Australia New Zealand Food Standards Code - Standard 3.2.1 - Food Safety Programs (Australia Only)

The Standard organises around a small set of recurring legal and operational concepts. Each concept is defined or used in a way that allocates primary responsibility to the food business, while linking certain decisions to enforcement agencies or to persons approved under the Act.

Key defined and operative concepts in the text are:

• auditing frequency: defined in clause 1 as "the most recently determined frequency of auditing determined by the appropriate enforcement agency, or a food safety auditor, in accordance with the Act." This concept governs how often an approved auditor must audit a given food business under clause 4(a).
• food safety program: the written program that "satisfies the requirements of clause 5" (clause 1). Clause 3 requires a food business to develop and implement such a program where hazards are identified.
• food safety auditor: a person "approved as a food safety auditor under the Act as a person competent to audit the relevant class of food business" (clause 1). Audit work under clause 4 must be performed by such an approved person.
• monitoring: expressly defined to include "checking, observing or supervising in order to maintain control" (clause 1). Monitoring appears as a discrete duty under clause 5(c).
• appropriate enforcement agency and authorised officer: these terms are not defined within the Standard text but the Standard attributes determinative and inspection roles to those entities. Clause 2(2) and the definition of auditing frequency reference the "appropriate enforcement agency" making classifications and frequency determinations under the Act. Clause 4(c) refers to inspection upon request by "an authorised officer."

Substantive operational obligations flow from those concepts:

• Hazards must be systematically identified (clauses 3(a) and 5(a)).
• Controls and control points must be identified and monitored (clause 5(b)-(c)).
• Corrective actions must be provided for where hazards are not under control (clause 5(d)).
• Records demonstrating compliance and actions taken must be made and kept by the business (clause 5(f); see also clause 4(b) and (c) as to availability and retention of audit reports).

The Standard also embeds a division of decision-making authority. The Standard applies "in accordance with Standard 3.1.1 and subclause (2)" (clause 2(1)); subclause (2) delegates to the "appropriate enforcement agency under the Act" the power to determine which food and primary production businesses are within a priority classification and therefore within the Standard’s scope from the commencement date for that classification (clause 2(2)). That introduces variable application determined by enforcement agencies within the statutory framework of the Act.

Finally, the Standard adopts the HACCP principle as its organising technical framework (Purpose). The HACCP principle is implemented through the structural requirements for systematic hazard analysis, control identification, monitoring, corrective action and record-keeping (clause 5), plus external auditing (clause 4) and regular internal review (clause 3(e); clause 5(e)).

The Standard assigns obligations primarily to "food businesses" and to "food and primary food production businesses" when they fall within the Standard’s application as determined by an appropriate enforcement agency (clause 2(1)-(2)). The word "food business" is used throughout to describe the actor required to carry out hazard analysis, develop the written program, retain the document at premises, comply with it, review it annually, and ensure audit and records availability (clauses 3 and 4). Clause 2(2) makes clear that coverage is not automatic across all enterprises: the appropriate enforcement agency determines which food and primary food production businesses are "within a priority classification of food business" and therefore subject to the Standard from the commencement date for that priority classification.

Other groups and decision-makers affected are:

• food safety auditors: the Standard requires that audits be conducted by a "food safety auditor" approved under the Act (clause 1 definition; clause 4(a)). Approval and competence are matters under the Act. Auditors also can participate in determining auditing frequency where the definition in clause 1 allows them to do so.
• appropriate enforcement agencies and authorised officers: the Standard delegates to these entities the authority to determine priority classifications, and it expressly provides for inspections by authorised officers (clause 4(c)). Auditing frequency is "most recently determined" by the appropriate enforcement agency or by a food safety auditor "in accordance with the Act" (clause 1), which gives enforcement agencies a central role in scope, frequency and enforcement.
• States and Territories: the Purpose states the Standard "enables States and Territories to require food businesses to implement a food safety program based upon the HACCP concepts." That describes an enabling relationship where the Standard provides the normative content and local governments may require implementation.
• persons organising fund raising events: clause 6 exempts "a food business" from preparing a food safety program in relation to a fund raising event conducted by the food business. That creates a narrow class of activity where the written program requirement does not apply.
• the broad public and purchasers of food: indirectly affected because the Standard prescribes processes intended to reduce hazards in food handling. The Standard itself does not describe rights for consumers, but the obligations on businesses and the auditing/inspection mechanisms create potential for external oversight of the safety of food handling operations.

