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Copyright © Freshcare Ltd 2019

www.freshcare.com.au

Food Safety & Quality

Resources

Copyright © Freshcare Ltd 2020

www.freshcare.com.au

Freshcare resources index

FRESHCARE FOOD SAFETY & QUALITY FACTSHEET INDEX Ref: 20201101 PAGE 1 OF 1

Below is a list of resources to assist the implementation of the Freshcare Food Safety & Quality Standard.

Freshcare Factsheets

Freshcare Factsheets are an interpretive guide to the Freshcare Food Safety & Quality Standard.

Freshcare Factsheets are available for download on FreshcareOnline for Growers via www.freshcare.com.au. To have your business logon reissued, please email [email protected] or contact the Freshcare Office on 1300 853 508.

Rules - Two-part audit process.

M1 Scope and commitment

M1 Food Safety Culture (New)

M2 Documentation

M3 Training and development (Updated)

M4 Internal audit, corrective and preventative action (updated)

M5 Customer requirements

F1 Hazard analysis

F2 Growing site

F3 Planting materials

F4 Chemicals

F5 Fertilisers and soil additives

F6 Water

F7 Allergens

F8 Premises, facilities, equipment, tools, packaging and vehicles

F9 Animals and pests

F10 People

F11 Suppliers

F12 Food defence and food fraud

F13 Product identification and traceability (updated)

F14 Incident Management, Recall and Withdrawal

Guidelines for Fresh Produce Food Safety

The Guidelines for Fresh Produce Food Safety (2019) have been used to provide guidance and reference for specified limits within the Freshcare FSQ Standard. In some areas, the Standard requirements exceed those outlined in the Guidelines. The Guidelines for Fresh Produce Food Safety (2019) are available for download on the Fresh Produce Safety Centre Australia and New Zealand website: https://fpsc-anz.com/food-safety-guidelines-2019/

http://www.freshcare.com.au/

mailto:[email protected]

https://fpsc-anz.com/food-safety-guidelines-2019/

Factsheet – Freshcare Two Part Audit Process.

FRESHCARE FOOD SAFETY & QUALITY (FSQ & SC1) FACTSHEET – TWO PART AUDIT PROCESS Ref: 20201101 PAGE 1 OF 2

This factsheet covers:

• What is the two-part audit process?

• What is information communication technology (ICT)?

• Audits that can be conducted using two-part audit process.

• Audits that are not covered under two-part audit process

• What elements are Part A and Part B?

What is the two-part audit process?

Freshcare has developed a process to enable participating businesses to have

their annual re-certification audits conducted in two parts:

• Part A – remote component using information communication technology

(ICT); and

• Part B – completion of the audit through an on-site visit.

This option is available to all participating businesses, who can meet the criteria

and mutually agree to the audit process with their Certification Body.

The two-part audit process is voluntary and shall be agreed with the participating

business and the Certification Body.

What is information communication technology (ICT)?

Information communication technology (ICT) is a fancy word for using internet-

based tools to share documents, conduct meetings, review documents and

records. This includes such things as shared document boxes (Dropbox,

Sharepoint, email) and the use of video conference such as Zoom, Cisco Webex,

Google hangouts etc. It may also include other features like wearable technology

such as “Google Glasses “.

The technology option used will be determined by your Certification Body in

conjunction with the business, but as a business you need to have a good internet

connection for the ICT resources to function effectively.

Audits that can be conducted using two-part audit process

Audits that can be conducted using two-part audit process:

• Re-certification audits for all programs

• Scope upgrades:

o where it is not the inclusion of a new site (crop scope upgrade), based on risk, remote only is permitted.

o where it is the addition of a new site and not greater than four (4)

months until next audit, remote audit permitted until next audit due.

• Agent/ Broker scope under the Supply Chain Standard can be competed fully remotely, particularly where they act as a virtual site.

The same auditor shall complete both Part A and Part B unless there are

extenuating circumstances.

The Part A and Part B audits shall be completed within maximum of 30 days Part A can commence prior to harvest/ operational months as long as Part B is finished within harvest/operational months and within the 30 days.

Audits that are not covered under two-part audit process

Audits that cannot be conducted using two-part audit process:

• Initial audits

• Unannounced audits

Factsheet – Freshcare Two Part Audit Process.

FRESHCARE FOOD SAFETY & QUALITY (FSQ & SC1) FACTSHEET – TWO PART AUDIT PROCESS Ref: 20201101 PAGE 2 OF 2

What is the two-part audit process?

Part A elements can be audited remotely.

Part B elements are to be audited on site.

The table included in this factsheet will be marked:

• A for Part A (remote) audit.

• B for Part B (on-site) audit.

Food Safety and Quality – On farm (FSQ4.2)

Element Part Element Part

M1 Scope and commitment A F6 Water A & B

M2 Documentation A F7 Allergens A & B

M3 Training and development A & B

F8 Premises, facilities,

equipment, tools, packaging

and vehicles

A & B

M4 Internal audit, corrective

and preventative action A F9 Animals and pests A & B

M5 Customer requirements A F10 People A & B

F1 Hazard analysis A F11 Suppliers A & B

F2 Growing site A & B F12 Food defence and food

fraud A

F3 Planting materials A & B F13 Product identification

and traceability A & B

F4 Chemicals A & B F14 Incident management,

recall and withdrawal A &B

F5 Fertilisers and soil additives A & B

Food Safety and Quality – Supply Chain (FSQ-SC1)

Element Part Element Part

M1 Scope and commitment A F5 Allergens A & B

M2 Documentation A F6 Premises, facilities and

vehicles A & B

M3 Training A & B F7 Maintenance, cleaning and

waste management A & B

M4 Inspections, internal audit

and corrective action A

F8 Equipment, containers,

packaging and labels A & B

M5 Customer requirements A F9 Pest management A & B

M6 Business continuity and

incident management A & B F10 People A & B

F1 Hazard analysis A F11 Suppliers A & B

F2 Chemicals A & B F12 Food defence and food

fraud A

F3 Water A & B F13 Product identification and

traceability A & B

F4 Foreign Objects A & B F14 Product withdrawal and recall

A & B

Factsheet – M1 Scope and commitment

FRESHCARE FOOD SAFETY & QUALITY FACTSHEET – M1 SCOPE AND COMMITMENT Ref: 1906 PAGE 1 OF 3


• Scope • Flowchart • Property map • Organisational chart and Position descriptions • Food Safety and Quality Policy

Scope

To ensure activities from all business enterprises undertaken on the property are considered in relation to the Freshcare Food Safety & Quality Program, it is important that the owner or appropriate senior manager defines the scope of the business/operation.

The scope clearly identifies the activities conducted by the business for which Freshcare certification is required (scope category, site address(es), crops grown/packed, destination), and any other business enterprises or activities that are undertaken on the property that need to be considered as part of the Freshcare Food Safety & Quality Program, such as intensive livestock or dairy operations.

The scope must be reviewed if different types of enterprises are introduced or if activities or practices change, to ensure all food safety and quality issues are addressed.

The Freshcare Crop List is a master list of crops that can be specified on Freshcare Certificates. The Crop List may be used as a reference when identifying the crops grown for which Freshcare certification is required.

The Freshcare Crop List is available for download via Freshcare website: www.freshcare.com.au/resources/freshcare-crop-list

Flowchart

All property activities undertaken by a business should be identified in a flowchart. A flowchart template is provided with Freshcare Forms (refer to Form – M1 Flowchart), which outlines generic practices undertaken in horticultural production.

Flowcharts will be completed differently by each business, depending on the business enterprises undertaken on the property.

Update the flowchart (or develop your own) to ensure all production and post-production practices undertaken by your business are identified and selected.

Property map

A property map is required to identify property areas, infrastructure and surrounding areas.

A property map can be aerial photographs, topographical maps, cadastral maps, self-drawn maps or overlays that document and define the required features and infrastructure on or adjacent to the property.

FSQ4.1 Standard M1.2.1 specifies what must be identified on the property map. The property map must be maintained and updated as required.

Organisational chart and Position descriptions

An organisational chart should be documented to demonstrate the workers responsible for the management of compliance to the Freshcare Food Safety & Quality Program, and to identify the reporting relationships (flow of information) of all workers whose roles may affect food safety and quality compliance.

The organisational chart should identify who is responsible for the management of food safety and quality i.e. owner, site manager or QA manager, and how other workers report to this manager.



Example organisational charts including an indication of reporting relationships are provided:

Example Organisational chart – simplified business structure

Example Organisational chart – more complex business structure

Food Safety and Quality Policy

The Food Safety and Quality Policy will incorporate the business’ existing commitment statement and extend to establishing measurable objectives associated with the businesses commitment to food safety and quality, including the businesses commitment to meeting the requirements of the Freshcare Food Safety & Quality Standard, the Freshcare Rules and all legislative requirements.

Whenever you write the food safety objectives for your food business always check that they cover these five aspects:

“SMART”

Specific to your business

Measurable (via monitoring and use of data)

Achievable,

Realistic and have a

Timeframe for completion.

Examples of measurable objectives could include

• reduction in complaints by x% each 6 months

• reduction in rejections of product from customers by x% each year

• to complete food safety induction training for new employees before job commencement

• to ensure 100% of product labelled correct first time

• to increase the pick rate by x%.

The Food Safety and Quality Policy must be reviewed at least annually, and when changes occur that may impact food safety or quality. This review shall be recorded, regardless of whether there are any changes to the Food Safety and Quality Policy.

Owner/Manager Food Safety and Quality

Seasonal labour Spray contractor

Pickers

Packers

Owner

Farm manager Field manager Packhouse manager Food Safety and Quality

QA manager Food Safety and Quality

Spray contractor Pickers Packers



The Food Safety and Quality Policy must be communicated to all workers, to ensure an awareness throughout the business of the importance of maintaining food safety and quality practices. All workers have a responsibility to the management of food safety and quality on-farm and should be encouraged to monitor and report on activities associated with the Freshcare Food Safety & Quality Program.

Prominently displaying the Food Safety & Quality Policy will remind visitors, contractors and workers of the importance the business places on the Freshcare Food Safety & Quality Program.

Factsheet – M1 Food Safety Culture

FRESHCARE FOOD SAFETY & QUALITY FACTSHEET – M1 FOOD SAFETY CULTURE Ref: 20210409 PAGE 1 OF 4


• Food Safety Culture

Food Safety Culture

Food Safety Culture is defined1 as “shared values, beliefs and norms that affect mindset and behaviour toward food safety in, across and throughout an organization and industry – vertically and horizontally.”

The Freshcare Standards have helped build food safety culture within the Australian fresh produce industry since the launch of the Program in the year 2000.

Through the embedded continuous improvement cycle, promoting program ownership and management commitment, a focus on training and development of workers, and the application and implementation of the program across the whole business, the Freshcare Standards have been the driver for keeping food safety front-of-mind, for Australian businesses in the fresh produce supply chain.

A good food safety culture can protect:

• consumers from foodborne illness • your business’ reputation • your business from financial loss.

This is regardless of the size and structure of your business.

Removing the negative behaviour based human factor is also key in driving a food safety culture. Businesses thinking “it will not happen to me”; “nothing has gone wrong - I know what I am doing”; and “there are more important matters” all need to be removed from the culture of the business for culture change to be a success.

1 https://mygfsi.com/wp-content/uploads/2019/09/GFSI-Food-Safety-Culture-Full.pdf?mc_cid=ad8e8b45e3&mc_eid=33b45c413d

However, training and knowledge alone will not mean behavioural change; the key to long term behavioural change is through effective leadership, proactively addressing issues, engagement with all employees, shared importance placed on food safety and quality.

Simple things such as observing all workers washing hands thoroughly and frequently are measures that can drive improvement in food safety.

A positive food safety culture is achieved within a business when there are shared values and a committed focus on delivering safe food by everyone. The top ways Freshcare helps businesses achieve this is by:

• Promoting program ownership • Management commitment • Hazard and risk awareness • Focusing on people • Providing support resources • Verification and continuous improvement

https://mygfsi.com/wp-content/uploads/2019/09/GFSI-Food-Safety-Culture-Full.pdf?mc_cid=ad8e8b45e3&mc_eid=33b45c413d



Promoting program ownership

Freshcare requires food safety program ownership by the participating business. Unlike other certification schemes, the Freshcare program ownership starts with training by a representative of the business. Freshcare food safety training covers the Standards’ requirements, Good Agricultural Practices (GAP), and HACCP principles, to ensure an understanding of the practices required to identify, mitigate and manage food safety risks is gained, and the required records and evidence needed to be kept, to verify compliance.

This is achieved through compliance to:

• M3.1 – Complete Freshcare training. • M1.4 - Document the business commitment to food safety and quality

and the Freshcare Program.

Management commitment

A food safety and quality policy (previously commitment statement) must be established by each Freshcare participating business and must be communicated to all workers, to ensure an awareness throughout the business of the importance the business places on maintaining food safety and quality practices. All workers have a responsibility for the management of food safety and quality and are encouraged to monitor and report on activities associated with the Freshcare program.

Setting measurable objectives for food safety and quality within the business, should include an objective related to food safety culture. This sets the direction and expectation of the business and must be aligned to the business goals and captures any changed circumstances – such as buying a new business, adding new products, sudden increases or decreases in supply volume, changing your supply chain (new customers), all of which can have an impact on culture.

Another demonstration of management commitment is through M1.3, and the provision of suitably qualified workers to implement, maintain, review and improve the food safety program of the business.

• Person appointed understands the business operations, products risks, legislative requirements, including any international requirements where it applies, and the Freshcare Standard and Rules.

• Person appointed understands what actions should be taken when a food safety risk is identified.

• Person appointed understands reporting requirements related to food safety (and other) incidents and how to undertake corrective and preventative action.

• Person understands food safety culture and how a positive culture in the business contributes to food safety (and quality) and communicates positively within the business on food safety culture and performance.

• Person understands actions that need to be taken where food safety culture issues are identified, including communicating expectations, re-training, changing processes.

Documenting these key objectives of the appointed food safety responsibility in the position descriptions (Form M1 – Position descriptions) and providing adequate training to this person is important.


• M1.1 - Define the business scope and the scope of Freshcare certification.

• M1.3 - Define the roles, responsibilities and reporting relationships of workers responsible for the management of food safety and quality.

• M1.4 - Document the business commitment to food safety and quality and the Freshcare Program.



Hazard and Risk awareness

Knowing the current and potential hazards and risks related to your business, industry sector at all levels is key to building and sustaining a food safety culture.

This is also knowing about entering new markets, serious food safety incidents and science, emerging food safety issues, new technology and analytical advances that may need to be considered and adapted by your business to ensure broader understanding of potential risks and hazards. Communicating the food safety risk(s) of the business is a challenge but ensures early detection of hazards or the “something does not look right” principle, and by encouraging workers to report their concerns and make decisions for safe food. Everyone must have procedures and/or work instructions including food safety and known hazards and risks for each of their tasks. This should include the important pre-requisite programmes such as cleaning, maintenance, allergens and pest control. Internal audits, review of incidents and near misses, corrective and preventative actions and behavioural observations all go together to manage hazards and risks.


• F1 Hazard Analysis • F7.1 - Identify and manage potential sources of allergens. • F8.1 - Construct and maintain growing, handling, packing and storage

facilities to ensure they are suitable for the production and preparation of produce.

• F9.2 - Document and implement a plan for managing pests. • F12.1 & F12.2 - Identify potential food defence and food fraud threats

that may impact food safety and implement control measures where required.

• F14.1 - Maintain an incident management plan to ensure produce that does not meet food safety requirements is effectively managed.

• M4.1 - Conduct internal audits to verify ongoing compliance with this Standard.

• M4.2 - Complete corrective actions for any non-compliance. • M4.3 - Conduct a management review of compliance and documentation.

