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Copyright © Freshcare Ltd 2019

www.freshcare.com.au

Food Safety & Quality

Edition 4.1

Resources

Copyright © Freshcare Ltd 2019

www.freshcare.com.au

Freshcare resources index

FRESHCARE FOOD SAFETY & QUALITY EDITION 4.1 – RESOURCES REF1906 FRESHCARE RESOURCES INDEX

Below is a list of resources to assist the implementation of the Freshcare Food Safety & Quality Standard.

Freshcare Factsheets

Freshcare Factsheets are an interpretive guide to the Freshcare Food Safety & Quality Standard Edition 4.1 (FSQ4.1).

Freshcare Factsheets are available for download on FreshcareOnline for Growers via www.freshcare.com.au. To have your business logon reissued, please email [email protected] or contact the Freshcare Office on 1300 853 508.

M1 Scope and commitment

M2 Documentation

M3 Training

M4 Internal audit and corrective action

M5 Customer requirements

F1 Hazard analysis

F2 Growing site

F3 Planting materials

F4 Chemicals

F5 Fertilisers and soil additives

F6 Water

F7 Allergens

F8 Premises, facilities, equipment, tools, packaging and vehicles

F9 Animals and pests

F10 People

F11 Suppliers

F12 Food defence and food fraud

F13 Product identification and traceability

F14 Incident Management, Recall and Withdrawal

Guidelines for Fresh Produce Food Safety

The Guidelines for Fresh Produce Food Safety (2019) have been used to provide guidance and reference for specified limits within the Freshcare FSQ4.1 Standard. In some areas, the FSQ4.1 Standard requirements exceed those outlined in the Guidelines. The Guidelines for Fresh Produce Food Safety (2019) are available for download on the Fresh Produce Safety Centre Australia and New Zealand website: https://fpsc-anz.com/food-safety-guidelines-2019/

http://www.freshcare.com.au/

mailto:[email protected]

https://fpsc-anz.com/food-safety-guidelines-2019/

Factsheet – M1 Scope and commitment

FRESHCARE FOOD SAFETY & QUALITY EDITION 4.1 – FACTSHEET REF1906 M1 SCOPE AND COMMITMENT – PAGE 1 OF 3

This factsheet covers:

• Scope

• Flowchart

• Property map

• Organisational chart and Position descriptions

• Food Safety and Quality Policy

Scope

To ensure activities from all business enterprises undertaken on the property are

considered in relation to the Freshcare Food Safety & Quality Program, it is

important that the owner or appropriate senior manager defines the scope of the

business/operation.

The scope clearly identifies the activities conducted by the business for which

Freshcare certification is required (scope category, site address(es), crops

grown/packed, destination), and any other business enterprises or activities that

are undertaken on the property that need to be considered as part of the

Freshcare Food Safety & Quality Program, such as intensive livestock or dairy

operations.

The scope must be reviewed if different types of enterprises are introduced or if

activities or practices change, to ensure all food safety and quality issues are

addressed.

The Freshcare Crop List is a master list of crops that can be specified on Freshcare

Certificates. The Crop List may be used as a reference when identifying the crops

grown for which Freshcare certification is required.

The Freshcare Crop List is available for download via Freshcare website:

www.freshcare.com.au/resources/freshcare-crop-list

Flowchart

All property activities undertaken by a business should be identified in a

flowchart. A flowchart template is provided with Freshcare Forms (refer to Form –

M1 Flowchart), which outlines generic practices undertaken in horticultural

production.

Flowcharts will be completed differently by each business, depending on the

business enterprises undertaken on the property.

Update the flowchart (or develop your own) to ensure all production and post-

production practices undertaken by your business are identified and selected.

Property map

A property map is required to identify property areas, infrastructure and

surrounding areas.

A property map can be aerial photographs, topographical maps, cadastral maps,

self-drawn maps or overlays that document and define the required features and

infrastructure on or adjacent to the property.

FSQ4.1 Standard M1.2.1 specifies what must be identified on the property map.

The property map must be maintained and updated as required.

Organisational chart and Position descriptions

An organisational chart should be documented to demonstrate the workers

responsible for the management of compliance to the Freshcare Food Safety &

Quality Program, and to identify the reporting relationships (flow of information)

of all workers whose roles may affect food safety and quality compliance.

The organisational chart should identify who is responsible for the management

of food safety and quality i.e. owner, site manager or QA manager, and how other

workers report to this manager.



Example organisational charts including an indication of reporting relationships

are provided:

Example Organisational chart – simplified business structure

Example Organisational chart – more complex business structure

Food Safety and Quality Policy

The Food Safety and Quality Policy will incorporate the business’ existing

commitment statement and extend to establishing measurable objectives

associated with the businesses commitment to food safety and quality, including

the businesses commitment to meeting the requirements of the Freshcare Food

Safety & Quality Standard, the Freshcare Rules and all legislative requirements.

Whenever you write the food safety objectives for your food business always

check that they cover these five aspects:

“SMART”

Specific to your business

Measurable (via monitoring and use of data)

Achievable,

Realistic and have a

Timeframe for completion.

Examples of measurable objectives could include

• reduction in complaints by x% each 6 months

• reduction in rejections of product from customers by x% each year

• to complete food safety induction training for new employees before

job commencement

• to ensure 100% of product labelled correct first time

• to increase the pick rate by x%.

The Food Safety and Quality Policy must be reviewed at least annually, and when

changes occur that may impact food safety or quality. This review shall be

recorded, regardless of whether there are any changes to the Food Safety and

Quality Policy.

Owner/Manager Food Safety and Quality

Seasonal labour Spray contractor

Pickers

Packers

Owner

Farm manager Field manager Packhouse manager

Food Safety and Quality

QA manager Food Safety and Quality

Spray contractor Pickers Packers



The Food Safety and Quality Policy must be communicated to all workers, to

ensure an awareness throughout the business of the importance of maintaining

food safety and quality practices. All workers have a responsibility to the

management of food safety and quality on-farm and should be encouraged to

monitor and report on activities associated with the Freshcare Food Safety &

Quality Program.

Prominently displaying the Food Safety & Quality Policy will remind visitors,

contractors and workers of the importance the business places on the Freshcare

Food Safety & Quality Program.

Factsheet – M2 Documentation

FRESHCARE FOOD SAFETY & QUALITY EDITION 4.1 – FACTSHEET REF1906 M2 DOCUMENTATION – PAGE 1 OF 2


• Procedures and Work Instructions

• Freshcare documents required to be kept

• Record keeping to verify compliance

• Developing effective records

• Document control

• Storing records

Freshcare documents required to be kept It is a requirement that Freshcare participating businesses have a current edition

of the Freshcare Food Safety & Quality Standard, and Freshcare Rules.

These documents along with record keeping forms, example templates,

factsheets and updates are available via Freshcare Online for Growers, accessed

via the Freshcare website: www.freshcare.com.au.

Procedures and Work Instructions

The Freshcare Standard requires that businesses document their processes for

activities that impact food safety via procedures and work instructions.

Procedures and work instructions are required to be reviewed at least annually or

when changes to processes occur.

Examples of procedures and work instructions that may need to be documented

for a business could include:

• handwashing and hygiene requirements

• use of Protective clothing

• inspection of growing sites prior to harvest

• incoming Inspection

• control of tools and knives

• operation of wash baths, flumes and treatment tanks

• product and label changeover

• product sampling and testing.

Remember, once documented, the procedures and work instructions must be

implemented and kept up to date. The M3 Factsheet – Training gives the guide on

training workers in these procedures and work instructions and what records to

keep.

Record keeping to verify compliance It is important to maintain all records as outlined in the requirements of the

Freshcare Food Safety & Quality Standard. Records are used to verify your

compliance to the Standard at audit, and to demonstrate ongoing management

on-farm. All records kept are required to include the following (as a minimum):

• title

• date of issue or version number

• your business name

• the name of person completing the record

• the date record was completed.

Other specific record requirements are outlined in individual elements of the FSQ4.1 Standard, guidance on records required is also outlined in the related factsheets.

Freshcare have developed form templates which reflect the record keeping

requirements of the Standard. These are provided in word format and may be

used as is or modified to suit your business. It is not mandatory to use the

Freshcare form templates, however the required information as specified in the

Standard must be captured.


FRESHCARE FOOD SAFETY & QUALITY EDITION 4.1 – FACTSHEET REF1906 M2 DOCUMENTATION – PAGE 2 OF 2

Factsheet – M2 Documentation

Developing effective records

To be effective, records should be:

• legible

• user friendly

• clearly understood

• relevant to the situation

• consistent in format

• identified with a version number or date of issue

• maintained and kept up to date, with out of date versions replaced

• signed and dated by the person completing the record

• easily accessible, located where needed.

Document control

Someone in the business needs to take responsibility for managing documents

and records to ensure that only the latest version is used and are available where

needed. This applies to business documents and records, and to external

documents such as off-label permits and quarantine regulations.

Storing records

Records may be kept in hard copy, soft copy, electronic or digital format.

Whichever format your business chooses to capture the required information, it

needs to be maintained and secure. Completed records need to be stored in a

safe and secure location for possible reference at a later time or during your

audit. IT systems should have backup processes in place, and the backups be

held secure.

The default retention period for records required by the Freshcare Standard is 2

years, although state-based legislation or your customers may require longer

retention periods for some records. For example, some States and Territories

require chemical application records be kept for at least 3 years.

Factsheet – M3 Training

FRESHCARE FOOD SAFETY & QUALITY EDITION 4.1 – FACTSHEET REF1906 M3 TRAINING – PAGE 1 OF 1


• Freshcare training

• Other training requirements

• Review of training needs

For more information refer to the Guidelines for Fresh Produce Food Safety (2019) Chapter 14 Managing people, page 72.

Freshcare training

It is a requirement that a management representative from each participating

business completes approved Freshcare Food Safety & Quality training. Approved

Freshcare training includes:

• Freshcare Food Safety & Quality Edition 4 training (including 4.1

amendments)

• Freshcare Food Safety & Quality 3rd Edition training.

Approved Freshcare training is provided by Freshcare trainers or via Freshcare

eLearning. Details of training courses are available from the Freshcare website:

www.freshcare.com.au.

A certificate of the training (detailing the trainee name, trainer and date of

training), should be kept as evidence that approved Freshcare training has been

undertaken by a management representative.

Other training requirements

Workers whose roles could have an impact on the food safety and quality

management of the business should have adequate knowledge and skills to

perform the duties required of them. Their training needs relevant to Freshcare

FSQ4.1 also need to be considered, with appropriate training planned and carried

out.

Within the business, the most appropriate person must conduct internal training.

For example, the person on farm that has completed recognised farm chemical

user training would be responsible for training other workers in chemical handling

and application.

All workers (and contractors) must receive basic food safety training before

starting work, and as a minimum, food safety instructions must be provided (refer

to Form – F10 Food safety instructions) including requirements for health status,

personal hygiene, protective clothing (where applicable), management of clothing

and personal items and general behaviour.

Training needs to be provided in the relevant language for workers and/or

pictorially.

Records of internal and external training must be kept, and include:

• name and signature of trainee

• name of trainer/training provider

• title or topic of training

• date of training and expiry date (when applicable).

Review of training needs

A review of all training by the owner or appropriate senior manager is to be

conducted at least annually; or when processes change or a worker’s tasks

change; or a new worker is appointed.

The training review will help identify any new training needs of workers, or

refresher training that may be required to ensure adequate knowledge is present

for all tasks undertaken.

It is a good management practice to advise workers that it is also their

responsibility to identify training needs within a business. Workers should be

encouraged to notify the owner or senior manager if they identify a process, task

or area where further workplace training or external training may be required.