Practical implications for affected parties, as expressed in the Standard, include who must carry out specific activities and retain documents: a food business must retain the written program at the food premises (clause 3(c)) and must retain audit reports for the last four years for inspection by auditors or authorised officers (clause 4(c)). Auditors must be "approved as a food safety auditor under the Act" (clause 1).

The Standard sets a compact set of duties that fall predominantly on the food business and specifies rights of access and inspection for auditors and authorised officers. All duties and several operational requirements are expressed in mandatory language.

Principal duties of a food business

• Systematic hazard analysis: The business must "systematically examine all of its food handling operations" to identify potential hazards reasonably expected to occur (clause 3(a); clause 5(a)). This is a primary investigatory duty.
• Program development and implementation: If hazards are identified, the business must "develop and implement a food safety program to control the hazard or hazards" (clause 3(b)).
• Documentation and availability: The food safety program must be set out in a written document, retained at the food premises (clause 3(c)), and made available to a food safety auditor who has been requested to conduct an audit (clause 4(b)).
• Compliance with program: The business must comply with the food safety program (clause 3(d)).
• Internal review: The business must conduct a review of its food safety program "at least annually" to ensure its adequacy (clause 3(e); clause 5(e) requires regular review).
• Auditing: The business must ensure that the food safety program "is audited by a food safety auditor at the auditing frequency applicable to the food business" (clause 4(a)). The auditing frequency is the most recently determined frequency as set by the appropriate enforcement agency, or by a food safety auditor, in accordance with the Act (clause 1).
• Record-keeping: Clause 5(f) requires the program to "provide for appropriate records to be made and kept" demonstrating action taken in relation to, or in compliance with, the program. Clause 4(c) requires retention of copies of all written reports of audit results conducted by a food safety auditor within the last four years, for inspection upon request by a food safety auditor who audits the program or an authorised officer.

Content duties for the program

• Identify where hazards can be controlled and the means of control (clause 5(b)).
• Provide for systematic monitoring of controls (clause 5(c)); monitoring is defined broadly as including checking, observing or supervising (clause 1).
• Provide for appropriate corrective action when hazards are not under control (clause 5(d)).
• Ensure records demonstrate actions taken and compliance (clause 5(f)).

Rights and inspection powers

• Auditors and authorised officers have a right to inspect program documents and the most relevant records. Clause 4(b) requires the business to make the written program and the appropriate records (clause 5(f)) available to any food safety auditor requested to conduct an audit. Clause 4(c) requires that copies of audit reports for the last four years be retained for inspection upon request by a food safety auditor who audits the program or an authorised officer. The Standard thus creates a structured right of access for auditors and authorised officers to specific documentation.

Delegated decision powers and administrative roles

• The appropriate enforcement agency has decision-making authority to determine which food and primary production businesses are within a priority classification and therefore subject to the Standard from a commencement date for that priority classification (clause 2(2)). The auditing frequency is a "most recently determined frequency" by the appropriate enforcement agency or a food safety auditor "in accordance with the Act" (clause 1). These delegations allocate administrative discretion outside the Standard itself, into the enforcement architecture of the Act.

Exemptions

• The only explicit operational exemption in the Standard is clause 6, which provides that a food business "does not have to prepare a food safety program in accordance with this Standard in relation to a fund raising event conducted by the food business." That narrows the scope of the written-program duty for an identifiable category of activity.

Procedural interaction with the Act

• Several duties refer to approval under the Act or to determinations made under the Act, signalling that rights and sanctions not expressed in the Standard will be found in the Act and in decisions by enforcement agencies. For example, "food safety auditor" requires approval under the Act (clause 1).

The Standard prescribes duties, documentation, audit and inspection rights, but it does not itself set out specific penalties for breaches. Enforcement mechanisms and any sanctions are referenced indirectly through the Act and through the roles of appropriate enforcement agencies, approved auditors and authorised officers.

Inspection and audit as enforcement levers

• The Standard mandates external audits by a "food safety auditor" approved under the Act (clause 4(a); clause 1 definition). Audits are thus a central mechanism for external verification of compliance.
• Clause 4(b) requires the food business to make the written food safety program and the relevant records available to any food safety auditor requested to conduct an audit. Clause 4(c) requires retention of copies of all written audit reports from the preceding four years for inspection upon request by a food safety auditor who audits the program or an authorised officer. These provisions create a record-access regime whereby auditors and authorised officers can review the business’s documentation and recent audit history.