Focussing on People

People are the fundamental key to successful fresh produce businesses. They are also the key to creating a positive food safety culture within each business. The Freshcare Standards have an element focused on ‘People’ and the role they have in managing risks and promoting food safety. Training of workers and briefing visitors in the food safety requirements and practices of the business helps to demonstrate the value the business places on food safety and emulates a positive food safety culture.

A business that devotes time and attention regularly to food safety information, education and accountability, and extending this to consider differences in language, literacy and education, cultural background and beliefs, socio economic status, and even gender of the workers helps sustain a strong food safety culture.

Additionally, through establishing strong external and supplier relationships through overseeing the material and services used within your business ensures your suppliers share your values.


• M1.3 - Define the roles, responsibilities and reporting relationships of workers responsible for the management of food safety and quality.

• M3.2 - Train all workers who complete tasks relevant to this Standard to ensure a base level of food safety awareness.

• F10.1 Food safety instructions are communicated to workers and visitors to minimise the risk of chemical, microbial and physical contamination of produce.

• F10.2 - Manage access to the property, growing sites and product handling areas to minimise the risk of contamination of produce.

• F11.1 - Identify and manage materials and services that may introduce a food safety risk.

• F11.2 - Manage Freshcare Certified produce.



Providing support resources

In addition to the training providing a program support resource, Freshcare provides its participants with program resources and supporting guidance including worked examples, forms, risk assessments, and farm signage templates.

Freshcare also provides technical support to industry via direct contact with the Freshcare office, T: 1300 853 508, E: [email protected]

Businesses can further identify where improvements in food safety culture can be driven, through using tools such as the FSANZ Food Safety Culture2 resources

Step 1 – Know: www.foodstandards.gov.au/foodsafety/culture/Documents/food-safety-culture-questionnaire.pdf

Step 2 – Do: www.foodstandards.gov.au/foodsafety/culture/Documents/food-safety-culture-checklists.pdf

Step 3 – Follow Through: www.foodstandards.gov.au/foodsafety/culture/Documents/Step%203%20for%20web%20-%20Track%20and%20improve%20July%202019.pdf

Verification and continuous improvement

Food safety management within each business requires the continued application of the plan, do, check, act cycle of continuous improvement. Successful implementation and ongoing program management of the Freshcare Standard will ensure awareness of food safety by all workers and embed food safety and quality as part of the everyday practices of the business.

Annual audits, conducted by independent third-party auditors, against the Freshcare program provide verification that the continuous improvement cycle

2 https://www.foodstandards.gov.au/foodsafety/culture/Pages/default.aspx

and management of food safety and quality are in place and provide certification as a recognition of success.


• M2.2 - Verify compliance with the Freshcare Standard through relevant documents and records.

• M4.1 - Conduct internal audits to verify ongoing compliance with this Standard.

• M4.2 - Complete corrective actions for any non-compliance. • M4.3 - Conduct a management review of compliance and

documentation. • Third Party Certification (External) Audits.

Regular communication, education, measuring performance, teamwork and personal accountability are vital to advancing a food safety culture. It’s not a “one size fits all” approach, and what works for a smaller operation, may not work for a larger one, who could also have many smaller “operations” residing within it, and this adds another layer of complexity.

Finally, a culture change takes time, don’t rush it.

mailto:[email protected]

http://www.foodstandards.gov.au/foodsafety/culture/Documents/food-safety-culture-questionnaire.pdf

http://www.foodstandards.gov.au/foodsafety/culture/Documents/food-safety-culture-questionnaire.pdf

http://www.foodstandards.gov.au/foodsafety/culture/Documents/food-safety-culture-checklists.pdf

http://www.foodstandards.gov.au/foodsafety/culture/Documents/food-safety-culture-checklists.pdf

http://www.foodstandards.gov.au/foodsafety/culture/Documents/Step%203%20for%20web%20-%20Track%20and%20improve%20July%202019.pdf

http://www.foodstandards.gov.au/foodsafety/culture/Documents/Step%203%20for%20web%20-%20Track%20and%20improve%20July%202019.pdf

Factsheet – M2 Documentation

FRESHCARE FOOD SAFETY & QUALITY FACTSHEET – M2 DOCUMENTATION Ref: 1906 PAGE 1 OF 2


• Procedures and Work Instructions • Freshcare documents required to be kept • Record keeping to verify compliance • Developing effective records • Document control • Storing records

Freshcare documents required to be kept It is a requirement that Freshcare participating businesses have a current edition of the Freshcare Food Safety & Quality Standard, and Freshcare Rules.

These documents along with record keeping forms, example templates, factsheets and updates are available via Freshcare Online for Growers, accessed via the Freshcare website: www.freshcare.com.au.

Procedures and Work Instructions

The Freshcare Standard requires that businesses document their processes for activities that impact food safety via procedures and work instructions.

Procedures and work instructions are required to be reviewed at least annually or when changes to processes occur.

Examples of procedures and work instructions that may need to be documented for a business could include:

• handwashing and hygiene requirements • use of Protective clothing • inspection of growing sites prior to harvest • incoming Inspection • control of tools and knives • operation of wash baths, flumes and treatment tanks • product and label changeover • product sampling and testing.

Remember, once documented, the procedures and work instructions must be implemented and kept up to date. The M3 Factsheet – Training gives the guide on training workers in these procedures and work instructions and what records to keep.

Record keeping to verify compliance It is important to maintain all records as outlined in the requirements of the Freshcare Food Safety & Quality Standard. Records are used to verify your compliance to the Standard at audit, and to demonstrate ongoing management on-farm. All records kept are required to include the following (as a minimum):

• title • date of issue or version number • your business name • the name of person completing the record • the date record was completed.

Other specific record requirements are outlined in individual elements of the FSQ4.1 Standard, guidance on records required is also outlined in the related factsheets.

Freshcare have developed form templates which reflect the record keeping requirements of the Standard. These are provided in word format and may be used as is or modified to suit your business. It is not mandatory to use the Freshcare form templates, however the required information as specified in the Standard must be captured.


Factsheet – M2 Documentation

FRESHCARE FOOD SAFETY & QUALITY FACTSHEET – M2 DOCUMENTATION Ref: 1906 PAGE 2 OF 2

Developing effective records

To be effective, records should be:

• legible • user friendly • clearly understood • relevant to the situation • consistent in format • identified with a version number or date of issue • maintained and kept up to date, with out of date versions replaced • signed and dated by the person completing the record • easily accessible, located where needed.

Document control

Someone in the business needs to take responsibility for managing documents and records to ensure that only the latest version is used and are available where needed. This applies to business documents and records, and to external documents such as off-label permits and quarantine regulations.

Storing records

Records may be kept in hard copy, soft copy, electronic or digital format. Whichever format your business chooses to capture the required information, it needs to be maintained and secure. Completed records need to be stored in a safe and secure location for possible reference at a later time or during your audit. IT systems should have backup processes in place, and the backups be held secure.

The default retention period for records required by the Freshcare Standard is 2 years, although state-based legislation or your customers may require longer retention periods for some records. For example, some States and Territories require chemical application records be kept for at least 3 years.

Factsheet – M3 Training and development

FRESHCARE FOOD SAFETY & QUALITY FACTSHEET – M3 TRAINING AND DEVELOPMENT Ref: 20201101 PAGE 1 OF 2


• Freshcare training • Other training requirements • Review of training needs and development

For more information refer to the Guidelines for Fresh Produce Food Safety (2019) Chapter 14 Managing people, page 72.

Freshcare training

It is a requirement that a management representative from each participating business completes approved Freshcare Food Safety & Quality training. Approved Freshcare training includes:

• Freshcare Food Safety & Quality Edition 4.1 training • Freshcare Food Safety & Quality Edition 4 training • Freshcare Food Safety & Quality 3rd Edition training.

Approved Freshcare training is provided by Freshcare trainers or via Freshcare eLearning. Details of training courses are available from the Freshcare website: www.freshcare.com.au.

Where in the case that the trained representative leaves, the business shall require a new trained representative to commence training within three (3) months.

A certificate of the training (detailing the trainee name, trainer and date of training) must be kept as evidence that approved Freshcare training has been undertaken by a management representative.

Other training requirements

Workers whose roles could have an impact on the food safety and quality management of the business should have adequate knowledge and skills to perform the duties required of them. Their training needs relevant to the Freshcare Food Safety and Quality Standard also need to be considered, with appropriate training planned and carried out.

Within the business, the most appropriate person must conduct internal training. For example, the person on farm that has completed recognised farm chemical user training would be responsible for training other workers in chemical handling and application.

All workers (and contractors) must receive basic food safety training before starting work, and as a minimum, food safety instructions must be provided (refer to Form – F10 Food safety instructions) including requirements for health status, personal hygiene, protective clothing (where applicable), management of clothing and personal items and general behaviour.

Training needs to be provided in the relevant language for workers and/or pictorially.

Records of internal and external training must be kept, and include:

• name and signature of trainee • name of trainer/training provider • title or topic of training • date of training and expiry date (when applicable).

Review of training needs and development

A review of all training by the owner or appropriate senior manager is to be conducted at least annually; or when processes change or a worker’s tasks change; or a new worker is appointed.

The training review will help identify any new training needs of workers, or refresher training that may be required to ensure adequate knowledge is present for all tasks undertaken.


Factsheet – M3 Training and development

FRESHCARE FOOD SAFETY & QUALITY FACTSHEET – M3 TRAINING AND DEVELOPMENT Ref: 20201101 PAGE 2 OF 2

This review should also highlight any qualifications licences and permits that are due for renewal. This can capture any food safety and quality related training (such as HACCP), as well as other needs of the business, such as safety (forklift, driving license etc).

It is a good management practice to advise workers that it is also their responsibility to identify training needs within a business. Workers should be encouraged to notify the owner or senior manager if they identify a process, task or area where further workplace training or external training may be required.

Further training or refresher training to Freshcare FSQ could be recommended by the auditor conducting your external FSQ audit. This would only occur if inadequate understanding, implementation or management of the Freshcare FSQ Standard was evident during the external audit.

Factsheet – M4 Internal audit, corrective and preventative action

FRESHCARE FOOD SAFETY & QUALITY FACTSHEET – M4 INTERNAL AUDIT, CORRECTIVE AND PREVENTATIVE ACTION Ref: 20201101 PAGE 1 OF 4


• Defining audits

• Internal auditing

• External auditing

• Two-part audit process

• Corrective and preventative action

• Management Review

Defining audits

An audit is a formal review of practices.

An internal audit is when a worker representing the business, reviews on-farm

practices.

An external audit is when a customer or an independent organisation (auditor

from one of the nominated Freshcare Certification Bodies) reviews the business

practices.

Internal auditing

The purpose of internal auditing is to:

• confirm that practices are being carried out as required by the Freshcare

Standard(s)

• ensure records are up-to-date, accurate and contain all the required

information

• identify inefficiencies and problems and correct them.

Who should conduct the internal audit?

Any person representing the business can conduct the internal audit. This may be

an owner, worker or external consultant. If it is an external consultant, it is

important that the owner or senior manager is made aware of the results of the

internal audit.

Ideally, the person conducting the internal audit should be independent of the

practices being carried out, however Freshcare recognises that this may not be

achievable by some businesses.

How often should internal audits be done?

It is always best to do an internal audit before any external audits from customers

or other independent organisations are undertaken, as it is better for you to

detect problems and correct them before the external auditor does. A good

practice is to break the internal audit into the sections of the Standard and

complete as several smaller activities and spread across the year. The Internal

audit form is designed to enable this to be done.

Freshcare requires businesses to conduct a minimum of one internal audit each

year, covering all elements of the Freshcare FSQ Standard. A record of internal

audits must be kept.

Internal audit report

Form – M4 Internal audit report, provides a useful tool to assist you in conducting

your internal audit. It provides a simple, systematic outline of the Standard

elements to assist you in reviewing practices.

Sections of the internal audit report should be signed and dated by the person

completing that section. Once completed the internal audit report provides a

record of the internal audit conducted and any areas that need to be addressed

or actioned as a corrective action.

Conducting an internal audit

Conducting an internal audit involves:

• talking to workers

• observing operations

• checking records for accuracy and completeness.

• recording the detail of what you find – both positive thing as well as any areas

to be addressed.



External auditing

An external audit is a review of your practices and documentation by someone

external to your business, such as a customer or an independent auditing

organisation – a Certification Body.

Customer audits (2nd party)

Wholesalers, packers and processors who have implemented a quality

management standard or code of practice may be required to carry out an audit

of their suppliers. They may carry out the audit themselves or contract an

external auditor.

Their audit activities may include:

• checking your records

• reviewing your internal audit report

• requesting a copy of your Freshcare certificate

• carrying out on-site audits of operations on your farm.

Independent or external audits (3rd party)

An independent or external (3rd party) audit will provide objective evidence of

compliance against a nominated code or standard. It is carried out by a

certification body independent of your business and of your customers. A

Freshcare audit is a 3rd party audit and will provide objective evidence to your

customers that you have met the requirements of Freshcare Food Safety &

Quality Standard.

The independent or external audit provides customers with the option of using 3rd

party auditors rather than doing the auditing themselves. It also means one audit

may satisfy all your customers, rather than having many customers auditing your

business. Auditing of the Freshcare Standard is managed by Freshcare Ltd and its

approved Certification Bodies.

Preparing for an external audit

The idea of an audit is not to ‘pass’ or ‘fail’. The audit should be an opportunity to

identify areas in your business where procedures and practices can be improved.

Part of the auditor’s role is to be helpful and understanding of your needs.

The most important thing to do is review your practices and documentation to

ensure that everything has been identified and applied as required by the

Standard. Use your internal audit checklist to complete this process.

Make sure records are up-to-date and available (or easily retrievable) for the

auditor to review.

What will happen on the day of the external audit?

Your audit will consist of three stages: the entry meeting, the audit, and the exit

meeting.

At the entry meeting, the auditor will discuss your business, your expectations,

describe what will happen during the audit and set a timeframe for the audit.

During the audit itself, the auditor will be looking for objective evidence that

requirements of the Freshcare Standard are being met. The auditor does this by

asking you questions, talking with your workers (and observing practices) in the

work environment and reviewing your documents. The auditor will be working

through a checklist similar to your internal audit checklist.

At the exit meeting the auditor will discuss their audit findings and provide you

with a summary of their findings. They will identify the strong points of your

system and any areas that you may need to improve. You will be invited to

respond and comment about the audit or audit process. If there are things that

need to be rectified (corrective actions) before certification is recommended,

they will be discussed at this point. Agreement is reached about what needs to be

done and when it will be done. A copy of the corrective action will be left with

you at the end of the audit.



Two Part Audit Process

Freshcare has recently made the option of having a two-part audit process

available for the conduct of external (3rd party) audits. This two-part audit process

allows you to send some of your documents and records to your Certification Body

for them to assess remotely (Part A) along with a formal meeting using

Information Communication Technology (ICT), and then once this is done, the

remaining sections are verified on site (Part B) to finalise the audit process.

There is a factsheet available to support this process and this should be read in

conjunction with this factsheet.

Corrective and preventative action

Despite best intentions, you can still encounter problems from time to time.

Whenever a problem arises, you must take action to ensure that the problem has

been brought under control. Further actions may be required to prevent the

problem happening again, thereby improving the system.

Keeping a record of corrective actions helps you to look back at problems that

have occurred in the past and show customers and other external bodies that you

have a system in place to fix such problems.

A Corrective Action Record (CAR) is completed when requirements of the

Standard are not being met, problems have caused or have the potential to have

significant food safety or quality implications. The recording of near miss activities

is also useful in identifying any areas where procedures or processes may require

additional support through training etc.

An important aspect of corrective action is checking that the steps taken have

been effective in eliminating or controlling the problem. Once the actions are

completed, a review must be conducted to ensure actions taken have been

effective. This is often termed preventative action.

