Written or Printed: The Confusion in the Australian Food Code

A brief explanation of the Australia/New Zealand Food Standard 3.2.2 and the confusion involving the clause demanding written documents
Food Regulations
Nowadays, running a food-related business is not just about preparing and selling food, but a huge part of it is about conforming to government regulations concerning food supply, food content, storing conditions, handling and restaurant environment, et cetera. Many people consider these regulations to be pesky, but they are necessary for ensuring that people get high-quality food. Let us go through the concept of traceability to understand better why these regulations are necessary and how they may help in case of a problem.
The Concept of Traceability
An important component of ensuring the quality of food is traceability. Traceability refers to recording all steps of production, processing, and distribution of the said food product so that it can be tracked and traced if necessary. For example, say that a certain food product sparks a health issue. Now first the government would need to do damage control by recalling all the problematic products so that they are not consumed. That is where traceability comes in since the documentation of all the steps of distribution will help them in implementing a product recall. If you do not know where your product went, how will you recall it?
Secondly, after the recall, there would be an investigation into why and when the problem occurred so as to avoid it in the future. That will be determined by going through the production and processing end of the chain, which is only possible if every link in the chain has been documented. When the problem has been determined, then it will be fixed, and steps will be taken to prevent it from happening again. This is an effective process and is only possible if the government imposes traceability regulations.
In legal terms, traceability is the ability to go from one step to the next, and one step to the previous, from any step in the whole system. It includes documenting the source of raw materials, additional ingredients and packaging, et cetera. The law demands that the following information is documented for every product:
• The name and business address of the place from where the raw material are bought from.
• The description and quantity of the said raw materials.
• Name and address of customers.
• Description and quantity of the sold product.
• Date of order.
• Date of delivery.
• Batch identification number.
• In case that during the manufacture of the product, some manufacturing tasks were outsourced to a third party, then the name and address of the said third party; the description and quantity of supplied products; the description and quantity of received products; and the relevant dates need also be recorded.
• Any other information deemed necessary for ensuring product traceability should also be recorded.
Food Standard 3.2.2
The Australia/New Zealand Food Standard 3.2.2 relates to food safety practices and other requirements. The relevant clauses covering traceability are 5(2), named Food Receipt; and clause 12 named Food Recall. Let us go through them to better understand the requirements, and clear the confusions that plague the food handlers of Australia and New Zealand.
Food Receipt
The clause about food receipt says that at any time, a business involving food must be able to reproduce upon request documents about the food it has in process or storage, and where it was bought or obtained from. The documentation must contain the name and address of the seller, manufacturer and packaging entity of the food; a description and quantity of the said food; and the relevant dates, for example, the date that the order was placed and the date that the food was delivered. In case that the food was imported from another country, it is necessary to document the name and address of the importer. It is to be noted that whether the food was imported or not, the addresses must be Australian. That is, the food manufacturer, supplier, packer and importer all must have valid Australian business addresses. Thus if there is any break in the chain or if it is not possible to determine where a certain food came from then it is illegal by the law of Australia to receive it.
Food Recall
Clause 12 of the Australia/New Zealand Food Standard 3.2.2, or the food recall clause, concerns food manufacturers, suppliers, and importers. It demands that the following information is recorded in writing by the concerned food supplier, manufacturer, and importer:
• The steps and details involved in production
• The description and quantity of the products manufactured and supplied
• Batch identification number
• The addresses of where the food was delivered
• Any other relevant information deemed necessary to assist in case of a product recall
All this information needs to be organized and in an easily accessible place to ensure ease of operation during a total or partial product recall. This will help the authorities in knowing from where to recall the food and how much of it needs to be recalled, so as to prevent further consumption.
The Problem
Now that you fully understand the laws regarding traceability, their effectiveness, and purpose, let us discuss the confusions many people have about these laws. The law clearly states that all the information which needs to be documented must be presented in a written document. Many people are concerned that they are, by law, required to write everything down with a pen. Nowadays businesses are run with the help of computers. Computer systems involve automatic handling and update of databases, and it records all the details. Even receipts are computer generated nowadays. Thus people dislike having to write everything down since it is messy and involves a lot of work, while the computer is doing all the work anyway. Thus this is a problem.
The Solution
Knowing how much this issue troubles people, we decided to clear it up once and for all. We went to the Food Standards Australia/New Zealand to confirm whether written means written by hand or could it also be printed. The guys at Food Standards Australia/New Zealand were only too happy to clear up our confusion, and they said that it does not have to be hand written, but it can also be in a digital format. The purpose is to just have a record of the details of the food, its mode of documentation is irrelevant. Thus, we hope that the mist has cleared up now, in which case we would like to take our leave since our work here is done.