Further training or refresher training to Freshcare FSQ could be recommended by

the auditor conducting your external FSQ audit. This would only occur if

inadequate understanding, implementation or management of the Freshcare FSQ

Standard was evident during the external audit.


Factsheet – M4 Internal audit and corrective action

FRESHCARE FOOD SAFETY & QUALITY EDITION 4.1 – FACTSHEET REF1906 M4 INTERNAL AUDIT AND CORRECTIVE ACTION – PAGE 1 OF 4


• Defining audits

• Internal auditing

• External auditing

• Corrective action

• Management Review

Defining audits

An audit is a formal review of practices.

An internal audit is when a worker representing the business, reviews on-farm

practices.

An external audit is when a customer or an independent organisation (auditor

from one of the nominated Freshcare Certification Bodies) reviews the business

practices.

Internal auditing

The purpose of internal auditing is to:

• confirm that practices are being carried out as required by the Freshcare

Standard(s)

• ensure records are up-to-date, accurate and contain all the required

information

• identify inefficiencies and problems and correct them.

Who should conduct the internal audit?

Any person representing the business can conduct the internal audit. This may be

an owner, worker or external consultant. If it is an external consultant, it is

important that the owner or senior manager is made aware of the results of the

internal audit.

Ideally, the person conducting the internal audit should be independent of the

practices being carried out, however Freshcare recognises that this may not be

achievable by some businesses.

How often should internal audits be done?

It is always best to do an internal audit before any external audits from customers

or other independent organisations are undertaken, as it is better for you to

detect problems and correct them before the external auditor does. A good

practice is to break the internal audit into the sections of the Standard and

complete as several smaller activities and spread across the year. The Internal

audit form is designed to enable this to be done.

Freshcare requires businesses to conduct a minimum of one internal audit each

year, covering all elements of the Freshcare FSQ Standard. A record of internal

audits must be kept.

Internal audit report

FSQ4.1 Form – M4 Internal audit report, provides a useful tool to assist you in

conducting your internal audit. It provides a simple, systematic outline of FSQ4.1

Standard elements to assist you in reviewing practices.

Sections of the internal audit report should be signed and dated by the person

completing that section. Once completed the internal audit report provides a

record of the internal audit conducted and any areas that need to be addressed

or actioned as a corrective action.

Conducting an internal audit

Conducting an internal audit involves:

• talking to workers

• observing operations

• checking records for accuracy and completeness.

• recording the detail of what you find – both positive thing as well as any areas

to be addressed.



External auditing

An external audit is a review of your practices and documentation by someone

external to your business, such as a customer or an independent auditing

organisation – a Certification Body.

Customer audits (2nd party)

Wholesalers, packers and processors who have implemented a quality

management standard or code of practice may be required to carry out an audit

of their suppliers. They may carry out the audit themselves or contract an

external auditor.

Their audit activities may include:

• checking your records

• reviewing your internal audit report

• requesting a copy of your Freshcare certificate

• carrying out on-site audits of operations on your farm.

Independent or external audits (3rd party)

An independent or external (3rd party) audit will provide objective evidence of

compliance against a nominated code or standard. It is carried out by a

certification body independent of your business and of your customers. A

Freshcare audit is a 3rd party audit and will provide objective evidence to your

customers that you have met the requirements of Freshcare Food Safety &

Quality Standard Edition 4.1

The independent or external audit provides customers with the option of using 3rd

party auditors rather than doing the auditing themselves. It also means one audit

may satisfy all your customers, rather than having many customers auditing your

business. Auditing of the Freshcare Standard is managed by Freshcare Ltd and its

approved Certification Bodies.

Preparing for an external audit

The idea of an audit is not to ‘pass’ or ‘fail’. The audit should be an opportunity to

identify areas in your business where procedures and practices can be improved.

Part of the auditor’s role is to be helpful and understanding of your needs.

The most important thing to do is review your practices and documentation to

ensure that everything has been identified and applied as required by the

Standard. Use your internal audit checklist to complete this process.

Make sure records are up-to-date and available (or easily retrievable) for the

auditor to review.

What will happen on the day of the external audit?

Your audit will consist of three stages: the entry meeting, the audit, and the exit

meeting.

At the entry meeting, the auditor will discuss your business, your expectations,

describe what will happen during the audit and set a timeframe for the audit.

During the audit itself, the auditor will be looking for objective evidence that

requirements of the Freshcare Standard are being met. The auditor does this by

asking you questions, talking with your workers (and observing practices) in the

work environment and reviewing your documents. The auditor will be working

through a checklist similar to your internal audit checklist.

At the exit meeting the auditor will discuss their audit findings and provide you

with a summary of their findings. They will identify the strong points of your

system and any areas that you may need to improve. You will be invited to

respond and comment about the audit or audit process. If there are things that

need to be rectified (corrective actions) before certification is recommended,

they will be discussed at this point. Agreement is reached about what needs to be

done and when it will be done. A copy of the corrective action will be left with

you at the end of the audit.



Corrective action

Despite best intentions, you can still encounter problems from time to time.

Whenever a problem arises, you must take action to ensure that the problem has

been brought under control. Further actions may be required to prevent the

problem happening again, thereby improving the system.

Keeping a record of corrective actions helps you to look back at problems that

have occurred in the past and show customers and other external bodies that you

have a system in place to fix such problems.

A Corrective Action Record (CAR) is completed when requirements of the

Standard are not being met, problems have caused or have the potential to have

significant food safety or quality implications.

An important aspect of corrective action is checking that the steps taken have

been effective in eliminating or controlling the problem. Once the actions are

completed, a review must be conducted to ensure actions taken have been

effective.

If the problem has not been fixed, or the same problem reoccurs, then the action

has not been effective and another CAR must be completed, including alternative

actions.

Reoccurrences of non-compliance must be reviewed by the owner or appropriate

senior manager, to ensure adequate measures are taken to effectively address

the problem and prevent the non-compliance from occurring again. This can be

included as part of the management review.

Documenting corrective actions

A CAR should be completed when the requirements of the Freshcare Food Safety

& Quality Standard, Freshcare Rules or legislation are not being met.

Issues may be identified during routine activities, internal audits, external audits,

receival of a compliant, produce identified as being contaminated, or potentially

contaminated. Non-conforming product is identified during monitoring, or

incidents.

FSQ4.1 Form – M4 Corrective action record (CAR) can be used when an issue is

identified.

CARs should be interpreted as a tool for documenting and demonstrating

continuous improvement, as they provide the mechanism for identifying a

problem, whether it has occurred before, how the problem is being managed and

what resolve has been established to prevent the problem from occurring again.

Management Review

The objective of the management review is to ensure the Food safety and quality

system implemented remains suitable, adequate and effective.

A Management Review is a formal, structured meeting which involves owners

and/or senior managers of the business and takes place at regular intervals

throughout the year but must occur at least annually.

The Management Review encourages management to consider the degree by

which the Freshcare System:

• continues to meet the businesses requirements and achieve the expected

results

• identifies any additional risks or practices to be considered

• functions in accordance with the established operating procedures and

processes

• can identify non-conformities and monitoring of effectiveness of

subsequent corrective and preventive actions.

A Management Review also ensures that all levels of management are made

aware of any changes, updates, revisions, etc. to the day-to-day workings of the

Management System itself, including policies and procedures.

An important part of your planning should be to produce an agenda for your

meeting that can then form the basis is the records you are required to keep. A

detailed and agreed agenda will help you to ensure all topics required by the



Freshcare Standard are covered, especially if you decide to hold multiple reviews

throughout the year focused on different topics.

A Management Review should cover the following topics:

• Discussion on the status of any issues from the previous meeting

• internal and external audits

• corrective actions

• customer feedback

• complaints

• training

• the food safety and quality policy and measurable objectives

• identification of further opportunities for improvement.

Factsheet – M5 Customer requirements

FRESHCARE FOOD SAFETY & QUALITY EDITION 4.1 – FACTSHEET REF1906 M5 CUSTOMER REQUIREMENTS – PAGE 1 OF 2


• Customers

• Product specifications

• Customer requirements

• Checking final product

Customers

A customer is the business to whom you supply produce. This may be a

commercial packer, marketing group, wholesaler, processor, retailer, export or

domestic market buyer.

Meeting customer expectations is an important part of any business. To be able

to meet these expectations, a clear understanding of what the customer requires

is essential.

Customers will often set specific specifications and requirements for suppliers to

comply with. These may be issued as part of your contract, written agreement or

provided in writing.

Product specifications

A product specification is a clear description of the features of the produce for

sale and any special handling requirements. The specifications can be provided by

your customer or developed by you in consultation with your customer.

Growers who supply produce to commercial packers or processors will require a

specification for harvested produce, while growers who pack their own produce

for commercial packers will require a specification for packed produce.

Contact your customer to see if they have a product and handling specification. If

not, check to see if there is an industry standard you should be following,

consider developing one with your customer.

Customer product specifications most commonly relate to:

• Product quality

o variety, size, maturity, colour

o defect allowances/tolerances.

• Handling requirements

o temperature management

o handling instructions

o packaging

o transport.

• Food safety requirements

o contaminants

o compliance with a nominated standard such as Freshcare Food Safety &

Quality.

Examples of product specifications can be found online via the FreshSpecs

website: www.freshmarkets.com.au/fresh-specs.

Customer requirements

Customer requirements are other specific requirements set or agreed with your

customer.

For example, Freshcare have established acceptable microbiological limits for

produce, water and fertilisers containing manures and therefore does not require

microbial testing on the final product. Your customer may require you to verify

that your produce complies with microbial limits by final product testing (for one

product, or all product lines). This is above what is specified as a requirement by

the Freshcare Code.

http://www.freshmarkets.com.au/fresh-specs

Factsheet – M5 Customer requirements

FRESHCARE FOOD SAFETY & QUALITY EDITION 4.1 – FACTSHEET REF1906 M5 CUSTOMER REQUIREMENTS – PAGE 2 OF 2

Checking final product

Why check product

Where a customer has provided a written specification, harvested and packed

produce should be checked to confirm that the product and handling

specifications have been achieved. If produce does not meet the written

specification, the customer (packer, processor, wholesaler or retailer) should be

informed before dispatch.

If testing is required as a customer requirement, sufficient produce should be

sampled to ensure that the assessment result is representative of the whole

batch. Some customers may specify the sample size in their written specification

or their approved supplier program.

Notifying the customer of variations

The customer should be notified if product does not meet their specification.

Keeping a record of your notification and the customer’s advice will help if any

complaints or disputes arise. This can be as simple as comments in a farm diary

or on a harvest and packing record, or communication from your customer.

Factsheet – F1 Hazard analysis

FRESHCARE FOOD SAFETY & QUALITY EDITION 4.1 – FACTSHEET REF1906 F1 HAZARD ANALYSIS – PAGE 1 OF 3


• HACCP

• Hazard analysis

• Freshcare risk assessments

• Risk assessments for other practices (additional hazards, Code Criteria not implemented)

• Review

For more information refer to the Guidelines for Fresh Produce Food Safety (2019), Chapter 3 Fresh produce food safety hazards, page 5

HACCP

Hazard Analysis and Critical Control Point (HACCP – pronounced ‘hassip’) is an

internationally recognised method of food safety risk management used in the

food industry.

When correctly implemented, HACCP will prevent hazards from occurring, and

therefore reduce the need for finished product testing.

The United Nation’s Codex Alimentarius Commission defines HACCP as ‘a system

which identifies, evaluates and controls hazards which are significant for food

safety’.

Put simply, the HACCP process involves:

• Identifying the biological, chemical and physical hazards that may occur at

each step of the growing and/or packing process.

• Evaluating the hazard (i.e. what is the likelihood of the hazard occurring, and

what will the consequences be if it does occur).

• Determining what are the Critical Control Points in the process (i.e. the things

that you must get right in order to ensure food safety).