If the problem has not been fixed, or the same problem reoccurs, then the action

has not been effective and another CAR must be completed, including alternative

actions.

Reoccurrences of non-compliance must be reviewed by the owner or appropriate

senior manager, to ensure adequate measures are taken to effectively address

the problem and prevent the non-compliance from occurring again. This can be

included as part of the management review.

Documenting corrective actions

A Corrective Action Record (CAR) should be completed when the requirements of

the Freshcare Food Safety & Quality Standard, Freshcare Rules or legislation are

not being met. Issues may be identified through:

• routine activities

• internal audits

• external audits

• receival of a compliant

• produce identified as being contaminated, or potentially contaminated

• incidents.

Non-conforming product is identified during monitoring, or incidents.

Form – M4 Corrective action record (CAR) provides you with a template to be

used when an issue is identified.

CARs should be interpreted as a tool for documenting and demonstrating

continuous improvement, as they provide the mechanism for identifying a

problem, whether it has occurred before, how the problem is being managed and

what resolve has been established to prevent the problem from occurring again.

Management Review

The objective of the management review is to ensure the Food safety and quality

system implemented remains suitable, adequate and effective.

A Management Review is a formal, structured meeting which involves owners

and/or senior managers of the business and takes place at regular intervals

throughout the year but must occur at least annually.



The Management Review encourages management to consider the degree by

which the Freshcare System:

• continues to meet the businesses requirements and achieve the expected

results

• identifies any additional risks or practices to be considered

• functions in accordance with the established operating procedures and

processes

• can identify non-conformities and monitoring of effectiveness of

subsequent corrective and preventive actions.

A Management Review also ensures that all levels of management are made

aware of any changes, updates, revisions, etc. to the day-to-day workings of the

Management System itself, including policies and procedures.

An important part of your planning should be to produce an agenda for your

meeting that can then form the basis is the records you are required to keep. A

detailed and agreed agenda will help you to ensure all topics required by the

Freshcare Standard are covered, especially if you decide to hold multiple reviews

throughout the year focused on different topics.

A Management Review should cover the following topics:

• Discussion on the status of any issues from the previous meeting

• internal and external audits

• corrective and preventative actions

• customer feedback

• complaints

• training

• the food safety and quality policy and measurable objectives

• identification of further opportunities for improvement.

The Freshcare Form – M4 Management Review Minutes has been provided as a

template for capturing a record of the management review/meeting process and

includes the required agenda items.

Please note that this form is provided is a suggested template only – minutes in an

alternate format; diary entry of the actions and discussion; or alternate records

could be used as evidence for the management review taking place.

Factsheet – M5 Customer requirements

FRESHCARE FOOD SAFETY & QUALITY FACTSHEET – M5 CUSTOMER REQUIREMENTS Ref: 1906 PAGE 1 OF 2


• Customers

• Product specifications

• Customer requirements

• Checking final product

Customers

A customer is the business to whom you supply produce. This may be a

commercial packer, marketing group, wholesaler, processor, retailer, export or

domestic market buyer.

Meeting customer expectations is an important part of any business. To be able

to meet these expectations, a clear understanding of what the customer requires

is essential.

Customers will often set specific specifications and requirements for suppliers to

comply with. These may be issued as part of your contract, written agreement or

provided in writing.

Product specifications

A product specification is a clear description of the features of the produce for

sale and any special handling requirements. The specifications can be provided by

your customer or developed by you in consultation with your customer.

Growers who supply produce to commercial packers or processors will require a

specification for harvested produce, while growers who pack their own produce

for commercial packers will require a specification for packed produce.

Contact your customer to see if they have a product and handling specification. If

not, check to see if there is an industry standard you should be following,

consider developing one with your customer.

Customer product specifications most commonly relate to:

• Product quality

o variety, size, maturity, colour

o defect allowances/tolerances.

• Handling requirements

o temperature management

o handling instructions

o packaging

o transport.

• Food safety requirements

o contaminants

o compliance with a nominated standard such as Freshcare Food Safety &

Quality.

Examples of product specifications can be found online via the FreshSpecs

website: www.freshmarkets.com.au/fresh-specs.

Customer requirements

Customer requirements are other specific requirements set or agreed with your

customer.

For example, Freshcare have established acceptable microbiological limits for

produce, water and fertilisers containing manures and therefore does not require

microbial testing on the final product. Your customer may require you to verify

that your produce complies with microbial limits by final product testing (for one

product, or all product lines). This is above what is specified as a requirement by

the Freshcare Code.

http://www.freshmarkets.com.au/fresh-specs

Factsheet – M5 Customer requirements

FRESHCARE FOOD SAFETY & QUALITY FACTSHEET – M5 CUSTOMER REQUIREMENTS Ref: 1906 PAGE 2 OF 2

Checking final product

Why check product

Where a customer has provided a written specification, harvested and packed

produce should be checked to confirm that the product and handling

specifications have been achieved. If produce does not meet the written

specification, the customer (packer, processor, wholesaler or retailer) should be

informed before dispatch.

If testing is required as a customer requirement, sufficient produce should be

sampled to ensure that the assessment result is representative of the whole

batch. Some customers may specify the sample size in their written specification

or their approved supplier program.

Notifying the customer of variations

The customer should be notified if product does not meet their specification.

Keeping a record of your notification and the customer’s advice will help if any

complaints or disputes arise. This can be as simple as comments in a farm diary

or on a harvest and packing record, or communication from your customer.

Factsheet – F1 Hazard analysis

FRESHCARE FOOD SAFETY & QUALITY FACTSHEET – F1 HAZARD ANALYSIS Ref: 1906 PAGE 1 OF 3


• HACCP • Hazard analysis • Freshcare risk assessments • Risk assessments for other practices (additional hazards, Code Criteria not

implemented) • Review

For more information refer to the Guidelines for Fresh Produce Food Safety (2019), Chapter 3 Fresh produce food safety hazards, page 5

HACCP

Hazard Analysis and Critical Control Point (HACCP – pronounced ‘hassip’) is an internationally recognised method of food safety risk management used in the food industry.

When correctly implemented, HACCP will prevent hazards from occurring, and therefore reduce the need for finished product testing.

The United Nation’s Codex Alimentarius Commission defines HACCP as ‘a system which identifies, evaluates and controls hazards which are significant for food safety’.

Put simply, the HACCP process involves:

• Identifying the biological, chemical and physical hazards that may occur at each step of the growing and/or packing process.

• Evaluating the hazard (i.e. what is the likelihood of the hazard occurring, and what will the consequences be if it does occur).

• Determining what are the Critical Control Points in the process (i.e. the things that you must get right in order to ensure food safety).

• Monitoring Critical Control Points (e.g. product temperature) to ensure that control is being maintained.

HACCP requires a number of underpinning or support programs to be in place. These programs address issues fundamental to food safety but not directly related to the production of food, such as cleaning, worker training and pest control.

The Freshcare Code of Practice Food Safety & Quality has always been based on HACCP principles. Elements of the FSQ Code were derived from an analysis of food safety hazards relevant to horticulture production and packing.

Freshcare Code of Practice Food Safety & Quality requires businesses to complete a more formal HACCP process and identify risks and control measures specific to their business.

Hazard analysis

In developing a food safety system, it is important to identify and evaluate physical, chemical and microbial hazards. The process of doing this is called hazard analysis. There is much commonality in the types of food safety hazards that exist in horticultural businesses and therefore an individual hazard analysis of every hazard is not necessary. Food safety risks can be effectively controlled by implementing good agricultural practices.

There are a number of food safety hazards that may require additional control measures, dependent on the significance the hazard has for the particular business. In these instances, each business is required to complete an analysis of the hazard as it relates to their specific situation and to identify control measures to minimise the risk of the hazard occurring.

The Freshcare Code of Practice Food Safety & Quality identifies the areas where a specific hazard analysis is required. Via the completion of specified risk assessments, you will determine the significance of the hazard, and subsequent compliance criteria will be identified.



Freshcare risk assessments

Freshcare have four risk assessments that all participating businesses must complete:

• Persistent chemicals • Heavy metals • Fertiliser and soil additives • Preharvest water

Each risk assessment must be conducted for the scope of the business i.e. each growing site/water use and crop type combination.

Freshcare risk assessments can be found in the Code Appendix. Form templates are also provided to aid in completing the risk assessments.

To conduct a Freshcare Risk Assessment:

Identify growing site and crop(s) and work through the risk assessment questions to identify the likelihood of the food safety hazard occurring in your business (Page 1 of Form).

Record the growing site, crop(s) and likelihood in the hazard analysis table (Page 2 of Form).

Using the Significance matrix, determine the significance of the risk with the Severity and Likelihood. The severity of the hazard has been predetermined by Freshcare.

If the significance of the hazard is high, review and implement the relevant additional actions for high significance. In this case, the hazard analysis determined the risk to be of low significance and no additional action is required.

Note: You may need to use the risk assessment a number of times for different growing sites/crops. The F1 Risk assessment forms have been split from the risk assessment decision tree over two pages for this purpose.

1

2

3

4

1

2 3

4



Risk assessments for other practices

Additional risk

Risk assessments may be conducted for any additional risks within the scope of Freshcare certification.

As a prescriptive, HACCP-based standard, identified food safety risks are managed in compliance with the Code and risk assessments. If any additional, business specific risks are identified within the scope of the FSQ4 Code, a risk assessment for other practices is completed (refer to Form – F1 Risk assessment – other practices).

Examples of possible other practices might include:

• farm gate sales – contamination from dust/dirt and other issues • sulphur dioxide contamination of grapes from grape guard pads during

storage caused by poor temperature control • homing pigeons flight path over produce or wildlife corridors through crops • glass in paddocks adjacent to public roads.

If required, control measures, monitoring and verification activities must be recorded and implemented using the outcomes of the risk assessment process.

Exempting from FSQ4 compliance criteria

If a business believes that an element of the Freshcare Code of Practice Food Safety & Quality is not-applicable to the business due to specific production methods/crops grown/other practices undertaken, a risk assessment must be conducted and evidence provided to clearly support the reason for any exclusion of specific Code requirements.

Documentation

The Form – F1 Risk assessment – other practices form template has been provided to document the risk assessment and relevant control measures, monitoring and verification activities.

Review

Risk assessments must be reviewed at least annually or when changes occur that may affect the significance of the hazard (for example, a new crop is grown or there is a change in farm inputs).

Factsheet – F2 Growing site

FRESHCARE FOOD SAFETY & QUALITY FACTSHEET – F2 GROWING SITE Ref: 1906 PAGE 1 OF 3


• Growing site • Chemical contamination • Microbial contamination • Physical contamination

For more information refer to the Guidelines for Fresh Produce Food Safety (2019) Chapter 5 Managing the growing site and planting material, page 17.

Growing site

Some growing sites may not be suitable for the production of produce. An assessment of the suitability of the growing site should be completed prior to planting (when possible) for annual crops (e.g. potatoes, onions, lettuce), and once for perennial crops (e.g. tree crops, vineyards). Growing sites may include paddocks, orchards or other growing facilities such as greenhouses and shadehouses.

The growing site can be a source for produce contamination with chemicals, microbes or foreign matter. The condition of sites should be suitable for the production and preparation of safe produce. Contamination may occur due to poor design, construction or maintenance of these structures, or the inappropriate use of these areas.

Growing site contamination can lead to produce contamination. The risk of contamination is often higher for crops where the harvestable part is grown in, or in direct contact with the soil.

An assessment of the growing site will help determine its suitability. When assessing the growing site, the main risks that may arise are:

• contamination from persistent chemicals or heavy metals remaining in the soil from past use

• contamination from chemicals through spray drift

• microbial contamination from use of untreated fertilisers and soil additives or flooding

• physical contamination from foreign matter such as sticks, stones, glass, metal, ceramics, etc.

Chemical contamination

To assess the risk of persistent chemical and heavy metal contamination of produce from the soil or growing medium to the crop, Freshcare FSQ4 have two risk assessments that must be completed for each growing site and crop combination. These risk assessments can be found in the Code Appendix, and form templates to record their completion are available in Freshcare Forms.

If the hazard analysis identified the risk of persistent chemical contamination of produce from soil/growing medium is high, additional control measures must also be implemented.

This may involve testing the soil/growing medium and/or testing the produce for persistent chemicals or heavy metals. The contaminated sites must be identified on the property map and managed to ensure that product grown at that site complies with ERLs/MRLs/MLs.

Maximum Residue Limits (MRLs)

The Maximum Residue Limit (MRL) is the maximum concentration of a residue that is legally permitted on produce after harvest. Food Standards Australia New Zealand (FSANZ) sets the MRLs permissible in or on a food, agricultural commodity or animal feed. FSANZ has established MRLs for fresh produce, which are published in the Australia New Zealand Food Standards Code, Section 1.4.2.

More information can be found at: www.foodstandards.gov.au. FSANZ may review a chemical and change the MRL for types of produce, so it is important to know what the current MRLs are for the produce grown.

Where produce is intended for export to another country, a check of the importing country and/or customer MRLs should also be undertaken.



Extraneous Residue Limits (ERLs)

An Extraneous Residue Limit (ERL) is the maximum permitted level of a chemical residue, arising from environmental sources other than the use of a chemical directly or indirectly on the food. For example, Dieldrin has no registered use, and an application to crops or pastures is no longer legal. Therefore any Dieldrin residue detected on produce is assumed to arise from an environmental source.

Maximum Levels (MLs)

Limits for heavy metal contaminants in growing medium and fertilisers and soil additives (Source: Australian Standard AS 4454-2012: Composts, soil conditioners and mulches):

• Cadmium <1mg/kg (dry weight basis) • Lead <150mg/kg (dry weight basis).

Exceeding the Legal Limits

Residues detected on produce exceeding the MRL are unacceptable, but do not necessarily represent a hazard to consumers because of the high safety margins used to set the standards. Where an MRL does not exist, no residues of that chemical is permitted on the final produce.

If chemical residue testing for organochlorine (OC) or organophosphate (OP) on produce detects levels above the MRL/ERL, isolate the crop and take measures to either dispose of the crop or reduce the residue level to an acceptable level. Do not sell produce with chemical residues of OC/OP above MRL/ERL, or feed the crop to livestock. If the residue is present in soil or dust on the produce surface, washing may reduce the residue to an acceptable level.

Avoid growing produce on or adjacent to sites where OC/OP chemicals have been recently detected in the soil or in previous crops grown. Alternatively, grow a crop where the harvestable part has no direct soil contact.

Spray drift

Spray drift is the movement of agricultural chemicals away from the target area during or after ground or aerial spraying (in the form of droplets, particles or

vapour). Agricultural chemicals can drift long distances under certain weather conditions.

Spray drift or overspray can be a possible source of chemical contamination on produce.

Growing sites must be assessed for the potential for spray drift and where spray drift is likely, plantings are planned to minimise the risk of contaminating non-target produce.

Neighbours also need to be aware of the potential for spray drift, and the effect it can have on adjacent properties. Talk to neighbours, discuss sensitive areas, and determine how the risk of spray drift between the properties can be managed. Request that neighbours avoid spraying when drift is likely.

Buffer zones

Buffer zones are a very good way to reduce the risk of spray drift. Buffer zones can be established by planting trees and shrubs downwind of a production area. Vegetation that is tall, rough and thin is better at catching droplets than vegetation that is short, smooth and thick.

A droplet-catching barrier should be less than 50% porous, with a height about 1.5 times the height of spray release. Use multiple vegetation layers as a screen rather than a single layer. Intercrop buffers such as rye corn or sweet corn can also act as barriers.

Microbial contamination

Livestock

Microbial contamination of fresh produce can be caused by the presence of livestock in growing sites i.e. sites which have been used for animal grazing, as a feedlot or for poultry production. Microbes present in the gut of animals may transfer into the manure, and then on to the fresh produce, causing a food safety hazard to consumers.

