I will post the article online once I receive the electronic copy of the article, however if you can read the online version of the Sydney Morning Herald article.

Staggering that 1 in 10 business can be listed, and some offended on multiple occasions, however at The Gourmet Guardian we prefer to focus on the positives and recognise the 90% of food businesses that are NOT on the list.

The NSWFA through their local council Environmental Health Officers also have a Scores on Doors program highlighting the businesses doing a good job.

So keep an eye out for the NSW rated 5 star businesses and those that have HACCP Programs in place.

We have multiple HACCP Certified clients in NSW. We will shortly be publishing a list of businesses we can recommend.

Support the businesses doing a SAFE job.

Click on the image below to access an online Food Safety Supervisor Training course.

At the session, John Fallon from the New South Wales Food Authority (NSWFA) explained that there are only 22 approved external third party auditors in NSW.

He provided an enforcement update on all VP audits that have been conducted (by NSWFA employed auditors and external third party auditors).

He indicated that the top TWO problems encountered during audits were:

• Ineffective monitoring records
• Not complying with there food safety program

#1 Non Conformance: “Ineffective” Monitoring records

This included:

• Not having records in place
• Missing records or records not available
• Completed records not identifying issues (i.e. Temperatures recorded outside critical limits)
• No recorded corrective action when problems were identified
• Supervisor signing off on incomplete or incorrect records

It is stated in the VP Guidelines that IT IS a requirement for someone to check all completed records. Even though it is not a requirement for records to be signed, we certainly recommend this practice to our clients.

We have a client who purchased from a newsagent, an “APPROVED” stamp and the person doing the checking stamps the monitoring record and signs above where it was stamped. I think this is a simple and effective means of verifying your records. You still need to make sure that the person who does the “approving” actually checks that the record has been completed correctly.

#2 Non Conformance: “Not complying with their food safety program”

Remember a couple of days ago I told you that your program should:

“Say as you do” and you should “Do as you say”.

Consistent areas where Corrective Action Requests (CARs) were raised included:

• Labeling techniques used
• Content of an internal audit – The internal audit process did not include a review of their food safety program. (Note: The findings of the internal audit should reflect what is found at an external audit)
• Good manufacturing practices
• Allergen management

The NSWFA will continue to monitor ALL Vulnerable Persons facilities (including businesses with Third Party Auditor (TPA) approval) and the Proprietor of the facility is responsible for ensuring that an audit is organised.

All VP audits conducted in NSW are reported electronically to the NSWFA. Every month, the NSWFA runs a report on facilities that are overdue for an audit. The following process is applied:

• If overdue by 3 months they will be sent a “reminder letter”
• If overdue by 6 months they will be sent a “warning letter”
• Failure to comply will result in a $1320 penalty for corporations
  and $660 for individuals.

All scheduled audits must be conducted within the allocated 6 or 12 month period.

Your license cannot be renewed if there are any outstanding audits that have not been conducted.

Whenever possible, I attend the meetings the different state regulators have for auditors and I am attending another one in September for Victorian auditors.

Joanne Bulle is a recent addition to The Gourmet Guardian team and she also travelled from Albury to Sydney for the one day meeting.

These meetings are an important forum for the regulator (in this case the NSWFA) to update auditors on resources, requirements, changes in legislation and also to provide an outlet to discuss any problems or concerns auditors may have and to seek clarification on them.

This meeting was no exception. There are two very important changes that have been made by the NSWFA.

The first is they have updated the audit checklist that all auditors are required to complete and the second is that they have revised the guidelines for businesses serving food to Vulnerable Persons Businesses (VP). The audit checklist was updated to match the guidelines.

If you are a VP business, I feel it is vital, if you have not already done so, to download and print these guidelines to ensure you are complying with them.

http://www.foodauthority.nsw.gov.au/_Documents/industry_pdf/guidelines_vp_2011.pdf Click Here To Download The Vulnerable Persons Business Guidelines

Your next audit will be made using these guidelines and you will be expected to comply with them.

To assist you in understanding the guidelines, I have taken the time to summarise the key changes that were highlighted and stressed to us at the forum.

The guidelines have been clarified and simplified, with the information and requirements now aligned with FSANZ Food Standards Code requirements. The clearer guidelines include:

• Greater flexibility in menu design
• Updates on the definition of what “higher risk foods” are
• Specific allergen control requirements that need to be documented in your food safety program
• Specific requirements for serving food to neutropenic patients/ residents (neutropenic means that they have NO immune system)
• Lettuce can be on the menu and is now encouraged – especially in aged care
• Washing of fruits and vegetables in chemical sanitisers is no longer a mandatory requirement (apart from melons – these must still be sanitised)
• Poached eggs no longer need to be “hard boiled”. The whites still need to be cooked and yolk “starts to thicken” but does not need to be fully cooked
• Cooking temperatures have been updated (there are multiple minimum temperatures listed that depends on the type of food. It was stated that facilities “have the ability” to adjust their temperatures
• Reheating food only needs to be > 60˚ C if the product will be used within 48 hours
• Potentially hazardous foods no longer must be used within 24 hours (48 hours recommended if no label)
• Clarification on the definition of what texture modified and pureed foods are
• Diabetic controls need to be documented and included into the allergen controls
• Infant formula (if applicable) MUST be covered by the food safety program (including milk rooms, sterilising of bottles, and formula made by parents etc.).

That being said, auditors will still be auditing you against what is documented in your food safety program. That means if you do not change your program to reflect these changes, you will still need to comply with your food safety program.

As an example, if you have stated in your food safety program that you sanitise fruits and vegetables, then this is what you will be audited against.

The saying that we always use is that you must “Say as you do” and “Do as you say!”

At the forum, it was stressed that aged care facilities, in particular, need to separate “dislikes” from “allergens”. It is important to confirm with the resident or patient as to why they have a dislike.

Many people have dismissed “dislikes”, however it has been found that perhaps the dislike did stem from a childhood reaction that is an allergen, and that they have avoided the product without actually realising that it is an “allergy”.

Other points that were discussed I think may be of interest were:

• It is expected that FSANZ are going to review microbiological limits for foods to align with international standards in the next two years.
• NSW Health have decided to continue to sanitise all fruit and vegetables, despite the changes indicated above as there is some evidence that there can be a 1 or 2 micro log reduction in pathogens if they are present. Washing under running water has shown to also reduce by one log as well.

In the next couple of weeks, I will send you an update on the main problems I find in audits, along with what your rights are in being able to change from the NSWFA to an approved third party auditor.

The Gourmet Guardian has two auditors that are approved by the NSWFA to conduct third party audits. Both are qualified chefs with more than 30 years combined hands-on cooking experience and both were at the auditor’s forum indicated above.

If you would like to discuss your upcoming audit with us, please contact us on 1800 FOOD SAFETY (1800 366 372).