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Guidelines

for Auditors
of Mandatory Food
Safety Programs

October 2010
National Library of Australia Cataloguing-in-Publication entry
Title: Guidelines for auditors of mandatory food safety programs.

ISBN: 9780730897446 (pbk.)

Subjects: Auditing--Standards--South Australia.


Food--Safety regulations--South Australia.
Food industry and trade--Standards--South Australia.

Other Authors/Contributors:
South Australia. Dept. of Health.
Dewey Number: 363.19262099423

Guidelines for Auditors of Mandatory Food Safety Programs


Contents

1 Introduction 2 6 Non-conformances 7
1.1 Aim 2 6.1 Non-conformances and inadequacies 7
1.2 Regulatory requirements 2 6.2 Critical non-conformance notification 7
6.3 Major non-conformances 8
2 Roles and responsibilities/ 6.4 Minor non-conformances 9
duties within the audit system 2
2.1 Department of Health 2 7 Audit frequency 10
2.2 Local government 2 7.1 Initial frequency of auditing 10
2.3 The food business 3 7.2 Redetermination of frequency of auditing 10
2.4 Duties of food safety auditors 3
8 Attachments 12
3 Appointment of food 1. Auditor application form
safety auditors 3 2. RABQSA NFSA Certification Scheme
3.1 Auditor application 3 3. Approved Auditors Code of Conduct
3.2 National food safety auditor certification 3 4. Priority classification system
3.3 Approval of food safety auditors 3 5. FSP audit checklist
3.4 Certificates of authority of food 6. FSP audit report
safety auditors 4
7. Audit system process flow diagram
3.5 List of food safety auditors 4
3.6 Term of approval 4
9 Acknowledgments 12
3.7 Conflict of interest 4
3.8 Suspension or cancellation of approval 5 10 References 12
3.9 Review of approval decision 5

4 The audit 5
4.1 Audits or inspections 5
4.2 Audit fees 6
4.3 Priority classification 6
4.4 Complaints 6
4.5 Verification activities 6

5 Audit reports 6
5.1 Auditor reporting requirements 6

Guidelines for Auditors of Mandatory Food Safety Programs page 1


1 Introduction
1.1 Aim
The aim of this publication is to outline the requirements for auditing food businesses in South Australia
that are required to have mandatory food safety programs.
The guidelines explain the responsibilities, duties and roles of auditors approved by the South Australian
Department of Health under the SA Food Act 2001 (the Act).
Primary Industries & Resources SA (PIRSA) and the Dairy Authority of South Australia (DASA) are responsible
for auditors authorised under the Primary Produce (Food Safety Schemes) Act 2004. Department of Health,
PIRSA & DASA are working closely to ensure South Australian jurisdictions comply with the National Food
Safety Audit Policy and apply consistent approval criteria.
The guidelines will assist auditors and prospective auditors to understand South Australia’s regulatory system
in relation to the food safety audit system and the requirements for auditing food safety programs, to ensure
provision of safe and suitable food by high-risk businesses required to have a mandatory food safety program.

1.2 Regulatory requirements


Part 7 of the Act outlines:
> the requirements for approving food safety auditors in Division 1
> auditing and reporting requirements in Division 2.
The approval and audit process will comply where practicable with the National Food Safety Audit Policy
agreed to by the Australia and New Zealand Food Regulation Ministerial Council in October 2006 to promote
national consistency in food safety auditor and audit management.

2 Roles and responsibilities / duties within the audit system

2.1 Department of Health


As defined in the Food Regulations 2002, the Department of Health acts as the relevant authority
for administration of the Act.
The Food Safety and Audit Section in Food Policy and Programs Branch, Public Health SA, will manage
the system for the new food safety requirements for higher risk food businesses in South Australia.
The Food Safety and Audit Section is responsible for the priority classification system, the auditor
approval process, the facilitation of training and support for local government auditors, and the completion
of verification audits.

2.2 Local government


Local government is the appropriate enforcement agency for food businesses requiring food safety programs,
except for the unincorporated areas where it is the Department of Health.
The appropriate enforcement agency will inform food businesses in writing of their requirement to have
a mandatory audited food safety program and of the initial audit frequency.
If a food business is required to have a mandatory audited food safety program, the Department of Health
would not expect the council to continue routine inspection of the business. Unannounced inspections may,
however, still be conducted at the discretion of the council.

page 2 Guidelines for Auditors of Mandatory Food Safety Programs


The majority of audits, particularly those that are scheduled, will be announced audits. The benefits
of announced audits include the following:
> They encourage a compliance relationship with the food business, where the business and auditor work
together to ensure that the food safety program is compliant.
> They ensure that relevant personnel are available on the day of the audit and that the timing of the audit
minimises disruption to the food business.
> They ensure that the food business is actually operational on the day of the audit.
The appropriate enforcement agency (local government or Department of Health) will be responsible for
following up any contraventions that are reported as critical (reported in 24 hours) by approved auditors.

2.3 The food business


The proprietor of a food business is responsible for the preparation, implementation and maintenance
of a mandatory food safety program. The proprietor is also responsible for ensuring that the food business
is audited at least as frequently as determined by the priority classification.

2.4 Duties of food safety auditors


Section 80 of the Act sets out the duties of food safety auditors:
> To carry out audits of mandatory food safety programs and determine their compliance with
the requirements of Food Safety Standards 3.2.1, 3.2.2 and 3.2.3.
> If necessary, to carry out any follow-up action, including follow up audits, to ensure that corrective actions
to fix non-conformances have been completed.
> To report in accordance with the requirements of the Act.
Approval as an auditor in no way diminishes from the applicant’s duties as an authorised officer.

3 Appointment of food safety auditors

3.1 Auditor application


Applications for approval (see attachment 1) as a food safety auditor under the Act need to be forwarded
to the Department of Health, Food Safety & Audit Section; and must be accompanied by the appropriate
certificate from the auditor certification body, Registrar Accreditation Board Quality Society of Australasia
(RABQSA), a criminal history clearance letter and the approval fee as specified on the application form.

3.2 National food safety auditor certification


RABQSA is the certification body recognised by the Department of Health to certify food safety auditors
under the National Food Safety Auditor (NFSA) scheme.
Attachment 2 provides a summary of the NFSA scheme and its process. Requirements and information
can be viewed on the RABQSA web site www.rabqsa.com.