Livestock refers to farm animals including, but not limited to, cattle, sheep, pigs, goats and poultry.



To manage the risk of microbial contamination, exclusion periods apply and livestock is not permitted on growing sites within:

• 90 days of intended harvest date for produce where the harvestable part is grown in, or has direct contact with the soil, and may be eaten uncooked; or

• 45 days of intended harvest date for all other produce.

The Form – F2 Livestock movement record template, has been provided to record movement of livestock in and out of growing sites.

Flooding

Consideration should also be given to the type of produce grown on sites that are prone to flooding. When flooding of the growing site occurs, the potential for microbial contamination of produce is increased by contact between floodwater and the harvestable part of the crop.

If growing sites have been affected by a flood event, the impact this will have on the affected crops or crops to be planted must be taken into account and planting must be scheduled to ensure that the period between flood water subsiding and harvest exceeds 90 days for produce where the harvest able part is grown in, or has direct contact with the soil, and may be eaten uncooked.

Any produce that has come into contact with floodwater should not be harvested for sale unless:

• the produce meets specified microbial limits of E.coli <10/g and Salmonella Not Detected 25/g, or

• customer specifications (which may indicate the produce should be disposed of).

Physical contamination

Growing sites must be assessed for the potential for physical contamination. The location of the site, or the sites proximity, may increase the risk of physical contamination; for example, if the growing site is adjacent to a busy road, or was previously used for industrial purposes, landfill or dumping of waste.

Physical hazards include glass, metal, wood, plastic, roots, sticks and stones, nuts and oil from equipment, or personal items from workers including cigarette butts, jewellery and rubbish. Weeds with the potential to cause poisoning or anaphylactic shock may be another potential contaminant present in growing sites that should be considered; for example, stinging nettle or deadly nightshade.

Where physical contamination is likely, sites are inspected before ground preparation and physical contaminants are removed, or managed to minimise the risk of contaminating produce.

Sites which are contaminated with physical contaminants must be identified on the property map.

Control measures to reduce the risk of physical contamination may include:

• inspecting the growing site before commencing and during land preparation • removing or controlling weeds with the potential to cause an anaphylactic

response or poisoning e.g. stinging nettles, deadly nightshade • training workers to identify, remove and not introduce physical hazards • consideration given to not crop areas with high levels of physical

contaminants or close to roadways.

Factsheet – F3 Planting materials

FRESHCARE FOOD SAFETY & QUALITY FACTSHEET – F3 PLANTING MATERIALS Ref: 1906 PAGE 1 OF 1


• Planting materials • Sourcing planting materials

For more information refer to the Guidelines for Fresh Produce Food Safety (2019), Chapter 5 Managing the growing site and planting material, page 17.

Planting materials

Planting materials include seeds, seedlings, young plants, roots, corms, bulbs, bits and suckers used for planting to establish crops.

Planting material should be assessed as a potential source of chemical contamination, in consideration of the chemicals used to treat seeds or control pests and diseases during the production of seedlings.

To prevent residues in the final product from exceeding the MRLs, chemical treatments to planting materials must be applied in accordance with legislation of the destination market; the directions on labels; or off-label permits.

The withholding period of chemicals must be checked before use as some chemicals have long withholding periods. To verify that chemicals have been used correctly, records of chemical treatments during production of planting material must be kept.

If planting materials are produced within the business, this must be noted in the M1 Scope record and records of chemical treatments during production of planting materials must be kept.

Sourcing planting materials

Planting material must be obtained from approved suppliers and suppliers informed of their responsibility to disclose any chemical treatments that may result in chemical residues in marketed produce exceeding MRLs. A record of purchase must be kept, including a description of the planting material, date of purchase and the name of the supplier.

Factsheet – F4 Chemicals

FRESHCARE FOOD SAFETY & QUALITY FACTSHEET – F4 CHEMICALS Ref: 1906 PAGE 1 OF 6


• Obtaining chemicals • Storing chemicals • Managing chemicals • Disposing of chemicals and chemical containers • Chemical application • Chemical residue testing

For more information refer to:

Guidelines for Fresh Produce Food Safety (2019) Chapter 8 Managing chemicals, page 49.

Guidelines for Fresh Produce Food Safety (2019) Chapter 18 Testing, page 90.

Obtaining chemicals

Agricultural chemicals must be purchased from approved suppliers to demonstrate that the suppliers are meeting the minimum requirements for supply, as outlined in the Freshcare FSQ4.1 Standard.

Approved suppliers for chemical purchases can be demonstrated by meeting the requirements as outlined in Factsheet F11:

• AgSafe accreditation • Establishing a supplier agreement that ensures:

o all chemicals provided are adequately labelled and in acceptable condition

o all chemicals provided are within Use By dates.

Agsafe

Agsafe accreditation and training supports the safe storage, handling, transport and sale of agricultural and veterinary chemicals for rural merchandise businesses. The program trains and accredits staff and businesses in handling and providing responsible advice in the safe and effective use of agvet chemicals.

The aim of this program is to ensure that there is responsibility and compliance with government regulations and industry standards throughout the supply chain.

Storing chemicals

Incorrect and careless storage and handling of chemicals can lead to the contamination of water, grounds, equipment, containers and packaging materials that come into contact with produce. Accidental spillage directly onto produce can also occur.

Approvals and label directions for chemicals can change. The age of a container of chemical can be determined from the date of manufacture and/or expiry date.

For safe and effective chemical storage:

• Locate the shed where it will not be flooded or where chemical spills might contaminate the growing site, produce, storage areas and packaging materials.

• Locate the shed away from where people may live and eat. • Use a structurally sound, adequately lit and well-ventilated shed that protects

chemicals from direct sunlight and weather exposure. The storage area can be inside the packing shed provided it is segregated from packing, storage and handling areas.

• Use an impervious floor (e.g. concrete), preferably with a bund to contain any spills or leaks and to prevent water entering.

• Keep the shed locked to ensure children and others (not trained in safe handling of chemicals and authorised for entry) are kept out.

• Store chemicals in their original containers with labels intact. • Separate chemicals into categories. • Separate containers of chemicals awaiting disposal so they are not

accidentally used.



• Keep a spill kit handy. Spill kits should include: o a shovel o dustless absorbent material e.g. kitty litter, activated charcoal,

vermiculite, hydrated lime, clay, earth or dry sand (avoid using sawdust and other combustible materials)

o a container to hold the absorbent material or other leaking containers.

Managing chemicals

Chemical inventory

Keep a record of all chemicals purchased in a chemical inventory, or equivalent record. The record must include:

• date received • place of purchase • name of chemical • batch number (where available) • expiry date or date of manufacture • quantity. Form – F4 Chemical inventory form template has been provided to capture this information, however the required information could also be kept on purchase/delivery receipts or via other purchase recording systems.

Annual check

An annual check of chemicals in storage will ensure they have current approval, that they are still within their expiry date and that containers are intact with readable labels. This will avoid illegal use/MRLs being unknowingly exceeded; ensure chemicals are still effective; and ensure containers can be safely handled.

Stored chemicals are checked to identify and segregate chemicals for disposal that have:

• exceeded the label expiry date • exceeded the permit expiry date • had their registration withdrawn

• containers that are leaking, corroded or have illegible labels. A record of the check must be kept. This can be recorded on the Form – F4 Chemical inventory.

Disposing of chemicals and chemical containers

Disposal of chemicals

Unwanted chemicals can be disposed of through ChemClear® or through a certified or approved chemical waste contractor.

For more information regarding disposal of unwanted chemicals and chemical containers, contact ChemClear®, drumMUSTER® or your local council.

ChemClear®

ChemClear® is the industry-funded program for the collection and disposal of unwanted, currently-registered agvet chemicals. The aim of this service is to minimise the potentially dangerous build-up of unwanted agvet chemicals on farms, which may create risks to the environment, public health and trade. A web-based booking system is available for users, as well as a free call number.

More information about the program can be found on the ChemClear® website: www.chemclear.com.au.

Disposal of chemical containers

Under various state regulations, businesses are required to dispose of empty chemical containers safely. When purchasing, ask if used chemical containers can be reused, returned, refilled or recycled.

Empty chemical containers must be stored in a designated, secure area (preferably locked), and disposed of either through a controlled approved disposal scheme, such as drumMUSTER®, or according to a documented procedure that meets state or territory regulations.

A record of disposal is kept e.g. disposal receipts/records.

http://www.chemclear.com.au/



drumMUSTER®

drumMUSTER® is the industry-funded national program for the collection and recycling of empty, pre-cleaned, crop protection and animal health chemical containers.

More information about the program including details of collection days and locations can be found on the drumMUSTER® website: www.drummuster.com.au.

Chemical application

Incorrect or careless use of chemicals and harvesting of crops within the withholding period (WHP) can result in residues exceeding the MRLs. Examples include:

• using untrained workers • using unregistered chemicals or chemicals without an ‘off label permit’ issued

by the Australian Pesticides and Veterinary Medicines Authority (APVMA) • incorrect mixing • incorrect calibration of equipment • not observing the withholding period.

Recognised farm chemical training

Freshcare requires that the person responsible for chemical application on farm is required to complete recognised farm chemical user training and be able to show ongoing competency.

A number of organisations deliver these training courses in groups and online.

Workers involved in the use of chemicals must be trained, assessed as competent and be authorised to use chemicals within the business by the person responsible for chemical application.

Freshcare requires the following national competencies be included in all farm chemical user training qualifications:

• AHCCHM303 – Prepare and apply chemicals • AHCCHM304 – Transport and store chemicals.

In some states, such as New South Wales (NSW), government regulations require all workers who use chemicals to complete recognised farm chemical user training.

Permits

In certain circumstances, ‘off label’ permits may be obtained for the legal use of chemicals in ways different to the registered use printed on the label (e.g. for minor use crops, exotic disease outbreaks, or research trials). Permits are granted by the APVMA, a database of registrations and permits for Agvet chemicals can be viewed online on the APVMA website: http://apvma.gov.au.

Maintenance and calibration of equipment

Calibration and maintenance of spray equipment must be undertaken regularly to ensure accuracy of chemical application. While different equipment has different calibration procedures, the principles remain the same – to check that the desired amount of chemical is directed onto the target. Poorly calibrated equipment can result in failure to control the target pest, crop damage, increased application costs and contamination of produce.

Maintenance of equipment includes:

• checking spray nozzles for wear, • checking hoses and joins for leaks, • checking spray rig tyre pressures and speed.

For further information on the calibration of equipment, refer to the resources provided at farm chemical user training. Detailed information and guidelines on how to calibrate equipment is also available from manufacturers or companies selling spray equipment.

Withholding period (WHP)

The withholding period is the time elapsed between the last treatment with a chemical and the harvest of a crop. Withholding periods are specified on product labels to ensure that any chemical residues on produce are below the Maximum Residue Limit (MRL).

Application and record keeping

http://www.drummuster.com.au/



Only approved chemicals shall be used and withholding periods for the harvesting and release of produce observed. Chemical application records must be maintained, refer to Form F4 – Preharvest chemical application and Form F4 – Postharvest chemical application.

Infopest

Infopest is a comprehensive Agvet chemical database of all chemicals registered and approved by the APVMA.

Information on chemical active constituents, permits, Safety Data Sheets (SDS) and label images, is available on their website: www.infopest.com.au.

Records of all preharvest chemical applications are kept and must include:

• application date • start and finish times • location and crop • chemical used (including batch number if available) • rate of application and quantity applied • equipment and/or method used to apply the chemical • withholding period (WHP) or earliest harvest date (EHD) • wind speed and direction • name and signature of person who applied the chemical.

Records of all postharvest chemical treatments are kept and must include:

• treatment date and time • produce treated • chemical used (including batch number if available) • rate of application and/or quantity applied • equipment and/or method used to apply the chemical • withholding period (WHP) (where applicable) • name and signature of person who carried out the chemical treatment.

Spray drift

Spray drift is the movement of agricultural chemicals away from the target area during or after ground or aerial spraying (in the form of droplets, particles or vapour). Agricultural chemicals can drift long distances under certain weather conditions.

Spray drift or overspray can be a possible source of chemical contamination on produce. One of the main causes of this may be from spraying chemicals in unsuitable weather conditions. Table 1 provides a guideline based on visual descriptions for assessing wind speeds suitable for spraying.

Table 1. Visually assessing wind speed

Approximate air speed at boom height

Description Visual indicators Suitability for spraying

0 – 2 km/h Calm Smoke rises vertically Spraying inadvisable

2 – 3.3 km/h Light air Smoke drifts in direction Avoid spraying

3.3 – 6.5 km/h Slight breeze Wind felt on face, leaves rustle

Optimum spraying conditions

6.5 – 9.6 km/h Gentle breeze

Leaves and twigs in constant motion

Use low drift nozzles (medium to coarse droplets)

9.9 – 14.5 km/h

Moderate breeze

Small branches moved and raises dust or loose paper

Increased risk of spray drift - use air induction nozzles (coarse droplets)

14.5 + km/h Fresh breeze +

Small trees in leaf begin to sway Spraying inadvisable

Silvan Australia Pty Ltd Selecta and Delta T. Ver.28, July 2010

The visual wind speed indicators in Table 1 do not provide complete assessment of the weather conditions affecting the likelihood of spray drift. Other weather conditions impacting on the likelihood for spray drift include temperature, humidity, evaporation rate and droplet lifetime.

http://www.infopest.com.au/



The APVMA will increasingly require chemical label directions to include relevant weather information for avoiding spray drift. Read each chemical label before spraying to check the suitability of weather conditions required for spraying the chemical. Freshcare recommends the use of weather monitoring devices to measure the temperature, relative humidity and wind speed and direction.

Measure the wind speed, wind direction and any other relevant weather conditions before and during spraying and record the relevant information on the spray diary for each application of the chemical.

Neighbours also need to be aware of the potential for spray drift, and the effect it can have on adjacent properties. Talk to neighbours, discuss sensitive areas, and determine how the risk of spray drift between the properties can be managed. Request that neighbours avoid spraying when drift is likely.

It is important to be aware that spray drift may occur and of the need to do a multi-screen residue test on produce (including organic produce) to check if spray drift has happened.

Planning the timing of plantings can also assist in minimising the risk of withholding period and MRL breaches on adjacent crops.

Chemical residue testing

Chemical testing

The requirement for testing fresh produce for chemical residues is to verify that chemicals are being applied according to current label or permit directions.

The chemical residue test required by Freshcare must be a multi-screen test that includes chemicals used as part of your spray program and, where applicable, postharvest chemical treatments. The test must be conducted on a random sample of produce that has had all preharvest and postharvest chemical treatments completed and is ready for sale and/or consumption.

Organic producers must also have their produce tested as per the requirements of the Freshcare Code. This is to verify chemical residues are not present from

previous use of the growing site, or from spray drift from adjacent sites/properties.

Heavy metal and other chemical testing of produce or soils may also be required in order to assess the risk of contamination from persistent chemicals and heavy metals in the soil.

Maximum Residue Limits

The Maximum Residues Limit (MRL) for registered crop protection chemicals is established by the APVMA.

The MRL is the maximum concentration (mg/kg) of a residue that is legally permitted on produce after harvest. Check state government requirements for on-farm legal use of chemicals, as there may be differences between state regulations.

The MRLs for harvested fresh produce are established by FSANZ and published in Food Standards Australia New Zealand (FSANZ) Food Standards Code – Section 1.4.2 Agvet chemicals and associated Schedules – Schedule 20 and 21, this document is available on their website: www.foodstandards.gov.au.

For produce that is exported, check the importing country regulations governing the application of chemicals and MRLs.

Produce chemical residue test results are checked against the MRL of the chemical for the specific crop.

