Food Control 11 (2000) 353±357

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HACCP in Australian food control

Richard Souness *
Australia New Zealand Food Authority, P.O. Box 7186, Canberra, MC ACT 2610, Australia
Received 1 January 1999; accepted 13 September 1999

Abstract
This paper details the reform of food hygiene legislation in Australia as an example of how Australian governments rede®ned
their roles and responsibilities in assessing Hazard Analysis and Critical Control Point (HACCP) like systems. The paper describes
the process of reform, the current hygiene legislation and the cultural change that the reforms promoted. The shift from inspection
of food business to auditing of food safety systems implemented by business is also discussed. The paper also addresses the scope of
a proposed national audit system, including the audit process, the necessary auditor competencies and training of auditors. The
paper concludes by listing the issues yet to be resolved in the reform process. Ó 2000 Elsevier Science Ltd. All rights reserved.

1. Introduction 2. Food hygiene reforms

This paper deals with issues relevant only to Australia
and does not intend to represent any position by New
Zealand on the topic of the paper.
Australia is a federation of eight States and Territo-
ries, with each having its own food legislation and also
the responsibility for enforcing its legislation, resulting
in considerable variation. In 1991, the National Food
Authority (now the Australia New Zealand Food Au-
thority or ANZFA) was established by agreement be-
tween the Federal, State and Territory governments and
was given responsibility for developing and amending
food standards which form the Food Standards Code.
The Food Standards Code is included in all State and
Territory food legislation without variation and so na-
tional consistency is achieved for these food standards.
In 1995, Australia and New Zealand signed a treaty
establishing a joint system for developing food stan-
dards in Australia and New Zealand. ANZFA came
into existence and was given responsibility for managing
this system. The arrangement with New Zealand does
not cover food hygiene regulations. Each country makes
its own arrangements although there are signi®cant
similarities in the approach taken by each country.
*
Tel.: +61-2-6271-2249; fax: +61-2-6271-2685.
E-mail address: richard.souness@anzfa.gov.au (R. Souness).
At present the national food standards as set out in
the Food Standards Code apply to the composition,
safety and labelling of food products. There are cur-
rently no national standards pertaining to the hygienic
production and processing of food in the Food Stan-
dards Code.
Food hygiene regulations are presently developed and
enforced separately by the States and Territories, re-
sulting in signi®cant variation. State and Territory
health departments have recently sought a nationally
consistent approach that is less prescriptive and have
asked ANZFA to develop a new set of food hygiene
standards.
The new food hygiene standards would promote a
preventative rather than a reactive approach to food
safety and ensure that the same hygiene requirements
are enforced throughout Australia. In this way regula-
tory duplication and overlap will be avoided and na-
tional consistency achieved. The hygiene reforms are a
major change in the way food is regulated in Australia
from a Ôcatch us if you canÕ mentality by business and
government to a commitment by all food businesses to
preventing food safety failures from occurring in the
®rst place.
A key feature of the new food hygiene standards will
be the requirement for all food businesses in Australia,
that can identify one or more potential food safety
hazards, to develop and implement food safety pro-
grams based on the Hazard Analysis and Critical

0956-7135/00/$ - see front matter Ó 2000 Elsevier Science Ltd. All rights reserved.
PII: S 0 9 5 6 - 7 1 3 5 ( 9 9 ) 0 0 0 9 1 - 2
354 R. Souness / Food Control 11 (2000) 353±357
Control Point (HACCP) principles. The details and
scope of individual programs would vary according to
the size and nature of the business and the level of risk it
posed to the community. It is recognised that for some
food businesses it is bene®cial to integrate a food safety
program with an appropriate quality management sys-
tem, although government would only assess for com-
pliance with the food safety program component.
The requirement for food safety programs will be
supported by two additional food hygiene standards
currently being developed requiring food businesses to
engage in good hygiene practices (GHP). These proposed
GHP standards focus on outcomes to be achieved rather
than speci®cally prescribing detailed requirements.