Delegation to enforcement agencies

• The Standard repeatedly places determinative roles with "the appropriate enforcement agency under the Act," for example in determining which businesses fall within priority classifications (clause 2(2)) and, via the clause 1 definition, in determining auditing frequency. The Standard therefore relies on enforcement agencies established under the Act to operationalise how the auditing and compliance regime functions in practice.

Absence of penalties in the Standard

• The Standard contains no explicit fines, offences, or administrative penalties within its text. Any enforcement action, sanctions, or penalties for non-compliance with the duties in clauses 3-5 would therefore arise under the broader statutory framework of the Act and under the powers of State or Territory enforcement agencies or authorised officers referenced in clause 4(c). The Amendment History indicates amendments are made under section 92 of the Food Standards Australia New Zealand Act 1991, which shows the Act is the legislative vehicle for amendments and the legal context for enforcement arrangements.

Practical enforcement implications

• Because audit frequency and scope of application depend on determinations by the appropriate enforcement agency or the most recent decision of a food safety auditor "in accordance with the Act" (clause 1), enforcement intensity can vary across jurisdictions and over time as agencies make classifications and set auditing frequencies. The Standard creates an enforcement architecture focused on documentation, audits, and records rather than listing penalties; therefore the practical effect of enforcement will depend on administrative policy under the Act and on the powers exercised by authorised officers.

Users of this Standard should therefore expect enforcement to rely on audit findings and authorised officer inspections supported by powers and sanctions provided in the Act. The Standard itself does not define the sanctioning instruments.

The Standard expressly embeds interaction with the Food Standards Australia New Zealand Act 1991 and with another Standard in the Code, and delegates to administrative decision-making bodies operating under that Act. The Standard is not a freestanding penal code; it functions as a component of a broader statutory and regulatory system.

Links to the Act

• Multiple provisions reference the Act for functions that the Standard does not itself authorise or supply. The definition of "food safety auditor" requires approval "under the Act" as a person competent to audit the relevant class of food business (clause 1). "Auditing frequency" is to be determined "in accordance with the Act" by the appropriate enforcement agency or a food safety auditor (clause 1). Clause 2(2) expressly ties the Standard’s application to determinations made "by the appropriate enforcement agency under the Act" about priority classifications of food businesses. The Amendment History states amendments are made under section 92 of the Food Standards Australia New Zealand Act 1991 unless otherwise indicated. These cross-references mean that procedural powers, approval processes, enforcement powers, and any penalties will typically be located in the Act and in the administrative instruments made under it.

Relation to other Standards in the Code

• Clause 2(1) states the Standard applies "to food businesses in Australia in accordance with Standard 3.1.1 and subclause (2)." That links the scope and application of Standard 3.2.1 to Standard 3.1.1 and to the determinations made under clause 2(2). The practical consequence is that Standard 3.2.1 should be read and applied together with Standard 3.1.1 to determine which businesses are covered and from what commencement date.

Administrative and enforcement interplay with States and Territories

• The Purpose paragraph indicates the Standard "enables States and Territories to require food businesses to implement a food safety program based upon the HACCP concepts." That indicates the Commonwealth-level Standard sets uniform content and process requirements but leaves implementation decisions and enforcement to State and Territory authorities within the framework of the Act.

Record-keeping and inspection obligations interacting with administrative powers

• Clause 4(c) requires retention of audit reports for the last four years "for inspection upon request by a food safety auditor who audits the food safety program or an authorised officer." The reference to "authorised officer" is to a class of persons typically empowered under enabling legislation or agency instruments. The text presumes inspection powers are supplied elsewhere, notably in the Act or in State and Territory enforcement instruments.

Amendment and legislative process

• The Amendment History in the text states that amendments "are made under section 92 of the Food Standards Australia New Zealand Act 1991 unless otherwise indicated." That identifies section 92 of the Act as the statutory vehicle for changes to the Standard and links the Standard’s evolution and any transitional arrangements to the Act’s procedures.

Operational implication

• Because the Standard defines technical and procedural minimums and expressly delegates scope, approval and frequency determinations to entities operating under the Act, practitioners will need to align their compliance work to both this Standard’s clauses and to the instructions, approvals, classifications and enforcement practices established under the Act and by the appropriate enforcement agency in their jurisdiction.