• Monitoring Critical Control Points (e.g. product temperature) to ensure that

control is being maintained.

HACCP requires a number of underpinning or support programs to be in place.

These programs address issues fundamental to food safety but not directly

related to the production of food, such as cleaning, worker training and pest

control.

The Freshcare Code of Practice Food Safety & Quality has always been based on

HACCP principles. Elements of the FSQ Code were derived from an analysis of

food safety hazards relevant to horticulture production and packing.

Freshcare Code of Practice Food Safety & Quality requires businesses to complete

a more formal HACCP process and identify risks and control measures specific to

their business.

Hazard analysis

In developing a food safety system, it is important to identify and evaluate

physical, chemical and microbial hazards. The process of doing this is called

hazard analysis. There is much commonality in the types of food safety hazards

that exist in horticultural businesses and therefore an individual hazard analysis of

every hazard is not necessary. Food safety risks can be effectively controlled by

implementing good agricultural practices.

There are a number of food safety hazards that may require additional control

measures, dependent on the significance the hazard has for the particular

business. In these instances, each business is required to complete an analysis of

the hazard as it relates to their specific situation and to identify control measures

to minimise the risk of the hazard occurring.

The Freshcare Code of Practice Food Safety & Quality identifies the areas where a

specific hazard analysis is required. Via the completion of specified risk

assessments, you will determine the significance of the hazard, and subsequent

compliance criteria will be identified.



Freshcare risk assessments

Freshcare have four risk assessments that all participating businesses must

complete:

• Persistent chemicals

• Heavy metals

• Fertiliser and soil additives

• Preharvest water

Each risk assessment must be conducted for the scope of the business i.e. each

growing site/water use and crop type combination.

Freshcare risk assessments can be found in the Code Appendix. Form templates

are also provided to aid in completing the risk assessments.

To conduct a Freshcare Risk Assessment:

Identify growing site and crop(s) and work through the risk assessment questions to identify the likelihood of the food safety hazard occurring in your business (Page 1 of Form).

Record the growing site, crop(s) and likelihood in the hazard analysis table (Page 2 of Form).

Using the Significance matrix, determine the significance of the risk with the Severity and Likelihood. The severity of the hazard has been predetermined by Freshcare.

If the significance of the hazard is high, review and implement the relevant additional actions for high significance. In this case, the hazard analysis determined the risk to be of low significance and no additional action is required.

Note: You may need to use the risk assessment a number of times for different

growing sites/crops. The F1 Risk assessment forms have been split from the risk

assessment decision tree over two pages for this purpose.

1

2

3

4

1

2 3

4



Risk assessments for other practices

Additional risk

Risk assessments may be conducted for any additional risks within the scope of

Freshcare certification.

As a prescriptive, HACCP-based standard, identified food safety risks are managed

in compliance with the Code and risk assessments. If any additional, business

specific risks are identified within the scope of the FSQ4 Code, a risk assessment

for other practices is completed (refer to Form – F1 Risk assessment – other

practices).

Examples of possible other practices might include:

• farm gate sales – contamination from dust/dirt and other issues

• sulphur dioxide contamination of grapes from grape guard pads during storage caused by poor temperature control

• homing pigeons flight path over produce or wildlife corridors through crops

• glass in paddocks adjacent to public roads.

If required, control measures, monitoring and verification activities must be

recorded and implemented using the outcomes of the risk assessment process.

Exempting from FSQ4 compliance criteria

If a business believes that an element of the Freshcare Code of Practice Food

Safety & Quality is not-applicable to the business due to specific production

methods/crops grown/other practices undertaken, a risk assessment must be

conducted and evidence provided to clearly support the reason for any exclusion

of specific Code requirements.

Documentation

The Form – F1 Risk assessment – other practices form template has been

provided to document the risk assessment and relevant control measures,

monitoring and verification activities.

Review

Risk assessments must be reviewed at least annually or when changes occur that

may affect the significance of the hazard (for example, a new crop is grown or

there is a change in farm inputs).

Factsheet – F2 Growing site

FRESHCARE FOOD SAFETY & QUALITY EDITION 4.1 – FACTSHEET REF1906 F2 GROWING SITE – PAGE 1 OF 3


• Growing site

• Chemical contamination

• Microbial contamination

• Physical contamination

For more information refer to the Guidelines for Fresh Produce Food Safety (2019) Chapter 5 Managing the growing site and planting material, page 17.

Growing site

Some growing sites may not be suitable for the production of produce. An

assessment of the suitability of the growing site should be completed prior to

planting (when possible) for annual crops (e.g. potatoes, onions, lettuce), and

once for perennial crops (e.g. tree crops, vineyards). Growing sites may include

paddocks, orchards or other growing facilities such as greenhouses and

shadehouses.

The growing site can be a source for produce contamination with chemicals,

microbes or foreign matter. The condition of sites should be suitable for the

production and preparation of safe produce. Contamination may occur due to

poor design, construction or maintenance of these structures, or the

inappropriate use of these areas.

Growing site contamination can lead to produce contamination. The risk of

contamination is often higher for crops where the harvestable part is grown in, or

in direct contact with the soil.

An assessment of the growing site will help determine its suitability. When

assessing the growing site, the main risks that may arise are:

• contamination from persistent chemicals or heavy metals remaining in the

soil from past use

• contamination from chemicals through spray drift

• microbial contamination from use of untreated fertilisers and soil additives or

flooding

• physical contamination from foreign matter such as sticks, stones, glass,

metal, ceramics, etc.

Chemical contamination

To assess the risk of persistent chemical and heavy metal contamination of

produce from the soil or growing medium to the crop, Freshcare FSQ4 have two

risk assessments that must be completed for each growing site and crop

combination. These risk assessments can be found in the Code Appendix, and

form templates to record their completion are available in Freshcare Forms.

If the hazard analysis identified the risk of persistent chemical contamination of

produce from soil/growing medium is high, additional control measures must also

be implemented.

This may involve testing the soil/growing medium and/or testing the produce for

persistent chemicals or heavy metals. The contaminated sites must be identified

on the property map and managed to ensure that product grown at that site

complies with ERLs/MRLs/MLs.

Maximum Residue Limits (MRLs)

The Maximum Residue Limit (MRL) is the maximum concentration of a residue

that is legally permitted on produce after harvest. Food Standards Australia New

Zealand (FSANZ) sets the MRLs permissible in or on a food, agricultural

commodity or animal feed. FSANZ has established MRLs for fresh produce, which

are published in the Australia New Zealand Food Standards Code, Section 1.4.2.

More information can be found at: www.foodstandards.gov.au. FSANZ may

review a chemical and change the MRL for types of produce, so it is important to

know what the current MRLs are for the produce grown.

Where produce is intended for export to another country, a check of the

importing country and/or customer MRLs should also be undertaken.



Extraneous Residue Limits (ERLs)

An Extraneous Residue Limit (ERL) is the maximum permitted level of a chemical

residue, arising from environmental sources other than the use of a chemical

directly or indirectly on the food. For example, Dieldrin has no registered use, and

an application to crops or pastures is no longer legal. Therefore any Dieldrin

residue detected on produce is assumed to arise from an environmental source.

Maximum Levels (MLs)

Limits for heavy metal contaminants in growing medium and fertilisers and soil

additives (Source: Australian Standard AS 4454-2012: Composts, soil conditioners

and mulches):

• Cadmium <1mg/kg (dry weight basis)

• Lead <150mg/kg (dry weight basis).

Exceeding the Legal Limits

Residues detected on produce exceeding the MRL are unacceptable, but do not

necessarily represent a hazard to consumers because of the high safety margins

used to set the standards. Where an MRL does not exist, no residues of that

chemical is permitted on the final produce.

If chemical residue testing for organochlorine (OC) or organophosphate (OP) on

produce detects levels above the MRL/ERL, isolate the crop and take measures to

either dispose of the crop or reduce the residue level to an acceptable level. Do

not sell produce with chemical residues of OC/OP above MRL/ERL, or feed the

crop to livestock. If the residue is present in soil or dust on the produce surface,

washing may reduce the residue to an acceptable level.

Avoid growing produce on or adjacent to sites where OC/OP chemicals have been

recently detected in the soil or in previous crops grown. Alternatively, grow a crop

where the harvestable part has no direct soil contact.

Spray drift

Spray drift is the movement of agricultural chemicals away from the target area

during or after ground or aerial spraying (in the form of droplets, particles or

vapour). Agricultural chemicals can drift long distances under certain weather

conditions.

Spray drift or overspray can be a possible source of chemical contamination on

produce.

Growing sites must be assessed for the potential for spray drift and where spray

drift is likely, plantings are planned to minimise the risk of contaminating non-

target produce.

Neighbours also need to be aware of the potential for spray drift, and the effect it

can have on adjacent properties. Talk to neighbours, discuss sensitive areas, and

determine how the risk of spray drift between the properties can be managed.

Request that neighbours avoid spraying when drift is likely.

Buffer zones

Buffer zones are a very good way to reduce the risk of spray drift. Buffer zones

can be established by planting trees and shrubs downwind of a production area.

Vegetation that is tall, rough and thin is better at catching droplets than

vegetation that is short, smooth and thick.

A droplet-catching barrier should be less than 50% porous, with a height about

1.5 times the height of spray release. Use multiple vegetation layers as a screen

rather than a single layer. Intercrop buffers such as rye corn or sweet corn can

also act as barriers.

Microbial contamination

Livestock

Microbial contamination of fresh produce can be caused by the presence of

livestock in growing sites i.e. sites which have been used for animal grazing, as a

feedlot or for poultry production. Microbes present in the gut of animals may

transfer into the manure, and then on to the fresh produce, causing a food safety

hazard to consumers.

Livestock refers to farm animals including, but not limited to, cattle, sheep, pigs,

goats and poultry.



To manage the risk of microbial contamination, exclusion periods apply and

livestock is not permitted on growing sites within:

• 90 days of intended harvest date for produce where the harvestable part is

grown in, or has direct contact with the soil, and may be eaten uncooked; or

• 45 days of intended harvest date for all other produce.

The Form – F2 Livestock movement record template, has been provided to record

movement of livestock in and out of growing sites.

Flooding

Consideration should also be given to the type of produce grown on sites that are

prone to flooding. When flooding of the growing site occurs, the potential for

microbial contamination of produce is increased by contact between floodwater

and the harvestable part of the crop.

If growing sites have been affected by a flood event, the impact this will have on

the affected crops or crops to be planted must be taken into account and planting

must be scheduled to ensure that the period between flood water subsiding and

harvest exceeds 90 days for produce where the harvest able part is grown in, or

has direct contact with the soil, and may be eaten uncooked.

Any produce that has come into contact with floodwater should not be harvested

for sale unless:

• the produce meets specified microbial limits of E.coli <10/g and Salmonella

Not Detected 25/g, or

• customer specifications (which may indicate the produce should be disposed

of).

Physical contamination

Growing sites must be assessed for the potential for physical contamination. The

location of the site, or the sites proximity, may increase the risk of physical

contamination; for example, if the growing site is adjacent to a busy road, or was

previously used for industrial purposes, landfill or dumping of waste.

Physical hazards include glass, metal, wood, plastic, roots, sticks and stones, nuts

and oil from equipment, or personal items from workers including cigarette butts,

jewellery and rubbish. Weeds with the potential to cause poisoning or

anaphylactic shock may be another potential contaminant present in growing

sites that should be considered; for example, stinging nettle or deadly nightshade.

Where physical contamination is likely, sites are inspected before ground

preparation and physical contaminants are removed, or managed to minimise the

risk of contaminating produce.

Sites which are contaminated with physical contaminants must be identified on

the property map.