All three hygiene standards will be enforced by o-
cers authorised by relevant authorities which in most
cases will be the State and Territory health department.
Enforcement ocers would be encouraged to shift from
an inspectorial role to one involving education, facili-
tating the implementation of food safety programs and
auditing food safety systems. Implementation of the
standards would be phased in over a six-year period
using criteria based on the risk classi®cation of food
businesses.
To support the implementation of the food hygiene
standards in a nationally consistent manner several in-
frastructure initiatives are being developed. These ini-
tiatives include the development of industry guidelines, a
food business risk classi®cation system, training com-
petency standards for food industry workers and a na-
tional food safety audit system.
The audit system currently under development will
require a shift from a Ôsingle point in timeÕ inspection to
government being responsible for auditing the food
safety management system of all food businesses in
Australia. To ensure national uniformity the audit sys-
tem will need to be consistently applied in all Australian
States and Territories.
These food hygiene reforms are occurring in an en-
vironment where governments are seeking to ensure that
the regulatory burden on industry is e€ectively targeted,
monitored and reviewed to ensure intended outcomes
are achieved at least cost to industry.
3. Scope of food safety auditing
An audit is a planned and documented activity per-
formed in accordance with written procedures to verify,
by investigation of objective evidence, that a food safety
management system has been developed, documented
and e€ectively implemented. There are three main types
of audits for food safety managements systems:
· ®rst party, where an internal audit which involves the
food business relying on its own sta€ to verify its own
system;
· second party, where food safety auditing required by
a government agency is undertaken by employees of
the agency; and
· third party, where an audit is carried out by an inde-
pendent, external individual or organisation.
The compliance audit can be a second or third party
and is a focussed, in-depth inspection of the food busi-
ness against the requirements of the food hygiene reg-
ulations. The compliance audit would either determine
the e€ectiveness of the implemented food safety system
or verify that non-conformities identi®ed in a previous
audit have been recti®ed as agreed.
An important consideration for food safety auditors
relates to the issue of con¯ict of interest in relation to
audit activities. To avoid the possibility of con¯ict of
interest, auditors, where possible, should not be in-
volved in the design or implementation of food safety
programs they audit. In general, auditors must avoid
any activities that con¯ict with their independence
of judgement and integrity in relation to their audit
activities.
To achieve cost eciency governments may choose to
provide a choice for food businesses between second and
third party compliance auditors. It will be necessary for
regulatory agencies to ensure that there are appropriate
management systems in place to support both second
and third party auditors. Auditors must be certi®ed and
possess the key competencies relevant to the food op-
erations they audit.
Both EHOs and third party compliance auditors will
have to meet nationally agreed competencies for par-
ticular types of food businesses to audit those types of
businesses. Health departments may seek to be accred-
ited by a recognised accreditation body as a certi®cation
body in their own right for third party food safety
compliance auditors or seek to rely on other accredited
certi®cation bodies for certi®cation of auditors (relying
on nationally agreed auditor competencies for particular
types of food businesses to audit those types of busi-
nesses).
As the HACCP system is increasingly accepted as the
preferred food safety management system individual
food businesses are experiencing costly multiple audits
both by a range of government agencies and food in-
dustry customers. There is a need for reciprocal recog-
nition of food safety audits performed by second and
third party auditors where these audits meet the re-
quirements of the regulations.
4. Audit process
It is generally recognised that programs encompass-
ing GHP can successfully support the development and
implementation of HACCP based food safety programs.
If GHP programs, such as cleaning and sanitation
 R. Souness / Food Control 11 (2000) 353±357
programs, have been properly implemented then the
team developing a food safety program can concentrate
on the application of the HACCP principles directly to
the product and process in question, having some con-
®dence that hygiene matters pertaining to personnel and
the surrounding environment are being controlled.
Consequently GHP programs should be audited in
conjunction with HACCP based food safety programs.
The diculty in assessing compliance with hygiene
requirements is to determine what aspect of GHP and
HACCP an authorised ocer can assess through the
audit process. Successful auditing will depend on the
presence of appropriate documentation of GHP pro-
grams. A food business should document their GHP
programs and ensure that the program is being fol-
lowed. Records detailing the checks carried out and the
action taken must be kept to demonstrate compliance.