3.3 Approval of food safety auditors


Under Part 7, s73 of the Act, auditors for mandatory food safety programs must be approved
by the Department of Health.
Approval Criteria
As part of the approval process prospective auditors will be required to:
> demonstrate technical and audit competence
> demonstrate knowledge of relevant Food Safety Standards including 3.1.1, 3.2.1, 3.2.2 and 3.2.3
> demonstrate relevant and ongoing work experience in administering food legislation, in particular,
the skills and experience collecting evidence and taking action where breaches of the Act are identified.

Guidelines for Auditors of Mandatory Food Safety Programs page 3


> hold current certification as National Food Safety Auditor Level 4 (High risk)
> demonstrate ongoing professional development or currency of skills
> demonstrate knowledge of the South Australian food regulatory system
> obtain a criminal history clearance letter.
As a general guide, the Department of Health considers that, in order to meet the competency requirements
for approval, an applicant should have had at least 2 years’ relevant work experience, that is, experience with
administering food safety legislation.
Employees of councils (or of bodies established by a council or councils) approved as food safety auditors will
be conducting food safety audits in the course of their employment.
Once approved, auditors are required to comply with the relevant provisions of the Act and conditions
of certification that have been determined by the Department of Health. As part of the application process,
the auditor will be required to agree to the Approved Auditors Code of Conduct (see attachment 3).
Auditors must notify the Department of Health immediately of any changes to their personal details
and qualifications that may affect their suitability to undertake the role of a Department of Health
approved auditor.
If an application is granted, the applicant must be issued with written approval that sets out any conditions
to which the approval is subject. If the application for approval is refused, the reasons must be set out in
writing to the applicant.

3.4 Certificates of authority of food safety auditors


The Department of Health will provide a certificate of authority in the form of an ID card for each approved
auditor. This will cite their authority under Part 7 of the Act and carry the auditor’s name, signature, photo
and expiry date.
The card is to be carried when conducting audits as evidence of approval to do so.

3.5 List of food safety auditors


A list of approved auditors will be available on the Department of Health web site.

3.6 Term of approval


Approval is granted for a 4-year period unless cancelled or suspended within that timeframe. Auditors must
re-apply to the Department of Health every 4 years to be re-approved.
Re-approval may be conditional upon attendance at annual auditor forums/workshops and other appropriate
professional development as determined by the Department of Health, to ensure skills maintenance and
development of the auditor workforce.

3.7 Conflict of interest


Auditors must, in all circumstances, avoid possible conflicts of interest. Auditors must not audit a food safety
program that they have written or provided direct assistance in preparing. Auditors must not audit premises
where they have a personal and financial interest in a business.
Payment for carrying out the function of an auditor does not constitute a direct or indirect interest in a
business. Inspection of a food business or general food safety advice to a food business does not constitute
a direct or indirect interest.
In situations where the auditor is the authorised officer and is the only educational resource for food
businesses, a conflict of interest can be managed by providing advice to the food business through examples
of how hazards may be controlled rather than giving specific direction to the food business on how specific
hazards will be controlled by that business.

page 4 Guidelines for Auditors of Mandatory Food Safety Programs


There is no conflict of interest where an auditor is a state or local government regulator. Currently,
environmental health officers conduct inspection where they are both the ‘inspector’ and the enforcement
agency. The Department of Health considers this to be a similar situation but including the audit process rather
than the inspection process.

3.8 Suspension or cancellation of approval


Under s76 of the Act, the Department of Health may vary the conditions of, suspend or cancel an auditor’s
approval under certain circumstances.
The Department of Health must be satisfied that the person:
> has failed to comply with the requirements of the Food Act; or
> is found not to be sufficiently competent; or
> has been guilty of any fraudulent conduct in carrying out an audit; or
> was granted certification on the basis of fraud, misrepresentation or concealment of facts; or
> is no longer an authorised officer under the Act.
The Department of Health may only vary conditions, cancel or suspend an approval after providing the person
with the reason(s) in writing, and having considered the person’s response should they make one.

3.9 Review of approval decision


If unhappy with a decision by the Department of Health relating to auditor approval, a person may apply
to the Administrative and Disciplinary Division of the District Court for a review of this decision in writing
within 28 days.
Reasons for requesting a review as defined under s77 of the Act are:
> the grant or refusal of an application for an approval
> the imposition of conditions on an approval
> the variation of conditions of an approval
> the suspension or cancellation of an approval.

4 The audit

4.1 Audits or inspections


An inspection is used to assess compliance where the standard is fairly prescriptive and where no
documentation or records are required to be kept by the business. The recognised international definition
for inspection is: ‘Evaluation for conformity by measuring, observing, testing or gauging the relevant
characteristics.’
An audit, on the other hand, is used to assess systems. Where a standard requires a business to have a
management system to control either processes or the quality of product, an audit is used to assess whether
the system has been implemented and is effective in meeting that standard. ‘Audit’ is used where there is a
documented system and records to review. The recognised international definition for audit is: ‘A systematic
and independent examination to determine whether quality/safety activities and related results comply with
planned arrangements and whether these arrangements are implemented effectively and are suitable to
achieve objectives.’

4.2 Audit fees


The Department of Health will only set audit fees for public hospitals and other businesses audited directly
by the Department of Health. Other audit fees may be determined by auditors or councils and will be
regulated by market forces.

Guidelines for Auditors of Mandatory Food Safety Programs page 5


4.3 Priority classification
The Food Act 2001:
> s79(1) requires that the appropriate enforcement agency must determine the priority classification
of individual food businesses for the purposes of food safety programs; and the frequency of auditing
of any food safety programs.
> s79(2) requires that the determination must be made having regard to a priority classification system
for types of food businesses approved by the relevant authority.
> s79(3) requires the appropriate enforcement agency to provide written notification to the food business
of its priority classification and audit frequency.
The priority classification system approved by the Department of Health is based on the Food Regulation
Standing Committee National Risk Profiling Framework (April 2007) (see attachment 4).
Enforcement agencies (local government or Department of Health) will be responsible for providing written
notification to the food business of its priority classification and audit frequency.

4.4 Complaints
If the council or a business is dissatisfied with a response from an auditor, has complaints of incompetence,
or has evidence of non-compliance with the requirements of the Act against an auditor, they must refer these
matters in writing to the Department of Health for resolution.

4.5 Verification activities


Auditing is a critical component in the mandatory food safety program system. The audit system must provide
sufficient competent auditors who perform at an appropriate level.
To ensure that auditor performance is appropriate, the Department of Health will monitor the performance
of approved auditors to confirm that appropriate audit outcomes are identified. This is also a requirement
of the National Food Safety Audit Policy.
To ensure the audit system is operating effectively and to identify improvement opportunities, the Department
of Health will review the system after 2 years in operation (2010).