Control measures to reduce the risk of physical contamination may include:

• inspecting the growing site before commencing and during land preparation

• removing or controlling weeds with the potential to cause an anaphylactic

response or poisoning e.g. stinging nettles, deadly nightshade

• training workers to identify, remove and not introduce physical hazards

• consideration given to not crop areas with high levels of physical

contaminants or close to roadways.

Factsheet – F3 Planting materials

FRESHCARE FOOD SAFETY & QUALITY EDITION 4.1 – FACTSHEET REF1906 F3 PLANTING MATERIALS – PAGE 1 OF 1


• Planting materials

• Sourcing planting materials

For more information refer to the Guidelines for Fresh Produce Food Safety (2019), Chapter 5 Managing the growing site and planting material, page 17.

Planting materials

Planting materials include seeds, seedlings, young plants, roots, corms, bulbs, bits

and suckers used for planting to establish crops.

Planting material should be assessed as a potential source of chemical

contamination, in consideration of the chemicals used to treat seeds or control

pests and diseases during the production of seedlings.

To prevent residues in the final product from exceeding the MRLs, chemical

treatments to planting materials must be applied in accordance with legislation of

the destination market; the directions on labels; or off-label permits.

The withholding period of chemicals must be checked before use as some

chemicals have long withholding periods. To verify that chemicals have been used

correctly, records of chemical treatments during production of planting material

must be kept.

If planting materials are produced within the business, this must be noted in the

M1 Scope record and records of chemical treatments during production of

planting materials must be kept.

Sourcing planting materials

Planting material must be obtained from approved suppliers and suppliers

informed of their responsibility to disclose any chemical treatments that may

result in chemical residues in marketed produce exceeding MRLs. A record of

purchase must be kept, including a description of the planting material, date of

purchase and the name of the supplier.

Factsheet – F4 Chemicals

FRESHCARE FOOD SAFETY & QUALITY EDITION 4.1 – FACTSHEET REF1906 F4 CHEMICALS – PAGE 1 OF 6


• Obtaining chemicals

• Storing chemicals

• Managing chemicals

• Disposing of chemicals and chemical containers

• Chemical application

• Chemical residue testing

For more information refer to:

Guidelines for Fresh Produce Food Safety (2019) Chapter 8 Managing chemicals, page 49.

Guidelines for Fresh Produce Food Safety (2019) Chapter 18 Testing, page 90.

Obtaining chemicals

Agricultural chemicals must be purchased from approved suppliers to

demonstrate that the suppliers are meeting the minimum requirements for

supply, as outlined in the Freshcare FSQ4.1 Standard.

Approved suppliers for chemical purchases can be demonstrated by meeting the

requirements as outlined in Factsheet F11:

• AgSafe accreditation

• Establishing a supplier agreement that ensures:

o all chemicals provided are adequately labelled and in acceptable

condition

o all chemicals provided are within Use By dates.

Agsafe

Agsafe accreditation and training supports the safe storage, handling, transport

and sale of agricultural and veterinary chemicals for rural merchandise

businesses. The program trains and accredits staff and businesses in handling and

providing responsible advice in the safe and effective use of agvet chemicals.

The aim of this program is to ensure that there is responsibility and compliance

with government regulations and industry standards throughout the supply chain.

Storing chemicals

Incorrect and careless storage and handling of chemicals can lead to the

contamination of water, grounds, equipment, containers and packaging materials

that come into contact with produce. Accidental spillage directly onto produce

can also occur.

Approvals and label directions for chemicals can change. The age of a container of

chemical can be determined from the date of manufacture and/or expiry date.

For safe and effective chemical storage:

• Locate the shed where it will not be flooded or where chemical spills might

contaminate the growing site, produce, storage areas and packaging

materials.

• Locate the shed away from where people may live and eat.

• Use a structurally sound, adequately lit and well-ventilated shed that protects

chemicals from direct sunlight and weather exposure. The storage area can

be inside the packing shed provided it is segregated from packing, storage

and handling areas.

• Use an impervious floor (e.g. concrete), preferably with a bund to contain any

spills or leaks and to prevent water entering.

• Keep the shed locked to ensure children and others (not trained in safe

handling of chemicals and authorised for entry) are kept out.

• Store chemicals in their original containers with labels intact.

• Separate chemicals into categories.

• Separate containers of chemicals awaiting disposal so they are not

accidentally used.



• Keep a spill kit handy. Spill kits should include:

o a shovel

o dustless absorbent material e.g. kitty litter, activated charcoal,

vermiculite, hydrated lime, clay, earth or dry sand (avoid using sawdust

and other combustible materials)

o a container to hold the absorbent material or other leaking containers.

Managing chemicals

Chemical inventory

Keep a record of all chemicals purchased in a chemical inventory, or equivalent

record. The record must include:

• date received

• place of purchase

• name of chemical

• batch number (where available)

• expiry date or date of manufacture

• quantity.

Form – F4 Chemical inventory form template has been provided to capture this

information, however the required information could also be kept on

purchase/delivery receipts or via other purchase recording systems.

Annual check

An annual check of chemicals in storage will ensure they have current approval,

that they are still within their expiry date and that containers are intact with

readable labels. This will avoid illegal use/MRLs being unknowingly exceeded;

ensure chemicals are still effective; and ensure containers can be safely handled.

Stored chemicals are checked to identify and segregate chemicals for disposal

that have:

• exceeded the label expiry date

• exceeded the permit expiry date

• had their registration withdrawn

• containers that are leaking, corroded or have illegible labels.

A record of the check must be kept. This can be recorded on the Form – F4

Chemical inventory.

Disposing of chemicals and chemical containers

Disposal of chemicals

Unwanted chemicals can be disposed of through ChemClear® or through a

certified or approved chemical waste contractor.

For more information regarding disposal of unwanted chemicals and chemical

containers, contact ChemClear®, drumMUSTER® or your local council.

ChemClear®

ChemClear® is the industry-funded program for the collection and disposal of

unwanted, currently-registered agvet chemicals. The aim of this service is to

minimise the potentially dangerous build-up of unwanted agvet chemicals on

farms, which may create risks to the environment, public health and trade. A

web-based booking system is available for users, as well as a free call number.

More information about the program can be found on the ChemClear® website:

www.chemclear.com.au.

Disposal of chemical containers

Under various state regulations, businesses are required to dispose of empty

chemical containers safely. When purchasing, ask if used chemical containers can

be reused, returned, refilled or recycled.

Empty chemical containers must be stored in a designated, secure area

(preferably locked), and disposed of either through a controlled approved

disposal scheme, such as drumMUSTER®, or according to a documented

procedure that meets state or territory regulations.

A record of disposal is kept e.g. disposal receipts/records.

http://www.chemclear.com.au/



drumMUSTER®

drumMUSTER® is the industry-funded national program for the collection and

recycling of empty, pre-cleaned, crop protection and animal health chemical

containers.

More information about the program including details of collection days and

locations can be found on the drumMUSTER® website: www.drummuster.com.au.

Chemical application

Incorrect or careless use of chemicals and harvesting of crops within the

withholding period (WHP) can result in residues exceeding the MRLs. Examples

include:

• using untrained workers

• using unregistered chemicals or chemicals without an ‘off label permit’ issued

by the Australian Pesticides and Veterinary Medicines Authority (APVMA)

• incorrect mixing

• incorrect calibration of equipment

• not observing the withholding period.

Recognised farm chemical training

Freshcare requires that the person responsible for chemical application on farm is

required to complete recognised farm chemical user training and be able to show

ongoing competency.

A number of organisations deliver these training courses in groups and online.

Workers involved in the use of chemicals must be trained, assessed as competent

and be authorised to use chemicals within the business by the person responsible

for chemical application.

Freshcare requires the following national competencies be included in all farm

chemical user training qualifications:

• AHCCHM303 – Prepare and apply chemicals

• AHCCHM304 – Transport and store chemicals.

In some states, such as New South Wales (NSW), government regulations require

all workers who use chemicals to complete recognised farm chemical user

training.

Permits

In certain circumstances, ‘off label’ permits may be obtained for the legal use of

chemicals in ways different to the registered use printed on the label (e.g. for

minor use crops, exotic disease outbreaks, or research trials). Permits are granted

by the APVMA, a database of registrations and permits for Agvet chemicals can be

viewed online on the APVMA website: http://apvma.gov.au.

Maintenance and calibration of equipment

Calibration and maintenance of spray equipment must be undertaken regularly to

ensure accuracy of chemical application. While different equipment has different

calibration procedures, the principles remain the same – to check that the desired

amount of chemical is directed onto the target. Poorly calibrated equipment can

result in failure to control the target pest, crop damage, increased application

costs and contamination of produce.

Maintenance of equipment includes:

• checking spray nozzles for wear,

• checking hoses and joins for leaks,

• checking spray rig tyre pressures and speed.

For further information on the calibration of equipment, refer to the resources

provided at farm chemical user training. Detailed information and guidelines on

how to calibrate equipment is also available from manufacturers or companies

selling spray equipment.

Withholding period (WHP)

The withholding period is the time elapsed between the last treatment with a

chemical and the harvest of a crop. Withholding periods are specified on product

labels to ensure that any chemical residues on produce are below the Maximum

Residue Limit (MRL).

http://www.drummuster.com.au/



Application and record keeping

Only approved chemicals shall be used and withholding periods for the harvesting

and release of produce observed. Chemical application records must be

maintained, refer to Form F4 – Preharvest chemical application and Form F4 –

Postharvest chemical application.

Infopest

Infopest is a comprehensive Agvet chemical database of all chemicals registered

and approved by the APVMA.

Information on chemical active constituents, permits, Safety Data Sheets (SDS)

and label images, is available on their website: www.infopest.com.au.

Records of all preharvest chemical applications are kept and must include:

• application date

• start and finish times

• location and crop

• chemical used (including batch number if available)

• rate of application and quantity applied

• equipment and/or method used to apply the chemical

• withholding period (WHP) or earliest harvest date (EHD)

• wind speed and direction

• name and signature of person who applied the chemical.

Records of all postharvest chemical treatments are kept and must include:

• treatment date and time

• produce treated

• chemical used (including batch number if available)

• rate of application and/or quantity applied

• equipment and/or method used to apply the chemical

• withholding period (WHP) (where applicable)

• name and signature of person who carried out the chemical treatment.

Spray drift

Spray drift is the movement of agricultural chemicals away from the target area

during or after ground or aerial spraying (in the form of droplets, particles or

vapour). Agricultural chemicals can drift long distances under certain weather

conditions.

Spray drift or overspray can be a possible source of chemical contamination on

produce. One of the main causes of this may be from spraying chemicals in

unsuitable weather conditions. Table 1 provides a guideline based on visual

descriptions for assessing wind speeds suitable for spraying.

Table 1. Visually assessing wind speed

Approximate air speed at boom height

Description Visual indicators Suitability for spraying

0 – 2 km/h Calm Smoke rises vertically Spraying inadvisable

2 – 3.3 km/h Light air Smoke drifts in direction

Avoid spraying

3.3 – 6.5 km/h Slight breeze Wind felt on face, leaves rustle

Optimum spraying conditions

6.5 – 9.6 km/h Gentle breeze

Leaves and twigs in constant motion

Use low drift nozzles (medium to coarse droplets)

9.9 – 14.5 km/h

Moderate breeze

Small branches moved and raises dust or loose paper

Increased risk of spray drift - use air induction nozzles (coarse droplets)

14.5 + km/h Fresh breeze +

Small trees in leaf begin to sway

Spraying inadvisable

Silvan Australia Pty Ltd Selecta and Delta T. Ver.28, July 2010

The visual wind speed indicators in Table 1 do not provide complete assessment

of the weather conditions affecting the likelihood of spray drift. Other weather

conditions impacting on the likelihood for spray drift include temperature,

humidity, evaporation rate and droplet lifetime.

http://www.infopest.com.au/



The APVMA will increasingly require chemical label directions to include relevant

weather information for avoiding spray drift. Read each chemical label before

spraying to check the suitability of weather conditions required for spraying the

chemical. Freshcare recommends the use of weather monitoring devices to

measure the temperature, relative humidity and wind speed and direction.

