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Summary of Submissions on the Transition Policy and Related Implementation Discussion Document

8 Food Handler Guidance

Introduction

The discussion document provides criteria for those ‘persons’ who do not need to operate under a Food Control Plan or National Programme. These ‘persons’ will be subject to Food Handler Guidance. The document proposes that Food Handler Guidance material will be available progressively following commencement of the new Food Bill.

Overview of Submissions

Fifteen submitters made comments specific to the provision of Food Handler Guidance. These submitters comprised:

• 8 government bodies (including TAs, PHUs and DHBs)

• 5 industry organisations

• 2 community groups

Summary

There was general support for the use of Food Handler Guidance as a non-regulatory tool for ‘persons’ who fit the criteria. There was some confusion in regard to the decision tree provided on page 27 of the discussion document and submitters asked for clarification of its design.

Several submitters supported the provision of Food Handler Guidance but expressed a range of associated concerns. A number were concerned that the food safety risk posed by occasional operators not be discounted and one industry organisation specifically proposed that the ‘primary guiding principle’ in determining the criteria for Food Handler Guidance be the level of risk and not whether the food operation is non-profit or for profit. One submitter, a community group, in recognising the potential risk associated with occasional operations, asked that Food Handler Guidance be available from the start of the transition.

One TA asserted that only small scale events and sausage sizzles should be included in the provisions for Food Handler Guidance.

A community group was concerned that for some people engaged in very small and occasional food operations, awareness of the availability of Food Handler Guidance and access to TAs, who distribute the material, may be limited. These submitters suggested that NZFSA use community networks to distribute Food Handler Guidance rather than solely rely on TAs.

One TA asked that the application of Food Handler Guidance be consistent in relation to the smallest operators subject to Food Control Plans. Another TA asserted that all commercial food operations, regardless of size or frequency of operation, be regulated under Food Control Plans.

One submitter, an industry organisation, expressed concern that, although Food Handler Guidance will be a non-regulatory tool, TAs will still have the ability to issue permits for activities that qualify for Food Handler Guidance.

Open-air markets

Four submitters consisting of two industry organisations and two TAs commented on the treatment of open-air markets under the new regime. Submitters pointed out that a risk management tool has not been specifically allocated to these events in the discussion document. Two submitters expressed their expectation that open-air markets meet the same regulatory requirements as other commercial food retail businesses, while one TA commented that:

“The regulatory framework on food hygiene should not be such that small community events and charity are compromised. A balance between the need to promote community well-being and inclusiveness and the overall principles of the review should be achieved.”