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What is alternative compliance?
Alternative compliance means food safety control measures that can be demonstrated to achieve the same level of food safety as established measures.
Alternative compliance methods must be approved by the NSW Food Authority before they are used.
Guidance for businesses
The NSW Food Authority encourages the use of appropriate alternative control measures, however, it is the responsibility of a food business to demonstrate to the Food Authority that it will achieve an equivalent outcome and not adversely affect the safety and suitability of the food.
Developing Innovative Food Safety Control Measures provides guidance for food businesses on demonstrating equivalent food safety outcomes using an alternative method of compliance and the type of information a business should document.
Approval process
A business that wants to use an alternative compliance method must have approval from the Food Authority before using the method to ensure continued compliance with all relevant food legislation.
Businesses that do not have approval risk being found non-compliant with specific regulatory requirements in the Australia New Zealand Food Standards Code or other relevant food safety standards.
If you are considering an alternative compliance method, you must notify the Food Authority before applying so we can discuss your proposed method with you before you apply for approval.
- Read the Developing Innovative Food Safety Control Measures guide for food businesses on demonstrating equivalent food safety outcomes using an alternative method of compliance.
- Notify the NSW Food Authority by emailing food.contact@dpird.nsw.gov.au to discuss your proposed method.
- Apply using the Alternative Compliance application form and provide relevant supporting documents.
The Food Authority will assess your application and advise you of the outcome.
Meat and meat products
Alternative compliance to Standard 4697 – 2007 Hygienic production and transportation of meat and meat products for human consumption
Part 9 Clause 84 of the NSW Food Regulation 2015 specifies that meat processing plants must comply with the relevant Australian Standards (AS). If a food business continues to have difficulties in meeting the AS requirement, they must apply for an approved alternative compliance.
Cooling of meat products
Part 4 Clause 13 of the AS4696-2007 has the following requirements for cooling meat products:
|
Type of product |
Cooling parameter |
Comment |
|
Cured cooked meats (e.g. hams) |
Cooled so that the temperature of the meat products at the site of microbiological concern:
|
Product is considered to be cured if curing salts have been added at a level which preserves the product, being a minimum 2.5% salt on water phase and 100 ppm nitrite ingoing. |
|
Uncured cooked meats (e.g. roast pork) |
Cooled so that the temperature of the meat products at the site of microbiological concern:
|
|
For both cured and uncured meat products there are provisions for alternative cooling regimes to be used, provided the business can demonstrate to the Food Authority that the finished product is safe.
For example, this can be done by demonstrating compliance with the US Food Safety and Inspection Service (FSIS) ‘Compliance guideline for stabilization (cooling and hot-holding) of fully and partially heat-treated RTE and NRTE meat and poultry products produced by small and very small establishments and revised Appendix B’ (June 2017) or having a suitably qualified food scientist prepare a report that demonstrates compliance with the MLA ‘Guidelines for the safe manufacture of smallgoods – 2nd edition’ (2015).
Alternatively, the business may submit the information requested in the cooling of ham pro forma and the Food Authority will undertake the assessment.
The Food Authority has developed a factsheet for cooling of large meat products.