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Vulnerable persons

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The NSW Food Authority currently licenses around 1,200 businesses that provide food service to vulnerable persons which includes:

  • hospitals
  • aged care facilities
  • same-day aged care services
  • respite services
  • certain delivered meal organisations such as Meals on Wheels.

To protect the vulnerable in our community such as older persons and people who have weakened immune systems due to illness, NSW businesses that serve food to vulnerable persons need to meet specific additional food standards set out in the Food Regulation 2015 Vulnerable Persons Food Safety Scheme.

Childcare service businesses such as child care centres are not included in NSW in the Vulnerable Persons Food Safety Scheme. See instead food service in children's services

Licensing, registration

Facilities in this sector need to:

  1. apply for a Food Authority licence online or download an application form (PDF, 411.67 KB), print and post it (for assistance see the licence application guide)
  2. meet food standards
  3. prepare for regular audits.

For more see applying for a food licence.

Skills & knowledge

There are no formal food safety qualifications required for food handlers in vulnerable persons facilities, however each food handler and person in control of a food business is required to have food safety skills and knowledge appropriate to their food handling activities.

For a guide see FSANZ Safe Food Australia 3rd Edition.

Requirements are set out in the Food Standards Code, Standard 3.2.2 - Food Safety Practices and General Requirements, clause 3.

Construction & facilities

Food services to vulnerable persons facilities need to:

  • be designed and constructed to protect food from contamination
  • be effectively cleaned and sanitised (where necessary) to protect food from contamination
  • segregate raw (for example, cut salad ingredients) from processed food, and protect food from contamination by covering or sealing appropriately.

For a guide, see Standard 3.2.3 in FSANZ Safe Food Australia.

Requirements are set out in Food Standards Code, Standard 3.2.3 – Food Premises and Equipment.

Hygiene & handling

Equipment and utensils should be cleaned in locations specifically for that purpose.

Separate utensils should be used for raw and ready-to-eat products, otherwise all equipment used for raw foods should be cleaned and sanitised before they are used for ready-to-eat and pre-cooked prepared foods.

Staff must practice good personal hygiene and there should be a procedure for food handlers suffering from a foodborne illness.

For more see our factsheets:

See also FSANZ guide Safe Food Australia.

Requirements are set out in Food Standards Code, Chapter 3, Standard 3.2.2, Division 4 - Health and Hygiene.

Food safety Controls

Food Safety Program

Facilities in the vulnerable persons sector need to have a written food safety management program that effectively controls the hazards of serving food to vulnerable persons.

The Guidelines for food service to Vulnerable Persons have been developed to assist.

See also FSANZ guide to Standard 3.2.1

The requirements are set out in Food Standards Code Standard 3.2.1 Food Safety Programs.

Receiving food

Businesses should have an approved supplier program, with a list of approved suppliers kept by the business for audit.

Potentially hazardous foods need to be:

  • received at the correct temperature and monitored and recorded (see below)
  • have all packaging intact
  • remain within the ‘use by date’
  • be placed in an appropriate storage area as soon as possible after being delivered. 


Potentially hazardous foods must be stored in fridges, freezers or hot boxes capable of maintaining the temperature as follows:

  • cold food: 5°C or lower
  • hot food: 60°C or hotter
  • frozen food: kept hard frozen
  • at a time and temperature that will not affect the safety and suitability of the food: eg. 2-hour/4-hour storage rule. Any alternative method of compliance must be documented and will be assessed during audit.

Only packaging that is suitable for contact with food and able to be effectively cleaned should be used to store food.

All stock should be rotated to ensure the oldest stock is used first.

Prior to using any food or ingredients, any ‘use-by’ dates must be checked. The product must be discarded if it has exceeded the stated date.


When transporting food from one facility to another, or to a resident or patient using a vehicle/trolley/insulated container:

  • potentially hazardous foods must be kept under temperature control
  • food transport vehicles must be maintained in a clean and sound condition so that food does not become contaminated
  • food transport units should be regularly serviced, and records of maintenance activities should be kept. 

Thawing food

Food should be thawed safely:

  • in a refrigerator maintained at a maximum of 5°C, or
  • in a microwave, and
  • not at room temperature for longer than necessary.

For safety you should ensure:

  • thawing food does not contaminate ready-to-eat foods, eg thaw food in a dedicated refrigerator or on a bottom shelf of the refrigerator or coolroom to make sure it does not contaminate ready-to-eat food
  • thawed food is used immediately, or stored in the coolroom (for potentially hazardous foods) for no longer than 48 hours
  • that food products are entirely thawed before they are cooked unless they can be cooked without thawing according to manufacturer’s instructions. Do not re-freeze thawed food unless it is safe to do so (thawed food has a limited shelf life because excessive moisture on the surface will allow more rapid microbial growth). 

