Document or Pay: Winning Queensland’s 3.2.2A Food Safety Audits
Queensland councils are now auditing against Standard 3.2.2A and the Food Act 2006, with higher‑risk activities assessed against accredited programs under Standard 3.2.1. The focus has shifted from “doing the right thing” to “proving it with records.” Here’s how to protect service, margins, and your licence.
1) The situation: evidence-based audits have arrived
Since 8 December 2023, many Australian food service businesses face strengthened requirements. Local government Environmental Health Officers (EHOs) in Queensland now verify compliance with the Food Standards Code and your licence conditions through documented evidence. If a control isn’t recorded, it may as well not exist at audit time.
2) Why this matters: a real Brisbane café lesson
During a routine visit, a busy café handled food safely but couldn’t produce staff training records, a probe‑thermometer calibration check, or cooling logs. Result: an improvement notice and a re‑inspection fee. That’s time and money diverted from service, plus reputational risk if issues escalate.
3) Core insight: documentation is the control
Document your business or get out. In 2024, evidence wins the audit.
Policies, procedures, and records are not admin overhead—they are your operational controls. A single source of truth ensures everyone, including remote or casual staff, follows the same instructions, versions, and checklists. Without that, you’re relying on memory and good intentions, which won’t pass an audit.
4) Action this week: run a 30‑minute gap check
Focus your quick audit on the essentials
- Confirm your Food Safety Supervisor (FSS) is current and documented (certificate on file, expiry tracked).
- Document food handler training: role‑based skills/knowledge, induction, refreshers; keep sign‑offs and dates.
- Verify your program covers the five Standard 3.2.1 essentials:
- Hazard identification
- Monitoring
- Corrective actions
- Regular review
- Records (receival, temperature, cooling, hot‑hold) kept onsite
- Check that forms are in use daily (paper or digital) and accessible during service and audits.
5) Make your records audit‑ready
What to capture, how often, and where
- Receival: supplier, batch/date, temperature on delivery, acceptance/rejection, corrective actions.
- Temperature logs: fridge/freezer daily mins/maxes, line checks during service.
- Cooling logs: time/temperature checkpoints (e.g., 60°C→21°C within 2 hours; 21°C→5°C within 4 hours) and actions if off target.
- Hot‑hold logs: equipment ID, setpoint vs. actual (≥60°C), verified at defined intervals.
- Probe thermometer: daily sanitising method, scheduled calibration checks (e.g., ice‑point/boiling‑point), results and adjustments.
Retention and accessibility
Keep records onsite for the period your council or licence specifies. Store them in one indexed place with clear version control so EHOs can verify quickly without disrupting service.
6) Close the loop: corrective actions and change management
Non‑conformances happen; what matters is your response. Define triggers (out‑of‑spec temps, missed checks, supplier issues), required actions, and who signs off. Maintain a change log for menu/process updates, update SOPs, re‑train impacted staff, and capture training acknowledgements. This keeps remote or rotating team members aligned to the latest method—your single source of truth.
7) Strategic advantage: turn compliance into operations excellence
Strong documentation reduces re‑inspection fees, prevents waste from temperature abuse, and speeds onboarding. It also stabilises quality across shifts and sites, enabling managers to lead rather than firefight. Treat audits like stress tests: if a control is hard to evidence, improve the system, not the story.
8) Your next move
Block 30 minutes this week to run the gap check. Schedule a monthly internal verification, spot‑audit yesterday’s logs, and test your probe calibration. If you’re unclear on alignment with the Food Act 2006, Food Standards Code 3.2.2A and 3.2.1, or licence conditions, contact your council or review the guidance below. Evidence‑first systems protect your customers, your brand, and your margins.
