By CELA on 1 Dec, 2023

From December 2024, children's services in NSW (including out-of-school-hours care that provide meals as part of their daily operations) need to comply with new food safety requirements, introduced under Standard 3.2.2A of the Food Standards Code.

If your service processes (cooks) unpackaged food, which is potentially hazardous, and serves it ready-to-eat, you are deemed a Category One business and must implement three management tools under standard 3.2.2A:  

  1. Food safety training to ensure that good handlers have adequate skills and knowledge in food safety and hygiene. 

  1. A food safety supervisor (FSS) readily available to advise and supervise food handlers. 

  1. Evidence to demonstrate compliance with specific requirements in Standard 3.2.2, especially regarding food temperature control, processing, and cleaning and sanitising (via record keeping). 

What is a potentially hazardous food? 

Potentially hazardous foods are foods that must be kept at a particular temperature to minimise the growth of food poisoning bacteria that may be in the food, or to stop the formation of toxins. 

Examples of potentially hazardous food include: 

  • raw or cooked meat

  • smallgoods

  • dairy products

  • seafood (excluding live seafood)

  • processed fruit and vegetables

  • cooked pasta and rice

  • foods containing eggs, beans, nuts, or other protein-rich foods.

Why were the changes introduced?  

In 2018, the Australia and New Zealand Ministerial Forum on Food Regulation identified that food-borne illness outbreaks in Australia were from food service and retail businesses. 

These changes will support services to improve their food-handling skills and knowledge to ensure the health and well-being of the children who attend their service.  

What is a Food Safety Supervisor?  

The Food Safety Supervisor (FFS) oversees the daily food handling operations, guides food handlers to ensure food is stored correctly, and manages any associated risks.  

The FFS must be certified within the past five years and have skills and knowledge in food safety, especially around high-risk foods. 

The service will also need to ensure all food handlers are trained in food safety and hygiene. This is available in the link below as a free non-accredited course. 

Demonstrating food is safe 

This can be achieved by keeping records and demonstrating safe food practices.  

A written instruction sheet and procedures would be useful to support handlers in their day-to-day work handling food.  

Specific activities that must be monitored include:  

  • temperature control during food receipt

  • storage

  • display 

  • transport 

  • pathogen reduction during food processing;

  • minimising time during food processing

  • cooling food

  • reheating food 

  • cleaning and sanitising.  

The requirements do not apply to: 

  • Services handling food supplied by parents or handling only packaged food. 

  • Services where food handling is part of an educational program and not a commercial offering. 

  • Services where the only potentially hazardous food served is milk. 

  • The handling of food for or at a fundraising event or providing food for free. Fundraising event means an event that raises funds solely for a community or charitable cause and not for personal financial gain. 


There are a series of posters and Fact sheets available on the website which you can access by the below links.  

Guidelines to Food Safety Supervisors (FFS) requirements  

Food Handlers Basics training  

Showing that food is safe - Standard 3.2.2A  

NSW Government Food Authority - overview 

About CELA

Community Early Learning Australia is a not for profit organisation with a focus on amplifying the value of early learning for every child across Australia - representing our members and uniting our sector as a force for quality education and care.



Posted on 6 Dec, 2023
hi do you do training to meet the regulation
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