What to test for

Standard multi-screen tests include a broad range of active constituents at a cost-effective price, and these are now used for verification testing. It is important that the multi-screen test includes chemicals that have been used during the spray program and postharvest.

The results of residue testing by industry or government testing programs can help in assessing the risk of chemicals exceeding the MRL.

http://www.foodstandards.gov.au/



When to test

Chemical residue testing verifies the chemical application program. The test must be conducted before initial Freshcare certification and then annually, or more frequently, if required by a customer specification. If more than one crop type is grown, Freshcare only requires a crop to be tested each year. A rotation system must be used so that a different crop is tested each year.

Where to sample

The produce must be sampled at or just prior to the point at which it could be first available to the customer. This can be just after the withholding period has lapsed, after harvest or packing or just before or on delivery to the customer. Where the produce is stored for an extended period before delivery, such as apples, collect the sample before storage. If the postharvest application of chemicals for long term storage is being verified, then produce should be sampled after storage.

The sample must be unbiased and representative of the produce supplied. The grower or customer such as a wholesaler, processor or packer may select the sample and organise residue testing.

How to sample

Before sending a sample for testing, check that the laboratory is NATA accredited (or accredited to ISO/IEC 17025 Standard) for the analysis of chemical testing for fresh produce and can test for chemicals included in your preharvest and postharvest spray.

Request the laboratory provide evidence of the tests and matrices for which they are accredited.

The laboratory will give instructions on the required sample size and how best to transport the sample. When collecting and transporting samples, avoid cross contamination from other sources and deterioration of the produce. Guidelines to follow are:

• Use disposable gloves (or thoroughly washed hands) to collect the sample.

• Place the sample in a clean plastic bag and/or box to protect it during transport.

• Clearly label the sample with your name, address, telephone number and other details (don’t forget to record the date of sample collection and from where it was collected).

• Clearly indicate what test you want the laboratory to undertake (e.g. specific chemical name, multi-screen).

• Store the sample in a cool (but not frozen) state until ready to transport. • Use overnight freight to ensure the sample gets to the laboratory promptly.

Factsheet – F5 Fertilisers and soil additives

FRESHCARE FOOD SAFETY & QUALITY FACTSHEET – F5 FERTILISERS AND SOIL ADDITIVES Ref: 1906 PAGE 1 OF 3


• Sourcing fertiliser inputs • Fertilisers and soil additives containing manures and/or food waste • Treated fertilisers and soil additives containing manures • Effective composting

For more information refer to the:

Guidelines for Fresh Produce Food Safety (2019), Chapter 6 Managing fertilisers and soil additives, page 27.

Guidelines for Fresh Produce Food Safety (2019), Chapter 18 Testing, page 90.

Sourcing fertiliser inputs

Fertilisers and soil additives are products that are added to the soil to improve fertility and structure, or control weeds. Examples include inorganic (chemical) fertilisers such as lime and gypsum; and those of organic origin such as animal manure, sawdust, compost, compost tea, seaweed, fish-based products, other biological compounds and those derived from food waste.

When sourcing fertilisers and soil additives and assessing the potential food safety risk of the farm input, consider the composition, treatment, application method and timing, of use.

For more information regarding sourcing and using fertilisers and soil additives safely, refer to the Compost Factsheet available for download on the Freshcare website: www.freshcare.com.au.

Human effluent and biosolids

Biosolids are solid or semisolid by-products obtained from treated human sewage or wastewater.

Freshcare does not permit the use of biosolids or human effluent, they must therefore not be applied to growing areas.

Heavy metal contamination

Heavy metal contamination of fresh produce can be caused by the presence of cadmium in fertilisers (especially phosphate and some trace element mixes) and soil additives such as gypsum, animal manures, biosolids and composts. Root and tuber crops and leafy vegetables can take up cadmium if growing conditions are favourable for uptake.

Only fertilisers and soil additives that comply with the legal limits for cadmium and have the lowest available impurity levels should be used. For example, special low cadmium superphosphates are now available and should be used where phosphorus application rates are high or where higher risk crops are grown.

Limits for heavy metal contaminants in growing medium and fertilisers and soil additives comply with those specified in AS4454-2012:

• Cadmium <1mg/kg (dry weight basis) • Lead <150mg/kg (dry weight basis).

Fertilisers and soil additives containing manures and/or food waste

Microbial contamination of fresh produce can be caused by the use of untreated or incorrectly treated fertilisers and soil additives containing manures. Microbes present in the gut of animals may transfer into the manure, and then on to the fresh produce, thus causing a food safety hazard to consumers.

Contamination of produce can occur through direct contact of untreated fertilisers and soil additives containing manures with the harvestable part of the crop (soil or foliar application); or indirectly through contact with contaminated soil or water.

Fertilisers and soil additives containing manures that have been treated to minimise microbe levels are less likely to cause contamination of produce. For example, the heat generated during correct composting of manure will kill microbes of concern for food safety. When purchasing treated fertilisers and soil additives containing manures from suppliers, obtain information including:

• evidence of certification to AS4454-2012, or • details of the treatment process (a documented, verified treatment process –

AS4454-2012 or other equivalent time/temperature treatment); and a



Certificate of Analysis for each batch of product supplied to verify the treatment process achieves E. coli <100 cfu/g, Salmonella Not Detected/25g.

There are a number of practices that can be adopted to minimise the risk of microbial contamination of produce from the use of fertilisers and soil additives containing manures, including:

• Locate or cover stockpiles to avoid contamination from wind drift onto adjacent crops and harvested produce or rainfall runoff into water sources.

• Adhere to exclusion periods between application of untreated fertiliser and soil additive containing manures and when the crop is harvested. Appropriate exclusion periods are determined by the Freshcare FSQ4 Risk assessment for fertilisers and soil additives (Refer to RA-F1.3 for risk assessment).

• Use an application method/growing practice that minimises the chance of the untreated fertiliser or soil additive coming into contact with the harvestable part of the crop, e.g. skirting tree crops, growing crops on plastic mulch.

• Incorporate untreated fertilisers and soil additives into the soil as soon as possible to minimise contamination of adjacent crops from wind drift or rainfall runoff.

• Avoid fertiliser and soil additives applications when the risk of wind drift and run-off onto adjacent crops is high.

• Request neighbours avoid fertiliser and soil additives applications when the risk of wind drift and run-off onto adjacent crops is high.

• Minimise the potential risk of faecal contamination from wildlife and domestic animals in growing sites.

Treated fertilisers and soil additives containing manures

If using fertilisers and soil additives containing manures within exclusion periods, it must be treated in accordance with AS4454-2012 or other equivalent time/temperature treatment and evidence of compliance kept.

Evidence of compliance for treated fertilisers and soil additives containing manures as referenced in the FSQ4 Code Appendix: A-F5 include:

• If sourced from suppliers with an approved certified treatment process – evidence of certification to AS4454-2012 is provided.

• If sourced from suppliers that follow a documented, verified treatment process (AS4454-2012 or other equivalent time/temperature treatments) – details of the treatment process and a Certificate of Analysis for each batch of product supplied to verify the treatment process achieves E. coli <100 cfu/g, Salmonella Not Detected/25g.

• If treated on farm to a documented, verified treatment process (AS4454-2012 or other equivalent time/temperature treatments) – treatment records are kept and must include: o product composition o description of treatment method o treatment start and end date o date and temperature readings o batch identification code o estimated quantity of batch o name of person that supervised the treatment.

A Certificate of Analysis for each batch of product is kept to verify the treatment process achieves E. coli <100 cfu/g, Salmonella Not Detected/25g.

Effective composting

If treating fertilisers and soil additives containing manures on-farm, effective composting techniques must be used, including:

• keeping the compost heap aerated and outer layers turned in for the process to work

• exposing all of the organic material to a minimum temperature of 55⁰C for three consecutive days

The time taken for complete composting of fertilisers and soil additives depends on the system used and factors such as the type of material, moisture content, aeration, nutrient ratio, pH, toxic substances and temperature.

Generally it takes between six and ten weeks (with a curing period of two to three months) to ensure that compost is mature.



Full details on the types of composting systems and detailed guidelines on procedures required can be found in the Australian Standard AS4454-2012: Composts, soil conditioners and mulches (Standards Australia).

Factsheet – F6 Water

FRESHCARE FOOD SAFETY & QUALITY FACTSHEET – F6 WATER Ref: 1906 PAGE 1 OF 3


• Contamination from water • Managing water sources and infrastructure • Reclaimed or recycled water • Water used preharvest • Water used postharvest • Water for other uses • Water treatment • Verification of water quality

For more information refer to the Guidelines for Fresh Produce Food Safety (2019)

Chapter 7 Managing water, page 33.

Chapter 18 Testing, page 90.

Contamination from water

Water is used during growing for irrigation and spraying, and after harvest for washing, unloading of field containers (water dumps), chemical treatment(s), hydrocooling, top icing, hand washing and cleaning. In some hydroponic systems, water is constantly in contact with the roots of produce.

In assessing the risk of contamination to produce from water use, factors that need to be considered are the source of water, when and how the water is used, and on what type of produce.

Taste, odour and colour may be the first indication of a potential food safety hazard but should not be relied upon to assess water quality. E. coli is used as an indicator of faecal contamination of water.

Types of produce

The part of the produce that is harvestable and the way it is consumed, may affect the risk of microbial contamination that need to be managed. The risk for

produce that has an edible skin and may be eaten uncooked can be higher than for produce that is peeled or cooked before eating.

Managing water sources and infrastructure

Water sourced from creeks and rivers, dams, bores and water storage tanks, may be contaminated by microbes or chemicals. Therefore, water sources used for produce need to be monitored and managed to minimise potential contamination by factors impacting the water quality.

Different water sources may have different levels of contamination. It is therefore important to consider the water source used preharvest and postharvest and assess the suitability of the water source for that use. For example, water in one dam may be suitable to irrigate a potato crop but may not be suitable to irrigate a lettuce crop. Refer to following sections for more information.

Records need to be maintained to identify water sources and how they are used, so if there is a food safety problem there is traceability to clearly show which water was used on each crop. Form – F6 Water source template has been provided to record this information.

Infrastructure used for water storage and delivery on the property must be monitored and maintained to avoid contamination of the water. Water extraction points, water storage, delivery infrastructure and irrigation equipment is to be inspected and maintained to ensure the quality of water delivered.

Freshcare FSQ4.1 requires infrastructure and equipment such as water storage tanks, water dumps, flumes and treatment tanks are suitable for such the purpose, constructed of materials that will not contaminate the water and are clean and maintained.



Reclaimed or recycled water

Reclaimed water is defined in Australia as water derived from sewage systems and industrial processes. Freshcare businesses using reclaimed or recycled water should contact their provider to ensure that the water sourced is approved for its intended use and the water meets, or is treated to meet, the requirements of the Freshcare FSQ4.1 Standard.

Water used preharvest

Preharvest water uses include irrigation, fertigation, hydroponics, crop spraying and foliar application.

A risk assessment is used to determine the risk of microbial contamination of produce from preharvest water and depending on the significance of the risk, whether the water quality needs to comply with Freshcare water quality limits for preharvest water.

If the completion of the risk assessment (refer to FSQ4.1 Standard Appendix RA-F1.4 or Risk assessment – preharvest water template) indicates high significance, all water used within 48 hours of harvest must meet E. coli <100 cfu/100ml. Evidence must be kept to verify water quality.

Water used postharvest

Water may be used during harvest or postharvest via the following process steps:

• unloading of field containers and bins (water dumps and troughs) • pre-washing* • washing/final rinse • chemical treatment with fungicides and insecticides • hydrocooling • top icing.

* Where water is used post-harvest as a pre-wash step (to remove soil or debris), where there is a subsequent wash step, the water used must meet the water quality for preharvest water E. coli <100 cfu/100ml.

All other water used in subsequent washes (including final wash), during a single wash step, for chemical treatment, hydrocooling, top icing, etc, must be suitable for the purpose intended, not be a source of food safety risk and meet (or be treated to meet) E. coli <1 cfu/100ml. This includes water in recirculation systems, water dumps, flumes and treatment tanks used post-harvest, whereby treatment and/or water is changed at an assessed frequency to ensure it meets the above.

Evidence of water quality must be kept, as well as treatment and water change records (where applicable).

Water for other uses

Water used for hand washing in toilets and hand washing facilities

Water used for hand washing must not be a source of food safety risk, be suitable for the purpose intended and meet (or be treated to achieve) E. coli <1 cfu/100ml, with evidence kept.

If water has not been proven to meet E. coli <1 cfu/100ml, an alcohol-based hand sanitiser must be used after washing hands with soap and water.

Water used for cleaning

Water used for cleaning or sanitising equipment, containers, tools and other produce contact surfaces must not be a source of food safety risk, be suitable for the purpose intended and meet (or be treated to achieve) E. coli <1 cfu/100ml, with evidence kept.

Any variation to the water quality (E. coli <1 cfu/100ml) for the above uses, must be supported by a risk assessment and associated documentation (refer to FSQ4.1 Standard F1.6 and Form – F1 Risk assessments – other practices template).



Water treatment

It is important to carefully review the best water treatment for the operation, based on sound technical advice and following the manufacturers guidelines. Treatment of water must be monitored (and equipment maintained) to ensure that it achieves the desired level of microorganism control. Records must be maintained, including the method, frequency and results of treatment (refer to Form – F6 Water treatment monitoring record template).

Verification of water quality

A practical approach to assess the risk of microbial contamination is to test for the presence of faecal contamination. Testing water for E. coli provides an indication of faecal contamination of the water, which could lead to microbial contamination of produce.

The quality of the water required (acceptable level of E. coli) depends on when and how the water is used, the type of produce and whether the organisms will survive on the produce. The Freshcare FSQ4.1 Standard compliance criteria outlines the quality of water required for its intended use. A consideration should also be how often water is changed within treatment, recirculation, water dumps and flumes.

If specific water quality is required, evidence of compliance for water quality for that source needs to be kept:

• External supplier e.g. town water – certificate of compliance from supplier. This could also be a water test verifying the water meets required limits.

• Water treated on-farm – water treatment process is documented and water tested to verify treatment process is effective. Treatment and monitoring records are kept. If water source or treatment method changes, process is reviewed, documented and water tested to verify treatment process is effective (refer to Form – F6 Water treatment monitoring record template).

• Untreated water – each water source is tested: o monthly during period of use, or o annually before use, once it is historically proven to achieve specified

E.coli limits (at least 4 consecutive tests below specified limits).

It is also important to ensure the testing records maintained to provide water quality are conducted by a competent lab (refer to Glossary for definition).

Factsheet – F7 Allergens

FRESHCARE FOOD SAFETY & QUALITY FACTSHEET – F7 ALLERGENS Ref: 1906 PAGE 1 OF 2


• What are allergens • Allergens in fresh produce • What do I need to do? • Allergen labelling • Further information

For more information refer to the Guidelines for Fresh Produce Food Safety (2019) Chapter 16 Allergens, page 81.

What are allergens

Allergens are substances, that even in small amounts, can cause a severe allergic reaction in susceptible individuals. It is therefore extremely important to review all inputs to your production for allergens, and implement control measures if required. All workers need to be made aware of allergens, and the role they play in ensuring that allergens are not inadvertently introduced to the product.

Allergens of concern include:

• cereals containing gluten and their products (namely wheat, rye, barley, oats, spelt and their hybridized strains)

• lupin • crustacea and their products • eggs and egg products • fish and fish products • peanuts and tree nuts and their products • milk and milk products • sesame seeds and their products • soybeans and their products • added sulphites in concentrations of 10mg/kg or more.

Allergens in fresh produce

In the fresh produce sector the risk of contaminating produce by cross contact must be considered. Cross contact is when a residue or other trace of an allergenic substance is unintentionally added to a food not intended to contain that allergenic substance and where such occurrences are sporadic.