This compilation is labelled No. 4 of Standard 3.2.1 and is "as in force on 19 July 2023 (up to Amendment No. 220)." The compilation notes that it includes any commenced amendment affecting the Standard up to that date. The Amendment History gives an origin and a list of specific amendments reflected in the instrument. Key points from the Amendment History included in the source are:

• Origin: Standard 3.2.1 was published in the Commonwealth of Australia Gazette No. P 28 on 7 December 2000 as part of Amendment No. 52, 2000. It was registered as a principal instrument on 24 September 2008 (F2008B00578). That establishes the Standard’s initial publication and registration milestones.

• Compilation details: The compilation was prepared by the Office of Parliamentary Counsel, Canberra. It notes this is compilation No. 4, reflecting the instrument as in force on 19 July 2023 and as amended up to Amendment No. 220.

• Specific amendment entries from the table:

  • Amendment No. 220, FRL registration F2023L010041, Gazette FSC160 19 July 2023, commencement 19 July 2023, noted as "am", described as "Correction to table of contents" and affecting "3.2.1,contents".
  • Amendment No. 101, FRL registration F2008L03058, Gazette FSC431 14 Aug 2008, commencement 14 Aug 2008, noted as "am", affecting "3.2.1,1" and described as "Omit the Editorial note following the definition of food safety auditor in clause 1."
  • Amendment No. 101 (same registration), affecting "3.2.1,2", with the description "Omit the Editorial note following clause 2."
  • Amendment No. 67, FRL registration F2008B00814, Gazette FSC931 24 Dec 2008, commencement 31 July 2003, noted as "am", affecting "3.2.1,2(1)", described as "Correction to name of standard."
  • Amendment No. 78, FRL registration F2005L01246, Gazette FSC202 26 May 2005, two entries:
    • affecting "3.2.1,2(1)" with code "rs", commenced 26 May 2005, described "Omit and substitute subclause 2(1)."
    • affecting "3.2.1,2(2)" with code "rs", commenced 26 May 2006, described "Omit and substitute subclause 2(2)."
  • Amendment No. 101 entry also affected clause 4 by omission of an editorial note.
  • Amendment No. 124, FRL registration F2011L01450, Gazette FSC661 11 July 2011, commencement 11 July 2011, noted as "rs", affecting "3.2.1,6", described "Omit and substitute clause 6."

• Uncommenced amendments and cessation: The compilation includes a note explaining that uncommenced amendments or provisions ceasing to have effect may be reflected in the Standard as shaded boxed text with relevant commencement or cessation dates, and that such amendments will be included in a compilation registered on the Federal Register of Legislation once the date is passed. The source also lists abbreviations used in the table such as ad, am, exp, rep, rs.

• Administrative source and legal basis for amendment: The Amendment History explicitly states that amendments are made under section 92 of the Food Standards Australia New Zealand Act 1991 unless otherwise indicated. That establishes the legal authority through which changes to the Standard have been and will be made.

The Amendment History therefore documents both the Standard’s origin and a sequence of technical and editorial changes, including substitution of clauses 2(1) and 2(2) at different points in time and substitution of clause 6 in 2011. The most recent amendment recorded in the table corrected the table of contents and took effect 19 July 2023.

The compilation text for Standard 3.2.1 that you provided does not record any litigation, court decisions, judicial interpretations, or administrative tribunal findings. The Standard itself is a technical regulatory instrument setting duties and administrative procedures; its Amendment History and compilation notes list the statutory amendments and editorial corrections but do not refer to any judgments or cases.

Practical implications of the absence of litigation material in the compilation

• The absence of litigation references means this document alone does not provide any judicial interpretation of the clauses, nor does it reflect how courts or tribunals have applied or enforced the Standard. The Standard refers to roles and approval processes "under the Act" and to determinations by the "appropriate enforcement agency", which implies that legal questions about scope, auditing frequency, approval of auditors, and sanctions are likely to be resolved under the Act and in administrative fora. None of those decisions or outcomes appear within this compilation.

What the compilation does include instead

• The compilation provides the text of the Standard, the operative clauses, definitions, and the Amendment History of the Standard itself. It documents the regulatory text and the sequence of statutory amendments made under the Act, but not any adjudicative outcomes.

