prescribed. Paper sheets, an app, annotated invoices, data logger graphs and photographs are all acceptable. Records must be available to an authorised officer at the premises whenever the business is operating.
What you are not required to do
- A written food safety program or a third party audit. Those come from Standard 3.3.1 and reach only listed facilities, such as hospitals, aged care and childcare centres, serving six or more vulnerable persons.
- Records from a category two business. Category two needs a supervisor and trained handlers, and not the evidence tool.
- A set schedule of checks. The standard names no daily, weekly or monthly check. How often you record should follow how often you do the activity.
- An allergen record. The word allergen does not appear in Standard 3.2.2A.
- A certificate for every food handler. Only the supervisor needs a certificate.
Doing it in Hospitality Shield
Hospitality Shield holds your checks as lists that staff complete as they work, with a name and time on every entry. The lists are yours: you choose which checks to keep and how often. Keeping records here is one way to show an officer what you do. Whether a venue meets the rules depends on what happens in the kitchen and on the officer's assessment, not on the software.
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Asked about this rule
Does Standard 3.2.2A apply to my café?
Almost certainly, if the café makes and serves unpackaged food that needs temperature control, such as sandwiches, cooked meals or cut fruit. WA Health's guide lists cafés as a category one example. Your local government's environmental health officer can confirm your category.
Do I have to keep records?
A category one business either keeps records for the prescribed provisions it carries out, or demonstrates to an authorised officer in another way that it meets them (clause 12). The second route puts the onus on the business, is judged provision by provision, and an officer who is not satisfied can require records from then on.
How long do records have to be kept?
At least three months from the date each record was made (clause 12(2)). A business covered by Standard 3.3.1 may need to keep them longer under its program.
Was there a grace period for small businesses?
No. The standard started on 8 December 2023 for every business, after a 12 month transition from gazettal that applied to everyone equally.
Sources
- Standard 3.2.2A Food Safety Management Tools, Federal Register of Legislation
- Overview of the food safety management tools, Food Standards Australia New Zealand
- Evidence tool, Food Standards Australia New Zealand
- Food safety management tools for food businesses, WA Department of Health
- Guide for food businesses on Food Safety Standard 3.2.2A, WA Department of Health
- Food Regulations 2009 (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.

