Review of Food Standards Code chapters 3 and 4 – Food Safety Management Requirements

FSANZ is reviewing chapters 3 and 4 of the Australia New Zealand Food Standards Code (the Code) to ensure a consistent and current approach to through-chain food safety management in Australia. Requirements in chapters 3 and 4 only apply in Australia.

In June, the FPSC A-NZ submitted a response, in summary, below.

  • The Review is limited to discussion in the foodservice sector and the possibility of a primary production and processing standard (PPPS) for high-risk horticultural products.
  • We welcome the current approach that applies a risk-based approach to clearly define the product scope for a possible standard.
  • The industry released new Guidelines for Fresh Produce Food Safety 2019 in June.
  • Need for caution about concentrating on products rather than the processes used to produce them.

  • The industry approach to managing risk has evolved over the years, to focus on the risks posed by system inputs, primarily composts, people and water, and the presence or absence of a human pathogen kill step.
  • Imported berries carrying hepatitis A virus are beyond the influence of any proposed Australian PPPS. As such, processing entities are in fact food processors and the product is not regarded as fresh.
  • A need for a clear definition of minimally processed fruits and vegetables as there are many degrees of minimal processing, ranging from topping and tailing of peas and beans through de-husking of sweet corn to sliced mushrooms and multi-product ‘chunky’ fresh fruit salads.
  • Traceability (and product identification) is driving greater capability across the industry, along with the increasing availability of technology (software) to enable this requirement to be met with greater speed and accuracy.
  • Any new standard must be implemented uniformly and consistently across all states and territories. A national approach is essential.
  • FSANZ incident management and culture groups need to be retained and effectiveness and strategy regularly reviewed in consultation with stakeholders.
  • Review of communication processes within jurisdictions, between jurisdictions and with other key stakeholders including industry. This extends to increasing awareness, prevention and preparedness during ‘peacetime’ as it does to enhancing communication and situational updates during incident response and recovery.
  • The aim must be to help steer producers of all horticulture products to safe production activities.

FSANZ will consider all submissions and report back to stakeholders.