The greatest risk to produce is from cross contamination from either workers or substances unintentionally introduced from other sources such as raw material inputs. For example:

• fruit, vegetable or nut in shell waxes containing soy, casein (milk protein), peanut or sesame

• use of tree nut waste materials as mulch on vegetable crops • peanuts or peanut shells in growing site • soy based grease or lubricants for machinery with potential produce contact

(e.g. machinery is above packing line) • compost teas can be a source of allergens e.g. using fish heads.

What do I need to do?

• Ensure your workers are aware of and can identify allergens and know how to avoid introducing allergens.

• Ensure proper hygiene practices are kept by all workers and that hands are washed after handling any food that may include allergens.

• Do not use any products on your produce, such as waxes or mulches, which may contain allergens.

• Document an allergen control procedure if you use any inputs containing allergens and train your workers accordingly in the control and removal of allergens.

Allergen labelling

Standard 1.2.3 of the Australia New Zealand Food Standards Code requires a mandatory declaration for all the main foods and their products (listed allergens

Factsheet – F7 Allergens

FRESHCARE FOOD SAFETY & QUALITY FACTSHEET – F7 ALLERGENS Ref: 1906 PAGE 2 OF 2

of concern) that may cause an allergenic reaction, even if these products are ingredients or processing aids. However, there is currently no legal requirement for mandatory declarations in the event of unintended cross contact.

Some countries allergen labelling requirements differ to those of Australia, and even some countries have other substances listed as allergens that Australia does not consider (i.e. celery and mustard seed). Therefore, when considering product for export that contains or may contain allergens, the appropriate legislation is consulted and applied in terms of labelling of product.

Further information

Documents and tools have been developed to assist food producers comply with the Australia New Zealand Food Standards Code, and minimise the risk of unintentional consumption of allergenic products:

The Food Industry Guide to Allergen Management and Labelling (2007) contains further information on the management of allergens and labelling requirements and is available on the Australian Food and Grocery Council website: http://www.afgc.org.au/wp-content/uploads/Food-Industry-Guide-to-Allergen-Management.pdf

Voluntary Incidental Trace Allergen Labelling (VITAL®) is a tool that allows food producers to assess the impact of allergen cross contact and provide appropriate precautionary labelling on their products. It includes a decision tree that can assist a business in understanding when labelling is required. VITAL® is available on the Allergen Bureau website: www.allergenbureau.net

http://www.afgc.org.au/wp-content/uploads/Food-Industry-Guide-to-Allergen-Management.pdf

http://www.afgc.org.au/wp-content/uploads/Food-Industry-Guide-to-Allergen-Management.pdf

http://www.allergenbureau.net/

Factsheet – F8 Premises, facilities, equipment, tools, packaging and vehicles

FRESHCARE FOOD SAFETY & QUALITY FACTSHEET – F8 PREMISES, FACILITIES, EQUIPMENT, TOOLS, PACKAGING AND VEHICLES Ref: 1906 PAGE 1 OF 3


• Premises, facilities, equipment, tools, packaging and vehicles • Toilet and handwashing facilities • Septic, waste and drainage systems • Tools, equipment and containers • Packaging materials • Vehicles and transportation • Preventative maintenance and cleaning • Waste disposal

For more information refer to the Guidelines for Fresh Produce Food Safety (2019)

Chapter 9 Managing facilities, page 55.

Chapter 10 Managing tools and equipment, page 59.

Chapter 11 Managing containers and packaging, page 64.

Chapter 12 Vehicle maintenance and hygiene, page 68.

Chapter 18 Testing, page 90.

Premises, facilities, equipment, tools, packaging and vehicles

Produce can be contaminated through contact with facilities, equipment, containers, materials and vehicles. All items that contact produce, areas where produce is handled or stored (including enclosed growing areas), and vehicles used to transport produce must be constructed, maintained and cleaned in a manner that minimises the risk of produce contamination.

The risk of contamination of produce varies with the type of produce grown and/or packed. For higher risk produce more rigorous practices such as sanitation are required to minimise the risk of contamination.

Premises and facilities include all produce handling areas and their surrounds (internal and external) including:

• storage sheds • cool rooms • pack houses • greenhouses and growing areas • field packing areas.

Premises and facilities should be:

• located away from likely sources of contamination (identified on the property map)

• properly located, designed, constructed and maintained to reduce likelihood of contamination to produce

• free from flaking paint, rust, dust, dirt, loose objects, splinters, etc.

• appropriate for the type of produce being handled and the processes being undertaken.

For produce packed for retail sale (includes, but is not limited to, retail crates, pre-packs) it is important to have designated ‘clean’ areas that are able to be kept free from dirt, dust and other contaminants during sorting and packing, in preparation for dispatch to the customer.

NOTE: We have extended the use of the Form - F8 Facility audit checklist to capture compliance against these criteria (F8.1.) This is one way to demonstrate for the business to demonstrate compliance, the use of this form is not mandatory for a business. The business should determine the frequency of monitoring if they choose to use the Form - F8 Facility audit checklist.

Toilet and handwashing facilities

Toilets and hand washing facilities must be:

• located to minimise the risk of contaminating produce and maximise accessibility (i.e. - ease of access)



• provided to accommodate the number of workers (i.e. - can cope with number workers on site)

• kept clean, and regularly maintained and serviced • designed to ensure hygienic removal of waste and to minimise the risk of

contaminating produce directly, or indirectly, through contamination of growing site or water sources

• equipped with running water (as specified in F6.4.1), liquid soap, mechanism/s for effective hand drying, and waste disposal facilities (See Appendix A-F8)

• hand washing instructions are displayed (including language translations and/or pictures where applicable).

*Approved mechanisms for effective hand drying include disposable paper towels, hand dryers.

Hand drying facilities must be used effectively and properly maintained to minimise the risk of contamination to produce.

For produce that has an edible skin and may be eaten uncooked, all workers must apply hand sanitiser after handwashing using soap and water. This shall be before handling produce or materials that may touch produce.

Maintenance records and checks, cleaning plans and product specifications (for hand dryers) are kept on file.

Septic waste and drainage systems

Septic, waste disposal and drainage systems should be located and maintained to minimise the risk of contaminating produce directly, or indirectly, through contamination of the growing site(s) or water source(s) and identified on the property map.

Drains should be designed and managed to:

• prevent ponding in areas where produce is handled and stored • prevent pests entering the facility • enable regular cleaning, and ensure they are kept clean.

Construction of new septic, waste disposal and drainage systems should be managed in accordance with the Freshcare FSQ4.1 Standard requirements ensuring they are located and constructed to minimise the risk of contamination to produce.

Tools, equipment and containers

Tools, equipment, and containers should be:

• made of substances that are non-toxic, and designed and constructed to enable regular cleaning and maintenance

• stored in a manner that minimises contamination.

Handheld harvesting tools should be cleaned each day, before use, and be accounted for at the end of each day. Any handheld harvesting tools unaccounted for should be reported and investigated via an internal Corrective Action Record (Form – M4 Corrective action record).

For produce that has an edible skin, and may be eaten uncooked:

• produce containers used at harvest are handled to avoid produce being contaminated by soil or other physical contaminants

• a food grade liner is used when containers cannot be effectively cleaned.

Wooden bins and pallets should be checked for cleanliness, foreign objects, pest infestation, odours and protruding nails or splinters. Where required, bins and pallets are cleaned, repaired, rejected or covered with a protective material to ensure contamination of produce is avoided.

Packaging materials

Packaging materials should be sourced from suppliers managed in accordance with F11 Suppliers.

Packaging materials must be stored in a manner that minimises contamination. Before use all packaging materials should be checked for cleanliness, foreign objects and pest infestation. When required, packaging materials should be



cleaned, rejected or covered with a protective material to ensure contamination of produce is avoided.

Packaging materials used for retail sale (includes, but is not limited to retail crates, pre-packs) must be food grade.

Vehicles and transportation

Fresh produce can be exposed to chemical, microbial and physical contamination during transport operations.

The important factors that need to be considered are the state of the vehicles used to transport the produce, and what else is stored or transported with the produce.

Vehicles may be refrigerated or non-refrigerated, depending on the produce being transported.

Preventative maintenance and cleaning

Cleaning to remove soil, dust, grease, oil, chemicals, and foreign objects minimises the risk of contaminating produce. All equipment, containers and materials that come in contact with produce, and areas where produce is handled, packed and stored needs to be regularly and effectively cleaned.

The method of cleaning and frequency will depend on the type of produce and how it is handled, packed and stored, and how often the equipment, container or area is used.

A cleaning plan must be documented (refer to Form – F8 Cleaning plan). Information required on this plan includes:

• areas and items to be cleaned • cleaning agents and the methods used • frequency of cleaning • name of the person responsible for ensuring cleaning is completed.

Chemicals and materials used for cleaning and maintenance must be appropriate for use. If using chemicals for cleaning it is important to make sure they do not contaminate produce through inappropriate use or storage.

Equipment used for cleaning should be stored appropriately. Workers that complete cleaning tasks must be trained, and a record of training retained.

To ensure cleaning is effective, monitoring must be undertaken. The Guidelines for Fresh Produce Food Safety (2019) Chapter 18 gives business information in how cleaning and sanitation can be monitored through facilities testing.

Cleaning contractors (if used) should be included on the approved supplier list. These contractors must meet the required specifications as outlined in F11 Suppliers.

Waste disposal

Waste generated on the property must be managed, appropriately stored and disposed of to reduce the potential for produce contamination.

Waste containers are provided, appropriate for use, clearly identified and emptied on a regular basis. Containers used for storing waste, chemicals or dangerous substances are clearly identified and not used for produce.

Waste storage onsite should be:

• clearly identified, adequately sized, and conveniently located for the type of waste generated

• located to minimise the risk of contaminating produce and kept clean and tidy

• identified on the property map.

Waste disposal should be appropriate for the type of waste generated; for example, chemical containers are appropriately segregated, stored and sent to drumMUSTER® (or other approved facility) and are not buried or burned.

Any waste disposal sites on the property should be located to minimise the risk of contaminating produce, clearly identified and recorded on the property map.

Factsheet – F9 Animals and pests

FRESHCARE FOOD SAFETY & QUALITY FACTSHEET – F9 ANIMALS AND PESTS Ref: 1906 PAGE 1 OF 1


• Animals and pests

For more information refer to the Guidelines for Fresh Produce Food Safety (2019), Chapter 13 Managing animals, page 70.

Animals and pests

Animals and pests, including dogs, cats, rats, mice, birds, cockroaches and other insects, can be a source of microbial contamination.

Livestock, domestic animals and wildlife are also considered a source of microbial contamination and should therefore (where possible) be excluded from growing sites and packing facilities.

The presence of animals and pests in and around growing, handling, packing and storage areas also needs to be minimised. This may be done through the use of physical barriers or chemical controls.

If using chemicals for pest control it is important to make sure they do not contaminate produce through inappropriate use or storage.

Workers should be trained to report all instances of pest sightings. Any workers responsible for laying and monitoring baits or traps must be trained, with a record of training kept.

Records of monitoring of pest baits or traps to ensure they are effective in controlling target pests should also be retained.

Pest control contractors (if used) should be included on the Supplier list (refer to Form – F11 Supplier table). These contractors must meet the required specifications as outlined in the element F11 Suppliers.

Factsheet – F10 People

FRESHCARE FOOD SAFETY & QUALITY FACTSHEET – F10 PEOPLE Ref: 1906 PAGE 1 OF 2


• People • Food safety instructions • Site security

For more information refer to the Guidelines for Fresh Produce Food Safety (2019) Chapter 14 Managing People, page 72.

People

People are an important part of fresh produce production. People can be a source of microbial contamination, including bacteria, such as E. coli and Salmonella, and viruses such as Hepatitis A. Adequate facilities must be provided for workers, such as toilets and hand washing facilities, to minimise contamination of produce.

People can unintentionally introduce allergens via cross-contamination from raw material inputs or other substances. See Factsheet F7 Allergens for more information.

People can also introduce physical contamination from items such as adhesive bandages, jewellery and other personal items.

In assessing the risk of contamination, review the competence, experience and capabilities of workers to ensure that they pose no threat to food safety while handling produce.

Basic food safety training must be conducted in personal hygiene standards (e.g. hand washing, no smoking, and no communicable diseases) with regular reinforcement on-site using written instructions and/or prominently displayed signs. Training materials should be provided in relevant languages and/or pictorially.

Any workers, visitors or contractors known (or suspected) to be suffering from or to be a carrier of a disease or illness likely to be transmitted through fresh produce must report to management. They shall not be permitted to enter food handling areas or handle produce.

Food safety instructions

Written food safety instructions must be provided to ALL workers and visitors (including contractors) and must include as a minimum, requirements for:

• health status, including what to do if ill • personal hygiene • handwashing • management of clothes and personal items • use of protective clothing (where necessary) • general behaviour.

Personal hygiene instructions should include requirements for cleanliness, handwashing, personal items and clothing, behaviour and health status.

All workers need to be made aware of allergens, and the role they play in ensuring that allergens are not inadvertently introduced to the product.

Refer to Form – F10 Food safety instructions for a form template. This may be used as is or modified to suit your business.

Compliance with food safety and hygiene requirements should be monitored and if required, food safety training should be repeated to update workers, contractors and/or visitors’ knowledge.

Site security

The Freshcare FSQ4.1 Standard requires that access to the property, growing sites and product handling areas is restricted to authorised persons.

An authorised person is defined in the Standard as ‘a person delegated the right to perform a task or access specific areas of a business; authorisation may be in consideration of training completed or position held.’

Property signage, secure doors, locked storage areas may also assist in restricting property access to authorised persons only. Workers must be trained in site security requirements and to report unauthorised access or unknown visitors to the owner and/or appropriate senior manager.

Factsheet – F10 People

FRESHCARE FOOD SAFETY & QUALITY FACTSHEET – F10 PEOPLE Ref: 1906 PAGE 2 OF 2

Information regarding site access, movement and emergency procedures should be communicated to all workers, visitors and contractors.

Freshcare provides access to free sign templates. Freshcare signs can be downloaded via the Resources section of the Freshcare eLearning website: www.freshcare.com.au/elearning.

http://www.freshcare.com.au/elearning

Factsheet – F11 Suppliers

FRESHCARE FOOD SAFETY & QUALITY FACTSHEET – F11 SUPPLIERS Ref: 1906 PAGE 1 OF 8


• Identifying suppliers that may be a food safety risk • Evidence of compliance • Managing Freshcare certified produce • Supplier requirements table

For more information refer to the Guidelines for Fresh Produce Food Safety (2019) Chapter 15 Suppliers of inputs and services, page 79.

Identifying suppliers that may be a food safety risk

Input materials and services (including outsourced services) can introduce food safety hazards into the business. This includes raw materials, such as produce, packaging, fertilisers and agricultural chemicals as well as services such as transport, crop spraying, co-packers or advice such as pest management or nutritional advice.

As they may introduce a food safety risk, input materials and services must be managed to ensure that the supplier complies with the applicable requirements of the Freshcare Food Safety & Quality Standard Edition 4.1.

Managing your suppliers to ensure they meet set specifications will help minimise the risk of introducing food safety hazards into your business.

If identified as an input material or service that may introduce a food safety risk, purchase records must be kept.

Evidence of compliance

Freshcare FSQ4.1 F11.1 requires that materials and services that may introduce a food safety risk are managed and evidence of compliance for suppliers of such materials and services be kept. This can be demonstrated by:

• Independent evidence of compliance – this may include evidence of Certification, Certificates of Analysis, Water Quality Reports, Statements of Compliance, etc.

• A written declaration to comply with requirements – establishing a supplier agreement (or contract) that they will meet the specifications as outlined in the supplier specifications table.

• A record of inspection/assessment against requirements/specifications as outlined in the Supplier requirements table (see following section).