The compliance auditor will ensure that the GHP pro-
gram is adequate, the program is being followed and any
non-compliance is detected and corrective action taken.
If appropriate records are not provided, an auditor
would have to rely on traditional inspection to con®rm
compliance with hygiene regulations, which could incur
greater inconvenience and cost to the business.
An auditor will essentially be seeking to verify the
e€ectiveness of a food safety program as it is being
followed. A business will be expected to make available
to the auditor appropriate records which particularly
pertain to critical control points, deviations from critical
limits and corrective actions. The scale and frequency of
the audit must be related to the nature, size and the risk
the businesses poses to public health.
An auditor will seek answers to questions about is-
sues such as:
· the implementation of GHP programs;
· product description and speci®cations;
· production ¯ow diagram;
· the hazard analysis process;
· the identi®cation of critical control points for signi®-
cant hazards;
· the establishment of critical limits and monitoring
procedures;
· the development and implementation of corrective
actions; and
· validation and veri®cation activities.
This question and answer approach to auditing could
encourage a check-list approach for auditing which may
be appropriate, especially for less complex food busi-
nesses. It is important though that this approach does
not evolve into a simple Ôtick the boxÕ approach where
there is no critical evaluation of the food safety man-
agement system.
The ÔapprovalÕ of a food safety program by a gov-
ernment agency is an issue yet to be resolved in Aus-
tralia. There is concern that in approving a food safety
program a food business may pass responsibility for the
355
production of safe food back to government. This could
be avoided by the ®rst audit being used to assess or
verify the appropriateness of the food safety program,
but not approve the program.
5. Auditor competencies
Both public and private sector auditors will have a
role as compliance auditors, although public sector au-
ditors (EHOs) who are authorised under relevant food
legislation will still form the backbone of the compliance
audit process.
Private sector independent (third party) auditors who
want to undertake compliance auditing would have to
seek Ôcerti®cationÕ by a relevant government agency,
normally a health department. EHOs would not have to
be certi®ed by their health department in addition to
already being authorised ocers.
The degree of assurance in the safety of food pro-
duced by the food industry depends not only on the
comprehensiveness and appropriateness of the food
safety program in place but also on the competence of
the auditing personnel and the integrity of the auditing
process. Regardless of whether the auditors are gov-
ernment ocers or private sector compliance auditors
their technical competence needs to be established be-
yond question.
ANZFA is currently developing a set of technical
competencies for compliance auditors. It is proposed
that the food industry will be broadly divided into
classes of businesses based on the complexity of the
business and the overall risk it poses to public health.
Auditor technical competencies for each class of food
business are to be developed and auditors will be ap-
proved to audit businesses up to and including the food
business class for which they meet the competency
standard.
To meet the growing demand for HACCP auditors
by the Australian food industry the Quality Society of
Australasia (QSA) has already developed a set of certi-
®cation criteria for food safety auditors. The QSA uses
these criteria to assess and certify auditors of HACCP
systems for the food industry in Australia.
The QSA system establishes three classes of food
safety auditor, associate auditor, auditor and senior
auditor. Each class of auditors has to meet certain pre-
requisite for the following requirements:
· tertiary or on-the-job training;
· auditor training;
· general work experience;
· food safety experience; and
· auditing experience.
The QSA also prescribes a set of key competency
standards (Appendix A) for food safety auditors. Once
356 R. Souness / Food Control 11 (2000) 353±357
certi®ed, auditor's details are included in a register ac-
cording to their relevant industry experience.
This system has been favourably received by the
Australian food industry although relevant government
agencies are cautious in how they view the role of the
QSA system in compliance auditing. Governments
generally consider they must have the ultimate role in
approval of compliance auditors because of their legis-
lative responsibilities. It would be undesirable though to
have a number of di€erent certi®cation systems for au-
ditors of HACCP based food safety systems.