Measure the wind speed, wind direction and any other relevant weather

conditions before and during spraying and record the relevant information on the

spray diary for each application of the chemical.

Neighbours also need to be aware of the potential for spray drift, and the effect it

can have on adjacent properties. Talk to neighbours, discuss sensitive areas, and

determine how the risk of spray drift between the properties can be managed.

Request that neighbours avoid spraying when drift is likely.

It is important to be aware that spray drift may occur and of the need to do a

multi-screen residue test on produce (including organic produce) to check if spray

drift has happened.

Planning the timing of plantings can also assist in minimising the risk of

withholding period and MRL breaches on adjacent crops.

Chemical residue testing

Chemical testing

The requirement for testing fresh produce for chemical residues is to verify that

chemicals are being applied according to current label or permit directions.

The chemical residue test required by Freshcare must be a multi-screen test that

includes chemicals used as part of your spray program and, where applicable,

postharvest chemical treatments. The test must be conducted on a random

sample of produce that has had all preharvest and postharvest chemical

treatments completed and is ready for sale and/or consumption.

Organic producers must also have their produce tested as per the requirements

of the Freshcare Code. This is to verify chemical residues are not present from

previous use of the growing site, or from spray drift from adjacent

sites/properties.

Heavy metal and other chemical testing of produce or soils may also be required

in order to assess the risk of contamination from persistent chemicals and heavy

metals in the soil.

Maximum Residue Limits

The Maximum Residues Limit (MRL) for registered crop protection chemicals is

established by the APVMA.

The MRL is the maximum concentration (mg/kg) of a residue that is legally

permitted on produce after harvest. Check state government requirements for

on-farm legal use of chemicals, as there may be differences between state

regulations.

The MRLs for harvested fresh produce are established by FSANZ and published in

Food Standards Australia New Zealand (FSANZ) Food Standards Code – Section

1.4.2 Agvet chemicals and associated Schedules – Schedule 20 and 21, this

document is available on their website: www.foodstandards.gov.au.

For produce that is exported, check the importing country regulations governing

the application of chemicals and MRLs.

Produce chemical residue test results are checked against the MRL of the

chemical for the specific crop.

What to test for

Standard multi-screen tests include a broad range of active constituents at a cost-

effective price, and these are now used for verification testing. It is important that

the multi-screen test includes chemicals that have been used during the spray

program and postharvest.

The results of residue testing by industry or government testing programs can

help in assessing the risk of chemicals exceeding the MRL.

http://www.foodstandards.gov.au/



When to test

Chemical residue testing verifies the chemical application program. The test must

be conducted before initial Freshcare certification and then annually, or more

frequently, if required by a customer specification. If more than one crop type is

grown, Freshcare only requires a crop to be tested each year. A rotation system

must be used so that a different crop is tested each year.

Where to sample

The produce must be sampled at or just prior to the point at which it could be

first available to the customer. This can be just after the withholding period has

lapsed, after harvest or packing or just before or on delivery to the customer.

Where the produce is stored for an extended period before delivery, such as

apples, collect the sample before storage. If the postharvest application of

chemicals for long term storage is being verified, then produce should be sampled

after storage.

The sample must be unbiased and representative of the produce supplied. The

grower or customer such as a wholesaler, processor or packer may select the

sample and organise residue testing.

How to sample

Before sending a sample for testing, check that the laboratory is NATA accredited

(or accredited to ISO/IEC 17025 Standard) for the analysis of chemical testing for

fresh produce and can test for chemicals included in your preharvest and

postharvest spray.

Request the laboratory provide evidence of the tests and matrices for which they

are accredited.

The laboratory will give instructions on the required sample size and how best to

transport the sample. When collecting and transporting samples, avoid cross

contamination from other sources and deterioration of the produce. Guidelines

to follow are:

• Use disposable gloves (or thoroughly washed hands) to collect the sample.

• Place the sample in a clean plastic bag and/or box to protect it during

transport.

• Clearly label the sample with your name, address, telephone number and

other details (don’t forget to record the date of sample collection and from

where it was collected).

• Clearly indicate what test you want the laboratory to undertake (e.g. specific

chemical name, multi-screen).

• Store the sample in a cool (but not frozen) state until ready to transport.

• Use overnight freight to ensure the sample gets to the laboratory promptly.

Factsheet – F5 Fertilisers and soil additives

FRESHCARE FOOD SAFETY & QUALITY EDITION 4.1 – FACTSHEET REF1906 F5 FERTILISERS AND SOIL ADDITIVES – PAGE 1 OF 3


• Sourcing fertiliser inputs

• Fertilisers and soil additives containing manures and/or food waste

• Treated fertilisers and soil additives containing manures

• Effective composting

For more information refer to the:

Guidelines for Fresh Produce Food Safety (2019), Chapter 6 Managing fertilisers and soil additives, page 27.

Guidelines for Fresh Produce Food Safety (2019), Chapter 18 Testing, page 90.

Sourcing fertiliser inputs

Fertilisers and soil additives are products that are added to the soil to improve

fertility and structure, or control weeds. Examples include inorganic (chemical)

fertilisers such as lime and gypsum; and those of organic origin such as animal

manure, sawdust, compost, compost tea, seaweed, fish-based products, other

biological compounds and those derived from food waste.

When sourcing fertilisers and soil additives and assessing the potential food

safety risk of the farm input, consider the composition, treatment, application

method and timing, of use.

For more information regarding sourcing and using fertilisers and soil additives

safely, refer to the Compost Factsheet available for download on the Freshcare

website: www.freshcare.com.au.

Human effluent and biosolids

Biosolids are solid or semisolid by-products obtained from treated human sewage

or wastewater.

Freshcare does not permit the use of biosolids or human effluent, they must

therefore not be applied to growing areas.

Heavy metal contamination

Heavy metal contamination of fresh produce can be caused by the presence of

cadmium in fertilisers (especially phosphate and some trace element mixes) and

soil additives such as gypsum, animal manures, biosolids and composts. Root and

tuber crops and leafy vegetables can take up cadmium if growing conditions are

favourable for uptake.

Only fertilisers and soil additives that comply with the legal limits for cadmium

and have the lowest available impurity levels should be used. For example, special

low cadmium superphosphates are now available and should be used where

phosphorus application rates are high or where higher risk crops are grown.

Limits for heavy metal contaminants in growing medium and fertilisers and soil

additives comply with those specified in AS4454-2012:

• Cadmium <1mg/kg (dry weight basis)

• Lead <150mg/kg (dry weight basis).

Fertilisers and soil additives containing manures and/or food waste

Microbial contamination of fresh produce can be caused by the use of untreated

or incorrectly treated fertilisers and soil additives containing manures. Microbes

present in the gut of animals may transfer into the manure, and then on to the

fresh produce, thus causing a food safety hazard to consumers.

Contamination of produce can occur through direct contact of untreated

fertilisers and soil additives containing manures with the harvestable part of the

crop (soil or foliar application); or indirectly through contact with contaminated

soil or water.

Fertilisers and soil additives containing manures that have been treated to

minimise microbe levels are less likely to cause contamination of produce. For

example, the heat generated during correct composting of manure will kill

microbes of concern for food safety. When purchasing treated fertilisers and soil

additives containing manures from suppliers, obtain information including:

• evidence of certification to AS4454-2012, or

• details of the treatment process (a documented, verified treatment process –

AS4454-2012 or other equivalent time/temperature treatment); and a



Certificate of Analysis for each batch of product supplied to verify the

treatment process achieves E. coli <100 cfu/g, Salmonella Not Detected/25g.

There are a number of practices that can be adopted to minimise the risk of

microbial contamination of produce from the use of fertilisers and soil additives

containing manures, including:

• Locate or cover stockpiles to avoid contamination from wind drift onto

adjacent crops and harvested produce or rainfall runoff into water sources.

• Adhere to exclusion periods between application of untreated fertiliser and

soil additive containing manures and when the crop is harvested. Appropriate

exclusion periods are determined by the Freshcare FSQ4 Risk assessment for

fertilisers and soil additives (Refer to RA-F1.3 for risk assessment).

• Use an application method/growing practice that minimises the chance of the

untreated fertiliser or soil additive coming into contact with the harvestable

part of the crop, e.g. skirting tree crops, growing crops on plastic mulch.

• Incorporate untreated fertilisers and soil additives into the soil as soon as

possible to minimise contamination of adjacent crops from wind drift or

rainfall runoff.

• Avoid fertiliser and soil additives applications when the risk of wind drift and

run-off onto adjacent crops is high.

• Request neighbours avoid fertiliser and soil additives applications when the

risk of wind drift and run-off onto adjacent crops is high.

• Minimise the potential risk of faecal contamination from wildlife and

domestic animals in growing sites.

Treated fertilisers and soil additives containing manures

If using fertilisers and soil additives containing manures within exclusion periods,

it must be treated in accordance with AS4454-2012 or other equivalent

time/temperature treatment and evidence of compliance kept.

Evidence of compliance for treated fertilisers and soil additives containing

manures as referenced in the FSQ4 Code Appendix: A-F5 include:

• If sourced from suppliers with an approved certified treatment process –

evidence of certification to AS4454-2012 is provided.

• If sourced from suppliers that follow a documented, verified treatment

process (AS4454-2012 or other equivalent time/temperature treatments) –

details of the treatment process and a Certificate of Analysis for each batch of

product supplied to verify the treatment process achieves E. coli <100 cfu/g,

Salmonella Not Detected/25g.

• If treated on farm to a documented, verified treatment process (AS4454-

2012 or other equivalent time/temperature treatments) – treatment records

are kept and must include:

o product composition

o description of treatment method

o treatment start and end date

o date and temperature readings

o batch identification code

o estimated quantity of batch

o name of person that supervised the treatment.

A Certificate of Analysis for each batch of product is kept to verify the

treatment process achieves E. coli <100 cfu/g, Salmonella Not Detected/25g.

Effective composting

If treating fertilisers and soil additives containing manures on-farm, effective

composting techniques must be used, including:

• keeping the compost heap aerated and outer layers turned in for the process

to work

• exposing all of the organic material to a minimum temperature of 55⁰C for

three consecutive days

The time taken for complete composting of fertilisers and soil additives depends

on the system used and factors such as the type of material, moisture content,

aeration, nutrient ratio, pH, toxic substances and temperature.



Generally it takes between six and ten weeks (with a curing period of two to three

months) to ensure that compost is mature.

Full details on the types of composting systems and detailed guidelines on

procedures required can be found in the Australian Standard AS4454-2012:

Composts, soil conditioners and mulches (Standards Australia).

Factsheet – F6 Water

FRESHCARE FOOD SAFETY & QUALITY EDITION 4.1 – FACTSHEET REF1906 F6 WATER – PAGE 1 OF 3


• Contamination from water

• Managing water sources and infrastructure

• Reclaimed or recycled water

• Water used preharvest

• Water used postharvest

• Water for other uses

• Water treatment

• Verification of water quality

For more information refer to the Guidelines for Fresh Produce Food Safety (2019)

Chapter 7 Managing water, page 33.

Chapter 18 Testing, page 90.

Contamination from water

Water is used during growing for irrigation and spraying, and after harvest for

washing, unloading of field containers (water dumps), chemical treatment(s),

hydrocooling, top icing, hand washing and cleaning. In some hydroponic systems,

water is constantly in contact with the roots of produce.