5 Audit reports

5.1 Auditor reporting requirements


In relation to reporting, s81 of the Act requires that the food safety auditor must prepare a written report on
the prescribed forms (Audit Checklist & Food Safety Audit Report; attachments 5 and 6) of the results of any
regulatory audit carried out.
A food safety auditor must report to the enforcement agency any contravention that is an imminent and
serious risk to the safety of food intended for sale, or that will cause significant unsuitability of food intended
for sale, as soon as possible but in any event within 24 hours.
A copy of the Audit Checklist and Food Safety Audit Report must be given to:
> the proprietor of the food business concerned
> the appropriate enforcement agency, usually the council
> the Department of Health
within 21 days after completion of the audit.
The report must take account of any action taken before submission of the report to remedy any deficiency
identified by the food safety auditor.
The food safety auditor must ensure in the audit report that any non-compliances are documented,
with details provided of the nature of the non-conformance including objective evidence.

page 6 Guidelines for Auditors of Mandatory Food Safety Programs


Where non-conformances have been identified and subsequently remedied by the food business proprietor,
the audit report must describe each failure or inadequacy that has been remedied.
A food safety auditor must report in writing to the appropriate enforcement agency when the frequency
of inspection is changed.
A food safety auditor must report in writing to the appropriate enforcement agency, and provide reasons,
if the auditor considers that the priority classification of a food business that has been audited should be
changed and no longer requires a food safety program. Examples of reasons why a business providing food
service to vulnerable populations may require a change of priority classification include ceasing to prepare
potentially hazardous food or clientele permanently dropping below six vulnerable persons.
Where non-conformances have been identified, the auditor must follow the procedures detailed in Section
6 ‘Non-conformances’.

6 Non-conformances

6.1 Non-conformances and inadequacies


A non-conformance is a food handling practice that is found not to comply with specified requirements
documented in the food safety program or the requirements of the Act or Food Safety Standards.

6.2 Critical non-conformance notification


A critical non-conformance is defined as a contravention of the requirements of the Act or Food Safety
Standards where a serious or imminent risk to public health is identified, or that will cause significant
unsuitability of food intended for sale. That is, if the food, practice or situation has compromised the health
of consumers or, if allowed to continue, will compromise consumers’ health.
Where a food safety auditor has conducted a food safety audit for the purposes of the Act, they must notify
the appropriate enforcement agency immediately by telephone and follow up by written confirmation as
soon as practical but no later than 24 hours.
The authorised officer of the appropriate enforcement agency should attend the premises and ensure action
is taken within 24 hours of the telephone notification to ensure the risk to health is removed. The appropriate
enforcement agency will advise the auditor when it is satisfied the risk to health has been removed and the
auditor will re-audit the premises to close out the critical non-conformance.
Where the auditor is auditing a food business within their own agency’s jurisdiction, that is they are the
appropriate enforcement agency, the auditor may choose to stop the audit and take action as the authorised
officer. It is recommended that the auditor advise the food business at the commencement of the audit that
they may exercise this option and, if they do, that they are clear in their communication.

Guidelines for Auditors of Mandatory Food Safety Programs page 7


Example of a critical non-conformance
During an audit of a nursing home, the auditor observes that kitchen staff are using the same
cutting board for cutting up raw chicken and for the preparation of fresh salad. The proprietor
explains that it is a waste of money buying extra cutting boards, though he will eventually do it.
The auditor also queries that the food handler didn’t wash their hands after handling the raw
chicken and then the salad.
Scenario 1 - The auditor immediately advises the nursing home manager that this is a critical
non-conformance; and that all ready-to-eat food cut on the cutting board in question should
not be served, and other food may be contaminated by poor personal hygiene of food handlers.
The auditor contacts the council environmental health officer by telephone as soon as possible,
advises of the critical non-conformance and follows up later that day with a facsimile to the council
of what was observed. A week later, the council environmental health officer advises the auditor
that the non-conformance has been rectified and that they can now re-audit the business.
Scenario 2 - The auditor immediately advises the nursing home manager that this is a critical
non-conformance and represents an imminent risk to public health, and that the audit will stop
at this point and the auditor will then be addressing the non-conformance as the council’s
authorised officer.

Where a critical non-conformance has been detected, the written advice to the appropriate enforcement
agency should contain:
> the name and address of the food business
> the date the non-conformance was issued
> the Standard or other requirement being breached by the non-conformance
> details of the non-conformance, including copies of records, if required
> signatures of the auditor and the person in the business with whom the non-conformance was discussed
> corrective action as proposed by the food business
> details of verification of corrective action.

6.3 Major non-conformances


A major non-conformance is a potential high-risk situation, where the potential impact is likely to compromise
food safety if no remedial action is taken. All major non-conformances will be submitted with the standard
audit report to the appropriate enforcement agency within 21 days, as the issue does not present an imminent
risk to health. The appropriate enforcement agency will decide if they need to act.
The auditor may conduct a follow-up audit to check that corrective action has been taken to remedy
any major non-conformances. This could be in addition to the regular frequency of audits.

page 8 Guidelines for Auditors of Mandatory Food Safety Programs


Example of a major non-conformance
During an audit of a hospital kitchen, the auditor observes that there are no disposable towels at the
wash hand basin. The proprietor explains that staff constantly wash their hands but use tea towels,
which aren’t sighted by the auditor, to dry their hands.
The auditor is satisfied that staff do wash their hands but issues a major non-conformance for the
lack of appropriate hand-drying facilities, and re-audits the business within 14 days.

6.4 Minor non-conformances


A minor non-conformance is a low-risk situation where there is a non-compliance with the requirements
of the Act or Food Safety Standards but the potential impact of the non-conformance is not likely to
be a serious or imminent risk to public health. This includes a non-conformance with the business’s food
safety program.
The auditor must negotiate with the business to determine an appropriate timeframe for rectification,
and then follow up to ensure the minor non-conformance has been rectified. This can generally be checked
at the next scheduled audit.
If an auditor identifies a number of minor non-conformances which, taken collectively, are likely to
compromise food safety, the non-conformances may be classified as a major or critical non-conformance
immediately, and appropriate action be taken.
Minor non-conformances must be reported to the appropriate enforcement agency by the auditor by means
of the ‘audit report and checklist’ within 21 days.