What users should note

• For practitioners seeking to understand how the Standard has been applied in contested matters, or how courts or tribunals have interpreted specific clauses, there is no litigation history embedded in this compilation. Any such interpretation or precedent will need to be identified by consulting judicial and tribunal databases, administrative determinations of enforcement agencies, and decisions arising from enforcement actions under the Act or relevant State or Territory laws. That step is outside the scope of this compilation as provided here because the Standard itself does not include those materials.

This Standard contains a number of practical features and delegations that can create traps for compliance if misread or if implementation assumes uniformity that the Standard does not provide. The following points are grounded in the Standard’s text and its Amendment History.

Scope is conditional and administratively determined

• The Standard does not apply uniformly to every food or primary food production business by its own terms. Clause 2(2) states the Standard applies "to all food and primary food production businesses that are determined by the appropriate enforcement agency under the Act to be within a priority classification of food business from the commencement date for that priority classification of food business." That means you cannot assume automatic application: a local enforcement agency’s determination about priority classification controls whether and when a given business becomes subject to the Standard. Practitioners should not treat the Standard as universally applicable to all businesses in a sector without checking appropriate enforcement agency classifications.

Auditing frequency can be administratively or auditor-determined and can change

• "Auditing frequency" is defined in clause 1 as "the most recently determined frequency of auditing determined by the appropriate enforcement agency, or a food safety auditor, in accordance with the Act." That definition allows either an enforcement agency or a food safety auditor, as those roles are constituted under the Act, to determine the auditing frequency, and it ties frequency to the "most recently determined" decision. The practical consequence is that a business’s audit schedule can change over time and may be set either by the agency or by an auditor with authority under the Act. Misunderstanding who has set the frequency or relying on an outdated determination could result in non-compliance with clause 4(a).

Approval of auditors is statutory, not merely contractual

• Clause 1 defines "food safety auditor" as a person approved under the Act "as a person competent to audit the relevant class of food business." That means that conducting an audit under clause 4 requires an auditor with statutory approval. Engaging an auditor who is not approved under the Act will not satisfy clause 4(a). The Standard places the approval requirement in the Act, so businesses and auditors must confirm approval status under that statutory regime.

Record retention window is finite and specific to audit reports

• Clause 4(c) requires retention of "copies of all written reports of the results of all audits of the food safety program conducted by a food safety auditor within the last four years." The Standard thus mandates a four-year rolling retention obligation for audit reports. It does not require retention of audit reports older than four years, though other laws might impose different retention obligations. The Standard also requires the program itself to be retained at the food premises (clause 3(c)), and other records under clause 5(f) to be "made and kept" but without prescribing their retention period except as to audit reports.

Narrow exemption for fund raising events

• Clause 6 exempts "a food business" from having to prepare a food safety program in relation to "a fund raising event conducted by the food business." The exemption is narrow: it applies to events conducted by the food business and does not say anything about events where the business is a vendor or where third parties run the fundraiser on premises. The precise scope depends on the factual question of whether the event is "conducted by the food business."

Annual internal review plus audit obligations

• The Standard requires both an internal review "at least annually" by the food business (clause 3(e)) and external audit at the applicable auditing frequency (clause 4(a)). Meeting one obligation does not relieve the business from the other. A business must maintain an internal review regime as well as have the externally imposed audit schedule met.

Dependency on external administrative instruments

• Several obligations operate only once an "appropriate enforcement agency" has made a determination, or once auditors have been approved "under the Act." That means that some practical aspects of compliance,scope, audit frequency and approved auditors,will be determined outside the text of the Standard. Businesses should verify the relevant agency decisions and approvals rather than relying solely on the Standard’s text.

No in-Standard penalty provisions

• The Standard sets duties and inspection access but does not itself set civil or criminal penalties. Any sanctions for non-compliance will be those provided under the Act or by the enforcement agencies, not within the Standard’s text. This can be surprising for readers expecting an instrument that both prescribes duties and lists penalties.

Editorial and historical quirks in the text

• The Amendment History shows that several editorial changes have been made over time (for example omitting editorial notes in 2008 and substituting clauses in 2005, 2006 and 2011). Practitioners should ensure they are working from up-to-date compilations; the compilation you have is No. 4 as in force on 19 July 2023 (up to Amendment No. 220). Uncommenced amendments may be handled differently in other compilations.

Be precise about which documents must be available during an audit

• Clause 4(b) requires making "the written document that sets out the food safety program, and the appropriate records referred to in paragraph 5(f), available to any food safety auditor who has been requested to conduct an audit." The phrase "appropriate records referred to in paragraph 5(f)" means the requirement to make records available is tied to the particular records that demonstrate action taken in relation to, or in compliance with, the program. Businesses should map which records fall within clause 5(f) to ensure they are available at audit.