6. Compliance auditor training
National consistency in the application of food hy-
giene reforms in Australia is an important objective.
Having food safety compliance auditors operating in a
consistent manner is an essential contribution to this
objective and to this end a training competency standard
for auditors is being developed. The competency stan-
dard includes components on food safety program
management, HACCP based quality assurance and
GHP, food safety programs and auditing.
The audit component of the draft competency stan-
dard requires that the auditor has the ability to conduct
an audit of a food safety program and speci®es the
following performance criteria:
· describe how to prepare to conduct an audit of a food
safety program;
· explain the importance of veri®cation of a food safety
program; and
· describe any relevant administrative arrangements
for auditing accountability.
Each performance criteria has an evidence guide
(Appendix B) to assist in the assessment of the perfor-
mance criteria. The competency standard would be used
to guide the development of curricula for training new
auditors and up-skilling practicing enforcement ocers
to become auditors.
7. Legal liability of auditors
Concern has been raised about the legal liability of
auditors who approve food safety programs at a food
premises from which unsafe food is later produced, de-
spite compliance with the approved program.
The liability of all auditors will depend upon their
role. If it is decided that the role of food safety program
auditors is only to verify that food businesses are fol-
lowing their food safety programs, then their liability
will be limited.
However, because food safety program auditing is a
relatively new concept, whether or not an auditor who
negligently approves a food safety program would be
found liable does not appear to have been tested in the
courts. Presumably the main issue a court would con-
sider is whether the negligent approval of the food safety
program 'caused' the loss, or whether the loss would
have been caused despite the auditor's negligence any-
way and therefore the auditor should not be liable.
8. Issues to be resolved
The following issues remain to be resolved in the
development of food hygiene reforms in Australia:
· the approval/assessment of food safety programs;
· the accreditation/certi®cation of auditors;
· the legal liability of auditors;
· the concept of compliance auditing versus enforce-
ment;
· the implication for the primary industry sector of
food hygiene reforms;
· the costs resulting from the implementation of the
new food hygiene regulations, particularly the costs
implications for small business; and
· the need for government services to be open to com-
petition and to ensure competitive neutrality.
1
Appendix A. Key competencies for food safety auditors
1. The ability to identify and assess potential hazards to
safe food production, handling, preparation, storage
and transportation including:
· biological hazards;
· chemical hazards; and
· physical hazards.
2. The ability to assess the e€ectiveness of methodolo-
gies for controlling the hazards identi®ed above.
3. Knowledge of, and experience in, auditing methodol-
ogies as described in ISO 10011 part 1.
4. Knowledge of relevant industry processes and the
ability to assess the adequacy of records for process
control.
5. Knowledge of relevant industry codes of practice, le-
gal requirements, guidelines and standards.
6. The ability to demonstrate the personal attributes
necessary for the e€ective performance of HACCP
or other recognised food hygiene and safety system
audits (ref ISO 10011 part 2 clause 7).
7. The ability to identify food safety objectives in the
context of quality assurance programs.
8. An understanding of the principles and practices rel-
evant to HACCP or other recognised food hygiene
and safety systems.
1
Developed by the Quality Society of Australia.
 R. Souness / Food Control 11 (2000) 353±357
Appendix B. Compliance auditor draft competency stan-
dard performance criteria and evidence guide
1. Describe how to prepare to conduct an audit of a
food safety program:
· identify the steps to be taken in an e€ective audit
of a food safety program;
· explain what is required when seeking objective
evidence;
· describe various questioning techniques applicable
to auditing;
· recognise the desirable skills and attributes of a
good auditor;
· explain the need to review records, food safety
357
manuals and product speci®cations before and
during auditing a food safety program.
2. Explain the importance of veri®cation of a food
safety program:
· list the necessary elements required on forms used
for documenting food safety audits;
· explain the issuing of non-conformance notices
and follow-up procedures.
3. Describe any relevant administrative arrangements
for auditing accountability:
· describe required reporting responsibilities;
· explain the relevant accreditation process for
auditors.