Audits in the food industry

To ensure the regulations are being implemented by licensed businesses the Food Authority:

• licenses a business to operate
• ensures that all new licensees can demonstrate effective long term compliance by undergoing additional licensing audits when first licensed
• provides guidelines to businesses on how to implement and maintain a food safety program
• provides information on food legislation and food safety programs
• conducts routine audits of licensed food businesses to check that there is a food safety program in place and that food safety is being maintained to a specified level

Why are the audits necessary?

The Food Authority has a legislative responsibility to conduct audits of licensed businesses. Audits are necessary to:

• ensure public health and safety
• ensure compliance with Food Regulation 2015 and the Food Standards Code

Without rigorous standards there is a danger of food being unsafe to consume which can cause serious illness, loss of work or even fatalities.

What is in the audit?

During an audit the audit officer will check that:

• there is a food safety program
• all food handling operations have been analysed to identify any critical food safety hazards and procedures put in place to control those hazards
• there are descriptions of all products handled by the business
• there are work instructions and procedures
• there are monitoring forms and they are up-to-date
• the business has designated supervisors and workers responsible for specific jobs
• there is a good manufacturing process which includes hygiene, chemical storage, pest control, training, product recall, internal review and customer complaint handling procedures
• the food business is complying with their food safety program and any relevant legislative requirements
• food handlers have satisfactorily completed the required training to ensure safe food production and to promote a safe food culture within the business

How is the audit outcome determined?

The authorised officer has a list of elements (eg process control, hygiene, sanitation) that have to be checked. If an element is not of an acceptable standard the officer will allocate a certain number of points. The number of points allocated will depend on whether the officer rates the element to be ‘critical’, ‘major’ or ‘minor’. The points allocated for each of the categories are:

• critical – 64 points
• major – 8 points
• minor – 2 points

At the conclusion of the audit the allocated points are added to give a total rating for the business from ‘A’ to an ‘E’ (shown in Table 1).

Table 1: Rating a business 

 A rating of ‘A’ or ‘B’ means the business has achieved an acceptable result for the audit. A rating of ‘C’ is marginal and will result in more frequent audits. ‘D’ or ‘E’ is unacceptable.

To ensure that all new licensees can demonstrate long term compliance with legislative requirements, they will be subject to an increased audit frequency (as outlined in Table 2) before moving to routine audits as part of the compliance audit model.

The increased audit frequency also applies to existing licensed low risk businesses that apply for a high risk licence permission to produce ready-to-eat foods.

Table 2: Licensing audit model for new licensees

*Priority classifications are applied to each NSW food business with Priority 1 being "high risk" and Priority 4 being "low risk". More information on the Priority Classification System can be found on the Food Authority’s website.

Once a food business can demonstrate long term compliance under the licensing audit model, they then move to the compliance audit model where routine audits will be conducted.

How often are routine compliance audits conducted if the business achieves an acceptable audit?

Every licensed business has regular audits. The frequency of audits will depend upon:

• the type of business (a Priority 1 or 2 business),
• the rating received at the last audit, and
• the compliance auditing calendar.

Table 3: Approximate compliance audit frequency of businesses with acceptable or marginal audits

What happens when a business is rated D or E for the audit?

The business will need additional audits, which must be acceptable before it returns to its original schedule of audits. The timeframes below can vary and depend on the compliance auditing calendar.

Table 4: Approximate compliance audit frequency of businesses with unacceptable audits

Additional enforcement action for businesses that rate D or E at a follow up audit

The business has to rectify the problem(s) identified in the audit process.

If the rating is unacceptable in the follow up or additional audits, the officer may issue a penalty notice (PN) and/or an improvement notice.

If the business does not rectify the issues in the improvement notice, the Food Authority may issue a prohibition order or the owner may be asked to show cause why their licence should not be cancelled.

The Food Authority will determine what further action is required for new businesses operating under the licensing audit model who fail to achieve a D or E rating for their second licensing audit.