Food safety auditor requirements
The Department of Health and Human Services (the department) has developed processes to assess, approve and monitor the competencies of auditors.
In Victoria, only auditors approved by the department’s Secretary (or delegate) under s. 19P of the Act are allowed to audit food premises.
Educational requirements:
Approval of a person under the Act is required because:
- the auditor must be competent to perform this type of audit
- legal consequences flow from these audits for businesses
- councils who register audited businesses must be able to rely on the audits
- these audits must be carried out in ways set out in the Act
- the outcomes must be reported to councils and the department in ways prescribed in the Act.
The Food Regulation Standing Committee approved the National Regulatory Food Safety Auditor Framework in 2009. This framework, which has been adapted for the Victorian context, details the required qualifications, skills, abilities and assessments required to gain approval.
All food safety auditors applying for approval must be able to show they have been trained and assessed as competent against the national units of competency. There are additional specialised competencies required for other high risk areas, for example the cook chill process, which the auditor must also complete if they want to audit premises engaging in these high risk processes.
Courses and certification are offered through training bodies that are formally registered to do so. They may be personnel certification bodies (for example, RABQSA International-now known as Exemplar Global) or tertiary education bodies.
Practical auditing ability must be assessed by a qualified skills examiner. The requirement is for one supervised audit following completion of the national units. It is the auditor’s responsibility to organise this and provide proof of the assessment to the department.
The Secretary certifies auditors subject to conditions that they must adhere to.
Code of conduct:
It is a recommendation of the National Regulatory Food Safety Auditor Framework that food regulators require auditors to re-certify against a regulator’s code of conduct each time their approval is renewed. In Victoria the expectation has been that the auditor will act in a professional manner but there has not been a formalised code of conduct which details what this would entail.
The department is finalising an auditor’s code of conduct. Once finalised, this will need to be read, understood and agreed to as a condition of approval. Further, on-going compliance with the department’s code of conduct will be a condition of any approval agreement. The formalisation of the code of conduct provides the opportunity to inform auditors of departmental expectations and will also be used as a reference for performance management if required.
Auditors may find the requirement to adhere to the departmental code of conduct is in addition to the auditor’s requirement to sign an employer’s or personnel certification body’s code of conduct.
Conflict of interest:
Included in the code of conduct is a section on conflict of interest. Section 19S of the Act specifically addresses conflict of interest for an auditor. Auditors should be familiar with this section as well as the detailed explanation of conflict of interest in the National Regulatory Food Safety Auditor Guideline.
Specifically, auditors should not be auditing a food premises if they have written or assisted in the preparation of the FSP for that premises or if the auditor is the proprietor or an employee or officer of the proprietor of the premises being audited.
Auditors who are unsure of whether a situation constitutes a conflict of interest should check with the department for clarification after reviewing this section in the code of conduct in the National Regulatory Food Safety Auditor Guideline.
Approval process:
A person seeking to be an approved auditor must apply to the department.
The Act provides a mechanism for certifying the competency of auditors who are then ‘approved auditors’ for the purposes of the Act.
Section 19P of the Act empowers the department Secretary (or delegate) to certify in writing that a natural person (individual) is competent to conduct a food safety audit for the purposes of the Act. A person’s approval may:
- apply to all or only to specified classes or categories of food premises, and
- be subject to conditions set out in the certificate, and
- be for a specified period of time.
Auditor conditions of approval:
Conditions of approval have, in the past, been set out in the Auditors Arrangements with some of the conditions being a minimum attendance at one departmental forum per year and demonstrated knowledge of the Act, the auditor’s handbook and the food safety standards of the Code.
The department has revised the auditor arrangement format. The new format is a list of conditions that are imposed upon any approval granted by the Secretary or delegate.
An on-line assessment of auditor knowledge is being developed and there will be an expectation that when it is finalised, satisfactory completion of this assessment will be required for on-going auditor approval.
Auditors will be kept up to date with versions of the application form and the list of standard conditions that will be imposed by the Secretary or delegate. Additionally, the Secretary or delegate may impose additional, non-standard conditions on any approval granted.
Term of an auditor’s approval:
If an approval is granted, it will generally be for a period for two years. Renewal is the auditor’s responsibility following receipt of a reminder notice from the department. Documentation previously supplied does not need to be re-sent.
Auditor register:
in line with other food regulators in Australia, the department lists the details of all approved auditors on a publicly available register on the department’s food safety website.
The register provides industry with a ready reference to identify and locate auditors who can conduct audits and also to verify whether persons claiming to be approved auditors are approved to do so.
The register contains the auditor’s name, contact details, company name, attainment of high-risk competencies, and expiry date of the auditor approval granted under the Act.
Auditor performance management:
The primary focus of performance management is to ensure high standards to protect public health.
As per the Act, the Secretary or delegate may, after giving the person a chance to be heard, revoke the person’s approval if satisfied that the person:
- has failed to comply with any requirement imposed by the Act on approved auditors
- is not sufficiently competent to conduct food safety audits
- has been found guilty of fraudulent conduct in conducting an audit
- has not satisfactorily carried out two or more food safety audits
- obtained approval under the Act to conduct food safety audits on the basis of fraud, misrepresentation, or concealment of facts.
The Act is clear about auditor obligations, competency and conduct. It is the auditor’s responsibility to ensure they are working within the Act.
When the department receives a complaint or establishes the performance of an auditor is unsatisfactory, an assessment, investigation and possible disciplinary action may occur.
A policy for performance management has been developed by the department with consideration for obtaining correct, verifiable information while dealing with the matter in an impartial manner. It allows for the auditor to be fully informed and to have the opportunity to provide verbal and written information. A support person can attend interviews at the auditor’s request.
If disciplinary action is taken, the opportunity exists for a review of the decision and finally to have the matter referred to Magistrate’s Court if the auditor does not accept the Secretary’s decision.
The department is currently establishing an ‘Audit-the-Auditor’ program.
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