The Standard sets a succinct compliance pathway that combines internal systems work, documentation, record-keeping and external auditing. Below is a stepwise, source-grounded checklist derived from the Standard’s operative provisions.

1. Confirm whether the Standard applies to your business

• Check whether your food or primary production business has been determined by the "appropriate enforcement agency under the Act" to be within a priority classification of food business and therefore subject to this Standard from the applicable commencement date (clause 2(2)). Also confirm any interactions under Standard 3.1.1 as clause 2(1) ties application to that Standard.

2. Conduct systematic hazard identification

• Systematically examine all food handling operations to identify potential hazards that may reasonably be expected to occur (clause 3(a); clause 5(a)). This is the foundational HACCP-consistent duty in the Standard.

3. Develop and document a food safety program when hazards are found

• If hazards are identified, develop and implement a food safety program to control those hazards (clause 3(b)). The program must be set out in a written document and retained at the food premises (clause 3(c)). Ensure the document expressly addresses the content requirements in clause 5.

4. Ensure the food safety program contains the mandatory elements set out in clause 5

• Identify where each hazard can be controlled and the means of control (clause 5(b)).
• Provide for systematic monitoring of controls (clause 5(c)); monitoring is to include checking, observing or supervising (clause 1).
• Provide for appropriate corrective action when hazards are not under control (clause 5(d)).
• Provide for regular review by the business to ensure adequacy (clause 5(e)); clause 3(e) also requires an internal review at least annually.
• Provide for appropriate records to be made and kept demonstrating action taken in relation to, or in compliance with, the program (clause 5(f)).

5. Set up record-keeping aligned to clause 5(f) and clause 4(c)

• Create and maintain the records that demonstrate actions taken and compliance with the program. Ensure that copies of all written audit reports produced by a food safety auditor in the last four years are retained and available for inspection by auditors and authorised officers (clause 4(c)). Retain the written program at the food premises (clause 3(c)).

6. Engage an approved food safety auditor and meet audit frequency obligations

• Verify the approval status of any auditor you engage, because clause 1 defines "food safety auditor" as a person approved under the Act. Ensure the program is audited at the auditing frequency applicable to your business (clause 4(a)). Auditing frequency is "the most recently determined frequency" set by the appropriate enforcement agency or by a food safety auditor "in accordance with the Act" (clause 1). Obtain written confirmation of the applicable auditing frequency and maintain records of determinations.

7. Make documents and records available to auditors and authorised officers

• On request from a food safety auditor who has been asked to conduct an audit, make the written program and the "appropriate records" referred to in clause 5(f) available (clause 4(b)). Maintain an organised document set so that both the program and the records that demonstrate compliance can be produced promptly.

8. Implement monitoring and corrective action procedures operationally

• Translate the program’s monitoring and corrective action provisions into operational checklists, schedules and responsible persons so that monitoring (clause 5(c)) and corrective action (clause 5(d)) are effective and evidenced by records as required in clause 5(f).

9. Conduct the internal review at least annually

• Perform and document the program review at least once every 12 months to ensure the program remains adequate (clause 3(e); clause 5(e)). Document the review findings and any changes made to the program.

10. Note the fund raising event exemption where applicable

• If the business conducts a fund raising event, clause 6 exempts the business from having to prepare a food safety program "in relation to a fund raising event conducted by the food business." Confirm that the event is indeed "conducted by the food business" before relying on this exemption.

11. Align with agency directions and keep administrative records

• Since auditing frequency, priority classifications and auditor approval are determined in accordance with the Act by enforcement agencies and approved auditors, maintain records of any written determinations or approvals supplied by the appropriate enforcement agency or by the approved auditor. That will help evidence compliance with clause 4(a) and the definition of auditing frequency in clause 1.

12. Keep up to date with amendments and compilations

• This compilation is No. 4 as in force on 19 July 2023 up to Amendment No. 220. Check for subsequent amendments and any jurisdictional instruments issued by the appropriate enforcement agency or under the Act that may affect application, auditing frequency, or approval of auditors.

By following these steps, a food business aligns its compliance activities to the duties and content requirements set out in clauses 3-5 and meets the auditing and record-keeping obligations in clause 4, while observing the narrow exemption in clause 6 where applicable.