Example of a minor non-conformance


During an audit of an aged care facility, the auditor observes that there are broken floor tiles in
the kitchen area, a build-up of grease in the filters of the exhaust canopy above the stoves, and
packaged food being stored on the floor of the cool room. The auditor also observes that stock
rotation, though not a safety issue at the time of the audit, could be improved.
The auditor negotiates with the proprietor of the business that the filters are to be cleaned within
24 hours, and that within 21 days the broken floor tiles will be replaced and that there will be
additional shelving for the cool room so that no packaged food has to be stored on the floor.
The auditor also gets an undertaking that ‘first-in-first-out’ stock rotation will be implemented.
Prior to closing out the non-conformance, the auditor verifies that it has been rectified––this may
be by a re-audit or by having the business send photographs of the clean filters, new floor tiles
and cool room shelving.
The auditor could leave the first-in-first-out stock rotation issue until the next audit.

Guidelines for Auditors of Mandatory Food Safety Programs page 9


7 Audit frequency

7.1 Initial frequency of auditing


The priority classification system approved by the Department of Health presently recommends an initial
audit frequency for high-risk businesses requiring food safety programs to be 6-monthly. The outcomes
of two audits will be required to establish a compliance history that can allow for the adjustment of
audit frequency.
All businesses required to have a mandatory food safety program will require an audit at least annually.
The audit frequency for high-risk businesses is based on the Food Standards Australia and New Zealand
(FSANZ) Food Safety Priority Classification System for Food Businesses (2001).

7.2 Redetermination of frequency of auditing


The food safety auditor, as per s82 of the Act, may advise the appropriate enforcement agency and the
Department of Health that the food business’s audit frequency will change to require either more frequent
audits in the case of poor performance or less frequent audits in the case of good performance. A food safety
auditor must have regard to the compliance history of the food business in making such a determination.

page 10 Guidelines for Auditors of Mandatory Food Safety Programs


Guidance on movement of food businesses within audit frequency ranges

Level of Audit Level of frequency Notes


frequency notes Audit confidence

Critical (notifiable) To be determined The food business’s food safety program is not effective
non-conformance by authorised officer in producing safe food. The auditor raises a critical
relative to the breach. non-conformance and the enforcement agency is notified.
Audit frequency It is then the responsibility of the enforcement agency
increases to the to take action to address the identified problems.
maximum level
Assessment of the food business, on identification of a
(3-monthly).
critical non-conformance, may include inspection as well
as audit, that is whatever is determined to be appropriate
by the enforcement agency.

Major non-conformance Audit frequency can The food safety program has been implemented but does
(marginal food remain the same or not always follow the documented process, e.g. there
safety program) increase a level (i.e. if may be a non-conformance identified that has not placed
the food business is on public health at risk, and therefore does not constitute a
6-monthly audits, the critical non-conformance.
frequency would move
A non-conformance against specific controls within the
to 3-monthly).
food safety program would most likely make the
The maximum program marginal, whereas it may take a number of
adjustment is one level. non-conformances against prerequisite or support
programs to make the program marginal.

Minor non-conformance Frequency remains There is confidence that the system has been
(satisfactory food the same or can be implemented and is effective. There may still be a small
safety program) decreased if the auditor number of non-conformances raised against prerequisite
has confidence in the or support programs.
food safety program.
The maximum
adjustment is one level.

Confidence in the Frequency reduces There is a high level of confidence in the food safety
food safety program to the minimum level program and the food business. Confidence can be
(i.e. if the food business measured in one of two ways: the food business has
is on 6-monthly a continuing compliance with the food safety program,
frequency, this moves or it has an effective internal food safety audit and
out to 12-monthly). management review process.
The maximum
Food businesses cannot be moved to this audit
adjustment is one level.
frequency unless there is a compliance history available
to the auditor, and the food business has had no critical
non-conformances identified in two previous audits.

Guidelines for Auditors of Mandatory Food Safety Programs page 11


8 Attachments
These attachments are correct at the time of publishing but may be updated periodically.

1. Auditor application form

2. RABQSA NFSA Certification Scheme


3. Approved Auditors Code of Conduct
4. Priority classification system
5. FSP audit checklist
6. FSP audit report
7. Audit system process flow diagram

9 Acknowledgments
This guideline was developed with the assistance of a working party comprising representatives from the
following organisations:
> Environmental Health Australia (SA Division)
> Department of Health, Food Policy and Programs Branch
> Local Government Association of South Australia
> Adelaide City Council
> Berri Barmera Council
> City of Holdfast
> City of Mitcham
> City of Port Adelaide Enfield
> City of Tea Tree Gully
> City of Unley
> City of West Torrens
> Eastern Health Authority
The Department of Health would like to convey their sincere appreciation to the supporting organisations for
making a representative available and to the members of the working party for their valued contribution.

10 References
Parliament of South Australia 2001, Food Act 2001, Parliament of South Australia, Adelaide, viewed
1 September 2008, <http://www.legislation.sa.gov.au/LZ/C/A/FOOD%20ACT%202001.aspx>
Australia New Zealand Food Authority 2001, Food safety: an audit system, Food Standards Australia New
Zealand, Canberra, viewed 1 September 2008,
<http://www.foodstandards.gov.au/_srcfiles/FS_Audit_Report_final%20edit0702.pdf>
Australia New Zealand Food Authority 2001, Food safety: guidance for food safety auditors, Food Standards
Australia New Zealand, Canberra, viewed 1 September 2008,
<http://www.foodstandards.gov.au/_srcfiles/Auditor%20Handbook%20final%20Oct%202001.pdf>
Australia New Zealand Food Authority 2001, Food safety: the priority classification system for food businesses,
Food Standards Australia New Zealand, Canberra, viewed 1 September 2008,
<http://www.foodstandards.gov.au/_srcfiles/ANZFA_1578_Info_Paper__final.pdf>
Australian and New Zealand Food Regulation Ministerial Council 2006, National food safety audit policy,
Department of Health and Ageing, Canberra, viewed 1 September 2008, <http://www.health.gov.au/internet/
main/Publishing.nsf/Content/2087CDEAEE7C703CCA256F190003AF4B/$File/nat-food-safety-aud-pol.pdf>

page 12 Guidelines for Auditors of Mandatory Food Safety Programs


For more information
Food Policy and Programs Branch
SA Health
PO Box 6, Rundle Mall
SA 5000
Telephone: (08) 8226 7100
Fax: (08) 8226 7102
Email: food@health.sa.gov.au
www.sahealth.sa.gov.au
Non-English speaking: for information in languages other than
English, call the interpreting and Translating Centre and ask them
to call The Department of Health. This service is available at no cost
to you, contact (08) 8226 1990.

http://www.gilf.gov.au/
© Department of Health, Government of South Australia.
All rights reserved. ISBN: 9780730897446 (pbk.)
FIS: 10189.1 Updated October 2010.
Approved Food Safety Auditor Application
New approval  Renewal of approval  Auditor No....................