In assessing the risk of contamination to produce from water use, factors that

need to be considered are the source of water, when and how the water is used,

and on what type of produce.

Taste, odour and colour may be the first indication of a potential food safety

hazard but should not be relied upon to assess water quality. E. coli is used as an

indicator of faecal contamination of water.

Types of produce

The part of the produce that is harvestable and the way it is consumed, may

affect the risk of microbial contamination that need to be managed. The risk for

produce that has an edible skin and may be eaten uncooked can be higher than

for produce that is peeled or cooked before eating.

Managing water sources and infrastructure

Water sourced from creeks and rivers, dams, bores and water storage tanks, may

be contaminated by microbes or chemicals. Therefore, water sources used for

produce need to be monitored and managed to minimise potential contamination

by factors impacting the water quality.

Different water sources may have different levels of contamination. It is therefore

important to consider the water source used preharvest and postharvest and

assess the suitability of the water source for that use. For example, water in one

dam may be suitable to irrigate a potato crop but may not be suitable to irrigate a

lettuce crop. Refer to following sections for more information.

Records need to be maintained to identify water sources and how they are used,

so if there is a food safety problem there is traceability to clearly show which

water was used on each crop. Form – F6 Water source template has been

provided to record this information.

Infrastructure used for water storage and delivery on the property must be

monitored and maintained to avoid contamination of the water. Water extraction

points, water storage, delivery infrastructure and irrigation equipment is to be

inspected and maintained to ensure the quality of water delivered.

Freshcare FSQ4.1 requires infrastructure and equipment such as water storage

tanks, water dumps, flumes and treatment tanks are suitable for such the

purpose, constructed of materials that will not contaminate the water and are

clean and maintained.



Reclaimed or recycled water

Reclaimed water is defined in Australia as water derived from sewage systems

and industrial processes. Freshcare businesses using reclaimed or recycled water

should contact their provider to ensure that the water sourced is approved for its

intended use and the water meets, or is treated to meet, the requirements of the

Freshcare FSQ4.1 Standard.

Water used preharvest

Preharvest water uses include irrigation, fertigation, hydroponics, crop spraying

and foliar application.

A risk assessment is used to determine the risk of microbial contamination of

produce from preharvest water and depending on the significance of the risk,

whether the water quality needs to comply with Freshcare water quality limits for

preharvest water.

If the completion of the risk assessment (refer to FSQ4.1 Standard Appendix RA-

F1.4 or Risk assessment – preharvest water template) indicates high significance,

all water used within 48 hours of harvest must meet E. coli <100 cfu/100ml.

Evidence must be kept to verify water quality.

Water used postharvest

Water may be used during harvest or postharvest via the following process steps:

• unloading of field containers and bins (water dumps and troughs)

• pre-washing*

• washing/final rinse

• chemical treatment with fungicides and insecticides

• hydrocooling

• top icing.

* Where water is used post-harvest as a pre-wash step (to remove soil or debris),

where there is a subsequent wash step, the water used must meet the water

quality for preharvest water E. coli <100 cfu/100ml.

All other water used in subsequent washes (including final wash), during a single

wash step, for chemical treatment, hydrocooling, top icing, etc, must be suitable

for the purpose intended, not be a source of food safety risk and meet (or be

treated to meet) E. coli <1 cfu/100ml. This includes water in recirculation systems,

water dumps, flumes and treatment tanks used post-harvest, whereby treatment

and/or water is changed at an assessed frequency to ensure it meets the above.

Evidence of water quality must be kept, as well as treatment and water change

records (where applicable).

Water for other uses

Water used for hand washing in toilets and hand washing facilities

Water used for hand washing must not be a source of food safety risk, be suitable

for the purpose intended and meet (or be treated to achieve) E. coli <1

cfu/100ml, with evidence kept.

If water has not been proven to meet E. coli <1 cfu/100ml, an alcohol-based hand

sanitiser must be used after washing hands with soap and water.

Water used for cleaning

Water used for cleaning or sanitising equipment, containers, tools and other

produce contact surfaces must not be a source of food safety risk, be suitable for

the purpose intended and meet (or be treated to achieve) E. coli <1 cfu/100ml,

with evidence kept.

Any variation to the water quality (E. coli <1 cfu/100ml) for the above uses, must

be supported by a risk assessment and associated documentation (refer to FSQ4.1

Standard F1.6 and Form – F1 Risk assessments – other practices template).



Water treatment

It is important to carefully review the best water treatment for the operation,

based on sound technical advice and following the manufacturers guidelines.

Treatment of water must be monitored (and equipment maintained) to ensure

that it achieves the desired level of microorganism control. Records must be

maintained, including the method, frequency and results of treatment (refer to

Form – F6 Water treatment monitoring record template).

Verification of water quality

A practical approach to assess the risk of microbial contamination is to test for the

presence of faecal contamination. Testing water for E. coli provides an indication

of faecal contamination of the water, which could lead to microbial

contamination of produce.

The quality of the water required (acceptable level of E. coli) depends on when

and how the water is used, the type of produce and whether the organisms will

survive on the produce. The Freshcare FSQ4.1 Standard compliance criteria

outlines the quality of water required for its intended use. A consideration should

also be how often water is changed within treatment, recirculation, water dumps

and flumes.

If specific water quality is required, evidence of compliance for water quality for

that source needs to be kept:

• External supplier e.g. town water – certificate of compliance from supplier.

This could also be a water test verifying the water meets required limits.

• Water treated on-farm – water treatment process is documented and water

tested to verify treatment process is effective. Treatment and monitoring

records are kept. If water source or treatment method changes, process is

reviewed, documented and water tested to verify treatment process is

effective (refer to Form – F6 Water treatment monitoring record template).

• Untreated water – each water source is tested:

o monthly during period of use, or

o annually before use, once it is historically proven to achieve specified

E.coli limits (at least 4 consecutive tests below specified limits).

It is also important to ensure the testing records maintained to provide water

quality are conducted by a competent lab (refer to Glossary for definition).

Factsheet – F7 Allergens

FRESHCARE FOOD SAFETY & QUALITY EDITION 4.1 – FACTSHEET REF1906 F7 ALLERGENS – PAGE 1 OF 2


• What are allergens

• Allergens in fresh produce

• What do I need to do?

• Allergen labelling

• Further information

For more information refer to the Guidelines for Fresh Produce Food Safety (2019) Chapter 16 Allergens, page 81.

What are allergens

Allergens are substances, that even in small amounts, can cause a severe allergic

reaction in susceptible individuals.

It is therefore extremely important to review all inputs to your production for

allergens, and implement control measures if required.

All workers need to be made aware of allergens, and the role they play in

ensuring that allergens are not inadvertently introduced to the product.

Allergens of concern include:

• cereals containing gluten and their products (namely wheat, rye, barley, oats,

spelt and their hybridized strains)

• lupin

• crustacea and their products

• eggs and egg products

• fish and fish products

• peanuts and tree nuts and their products

• milk and milk products

• sesame seeds and their products

• soybeans and their products

• added sulphites in concentrations of 10mg/kg or more.

Allergens in fresh produce

In the fresh produce sector the risk of contaminating produce by cross contact

must be considered. Cross contact is when a residue or other trace of an

allergenic substance is unintentionally added to a food not intended to contain

that allergenic substance and where such occurrences are sporadic.

The greatest risk to produce is from cross contamination from either workers or

substances unintentionally introduced from other sources such as raw material

inputs. For example:

• fruit, vegetable or nut in shell waxes containing soy, casein (milk protein),

peanut or sesame

• use of tree nut waste materials as mulch on vegetable crops

• peanuts or peanut shells in growing site

• soy based grease or lubricants for machinery with potential produce contact

(e.g. machinery is above packing line)

• compost teas can be a source of allergens e.g. using fish heads.

What do I need to do?

• Ensure your workers are aware of and can identify allergens and know how to

avoid introducing allergens.

• Ensure proper hygiene practices are kept by all workers and that hands are

washed after handling any food that may include allergens.

• Do not use any products on your produce, such as waxes or mulches, which

may contain allergens.

• Document an allergen control procedure if you use any inputs containing

allergens and train your workers accordingly in the control and removal of

allergens.

Allergen labelling

Standard 1.2.3 of the Australia New Zealand Food Standards Code requires a

mandatory declaration for all the main foods and their products (listed allergens

Factsheet – F7 Allergens

FRESHCARE FOOD SAFETY & QUALITY EDITION 4.1 – FACTSHEET REF1906 F7 ALLERGENS – PAGE 2 OF 2

of concern) that may cause an allergenic reaction, even if these products are

ingredients or processing aids. However, there is currently no legal requirement

for mandatory declarations in the event of unintended cross contact.

Some countries allergen labelling requirements differ to those of Australia, and

even some countries have other substances listed as allergens that Australia does

not consider (i.e. celery and mustard seed). Therefore, when considering product

for export that contains or may contain allergens, the appropriate legislation is

consulted and applied in terms of labelling of product.

Further information

Documents and tools have been developed to assist food producers comply with

the Australia New Zealand Food Standards Code, and minimise the risk of

unintentional consumption of allergenic products:

The Food Industry Guide to Allergen Management and Labelling (2007) contains

further information on the management of allergens and labelling requirements

and is available on the Australian Food and Grocery Council website:

http://www.afgc.org.au/wp-content/uploads/Food-Industry-Guide-to-Allergen-

Management.pdf

Voluntary Incidental Trace Allergen Labelling (VITAL®) is a tool that allows food

producers to assess the impact of allergen cross contact and provide appropriate

precautionary labelling on their products. It includes a decision tree that can

assist a business in understanding when labelling is required. VITAL® is available

on the Allergen Bureau website: www.allergenbureau.net

http://www.afgc.org.au/wp-content/uploads/Food-Industry-Guide-to-Allergen-Management.pdf

http://www.afgc.org.au/wp-content/uploads/Food-Industry-Guide-to-Allergen-Management.pdf

http://www.allergenbureau.net/

Factsheet – F8 Premises, facilities, equipment, tools, packaging and vehicles

FRESHCARE FOOD SAFETY & QUALITY EDITION 4.1 – FACTSHEET REF1906 F8 PREMISES, FACILITIES, EQUIPMENT, TOOLS, PACKAGING AND VEHICLES – PAGE 1 OF 3


• Premises, facilities, equipment, tools, packaging and vehicles

• Toilet and handwashing facilities

• Septic, waste and drainage systems

• Tools, equipment and containers

• Packaging materials

• Vehicles and transportation

• Preventative maintenance and cleaning

• Waste disposal

For more information refer to the Guidelines for Fresh Produce Food Safety (2019)

Chapter 9 Managing facilities, page 55.

Chapter 10 Managing tools and equipment, page 59.

Chapter 11 Managing containers and packaging, page 64.

Chapter 12 Vehicle maintenance and hygiene, page 68.

Chapter 18 Testing, page 90.

Premises, facilities, equipment, tools, packaging and vehicles

Produce can be contaminated through contact with facilities, equipment,

containers, materials and vehicles. All items that contact produce, areas where

produce is handled or stored (including enclosed growing areas), and vehicles

used to transport produce must be constructed, maintained and cleaned in a

manner that minimises the risk of produce contamination.

The risk of contamination of produce varies with the type of produce grown

and/or packed. For higher risk produce more rigorous practices such as sanitation

are required to minimise the risk of contamination.

Premises and facilities include all produce handling areas and their surrounds

(internal and external) including:

• storage sheds

• cool rooms

• pack houses

• greenhouses and growing areas

• field packing areas.

Premises and facilities should be:

• located away from likely sources of contamination (identified on the property map)

• properly located, designed, constructed and maintained to reduce likelihood of contamination to produce

• free from flaking paint, rust, dust, dirt, loose objects, splinters, etc.