Food disposal

The disposal of any food due to a product recall, being past the ‘use by’ date or not complying with a food safety program should occur in a manner that it cannot be consumed after disposal.

Support programs

Businesses should document the following programs:

  • calibration
  • cleaning and sanitising
  • internal audit
  • food recall procedure
  • maintenance
  • pest control
  • product identification/labelling
  • staff training. 

Menu design

Certain foods present a higher risk to vulnerable people due to increased potential for these foods to cause food poisoning.

Foods which need specific control measures to minimise potential risks include:

  • dairy
  • fruits, vegetables and salads
  • juices
  • meat and poultry
  • paté and dips
  • seafood.

Control measures are listed in the Guidelines for food service to Vulnerable Persons.

Ready-to-eat foods that are not cooked

These foods are usually prepared with the intention of immediate service or service within 48 hours.

Good hygiene practice is required during preparation of ready-to-eat foods such as sandwiches and salads.

Cook-serve foods

Cook-serve foods are cooked with the intention of immediate service or service within 48 hours.

Cooking temperatures are not as strict as for cook-chill, as there is less time between cooking and serving for pathogenic bacteria to grow.

Cook-chill foods

Cook-chill foods require special processing to ensure they are safe from pathogenic bacteria such as Listeria monocytogenes and Clostridium botulinum.

Time and temperature control during cooling, storage and handling are critical to the cook chill system because bacteria can grow in the extended time between food production and consumption.

It is strongly recommended that you seek expert advice to determine cooking process, storage temperatures and shelf life, especially if you are making cook chill-food with extended life.

Many factors will influence the safety of cook-chill products such as cooking times and temperatures, size or amount of food you are heating, storage temperature, aseptic packaging, acidity, composition, consistency, moisture content and chilling process.

Preparation of texture modified and puréed food

Texture modified meals are provided for residents or patients that have difficulty swallowing/chewing and may be thickened, minced or puréed.

Good hygienic practice is required during the preparation of texture modified and puréed foods because the extra handling increases the potential for cross contamination.

Contamination of blenders and mixers has been identified during audits as a potential problem area because they are difficult to clean.

Poor cleaning and sanitation of this equipment has led to outbreaks of foodborne illness in the past and close attention needs to be paid to this area.

Nutritional supplements and milkshakes

The preparation of nutritional supplements and milkshakes requires special attention. These items are able to support the rapid growth of pathogenic bacteria.

Specific steps need to be taken to make sure you reconstitute, prepare and handle these items safely.

Staff hygiene, in particular hand washing, is extremely important in ensuring the safety of in-house prepared nutritional supplements and milkshakes.

The Food safety program guidelines also apply to commercial shelf-stable reconstituted products once they have been opened.

Infant formula

Staff hygiene and storage temperature of prepared formula are the two main elements to ensure the safety of infant formula from pathogenic bacteria such as Salmonella and Cronobacter sakazakii.

Allergen control

Foods such as peanuts, tree nuts (eg cashews, almonds, walnuts), shellfish, finned fish, milk, eggs, sesame and soybeans can cause severe allergic reactions and must be declared on a food label.

Gluten is also included in the list for those with Coeliac disease.

Cross contact occurs when an allergen is transferred from a food containing an allergen to a food that does not contain the allergen. Control measures to control allergens are outlined in the Food safety program guidelines.

Inspections & audits

Vulnerable persons facilities will be routinely audited by the Food Authority for compliance with requirements.

Compliance or regulatory action will be taken if required.

There are fees for audits and inspections, payable by the licence holder.

For more see audits of licensed businesses.

Legislation & standards

As an operator in the vulnerable persons sector industry you need to meet the relevant requirements of the:

  1. Food Act 2003 (NSW)
  2. Food Regulation 2015, including the Vulnerable Persons Food Safety Scheme
  3. Food Standards Code, including -
    • Standard 3.2.1 - Food Safety Programs
    • Standard 3.2.2 - Food Safety Practices and General Requirements
    • Standard 3.2.3 - Food Premises and Equipment
    • Standard 3.3.1 - Food safety programs for food service to vulnerable persons


The NSW Food Authority, NSW Department of Primary Industries and Regional Development and NSW Ministry of Health consults with the industry over food safety regulation via the Vulnerable Persons Food Safety Scheme Consultative Committee.

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