Applicant details
Name:
....................................................................................................................................................................................
Address:
...................................................................................................................................................................................
Website contact details (only include details you want added to the SA Health website)

Telephone: .......................................... Mobile: ................................................. Work: ............................................


Email Address: ...........................................................................................................................................................

Qualification details
Authorised Officer of Council / Authority:..................................................................................................................
RABQSA Registration Number:................................................................................................................................

 attached copy of my NFSA Level 4 certification.


 attached copy of my Criminal History Screening Unit letter of clearance.
 emailed a current photograph (email digital photo to chris.grove@health.sa.gov.au)
 invoice council or  I have attached cheque or money order for $147.40 ($134.00 + GST).
Audit area (please indicate  this will be included on the SA Health website)
Own council/authority Other council/authority Specify ........................................................

All councils

Declaration by applicant
I, (print full name) ......................................................................................................................................................
Being the applicant, apply for approval as a food safety auditor under the provisions of the South Australian Food
Act 2001, and confirm that:
> I have read and agree to comply with the Approved Auditors Code of Conduct and the South Australian
Guidelines for Auditors of Mandatory Food Safety Programs.
> I will be able to demonstrate skills, knowledge and competencies required to be an approved auditor if
requested.
> I understand that I must notify the Department for Health and Ageing immediately of any changes to my
personal details and qualifications that may affect my suitability to undertake the role of a SA Health
approved auditor.
> I note that attendance at the annual auditor forum will be required.
> I declare that all information supplied in preparing this application is true.

Signature of Applicant: ....................................................... OFFICE USE ONLY


Application/Auditor number
Date Received
Date: ...................................................................................

Under the Food Act 2001 June 2014


Attachment 2
RABQSA National Food Safety
Auditor Certification Scheme (NFSA)
As part of the development of the National Food Safety Audit Policy the National Food
Safety Auditor Certification Scheme (NFSA) was developed by the Australian
Government Department of Agriculture, Fisheries and Forestry (DAFF) and RABQSA
International Inc. (Personal certification body PCB) in partnership with industry and
food safety regulators. It was launched on 28 Feb 2006 and highlighted the food
industry’s need for the Scheme which establishes a national benchmark for certifying
food safety auditors.
The Department of Agriculture, Fisheries and Forestry headed the initiative to develop
a single national certification scheme that encompasses first, second and third party
auditors, and provides confidence to industry in the abilities of food safety auditors.
Improved confidence and national consistency in food safety auditor competency
should contribute to reducing audit duplication and compliance costs.
The scheme represents a world’s first in terms of government and industry
engagement on an issue of national importance involving food safety.
The scheme is the catalyst for the coming together of producer, supplier, regulator and
retailer in the aim of unifying food safety standards, audit consistency and conformity
assessment rationalization.

The NFSA scheme reflects an innovative approach by combining:


> Knowledge competency;
> Education requirements associated with each high risk scope, to determine auditor
competence.
> Personal attributes; and
> Required auditor performance (Skill) competency.

The committee reviewed the diversity and scope of the food industry in Australia and
aligned food safety auditor certification levels according to food safety risk rather than
industry sector scopes. This risk-based approach provides clear advice to system
owners selecting auditors and also enables NFSA certified Auditors to audit across a
broad range of industries.
The scope is determined by risk
> Level 1 Compliance
> Level 2 Low Risk
> Level 3 Medium Risk
> Level 4 High Risk
RABQSA are related to those defined in
Level 4 Auditor Certification ISO 19011:2002 Guidelines for quality
requirments and/or environmental management
NFSA-4 auditors are recognised as systems auditing.
competent to audit high, medium or low
Applicants are required to demonstrate
risk businesses/processes.
these personal attributes through
1. Knowledge Requirements completion of the e-based PAAS Master®
All Applicants for Level 4 (NFSA-4) Examination. Details to enable the
certification must provide evidence of the completion of the PAAS Master®
knowledge competency defined by Examination will be provided to each
RABQSA in the following competency Applicant when RABQSA receives their
units. Application.

RABQSA-NFS2: Communicate and PAAS Master® Examination Fees are


negotiate to conduct food safety audits submitted with the Application Fees for
Certification.
> Develop a communication plan to
support audit processes > Ethical – fair, truthful, sincere, honest and
discreet;
> Select and use appropriate
communication methods to conduct > Proactive and Organised – takes the
an audit initiative with issues, and is personally

> Negotiate to achieve agreement on > organised;


audit outcomes > Systematic – shows a balanced affiliation
for both tasks and people;
RABQSA-NFS3: Conduct food safety
audits > Logical – makes decisions based on facts
and reasoned logic;
> Plan the audit
> Decisive – expedites decisions
> Conduct the audit
methodically;
> Manage the audit process
> Observant – shows the ability to identify
> Consolidate audit outcomes both patterns and exceptions in
> Confirm and close out corrective actions complex situations;
RABQSA-NFS4: Identify, evaluate and
control food safety hazards > Diplomatic – relates to others and shows
> Identify food safety hazards in a food tact in appropriate situations;
business > Flexible – shows a balanced global and
> Control food safety hazards in a detail focus;
food business > Process focused – demonstrates the
ability to follow a pre-determined method;
2. Education
> People Sensitive – is sensitive to and can
Applicants for NFSA-4 certification must
identify a person’s emotional state;
provide evidence of a relevant nationally or
internationally recognised tertiary > Adaptable and Resourceful – adapts to,

qualification at Australian AQTF Certificate and works with, different types of people
IV (or equivalent) or higher, such as a > in a range of situations and copes with
Degree, Diploma or Advanced Certificate change; and
in Food Technology or related field. > Confident – demonstrates certainty and

3. Examination of Personal Attributes competency, and reacts well to a variety


of challenges, i.e. demonstrates calm
All Applicants for Level 4 (NFSA-4)
and poise in challenging situations.
certification must provide evidence they
possess appropriate personal attributes, as
shown. The attributes examined by