• appropriate for the type of produce being handled and the processes being undertaken.

For produce packed for retail sale (includes, but is not limited to, retail crates,

pre-packs) it is important to have designated ‘clean’ areas that are able to be kept

free from dirt, dust and other contaminants during sorting and packing, in

preparation for dispatch to the customer.

Toilet and handwashing facilities

Toilets and hand washing facilities must be:

• located to minimise the risk of contaminating produce and maximise

accessibility (i.e. - ease of access)

• provided to accommodate the number of workers (i.e. - can cope with

number workers on site)

• kept clean, and regularly maintained and serviced

• designed to ensure hygienic removal of waste and to minimise the risk of

contaminating produce directly, or indirectly, through contamination of

growing site or water sources



• equipped with running water (as specified in F6.4.1), liquid soap,

mechanism/s for effective hand drying, and waste disposal facilities (See

Appendix A-F8)

• hand washing instructions are displayed (including language translations

and/or pictures where applicable).

*Approved mechanisms for effective hand drying include disposable paper

towels, hand dryers.

Hand drying facilities must be used effectively and properly maintained to

minimise the risk of contamination to produce.

For produce that has an edible skin and may be eaten uncooked, all workers must

apply hand sanitiser after handwashing using soap and water. This shall be before

handling produce or materials that may touch produce.

Maintenance records and checks, cleaning plans and product specifications (for

hand dryers) are kept on file.

Septic waste and drainage systems

Septic, waste disposal and drainage systems should be located and maintained to

minimise the risk of contaminating produce directly, or indirectly, through

contamination of the growing site(s) or water source(s) and identified on the

property map.

Drains should be designed and managed to:

• prevent ponding in areas where produce is handled and stored

• prevent pests entering the facility

• enable regular cleaning, and ensure they are kept clean.

Construction of new septic, waste disposal and drainage systems should be

managed in accordance with the Freshcare FSQ4.1 Standard requirements

ensuring they are located and constructed to minimise the risk of contamination

to produce.

Tools, equipment and containers

Tools, equipment, and containers should be:

• made of substances that are non-toxic, and designed and constructed to

enable regular cleaning and maintenance

• stored in a manner that minimises contamination.

Handheld harvesting tools should be cleaned each day, before use, and be

accounted for at the end of each day. Any handheld harvesting tools unaccounted

for should be reported and investigated via an internal Corrective Action Record

(Form – M4 Corrective action record).

For produce that has an edible skin, and may be eaten uncooked:

• produce containers used at harvest are handled to avoid produce being

contaminated by soil or other physical contaminants

• a food grade liner is used when containers cannot be effectively cleaned.

Wooden bins and pallets should be checked for cleanliness, foreign objects, pest

infestation, odours and protruding nails or splinters. Where required, bins and

pallets are cleaned, repaired, rejected or covered with a protective material to

ensure contamination of produce is avoided.

Packaging materials

Packaging materials should be sourced from suppliers managed in accordance

with F11 Suppliers.

Packaging materials must be stored in a manner that minimises contamination.

Before use all packaging materials should be checked for cleanliness, foreign

objects and pest infestation. When required, packaging materials should be

cleaned, rejected or covered with a protective material to ensure contamination

of produce is avoided.



Packaging materials used for retail sale (includes, but is not limited to retail

crates, pre-packs) must be food grade.

Vehicles and transportation

Fresh produce can be exposed to chemical, microbial and physical contamination

during transport operations.

The important factors that need to be considered are the state of the vehicles

used to transport the produce, and what else is stored or transported with the

produce.

Vehicles may be refrigerated or non-refrigerated, depending on the produce

being transported.

Preventative maintenance and cleaning

Cleaning to remove soil, dust, grease, oil, chemicals, and foreign objects

minimises the risk of contaminating produce. All equipment, containers and

materials that come in contact with produce, and areas where produce is

handled, packed and stored needs to be regularly and effectively cleaned.

The method of cleaning and frequency will depend on the type of produce and

how it is handled, packed and stored, and how often the equipment, container or

area is used.

A cleaning plan must be documented (refer to Form – F8 Cleaning plan).

Information required on this plan includes:

• areas and items to be cleaned

• cleaning agents and the methods used

• frequency of cleaning

• name of the person responsible for ensuring cleaning is completed.

Chemicals and materials used for cleaning and maintenance must be appropriate

for use. If using chemicals for cleaning it is important to make sure they do not

contaminate produce through inappropriate use or storage.

Equipment used for cleaning should be stored appropriately. Workers that

complete cleaning tasks must be trained, and a record of training retained.

To ensure cleaning is effective, monitoring must be undertaken. The Guidelines

for Fresh Produce Food Safety (2019) Chapter 18 gives business information in

how cleaning and sanitation can be monitored through facilities testing.

Cleaning contractors (if used) should be included on the approved supplier list.

These contractors must meet the required specifications as outlined in F11

Suppliers.

Waste disposal

Waste generated on the property must be managed, appropriately stored and

disposed of to reduce the potential for produce contamination.

Waste containers are provided, appropriate for use, clearly identified and

emptied on a regular basis. Containers used for storing waste, chemicals or

dangerous substances are clearly identified and not used for produce.

Waste storage onsite should be:

• clearly identified, adequately sized, and conveniently located for the type of waste generated

• located to minimise the risk of contaminating produce and kept clean and tidy

• identified on the property map.

Waste disposal should be appropriate for the type of waste generated; for example, chemical containers are appropriately segregated, stored and sent to drumMUSTER® (or other approved facility) and are not buried or burned.

Any waste disposal sites on the property should be located to minimise the risk of contaminating produce, clearly identified and recorded on the property map.

Factsheet – F9 Animals and pests

FRESHCARE FOOD SAFETY & QUALITY EDITION 4.1 – FACTSHEET REF1906 F9 ANIMALS AND PESTS – PAGE 1 OF 1


• Animals and pests

For more information refer to the Guidelines for Fresh Produce Food Safety (2019), Chapter 13 Managing animals, page 70.

Animals and pests

Animals and pests, including dogs, cats, rats, mice, birds, cockroaches and other

insects, can be a source of microbial contamination.

Livestock, domestic animals and wildlife are also considered a source of microbial

contamination and should therefore (where possible) be excluded from growing

sites and packing facilities.

The presence of animals and pests in and around growing, handling, packing and

storage areas also needs to be minimised. This may be done through the use of

physical barriers or chemical controls.

If using chemicals for pest control it is important to make sure they do not

contaminate produce through inappropriate use or storage.

Workers should be trained to report all instances of pest sightings. Any workers

responsible for laying and monitoring baits or traps must be trained, with a record

of training kept.

Records of monitoring of pest baits or traps to ensure they are effective in

controlling target pests should also be retained.

Pest control contractors (if used) should be included on the Supplier list (refer to

Form – F11 Supplier table). These contractors must meet the required

specifications as outlined in the element F11 Suppliers.

Factsheet – F10 People

FRESHCARE FOOD SAFETY & QUALITY EDITION 4.1 – FACTSHEET REF1906 F10 PEOPLE – PAGE 1 OF 2


• People

• Food safety instructions

• Site security

For more information refer to the Guidelines for Fresh Produce Food Safety (2019) Chapter 14 Managing People, page 72.

People

People are an important part of fresh produce production. People can be a source

of microbial contamination, including bacteria, such as E. coli and Salmonella, and

viruses such as Hepatitis A. Adequate facilities must be provided for workers, such

as toilets and hand washing facilities, to minimise contamination of produce.

People can unintentionally introduce allergens via cross-contamination from raw

material inputs or other substances. See Factsheet F7 Allergens for more

information.

People can also introduce physical contamination from items such as adhesive

bandages, jewellery and other personal items.

In assessing the risk of contamination, review the competence, experience and

capabilities of workers to ensure that they pose no threat to food safety while

handling produce.

Basic food safety training must be conducted in personal hygiene standards (e.g.

hand washing, no smoking, and no communicable diseases) with regular

reinforcement on-site using written instructions and/or prominently displayed

signs. Training materials should be provided in relevant languages and/or

pictorially.

Any workers, visitors or contractors known (or suspected) to be suffering from or

to be a carrier of a disease or illness likely to be transmitted through fresh

produce must report to management. They shall not be permitted to enter food

handling areas or handle produce.

Food safety instructions

Written food safety instructions must be provided to ALL workers and visitors

(including contractors) and must include as a minimum, requirements for:

• health status, including what to do if ill

• personal hygiene

• handwashing

• management of clothes and personal items

• use of protective clothing (where necessary)

• general behaviour.

Personal hygiene instructions should include requirements for cleanliness,

handwashing, personal items and clothing, behaviour and health status.

All workers need to be made aware of allergens, and the role they play in

ensuring that allergens are not inadvertently introduced to the product.

Refer to Form – F10 Food safety instructions for a form template. This may be

used as is or modified to suit your business.

Compliance with food safety and hygiene requirements should be monitored and

if required, food safety training should be repeated to update workers,

contractors and/or visitors’ knowledge.

Site security

The Freshcare FSQ4.1 Standard requires that access to the property, growing sites

and product handling areas is restricted to authorised persons.

An authorised person is defined in the Standard as ‘a person delegated the right

to perform a task or access specific areas of a business; authorisation may be in

consideration of training completed or position held.’

Property signage, secure doors, locked storage areas may also assist in restricting

property access to authorised persons only. Workers must be trained in site

security requirements and to report unauthorised access or unknown visitors to

the owner and/or appropriate senior manager.

Factsheet – F10 People

FRESHCARE FOOD SAFETY & QUALITY EDITION 4.1 – FACTSHEET REF1906 F10 PEOPLE – PAGE 2 OF 2

Information regarding site access, movement and emergency procedures should

be communicated to all workers, visitors and contractors.

Freshcare provides access to free sign templates. Freshcare signs can be

downloaded via the Resources section of the Freshcare eLearning website:

www.freshcare.com.au/elearning.

http://www.freshcare.com.au/elearning

Factsheet – F11 Suppliers

FRESHCARE FOOD SAFETY & QUALITY EDITION 4.1 – FACTSHEET REF1906 F11 SUPPLIERS – PAGE 1 OF 8


• Identifying suppliers that may be a food safety risk

• Evidence of compliance

• Managing Freshcare certified produce

• Supplier requirements table

For more information refer to the Guidelines for Fresh Produce Food Safety (2019) Chapter 15 Suppliers of inputs and services, page 79.

Identifying suppliers that may be a food safety risk

Input materials and services (including outsourced services) can introduce food

safety hazards into the business. This includes raw materials, such as produce,

packaging, fertilisers and agricultural chemicals as well as services such as

transport, crop spraying, co-packers or advice such as pest management or

nutritional advice.

As they may introduce a food safety risk, input materials and services must be

managed to ensure that the supplier complies with the applicable requirements

of the Freshcare Food Safety & Quality Standard Edition 4.1.

Managing your suppliers to ensure they meet set specifications will help minimise

the risk of introducing food safety hazards into your business.

If identified as an input material or service that may introduce a food safety risk,

purchase records must be kept.

Evidence of compliance

Freshcare FSQ4.1 F11.1 requires that materials and services that may introduce a

food safety risk are managed and evidence of compliance for suppliers of such

materials and services be kept. This can be demonstrated by:

• Independent evidence of compliance – this may include evidence of

Certification, Certificates of Analysis, Water Quality Reports, Statements of

Compliance, etc.

• A written declaration to comply with requirements – establishing a supplier

agreement (or contract) that they will meet the specifications as outlined in

the supplier specifications table.

• A record of inspection/assessment against requirements/specifications as

outlined in the Supplier requirements table (see following section).

If you have more than one supplier (including any backup or emergency suppliers)

of a material or service, evidence of compliance is required for each supplier.

