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Regulatory food safety audits

The Authority has developed a Regulatory Food Safety Auditor System to approve persons other than Authority employees to conduct regulatory food safety audits of licensed food businesses in NSW.

These auditors may also be known as third party (3rd or third party) or commercially employed auditors.

Only facilities licensed to provide food to vulnerable persons can apply to use this system at present. Other selected industries will move to this system from 1 January 2010.

The system started on 1 October 2009.

Key features include:

  • auditors must have appropriate qualifications, be trained and assessed on the system and be individually approved by the Authority
  • only food businesses with a suitable audit history from Authority auditors may apply to use a regulatory food safety auditor
  • audit results must be sent to the Authority and will form part of an ongoing verification program for both auditors and food businesses
  • the system complies with the National Food Safety Audit Policy and the National Food Safety Auditor Guidelines.

Approval of auditors

The minimum requirements to become an auditor under this system are:

  • RABQSA National Food Safety Auditor (NFSA) Level 2, 3 or 4 or demonstrated equivalent
  • tertiary qualifications: Certificate IV in Food Science or equivalent, including a minimum of 40 hours of microbiology (for high risk endorsements)
  • completion of application form TPA001 (pdf, 81KB)
  • payment of a non-refundable application fee of $880
  • participation in 2 days training and assessment by the Authority
  • completion of a verification audit which will be observed by a RABQSA Skill Examiner employed by the Authority


Details are in the Regulatory food safety auditor manual (pdf, 335KB).

Additional requirements to audit Central Processing Units (CPU’s) under the vulnerable persons food safety scheme:

  • RABQSA NFSA Level 4 (minimum)
  • high risk endorsement – Cook Chill (FDFFSCC4A: Audit a cook chill process)


A central processing unit is a facility that cooks and chills food that will be stored and or transported in excess of 48 hours for service to vulnerable persons. All other licensed facilities under the vulnerable persons food safety scheme will only require a general regulatory food safety auditor to perform their audits.

Auditors

Approved auditors are issued with an identification card from the Authority which they must produce on demand.

Regulatory food safety auditors will be looking for the same issues that an Authority auditor would look for during an audit.

All auditors are required to use the standard Authority checklists when conducting an audit.

Regulatory food safety auditors have the duties of a food safety auditor as described in the Food Act 2003, but do not have the powers of an authorised officer under the Act.

Duties of auditors

A food safety auditor has a duty to:

  • carry out audits of any food safety programs required by the regulations
  • carry out any necessary follow-up action, including further audits, to determine whether action has been taken to remedy any deficiencies of any such food safety program identified in an audit,
  • carry out assessments of food businesses to ascertain their compliance with requirements of the Food Safety Standards,
  • report in accordance with s95 Food Act 2003.


The food safety auditor must advise the food business that they intend to audit of any relationship that the auditor or an auditor’s family member or associate may have with a direct competitor.

Reporting duties

Auditors must report audit results to the Authority within 21 days however, serious breaches must be reported immediately. Examples of serious breaches could be where:

  • audit results are unacceptable
  • an imminent and serious risk to the safety of food intended for sale exists
  • an issue that will cause significant unsuitability of food intended for sale exists
  • there is no food safety program on site
  • monitoring records are not up to date
  • product testing results are missing
  • there are hygiene issues relating to product contact surfaces for ready to eat foods
  • maintenance issues are affecting product
  • there is an infestation of pests
  • the audit cannot be performed or completed
  • abuse, intimidation, obstruction or anything else happens that may restrict the ability of the auditor to perform the audit


Auditors must leave a copy of the audit report at the food business, and ensure that the business is aware of the report findings that will be sent to the Authority.

Which businesses can apply to use this system?

Businesses licensed to provide food to vulnerable persons are the only ones, at this time, that can apply to use this system. The Authority will be progressively rolling out the system for other sectors at a later stage. Licensed food businesses in other industries will be informed when they can apply to use this system.

NSW Food Authority licensees are under no obligation to implement this system. The Authority will continue to perform audits of facilities that choose not to implement this system.

To qualify for this system, facilities must:

  • have no outstanding compliance issues
  • have received an A or B rating at their most recent audits
  • have no outstanding enforcement action and
  • be in an industry that is approved to use the regulatory food safety auditor system.


Full minimum requirements for licensed facilities to be approved are detailed in the Guide to Implementing a Regulatory Food Safety Auditor System (pdf, 164KB).

Licensees who meet all of the criteria can apply using form TPA006 (pdf, 42KB).

The Authority will assess applications against set criteria and contact the applicant in writing with the decision.

Finding an auditor

Auditors that have been approved by the Authority are listed on an auditor register on the Authority’s website.

Information includes the region or areas within NSW where the auditors operate.

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