September 2008
4. Examination of Skill RABQSA Skill Examination Level 3
All Applicants for Level 4 (NFSA-4) > All competency in Skill Examination
certification must provide evidence of Level 2 and
the skill competency defined by RABQSA. > Identify food safety hazards
Competency is to be demonstrated under
> Identify methods to control food safety
auditing (onsite) conditions during an audit
hazards
of a high risk business/process. The Skill
Examination will be conducted by an 5. Surveillance
RABQSA Certified NFSA Skill Examiner To maintain certification, all certified NFSA
(Skill Examiner) who holds NFSA Level 4 Auditors are required to demonstrate
certification. It is the responsibility of each continuing compliance with the current
Applicant to arrange for a Skill certification criteria for the level of NFSA
Examination. certification awarded.
The Skill Examiner examines and reports RABQSA will provide reminders with the
on the competency defined in the invoice for Annual Certification Fee to all
RABQSA Skill Examinations Level 2 and certified auditors when the date for
Level 3. Applicants must provide a copy of surveillance is due and the information
the completed Skill Examination Report, required to be provided to RABQSA.
signed by both the Skill Examiner and the
Every two years from the date of initial
Applicant, as evidence of demonstration of
certification or each re-certification, NFSA
the required Skill competency.
Auditors must demonstrate continuing
RABQSA Skill Examination Level 2 compliance with the current certification
> Implement the audit plan criteria by providing:
> Maintain communication during the audit > evidence of current knowledge
> Collect and verify information competency through successful
completion of the relevant RABQSA
> Assess food safety and implementation
e-based examination for the type and
of food safety programs
level of certification; and
> Conduct interviews
> confirmation that the RABQSA Code of
> Generate audit findings
Conduct has been adhered to and any
> Prepare audit conclusions complaints against performance have
> Conduct closing meeting been resolved.
> Prevent and resolve conflicts The Annual Certification Fee includes the
cost for Surveillance.

September 2008
6. Re - certification
RABQSA will provide reminders with the
invoice for Re-certification Fee when the
date for re-certification is due and the
information required.
Every four years from the date of initial
certification and each subsequent re-
certification, certified Auditors must
demonstrate continuing compliance with
the current certification criteria by
providing:
> evidence of examination of skill
competency by an RABQSA certified
NFSA Skill
> Examiner appropriate for the NFSA level
of certification;
> evidence of evaluation of personal
attributes by successful completion of
the RABQSA PAAS Master®
Examination within the previous four
years;
> confirmation that the RABQSA Code of
Conduct has been adhered to and any
complaints against performance have
been resolved.

September 2008
Guidelines for Auditors

Code of Conduct
for Approved Food
Safety Auditors September 2008

Purpose of the code > An auditor shall not use abusive, obscene
or threatening language or behaviour towards
Audit services must be delivered with honesty, others. Physical and/or verbal violence against
integrity, professionalism and accountability. any person in the audit process is considered
The Code of Conduct outlines how such an a breach of the Code of Conduct.
outcome is to be achieved.
> An auditor shall observe the principles
of procedural fairness when making decisions
Application of the code by allowing the person concerned the
opportunity to put their side of the case
Auditors should: and have it considered before any decision is
made, and provide reasons for their decisions.
> familiarise themselves with the Code of Conduct
> An auditor has a duty to use due care
> ensure that its provisions are observed.
and diligence, including consideration
An auditor who fails to comply with the provisions of equal opportunity, occupational health
of the Code of Conduct may be subject to and safety, discrimination, harassment
suspension or cancellation of their approved and victimisation legislation.
auditor status. > Audits are to be carried out in accordance with
Department of Health policies. And auditors
are expected to conduct themselves in a
Code of Conduct positive manner with a demonstrated positive
> An auditor shall act professionally, with attitude to the Department of Health policies
honesty, in good faith and in the best interests and directions.
of the consumers of food as a whole. > Auditors should conform to a standard of
> Auditors are expected to maintain open, honest dress that is suitable for the type of work
and thorough communication with all parties performed and meet all bio-security and
involved in the audit process. occupational health and safety requirements
> An auditor has an obligation at all times of the businesses being audited. It should be
to comply with all legislative requirements, respectable, clean, and not compromising to
the ‘Guidelines for Auditors of Mandatory the professional image of food safety auditors.
Food Safety Programs’ and the principles > Auditors shall not smoke in non-smoking
of this Code of Conduct. areas at workplaces or at any time allow
> Auditors shall show respect for other the consumption of alcohol, or restricted
people, avoiding patronage and favouritism or dangerous drugs, to adversely affect their
and not allow personal beliefs to influence work performance or conduct.
their judgments or decisions on food safety > An auditor shall not undertake auditing
audit-related issues. activities where there is a conflict of interest.
> Auditors shall treat audit participants fairly, At any time, an auditor who is unsure whether
equitably and consistently, and follow clearly a conflict of interest exists should consult
defined and recognised criteria, processes the auditor guidelines or, where appropriate,
and delegations when making decisions. seek direction from the Department of Health.
Code of Conduct for Approved Food Safety Auditors

> In short, the fundamental policy of the > An auditor shall not improperly use information
Department of Health is that no auditor acquired in the course of their duties. Official
may solicit or accept gifts from any member and commercial information shall not be
of the public concerned with any matter used by auditors to improperly gain any kind
connected with the duties of the auditor. of advantage for themselves, or for another
These policies do not apply to the acceptance person or organisation.
of meals during the course of an audit. > The falsifying of any audit related
> An auditor shall never ask for, encourage documentation constitutes a breach of the
or initiate a bribe of any sort, whether it is Code of Conduct and may result in suspension
for himself, herself, or anyone else. Auditors or cancellation of the auditor’s approval.
shall immediately report any situation to the
Department of Health where it is considered
that a benefit is being offered in return for
preferential treatment or to cause a conflict
of interest.
> Confidential information received by an
auditor in the course of the exercise of their
duties remains the property of the auditee.
It is improper to disclose that information
or allow it to be disclosed, unless that
disclosure has been authorised by the persons
from whom the information is provided, is
required by law or generated by, or supplied
for the purpose of communicating it to other
people or organisations, and has been released
for circulation (e.g. drafts of legislation,
guidelines, policies, Green Papers).
Attachment 4

Department of Health
Food Business Priority Classification
System
Part 7 Division 2 of the Food Act 2001 has provisions for auditing and
reporting requirements relative to food safety programs.
The relevant enforcement agency must determine the priority classification and
frequency of auditing of food safety programs for each food business having regard
to a priority classification system for types of businesses approved by the relevant
authority, in this case the South Australian Department of Health (DH).
The priority classification system establishes the initial auditing frequency and
the range of allowable auditing frequencies for food businesses requiring a food
safety program.
At this time, the priority classification system identifies only those food businesses
that are required to have mandatory food safety programs compliant with Food Safety
Standard 3.3.1 that is food businesses serving vulnerable populations. No other
businesses are classified.