If you have more than one supplier (including any backup or emergency suppliers) of a material or service, evidence of compliance is required for each supplier.

Agricultural chemicals must be purchased from approved suppliers to demonstrate that the suppliers are meeting the minimum requirements for supply, as outlined in the Freshcare Food Safety & Quality Standard Edition 4.1

Three examples demonstrating supplier compliance for agricultural chemicals:

1. AgSafe accreditation, evidence provided. 2. Establishing a supplier agreement (see example on page 2) that ensures:

o all chemicals provided are adequately labelled and in acceptable condition;

o all chemicals provided are within Use By dates; and o all chemicals provided are appropriate for the use required.

3. Inspecting each purchase/delivery against specifications, to ensure:

o all chemicals provided are adequately labelled and in acceptable condition;

o all chemicals provided are within Use By dates; and o all chemicals provided are appropriate for the use required.



Example of supplier agreement for an agricultural chemical supplier

Managing Freshcare certified produce

If a business is representing their produce as Freshcare certified and they:

• source produce from another business – The business providing the sourced produce must also hold a current certification to the Freshcare Food Safety & Quality Standard or alternate, approved GFSI benchmarked standard.

• send their product to another business (e.g. for packing) – The packing business must also hold a current certification to the Freshcare Food Safety & Quality Standard or alternate, approved GFSI benchmarked standard.

The approved GFSI Benchmarked Standards recognised by Freshcare is available in the Appendix of the Food Safety & Quality Standard (See Appendix A-F11).

This can be managed through the suppliers list (refer to Form – F11 Supplier table) and traceability records (refer to Form – F13 Supplier traceability).

Business logo Business name

Business address

Date

Approved supplier acknowledgement We acknowledge the requirements of Freshcare Food Safety & Quality Standard and agree to: • Provide chemicals appropriate for the use required. • Be approved in accordance with the relevant legislative/regulatory

requirements. • Provide products that are packaged accordingly and adequately

labelled (including Expiry Date or Date of Manufacture). • Advise if we are aware that product contains or has been in contact

with known allergens. • If entering site, abide by food safety instructions when handling

produce or entering growing, storage and packing areas. Regards, Name Position Contact details

EXAMPLE ONLY



Supplier requirements table

Suppliers of materials and services (including outsourced services) identified in Form – F11 Supplier table must comply with the applicable requirements of the Freshcare Food Safety & Quality Standard, as outlined in the table below.

Input material/service Requirements for suppliers

Agricultural chemicals

• Evidence of Ag Safe accreditation/compliance with legislative requirements. • Provide chemicals appropriate for the use required. • Approved in accordance with the relevant legislative/regulatory requirements. • Packaged accordingly, adequately labelled (including Expiry Date or Date of Manufacture). • Advise if you are aware that product contains or has been in contact with known allergens. • If entering site, abide by food safety instructions when handling produce or entering growing, storage and packing areas.

Agricultural chemical application

• Hold appropriate accreditation e.g. commercial spray licence and provide copies of accreditation. • Apply chemicals:

o according to label directions, or o under ‘off-label permits’ issued by the Australian Pesticides and Veterinary Medicines Authority (APVMA), with a current copy of the

permit kept, or o according to relevant state legislation for ‘off-label use’, and o according to specific customer and/or destination market requirements.

• Check chemicals for withholding periods prior to use. • Check chemicals for label changes when opening each new container. • Avoid chemical application when the risk of contaminating adjacent crops or off-target areas with spray drift is high. • Ensure application equipment is maintained and checked for effective operation before and during each use. • Ensure equipment is calibrated at least annually or as per manufacturer’s instructions, and immediately after spray nozzles are replaced.

Provide records of calibration. • Dispose of leftover chemical solutions according to label directions where specified, or in a manner that minimises the risk of

contaminating produce directly or indirectly through contamination of growing site or waterways. • Record all chemical applications including:

o application date




o start and finish times o location and crop o chemical used (including batch number if available) o rate of application and quantity applied o equipment and/or method used to apply the chemical o withholding period (WHP) or earliest harvest date (EHD) o wind speed and direction o name and signature of person who applied the chemical.

• Advise if you are aware that products used contain or have been in contact with known allergens. • If entering site, abide by food safety instructions when handling produce or entering growing, storage and packing areas.

Agronomist/technical advisor

• Be appropriately certified/qualified and provide details of these qualifications. • Make all recommendations in writing. • Ensure all agricultural chemical recommendations are in accordance with label or permit specifications. • Ensure recommendations consider withholding periods (WHP) and anticipated harvest dates. • If entering site, abide by food safety instructions when handling produce or entering growing, storage and packing areas.

Bin/tubs/crates, and liners

• Ensure bin/tubs/crates are constructed from materials that are non-toxic and designed and constructed to enable regular cleaning and maintenance. Provide evidence of compliance documentation.

• Use only food-grade chemicals when cleaning and sanitising bin/tubs/crates. Provide copy of SDS as evidence. • Ensure bin/tubs/crates supplied are cleaned, in appropriate condition, free from foreign objects and pest infestation. • Ensure bin/tub/crate liners are of food grade. • Advise if you are aware that product has been in contact with known allergens. • If entering site, abide by food safety instructions when handling produce or entering growing, storage and packing areas.

Calibration of scales • Be a licensed certifier, per the relevant legislation i.e. Trade Measurement Act, and provide evidence of certification. • Provide a record of calibration results. • If entering site, abide by food safety instructions when handling produce or entering growing, storage and packing areas.

Calibration of thermometers, cool rooms

• Be a licensed certifier, per the relevant legislation i.e. Trade Measurement Act, and provide evidence of certification. • Provide a record of calibration results.




• If entering site, abide by food safety instructions when handling produce or entering growing, storage and packing areas.

Chemicals – cleaning

• Ensure chemicals are approved for use in a food handling area. Provide copy of SDS as evidence. • Packaged accordingly and adequately labelled (including Expiry Date or Date of Manufacture). • Advise if you are aware that product contains or has been in contact with known allergens. • If entering site, abide by food safety instructions when handling produce or entering growing, storage and packing areas.

Chemicals – water treatment

• Ensure chemicals are approved for use in a food handling area. Provide copy of SDS as evidence. • Packaged accordingly and adequately labelled (including Expiry Date or Date of Manufacture). • Where required, ensure additional validation and monitoring requirements are provided for the required use. • If responsible for monitoring, ensure staff undertaking monitoring are appropriately trained. • Advise if you are aware that product contains or has been in contact with known allergens. • If entering site, abide by food safety instructions when handling produce or entering growing, storage and packing areas.

Contract cleaning – food contact equipment

• Ensure chemicals are approved for use in a food handling area. Provide copy of SDS as evidence. • If cleaning occurs off-site, ensure food contact equipment is transported back to the production site in a hygienic manner and protected

during transport to maintain cleanliness. • Ensure staff undertaking cleaning are appropriately trained. • Advise if you are aware that product contains or has been in contact with known allergens. • If entering site, abide by food safety instructions when handling produce or entering growing, storage and packing areas.

Contract cleaning – premises

• Ensure chemicals are approved for use in a food handling premises and provide evidence. • Ensure cleaning equipment and chemicals are stored, applied and handled to prevent contamination of produce. • Provide details of cleaning activities as requested including areas/items cleaned, cleaning agents and methods used and frequency of

cleaning. • Ensure staff undertaking cleaning are appropriately trained. • Advise if you are aware that any products used contain or have been in contact with known allergens. • If entering site, abide by food safety instructions when handling produce or entering growing, storage and packing areas.

Contract labour • Provide evidence of compliance to relevant statutory/regulative requirements for this type of business (i.e. Worksafe, superannuation,

etc.). • Ensure all workers have been trained in the food safety requirements of the Freshcare Food Safety & Quality Program.




• Maintain records of training and provide copies of records. • If entering site, abide by food safety instructions when handling produce or entering growing, storage and packing areas.

Fertilisers and soil additives

• Provide fertilisers and soil additives appropriate for the use required. • Ensure packaging is intact and there is no leakage or possibility of contamination. • Ensure fertiliser or soil additive is mixed to correct specifications and is of good quality, free flowing and dry (if solid). • Ensure fertilisers and soil additives meet legal requirements for heavy metals. • Advise if you are aware that products contain or have been in contact with known allergens. • If entering site, abide by food safety instructions when handling produce or entering growing, storage and packing areas

Fertilisers and soil additives containing manures and/or food waste

• If sourced from suppliers: o with an approved certified treatment process – provide evidence of certification to AS4454-2012 o that follow a documented, verified treatment process (AS4454-2012 or other equivalent time/temperature treatments) – details of

the treatment process and a Certificate of Analysis for each batch of product supplied to verify the treatment process achieves E. coli <100 cfu/g, Salmonella Not Detected/25g.

• Ensure packaging (where applicable) is intact and there is no leakage or possibility of contamination. • Ensure fertiliser is mixed to correct specifications and is of good quality. • Advise if you are aware that products contain or have been in contact with known allergens. • Records of time and temperature monitoring must be available if required. • If entering site, abide by food safety instructions when handling produce or entering growing, storage and packing areas

Laboratory testing (Competent Laboratory)

• Hold NATA accreditation, or be accredited against ISO/IEC 17025, for the required scope of testing and provide evidence of accreditation. Or a laboratory run by a local, state or federal government authority or university, that follows Australian Standard methods for the required scope of testing. Records are available and show methods used against the testing conducted.

• If entering site, abide by food safety instructions when handling produce or entering growing, storage and packing areas

Packaging

• Ensure packaging is appropriate for use and made of substances that are non-toxic and are food grade, compliant with relevant statutory/regulative/customer requirements. This will require evidence in the form of a statement of compliance from the packaging manufacturer.

• Ensure packaging is clean and free of foreign objects and pest infestation prior to delivery. • Advise if you are aware that any products used contain or have been in contact with known allergens. • If entering site, abide by food safety instructions when handling produce or entering growing, storage and packing areas.




Packing Services (co-packers)

• The packing business must also hold a current certification to the Freshcare Food Safety & Quality Standard, or alternate, approved GFSI benchmarked standard for the scope of services being provided. Evidence of current certification to be provided.

• Advise the business immediately if the certification is withdrawn or expires. • Advise if you are aware the produce contains or has been in contact with known allergens. • If entering site, abide by food safety instructions when handling produce or entering growing, storage and packing areas.

Pest control

• Be appropriately licensed/certified and provide copies of credentials. • Ensure all chemicals and baits supplied or recommended are approved for use, used in accordance with label instructions and not applied

to the harvestable part of the crop. • Ensure baits/traps are located and contained to minimise the risk of contaminating produce, packaging containers, materials and

equipment. • Provide a map of bait/trap locations. • Provide written records of inspections, pest levels and action taken after each visit. • If entering site, abide by food safety instructions when handling produce or entering growing, storage and packing areas.

Planting material

• Ensure planting material containers/trays are free from physical contaminants. • Provide healthy and disease-free planting materials. • Provide seedlings of the age/growth stage and variety requested. • Provide records demonstrating any treatment processes that may have been applied prior to delivery. • If applicable, provide evidence of compliance to interstate requirements (e.g. Interstate Plant Health Certificates). • Advise if you are aware that planting materials contain or have been in contact with known allergens. • If entering site, abide by food safety instructions when handling produce or entering growing, storage and packing areas.

Portable toilets

• Position portable toilets to minimise risk to produce and maximise accessibility. • Regularly maintain and service portable toilets. • Ensure portable toilets are designed to ensure hygienic removal of waste and minimise the risk of contaminating produce directly or

indirectly through contamination of growing site or water sources. • Ensure portable toilets are equipped with running water (meeting specified water limit E. coli <1cfu/100ml), liquid soap, disposable paper

towels/hand dryers and waste disposal facilities. Where requested, alcohol based hand sanitiser may also be required. • If entering site, abide by food safety instructions when handling produce or entering growing, storage and packing areas.




Produce

• Provide evidence of current certification to Freshcare Food Safety & Quality Standard, or alternate, approved GFSI benchmarked standard, the scope of which covers the type of produce being supplied.

• Advise the business immediately if the certification is withdrawn or expires. • Advise if you are aware the produce contains or has been in contact with known allergens. • If entering site, abide by food safety instructions when handling produce or entering growing, storage and packing areas.

Transport

• Evidence of current certification to a third party audited food safety standard for the scope of transport services being supplied. • Ensure produce is not transported under conditions or with other goods that present a potential source of contamination. • Check transport vehicles before use for cleanliness, foreign objects and pest infestation and, where necessary, clean to prevent

contamination of produce. • Check transport refrigeration systems prior to loading to ensure they are operating at specified temperatures. Maintain records to verify

temperature during transit. • Ensure that all vehicles used are free of / have not been in contact with known allergens (unless properly cleaned). • If entering site, abide by food safety instructions when handling produce or entering growing, storage and packing areas.

Water • Ensure water quality supplied for use meets relevant specified limit (E. coli <100cfu/100ml, E. coli <1cfu/100ml) and evidence of

compliance is provided (e.g. Certificates of Analysis, Water Quality Reports, Statements of Compliance). • If entering site, abide by food safety instructions when handling produce or entering growing, storage and packing areas.

Water – recycled/reclaimed

• Ensure water quality supplied for use meets the appropriate specifications as defined in the Australian Guidelines for Water Recycling and evidence of compliance is provided (e.g. Certificates of Analysis, Water Quality Reports, Statements of Compliance).

• If entering site, abide by food safety instructions when handling produce or entering growing, storage and packing areas.

Factsheet – F12 Food defence and food fraud

FRESHCARE FOOD SAFETY & QUALITY FACTSHEET – F12 FOOD DEFENCE AND FOOD FRAUD Ref: 1906 PAGE 1 OF 3


• Food defence • Food fraud • Risk assessments for control plans

For more information refer to the Guidelines for Fresh Produce Food Safety (2019) Chapter 8 Managing people, page 72.

Food defence

Agriculture is part of Australia’s critical infrastructure, but it is also potentially vulnerable to threats that may impact both public health and the economic position of the individual market and wider sector, both locally and internationally, as well as causing reputation damage.

Definition: Food Defence – the efforts to prevent intentional contamination of food products by biological, chemical, physical, or radiological agents that are not reasonably likely to occur in the food supply chain.

What motivates intentional contamination?

• Terrorism – intent to kill as many people as possible. • Economic – intentional (malicious) damage to an individual business to cause

economic harm; intentional damage to an individual business to impact product value in the market; intentional damage to an individual business to affect land utilisation/value.

• Issue Related – interest groups seeking to damage an industry. • Extortion – criminal effort to obtain financial gain.

How is this relevant to the fresh produce sector and/or individual Freshcare businesses?

If there is an ability, opportunity and desire to do harm, then the ‘risk’ is present. Eliminating opportunity is the only realistic and practical way to address that risk. Whilst it’s obviously impossible to secure the entire supply chain, understanding potential risks and control measures is key to control.

Are there real examples of intentional contamination in the fresh produce sector?

• In 1978, several children in Holland fell ill after eating Israeli Jaffa oranges contaminated with mercury. The event was attributed to Palestinian terrorists, seeking not to harm individuals, but to damage the Israeli economy.

• In 2007, the alleged contamination of a water contractor’s tanker with herbicide resulted in over $1 million worth of crop damage in Queensland. Crops not directly lost to the herbicide damage were deemed unsaleable in consideration of detectable levels of chemical residue.

• In 2018, Strawberries were removed from the retail markets across the nation as a needle was found in a punnet. This resulted in a social media frenzy and a host of “copycat” claims that resulted in significant impact to the industry.

What does an individual business need to do?

A food defence vulnerability assessment needs to be completed. Identifying specific points where intentional contamination has the greatest potential to cause economic and/or public health harm; and documenting the likelihood and severity should it occur and then mechanisms for control to mitigate the risk to public health. Mechanisms that are likely to include site access and security and, team training and awareness.