Food Businesses Priority Compliance


Type Classification Arrangements
Food businesses required by the Priority 1 (P1) Audit by Department of Health
Food Act 2001 to comply with Approved Food Safety Auditor
Food Safety Standard 3.2.1
Food Safety Programs.
Frequency of audit

Currently food businesses as set


out in Standard 3.3.1 Food Initially audit frequency
Safety Programs for Food - 6 months.
Service to Vulnerable Person
(generally hospitals, aged care Audit frequency range
facilities, childcare centres and
delivered meals organisations - maximum 3 months to
but not including supported minimum12 months.
residential facilities and
retirement villages). An approved food safety auditor
may change the audit frequency
in accordance with section 82
after two complete audits.

Other food businesses Not classified at


this time.

September 2008
Audit Checklist
Name of facility:

Address:

Telephone: Fax:

Email Address:

Date of visit: Date of previous visit:

Reason for visit:

Business representatives:

Auditor representatives:

Legend

N/A Not applicable to this business


 Complies with the requirement
 Does not comply with the requirement
/ The business generally complies but there is some area of non-compliance.

Page 1 of 10 October 2010


REQUIREMENT – FOOD SAFETY PROGRAM
 or  COMMENTS
(Std 3.2.1)

1. Is there evidence that all food handling


operations have been identified?
(eg by use of process flow chart).

2. Is there evidence that these activities have been


assessed for potential hazards?
(Physical, Microbiological, Chemical)
3. Are control steps identified and documented for
each identified food safety hazard?
4. Tick nominated Controls: List Critical Limits for controls
Receipt

Storage

Thawing

Preparation

Cooking

Cooling

Reheating

Service

Delivery (on site)

Transport

Are the controls appropriate for the products /


processes?
5. In monitoring is it clear who, where, when and
how procedures are implemented?

6. Is there an appropriate corrective action for each


control? Are there records of validation?

7. Are records maintained for all corrective actions


taken when control measures are not complied
with?

8. Are all records easily accessible and identified?

9. Does the internal audit check that all records are


present and review any deviations?

Page 2 of 10 October 2010


REQUIREMENT – FOOD SAFETY PROGRAM
 or  COMMENTS
(Std 3.2.1)

10. Does the internal audit provide verification that


hazards are kept under control?

11. Does the business conduct a review at least


annually to ensure the adequacy of the
program?

12. Does the review highlight any deviations and


indicate corrective actions?

REQUIREMENT – CONTROL
 or  COMMENTS
(Std 3.2.1 and Std 3.2.2)

RECEIVAL

13. Are staff conducting visual examination of foods


on receipt?

14. Are staff monitoring and recording temperatures


/ condition of incoming Potentially Hazardous
Food?

DRY STORAGE AND PACKAGING

15. Are foods protected from contamination and


clearly identified?

16. Is the packaging material fit for intended use,


protected from and not likely to cause
contamination?

17. Are single use items protected from


contamination?

COLD AND FROZEN STORAGE

18. Are foods protected from contamination and


clearly identified?
Examples - Are raw foods stored separate from
RTE food? Is food adequately covered?

19. Are the temperatures of all cool room facilities


including fridges and freezers, checked,
recorded and under control?

Page 3 of 10 October 2010


REQUIREMENT – CONTROL
 or  COMMENTS
(Std 3.2.1 and Std 3.2.2)

THAWING

20. Does the business have a documented thawing


procedure?

21. Depending on the procedure, is the control step


documented and monitored?

PREPARATION

22. Raw / unprocessed foods separated from


cooked / processed / RTE foods.

23. No potential for physical or chemical product


contamination.

24. Are food contact surfaces, utensils, equipment


and chopping boards properly cleaned and
sanitised before use?

25. Is the time that PHF foods are out of


temperature control monitored and / or
controlled?

COOKING

26. Are foods thoroughly cooked?


Example - by ensuring the core temperature
reaches 75°C or greater.

27. Is the cooking procedure documented and


recorded?

COOLING

28. Is the procedure used for cooling adequate?

29. Is the cooling procedure documented and


recorded?

Page 4 of 10 October 2010


REQUIREMENT – CONTROL
 or  COMMENTS
(Std 3.2.1 and Std 3.2.2)

REHEATING

30. Are food handlers ensuring the internal


temperature of food is 60°C or greater?

31. Is the reheating procedure documented and


recorded?

SERVING

32. Is food kept covered and protected from


contamination?

33. Is food for hot holding held at 60°C or greater ?

34. Is the serving procedure documented and


recorded?

35. Is food served to the client within a defined and


monitored time?

36. Are staff observing appropriate health and


hygiene practices when serving and plating
food?

DELIVERY

37. Is food protected from contamination?

38. Is food being transported under appropriate


temperature control or delivered within a defined
and monitored time?

Page 5 of 10 October 2010


REQUIREMENT – SUPPORT PROGRAMS
 or  COMMENTS
(Std 3.2.2)

SKILLS AND KNOWLEDGE

39. Do staff have adequate Skills & Knowledge?

40. Are records of staff skills & knowledge kept?


(Food handler skills & knowledge register)

FOOD HANDLER HEALTH AND HYGIENE

41. Does the business have a policy for food


handler hygiene? It must give adequate
consideration to reduce the risk of food
contamination. Example – hair covering,
protective clothing, allowable jewellery.

42. Does visual observation confirm compliance with


hygiene policy?

43. Is there a policy for managing food borne illness


in staff?

44. Hand washing stations adjacent to work areas?

45. Are all hand washing stations supplied with soap


and suitable drying tools?

46. Is there evidence of frequent hand washing?

SUPPLIERS

47. Is there a policy on purchasing and donations?

48. Is there a specific policy on high risk Listeria


foods?

49. Is a list kept of suppliers? Does it detail approval


criteria?

Page 6 of 10 October 2010


REQUIREMENT – SUPPORT PROGRAMS
 or  COMMENTS
(Std 3.2.2)

RECALL

50. Is there a documented food recall plan if


required?

51. Is there a procedure in place to deal with recalls


from suppliers?

52. Does the business have a documented


procedure to ensure that food for disposal is
labelled and kept separate?

CLEANING & SANITATION

53. Are premises & fittings clean?

54. Are food contact surfaces clean and sanitary?

55. Are all equipment and utensils used in a clean


and sanitary condition prior to use and stored to
prevent contamination?

56. Are there documented cleaning & sanitising


procedures / schedules / records.

57. Are cleaning chemicals stored well separated


from food?

58. If used, what is the final rinse temperature of


dishwashers? Is this checked and recorded?

TEMPERATURE & CALIBRATION

59. Does the business have a temperature


measuring device that is readily accessible and
can accurately measure the temperature of PHF
to +/- 1°C?

60. Are there recorded checks on calibration and


accuracy of all monitoring devices e.g.
• Thermometers / Probes
• Cool rooms
• Dishwashers?

Page 7 of 10 October 2010


REQUIREMENT – SUPPORT PROGRAMS
 or  COMMENTS
(Std 3.2.2)

PEST CONTROL

61. Is there an effective and recorded pest control


program?

62. No visual evidence of pests?

63. Are all practicable measures being taken to


prevent pests entering the premises?

WASTE DISPOSAL

64. Internal rubbish placed in plastic lined bins and


emptied frequently? If unlined, are bins part of
cleaning schedule?

65. Is there a separate waste disposal area and is it


kept clean?

MAINTENANCE

66. Does the business have a system to maintain


the food premises, fixtures, fittings and
equipment in a good state of repair and working
order?

REQUIREMENT – PREMISES (Std 3.2.3 ref)  or  COMMENTS

67. Floors – are they sealed, non-absorbent


surfaces, able to be easily and effectively
cleaned and in good repair?

68. Walls – are they sealed, non-absorbent


surfaces, able to be easily and effectively
cleaned and in good repair?

69. Ceilings – are they appropriate for the area,


sealed, non-absorbent surfaces, able to be
easily and effectively cleaned and in good
repair?

70. Fixtures, Fittings and Equipment? Are they in


good repair, able to be easily and effectively
cleaned and not likely to contaminate food?

71. Is there sufficient lighting for the activities


conducted?

72. Is there sufficient ventilation?

Page 8 of 10 October 2010


REQUIREMENT – PREMISES (Std 3.2.3 ref)  or  COMMENTS

73. Are there windows in production areas? If so, do


they open and do they have screens?

74. Does the business have an adequate supply of


potable water?

75. Does the business have an effective sewage


and waste water disposal system?

76. Are external openings adequately sealed to


prevent entry of pests? (Air curtains / screens /
insectocutors)?

77. Is there adequate drainage of floors?

78. Are adequate storage facilities available for


chemicals, clothing and personal effects?

79. Are adequate toilet facilities available for food


handlers?

80. Is the space and layout of food preparation and


storage areas adequate?

REQUIREMENT - ADDITIONAL  or  COMMENTS

Page 9 of 10 October 2010


OBSERVATIONS COMMENTS

Page 10 of 10 October 2010


Food Safety Audit Report
Food Act 2001.

Business Name:
Manager / Key Contact Person:
Premises address:
Council Area:
Business phone:
Type of audit (first / scheduled / follow up):

Entry & Exit meeting attendance (business representative & auditor to sign) Date:
Name (print) Position Entry initial Exit initial

AUDIT SCOPE
REQUIREMENTS  or  Comments
Food safety program
Hazard identification
Documented controls
Monitoring & records
Controls
Receival
Dry storage & packaging
Cold and frozen storage
Thawing
Preparation
Cooking
Cooling
Reheating
Serving
Delivery
Support programs
Skills & Knowledge
Food handler health & hygiene
Suppliers
Recall
Cleaning & sanitation
Temperature & calibration
Pest control
Waste disposal
Maintenance
Premises
Building
Equipment
Additional

Start time: End time:


Non-conformances Critical – Major – Minor –
Frequency & date for next audit 3 months – 6 months – 12 months –

Business contact’s signature: Date:


Auditors signature: Date:

Page 1 of 2 October 2010


Food Safety Audit Report
Food Act 2001.

Areas of non-conformance and corrective action Business name:

Reference: Food process: Type of non- Areas of non-conformance: Agreed date Company’s proposed Evidence of closure:
(standard, (e.g. Receival, Storage, compliance: (non-compliance or inadequacy) for corrective corrective action: (Auditor to date & sign
audit checklist Preparation, Cooking, (critical, major Stating reasons when evidence of
or food safety Support Programs, Training,
action: corrective action has been
or minor)
program) Food Recall and Records) supplied or sighted)

Business contact’s signature: Date:

Auditors signature: Date:

Page 2 of 2 October 2010


September 2008
Attachment 7: Guidelines for Auditors

Auditor Approval Food Business Food Safety


Process Audit Process Audit Process

Applicant applies for Food safety program is Council notifies business of


NFSA level 4 certification developed and implemented requirement for mandatory
from RABQSA through by food business. food safety program based
Department of Health. on Department of Health
Priority Classification.

Department of Health Food business contacts


Critical
facilitates Skill Examination. approved auditor and audit
is conducted according Non-conformance
to the set audit frequency. Identified

Once certified the applicant Auditor notifies Auditor acts


No Critical
applies to the Minister council within as Authorised
of Health for approval Non-conformances 24 hours Officer.
as a Food Safety Auditor Identified
under Food Act 2001.

Applicant assessed against Audit report provided to Council environmental health


set approval criteria. If the food business and copies officer should attend the
approved auditor is issued sent to enforcement agency premises and ensure action
with ID card as certificate (council) and the Department is taken within 24 hours
of approval. of Health within 21 days. of notification to ensure
the risk to health is removed.

Approved auditor may The auditor will re-audit


audit food businesses premises on council
defined as requiring notification that the risk
regulatory food safety to health has been removed.
programs (Standard 3.2.1).

Audit System Management Enforcement agency reviews


and assesses audit outcomes.
Department of health

Department of Health Environmental health


conducts verification activities officers may conduct follow
to monitor competency up inspections as result
Department of Health acts on & conduct of auditors. of complaints or major
misconduct or incompetence non conformances.
No problem
by auditors, disputes, identified
complaints and appeals
within the audit system. Review and continual
improvement of the
audit system.

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