At a minimum, your Food Defense Plan should address:

• processing/ product security

• storage security

• shipping and receiving security

• water and ice security

A form template has been provided to document the vulnerability assessment and control plan, refer to Form – F12 Food defence vulnerability assessment and control plan.



The food defence vulnerability assessment and control plan must be reviewed at least annually by the business and amended where additional risks identified, or changes occur in the business that impact the plan.

Food fraud

Food fraud is considered an increasingly important issue in the overall food supply chain, impacting all sectors including fresh produce. Food fraud has the potential to impact both public health and the economic position of an individual business or wider industry sector, both locally and internationally.

Definition: Food Fraud - the deliberate and intentional substitution, addition, tampering or misrepresentation of food, food ingredients or food packaging; and/or the mislabelling of a product resulting in economic gain and/or impact to public health.

What types of food fraud might be encountered?

Common types of food fraud include:

• Adulteration – the addition of substances to a food product, generally for economic advantage, making it potentially unsafe or no longer fit for purpose.

• Substitution – the replacement of a food or food ingredient with an alternate product, with an economic advantage and potential food safety implications.

• Misrepresentation or mislabelling of a product for economic gain, with potential associated food safety risks.

How is this relevant to the fresh produce sector and/or individual Freshcare businesses?

The opportunity for food fraud in the fresh produce sector is potentially very real, in consideration of both business inputs and final product, both potentially impacting on product integrity and safety. Whilst it is recognised that an individual grower is unlikely to have the ability to control instances of food fraud occurring further up the supply chain, there are several aspects of food fraud that should be considered at farm level.

Are there real examples of food fraud in the fresh produce sector?

Several examples of food fraud are directly related to the fresh produce sector.

• The marketing of cherries in key export markets as ‘Australian Cherries’ in counterfeit packaging, well outside the Australian season of supply. The misrepresentation presenting an assurance of quality and food safety compliance that is not real.

• A similar misrepresentation occurs if product from non-certified fresh produce businesses is packed by a Freshcare certified business and represented for sale as Freshcare certified. In this instance the customer has an expectation of food safety compliance that may not be the case.

• The use of second hand packaging without completely obscuring the original grower’s details presents a potential food fraud scenario. Product presented to the marketplace as the original grower may provide direct commercial advantage for the second grower, it may also present an assurance of food safety compliance which may not be correct.

• The supply of counterfeit (copy) agricultural chemicals can also be considered as food fraud. This key input into most fresh produce businesses, can introduce significant business risk if counterfeit chemicals are used (efficacy/crop impact) and has the potential to directly impact food safety and human health.

What does an individual business need to do?

A food fraud vulnerability assessment needs to be completed, identifying a business’s food fraud vulnerabilities that have the potential to cause economic and/or public health harm; and documenting the likelihood and severity should it occur and documenting the mechanisms for control to mitigate the risk to public health. Mechanisms for control are likely to include supplier management (business inputs and fresh produce), product identification and traceability (raw material and finished product) and team training.



A form template has been provided to document the vulnerability assessment and control plan, refer to Form – F12 Food fraud vulnerability assessment and control plan. The food fraud vulnerability assessment and control plan must be reviewed at least annually by the business and amended where additional risks identified, or changes occur in the business that impact the plan.

Risk assessment for control plans

When developing your food defence and food fraud vulnerability assessment and control plans undertake a risk assessment utilising the significance matrix below to help you identify the significance of the threat and establish control measures to manage and mitigate potential risks.

Significance matrix Severity Likelihood

Consumer Business

1. Fatality 1. Closure of Business A. Common occurrence

2. Serious sickness/ Hospitalisation 2. Major Financial loss B. Known to occur

3. Product recall/ Minor Harm 3. Minor Financial Loss C. Could occur

4. Customer complaint/ Repulsion or Disgust

4. Disruption to Normal Operations

D. Not expected to occur

5. Not significant 5. Not significant E. Practically

impossible

Likelihood Severity A B C D E

1 High High High Medium Medium 2 High High Medium Medium Low 3 High Medium Medium Low Low 4 Medium Medium Low Low Low 5 Low Low Low Low Low

Factsheet – F13 Product identification and traceability

FRESHCARE FOOD SAFETY & QUALITY FACTSHEET – F13 PRODUCT IDENTIFICATION AND TRACEABILITY Ref: 20201101 PAGE 1 OF 3


• Product identification and traceability • Traceability test • Product Release

For more information refer to the Guidelines for Fresh Produce Food Safety (2019) Chapter 17 Product identification, traceability and recall, page 84.

Product identification and traceability

One of the most important parts of a food safety and quality system is the ability to trace produce ‘one step up and one step back’. When all members of the supply chain, from paddock to plate, have strong identification and traceability systems, unsafe or unsuitable produce can be easily identified and removed from sale.

Identification and traceability relies on having ‘batches’. A batch needs to be a manageable quantity of produce (i.e. tracing fruit to the particular tree is not likely to be an effective way to run a commercial orchard) and should relate to the inputs or treatments applied. A paddock may be a good batch if it includes only one type of produce and the same chemicals and fertilisers are applied across the paddock.

If batches are too large, the business risks having to recall more produce in the event of a significant problem occurring. If batches are too small, the business can spend more time recording traceability details than is necessary. Ultimately the batch size relates to risk and the level of risk a business is prepared to take.

Growing produce

The location of separate growing sites/areas must be identified on a property map to enable traceability to where the produce is grown. Identification used to distinguish separate growing sites/areas should be documented on all records used for the production of the crop.

Harvested produce

For harvested produce, the batch identification should be linked to harvest date and destination, and where on the farm the produce was grown. This information can be recorded in a diary, a harvest record, or on a delivery docket. One way of doing this is to number the container or trailer and record the number on the delivery docket along with harvest date, destination and growing area identification.

Cross referencing the harvest date and growing area identification to farm records, allows for traceability of each batch of produce during production.

Packed produce

For packed produce, a batch can be all the produce packed on the same day and treated the same before and after harvest. The batch can be identified by marking the packed container with business name and packing date or other coding.

It is recommended to mark each package, as traceability can be lost when packages are removed from pallet loads. This is particularly important when product is intended for the retailers. Depending on the destination of the packed produce, there are legislative and customer specific requirements regarding identification and labelling.

Some common batch identification codes used include consignment note number, pallet number, random number, or a date code. Examples of codes for a packing date of the 1 July 2016 are:

• 010716 • 160701 (first and last 2 numbers reversed) • 071601 (day of the month last) • 182 (the 182nd day of the year).

The packing date or batch identification code (if used) must be linked to the growing area and destination.

This information can be recorded in a diary, packing record, delivery advice, or consignment note.



If produce packed on the same day comes from different growing areas that have been treated differently, marking the growing area identification on the package will help traceability.

Cross-referencing the packing date, growing area identification and harvest date to farm and packing records allows the chemical treatment(s) of each batch before and after harvest to be identified. For example, chemicals applied to the produce will be recorded in the spray record and postharvest chemical record.

Sourced produce

Product and traceability records must also be maintained for all product sourced from suppliers. This includes packing product from another business, or providing other services such as packing, product sorting, grading etc. for other businesses.

Dispatch of Product

All produce dispatched to a customer is marked with:

• business name and physical address • packing date and/or batch identification code • other trade descriptions required by legislation and/or customer.

Dispatch records must be kept and include the following details:

• customer and/or destination. • dispatch date • batch identification code • quantity. Dispatch records could be recorded in a diary, delivery advice, consignment note or other tracking system.

Conducting a Traceability Exercise

For all produce harvested and packed by a business, it is essential that each business is able to quickly and accurately trace product back to the previous point in the process, whether it is for your own product or supplied product.

The product traceability system must be tested at least annually to verify full traceability of produce from production to its destination/ immediate customer (or vice versa) is achieved.

Depending on the destination of your produce supply, there may be additional customer specific requirements to consider as part of the produce traceability review.

As a minimum your system should be able to identify the points in the process where product has been handled:

• Incoming seed/ seedling/plant and any treatments applied (where applicable)

• Date of planting and location of planting (block/ row identifiers) (where applicable)

• Any pre-harvest chemical and fertiliser applications and the withholding periods have been met

• Harvest records, including location of harvest, crop/variety, date, quantity.

• Any post-harvest treatment records (where applicable) • Packing records, including packing date and/or batch identification,

quantity, • Records of packaging used, including type, date and quantity (where

applicable) • Records of product that has been sent to another supplier for treatment or

packing • Product release and dispatch records, including destination.



A record of the product traceability system review must be kept. The Form F13 - Traceability Review is available to complete this, however a business may use other recording methods to demonstrate compliance.

For those business that also need to do a mock recall (F14) the traceability exercise is incorporated into the mock recall exercise, there is no need to do this separately.

Product Release

Checking product that is ready for dispatch is essential to prevent sending non-conforming product into the supply chain. Having the right processes in place at dispatch can prevent product being rejected by your customers or pick up an issue that could result in a food safety incident.

Your business should have a documented procedure in place that includes an assessment of product before it leaves. The product release procedure is to ensure all in-process and finished product controls relating to product safety, quality, regulatory and customer requirements have been completed and product compliance verified prior to product dispatch.

Where a customer has provided a written specification, produce should be assessed and checked to confirm that the product and handling specifications have been achieved. If produce does not meet the written specification, the customer (processor, retailer, exporter) should be informed before dispatch, refer to variations for further guidance.

It is also essential that any product that has been identified as non-conforming is clearly labelled and segregated to prevent accidental use. A corrective action record should be generated to investigate the cause of the failure and put steps in place to prevent it from happening again.

Businesses should be on the lookout for the following when checking product

• Is it labelled correctly? • Is it traceable? • Has it been packed according to customer requirements?

• Is it at the right temperature or had the correct treatment applied? • Is there any evidence of contamination? • If it is being sold by weight, does it meet the requirements?

Factsheet – F14 Incident Management, Recall and Withdrawal.

FRESHCARE FOOD SAFETY & QUALITY EDITION 4.2 – FACTSHEET REF1906 F14 INCIDENT, RECALL, WITHDRAWAL – PAGE 1 OF 3


• Incident Management (Business continuity) (Crisis Management) • Incident management plan • Responding to an incident • Recall and withdrawal • Conducting a recall • Trade level recall • Consumer level recall

External Resources:

Department of Industry, Innovation and Science – Business: The continuity plan section www.business.gov.au

Guidelines for Fresh Produce Food Safety (2019) Chapter 17 Product identification, traceability and recall, page 84.

Incident Management

With food safety-related recalls becoming more commonplace, it is essential for businesses to understand and implement processes that will help manage these events in the most transparent and effective ways possible. How your business chooses to function in the middle of a crisis, especially during the early stages when communication is most critical, will undoubtedly affect your entire business going forward.

Proper planning and preparation by your business is key to avoid and reduce the risks associated with events or incidents that could result in major disruptions to operations; and preparing a plan to ensure services to customers can continue.

Incident management planning will help detail the steps to be taken before, during and after an incident or event to maintain the financial viability of the business. It helps you to anticipate, prevent or prepare for disruptions such as fire, flood or storms, transport issues, computer or system crashes, or illness, product contamination (micro, allergens, chemical residues) and supply chain interruptions, and how to respond and recover from them.

Preparing effectively for incident management makes your business more likely to survive an emergency or critical disruption.

Incident management plan

An incident management plan should be developed in consideration to identify ways to:

• reduce the likelihood of an incident occurring • ensure product food safety and quality is not compromised • respond to, and recover from, an incident. • ensure all communications from your business

The Freshcare Food Safety & Quality Standard requires an incident management plan to be documented and identify:

• potential risks to business continuity, and should consider different sources of information

• strategies and practices to manage the identified risks • a list of workers responsible for incident management • details of internal contacts that need to be contacted in the event of an

incident • external stakeholder contacts that need to be contacted in the event of an

incident or to get help to manage an incident • name of the person developing and documenting the plan • date the plan was developed.

A test of the incident management plan must be conducted at least annually with a record kept. The incident management plan should be tested using different incidents/scenarios each time to aid in identifying any updates that may be required of the plan.



Responding to an incident

When responding to an incident, the critical aspect for any fresh produce supply chain business is ensuring that product food safety and quality has not been compromised.

When an incident occurs, the incident management plan must be followed to ensure:

• product safety and quality are not compromised • affected product is identified and isolated (placed on hold) • compliance with food safety and quality requirements is verified, prior to

product release.

If an incident has occurred requiring the incident management plan to be actioned, a record of protocols undertaken must be kept.

Following an incident, a review of the event and incident management plan should be undertaken by workers responsible for incident management and the management of the business. A record of the review and any updates to the plan must also be documented.

Recall and withdrawal

Product recall

A product recall is defined as an action taken to remove from distribution, sale and consumption, food which may pose a health and safety risk to consumers. A recall may arise from:

• internal reviewing of records e.g. spray records show incorrect rate applied • adverse test results e.g. residue test results show MRL exceeded • customer complaint/feedback • notification of a problem from a raw material supplier (such as a chemical

manufacturer or seed supplier) • government authorities such as local government or Food Standards Australia

New Zealand (FSANZ) indicating there is an issue with a product.

More information on product recalls can be sourced from Food Standards Australia and New Zealand (FSANZ) by visiting the food recall section of the FSANZ website: www.foodstandards.gov.au/industry/foodrecalls.

Product withdrawal

A product may be withdrawn from sale for two reasons:

• the product has a quality defect (e.g. colour or texture); is underweight or has labelling irregularities that do not pose a potential risk to public health and safety

• as a precaution, produce may be withdrawn from distribution and/or sale pending further investigation — if a risk to public health and safety is established, the product must be recalled.

Withdrawals do not require notification to statutory authorities or media.

Conducting a recall

If a batch of produce has been identified as being contaminated or potentially contaminated, you need to carry out a product recall as a corrective action. This involves using your product identification and traceability system to:

• identify where produce from the same batch has been sent and notify your customers to remove it from sale

• trace affected produce using records to identify the cause of the contamination and prevent it from occurring again.

It is recommended that the Food Standards Australian New Zealand (FSANZ) Food Industry Recall Protocol booklet be used as a reference when conducting any recalls. This booklet as well as other resources on conducting a food recall can be found on the FSANZ website: www.foodstandards.gov.au/industry/foodrecalls.

There are two levels of recall: trade level recall and consumer level recall.

http://www.foodstandards.gov.au/industry/foodrecalls

http://www.foodstandards.gov.au/industry/foodrecalls



Trade level recall

A Trade level recall involves recovery of the produce from businesses in the supply chain that are not controlled by the primary supplier of the produce (i.e. grower or packer). It does not involve recovery of produce from consumers.

When conducting a Trade level recall, as much information as possible is obtained on the batch or batches of produce that may be affected, the source of the produce, and the cause of the problem. Information is then recorded on the Trade level recall form (refer to Form – F14 Trade level recall template).

Consumer level recall

A Consumer level recall involves recovery of the produce from consumers and businesses in the supply chain.

A determination must be made on whether the situation requires a recall (carried out if there is a food safety or potential food safety risk to consumers) or a withdrawal (carried if there is a quality defect or regulatory breach). Withdrawals are managed using a corrective action record.

As much information as possible must be obtained on the batch or batches of produce that may be affected, the source of the produce, and the cause of the problem. Information is recorded on the A&NZ Product Recall/Withdrawal form.

If produce is supplied to the consumer level, a ‘mock’ recall is completed annually, using the A&NZ Product Recall/Withdrawal form. It is not necessary to notify customers of the mock recall. A record of this activity should be kept as part of your Freshcare Food Safety & Quality Program records.

Updated copies of the A&NZ Product Recall/Withdrawal form can be found on the Australian Food and Grocery Council website: www.afgc.org.au/publications.

http://www.afgc.org.au/publications