Agricultural chemicals must be purchased from approved suppliers to

demonstrate that the suppliers are meeting the minimum requirements for

supply, as outlined in the Freshcare Food Safety & Quality Standard Edition 4.1

Three examples demonstrating supplier compliance for agricultural chemicals:

1. AgSafe accreditation, evidence provided.

2. Establishing a supplier agreement (see example on page 2) that ensures:

o all chemicals provided are adequately labelled and in acceptable condition;

o all chemicals provided are within Use By dates; and

o all chemicals provided are appropriate for the use required.

3. Inspecting each purchase/delivery against specifications, to ensure:

o all chemicals provided are adequately labelled and in acceptable condition;

o all chemicals provided are within Use By dates; and

o all chemicals provided are appropriate for the use required.



Example of supplier agreement for an agricultural chemical supplier

Managing Freshcare certified produce

If a business is representing their produce as Freshcare certified and they:

• source produce from another business – The business providing the sourced

produce must also hold a current certification to the Freshcare Food Safety &

Quality Standard or alternate, approved GFSI benchmarked standard.

• send their product to another business (e.g. for packing) – The packing

business must also hold a current certification to the Freshcare Food Safety &

Quality Standard or alternate, approved GFSI benchmarked standard.

The approved GFSI Benchmarked Standards recognised by Freshcare is available

in the Appendix of the Food Safety & Quality Standard (See Appendix A-F11).

This can be managed through the suppliers list (refer to Form – F11 Supplier

table) and traceability records (refer to Form – F13 Supplier traceability).

Business logo

Business name

Business address

Date

Approved supplier acknowledgement

We acknowledge the requirements of Freshcare Food Safety & Quality

Standard and agree to:

• Provide chemicals appropriate for the use required.

• Be approved in accordance with the relevant legislative/regulatory requirements.

• Provide products that are packaged accordingly and adequately labelled (including Expiry Date or Date of Manufacture).

• Advise if we are aware that product contains or has been in contact

with known allergens.

• If entering site, abide by food safety instructions when handling

produce or entering growing, storage and packing areas.

Regards,

Name

Position

Contact details

EXAMPLE ONLY



Supplier requirements table

Suppliers of materials and services (including outsourced services) identified in Form – F11 Supplier table must comply with the applicable requirements of the Freshcare

Food Safety & Quality Standard, as outlined in the table below.

Input material/service Requirements for suppliers

Agricultural chemicals

• Evidence of Ag Safe accreditation/compliance with legislative requirements.

• Provide chemicals appropriate for the use required.

• Approved in accordance with the relevant legislative/regulatory requirements.

• Packaged accordingly, adequately labelled (including Expiry Date or Date of Manufacture).

• Advise if you are aware that product contains or has been in contact with known allergens.

• If entering site, abide by food safety instructions when handling produce or entering growing, storage and packing areas.

Agricultural chemical application

• Hold appropriate accreditation e.g. commercial spray licence and provide copies of accreditation.

• Apply chemicals:

o according to label directions, or

o under ‘off-label permits’ issued by the Australian Pesticides and Veterinary Medicines Authority (APVMA), with a current copy of the permit kept, or

o according to relevant state legislation for ‘off-label use’, and

o according to specific customer and/or destination market requirements.

• Check chemicals for withholding periods prior to use.

• Check chemicals for label changes when opening each new container.

• Avoid chemical application when the risk of contaminating adjacent crops or off-target areas with spray drift is high.

• Ensure application equipment is maintained and checked for effective operation before and during each use.

• Ensure equipment is calibrated at least annually or as per manufacturer’s instructions, and immediately after spray nozzles are replaced. Provide records of calibration.

• Dispose of leftover chemical solutions according to label directions where specified, or in a manner that minimises the risk of contaminating produce directly or indirectly through contamination of growing site or waterways.

• Record all chemical applications including:

o application date

o start and finish times

o location and crop




o chemical used (including batch number if available)

o rate of application and quantity applied

o equipment and/or method used to apply the chemical

o withholding period (WHP) or earliest harvest date (EHD)

o wind speed and direction

o name and signature of person who applied the chemical.

• Advise if you are aware that products used contain or have been in contact with known allergens.


Agronomist/technical advisor

• Be appropriately certified/qualified and provide details of these qualifications.

• Make all recommendations in writing.

• Ensure all agricultural chemical recommendations are in accordance with label or permit specifications.

• Ensure recommendations consider withholding periods (WHP) and anticipated harvest dates.


Bin/tubs/crates, and liners

• Ensure bin/tubs/crates are constructed from materials that are non-toxic and designed and constructed to enable regular cleaning and maintenance. Provide evidence of compliance documentation.

• Use only food-grade chemicals when cleaning and sanitising bin/tubs/crates. Provide copy of SDS as evidence.

• Ensure bin/tubs/crates supplied are cleaned, in appropriate condition, free from foreign objects and pest infestation.

• Ensure bin/tub/crate liners are of food grade.

• Advise if you are aware that product has been in contact with known allergens.


Calibration of scales

• Be a licensed certifier, per the relevant legislation i.e. Trade Measurement Act, and provide evidence of certification.

• Provide a record of calibration results.


Calibration of thermometers, cool rooms

• Be a licensed certifier, per the relevant legislation i.e. Trade Measurement Act, and provide evidence of certification.

• Provide a record of calibration results.





Chemicals – cleaning

• Ensure chemicals are approved for use in a food handling area. Provide copy of SDS as evidence.

• Packaged accordingly and adequately labelled (including Expiry Date or Date of Manufacture).



Chemicals – water treatment


• Packaged accordingly and adequately labelled (including Expiry Date or Date of Manufacture).

• Where required, ensure additional validation and monitoring requirements are provided for the required use.

• If responsible for monitoring, ensure staff undertaking monitoring are appropriately trained.



Contract cleaning – food contact equipment


• If cleaning occurs off-site, ensure food contact equipment is transported back to the production site in a hygienic manner and protected during transport to maintain cleanliness.

• Ensure staff undertaking cleaning are appropriately trained.



Contract cleaning – premises

• Ensure chemicals are approved for use in a food handling premises and provide evidence.

• Ensure cleaning equipment and chemicals are stored, applied and handled to prevent contamination of produce.

• Provide details of cleaning activities as requested including areas/items cleaned, cleaning agents and methods used and frequency of cleaning.

• Ensure staff undertaking cleaning are appropriately trained.

• Advise if you are aware that any products used contain or have been in contact with known allergens.


Contract labour

• Provide evidence of compliance to relevant statutory/regulative requirements for this type of business (i.e. Worksafe, superannuation, etc.).

• Ensure all workers have been trained in the food safety requirements of the Freshcare Food Safety & Quality Program.

• Maintain records of training and provide copies of records.





Fertilisers and soil additives

• Provide fertilisers and soil additives appropriate for the use required.

• Ensure packaging is intact and there is no leakage or possibility of contamination.

• Ensure fertiliser or soil additive is mixed to correct specifications and is of good quality, free flowing and dry (if solid).

• Ensure fertilisers and soil additives meet legal requirements for heavy metals.

• Advise if you are aware that products contain or have been in contact with known allergens.

• If entering site, abide by food safety instructions when handling produce or entering growing, storage and packing areas

Fertilisers and soil additives containing manures and/or food waste

• If sourced from suppliers:

o with an approved certified treatment process – provide evidence of certification to AS4454-2012

o that follow a documented, verified treatment process (AS4454-2012 or other equivalent time/temperature treatments) – details of the treatment process and a Certificate of Analysis for each batch of product supplied to verify the treatment process achieves E. coli <100 cfu/g, Salmonella Not Detected/25g.

• Ensure packaging (where applicable) is intact and there is no leakage or possibility of contamination.

• Ensure fertiliser is mixed to correct specifications and is of good quality.

• Advise if you are aware that products contain or have been in contact with known allergens.

• Records of time and temperature monitoring must be available if required.


Laboratory testing (Competent Laboratory)

• Hold NATA accreditation, or be accredited against ISO/IEC 17025, for the required scope of testing and provide evidence of accreditation. Or a laboratory run by a local, state or federal government authority or university, that follows Australian Standard methods for the required scope of testing. Records are available and show methods used against the testing conducted.


Packaging

• Ensure packaging is appropriate for use and made of substances that are non-toxic and are food grade, compliant with relevant statutory/regulative/customer requirements. This will require evidence in the form of a statement of compliance from the packaging manufacturer.

• Ensure packaging is clean and free of foreign objects and pest infestation prior to delivery.

• Advise if you are aware that any products used contain or have been in contact with known allergens.


Packing Services (co-packers)

• The packing business must also hold a current certification to the Freshcare Food Safety & Quality Standard, or alternate, approved GFSI benchmarked standard for the scope of services being provided. Evidence of current certification to be provided.

• Advise the business immediately if the certification is withdrawn or expires.




• Advise if you are aware the produce contains or has been in contact with known allergens.


Pest control

• Be appropriately licensed/certified and provide copies of credentials.

• Ensure all chemicals and baits supplied or recommended are approved for use, used in accordance with label instructions and not applied to the harvestable part of the crop.

• Ensure baits/traps are located and contained to minimise the risk of contaminating produce, packaging containers, materials and equipment.

• Provide a map of bait/trap locations.

• Provide written records of inspections, pest levels and action taken after each visit.


Planting material

• Ensure planting material containers/trays are free from physical contaminants.

• Provide healthy and disease-free planting materials.

• Provide seedlings of the age/growth stage and variety requested.

• Provide records demonstrating any treatment processes that may have been applied prior to delivery.

• If applicable, provide evidence of compliance to interstate requirements (e.g. Interstate Plant Health Certificates).

• Advise if you are aware that planting materials contain or have been in contact with known allergens.


Portable toilets

• Position portable toilets to minimise risk to produce and maximise accessibility.

• Regularly maintain and service portable toilets.

• Ensure portable toilets are designed to ensure hygienic removal of waste and minimise the risk of contaminating produce directly or indirectly through contamination of growing site or water sources.

• Ensure portable toilets are equipped with running water (meeting specified water limit E. coli <1cfu/100ml), liquid soap, disposable paper towels/hand dryers and waste disposal facilities. Where requested, alcohol based hand sanitiser may also be required.


Produce

• Provide evidence of current certification to Freshcare Food Safety & Quality Standard, or alternate, approved GFSI benchmarked standard, the scope of which covers the type of produce being supplied.

• Advise the business immediately if the certification is withdrawn or expires.

• Advise if you are aware the produce contains or has been in contact with known allergens.





Transport

• Evidence of current certification to a third party audited food safety standard for the scope of transport services being supplied.

• Ensure produce is not transported under conditions or with other goods that present a potential source of contamination.

• Check transport vehicles before use for cleanliness, foreign objects and pest infestation and, where necessary, clean to prevent contamination of produce.

• Check transport refrigeration systems prior to loading to ensure they are operating at specified temperatures. Maintain records to verify temperature during transit.

• Ensure that all vehicles used are free of / have not been in contact with known allergens (unless properly cleaned).


Water

• Ensure water quality supplied for use meets relevant specified limit (E. coli <100cfu/100ml, E. coli <1cfu/100ml) and evidence of compliance is provided (e.g. Certificates of Analysis, Water Quality Reports, Statements of Compliance).


Water – recycled/reclaimed

• Ensure water quality supplied for use meets the appropriate specifications as defined in the Australian Guidelines for Water Recycling and evidence of compliance is provided (e.g. Certificates of Analysis, Water Quality Reports, Statements of Compliance).


Factsheet – F12 Food defence and food fraud

FRESHCARE FOOD SAFETY & QUALITY EDITION 4.1 – FACTSHEET REF1906 F12 FOOD DEFENCE AND FOOD FRAUD – PAGE 1 OF 3


• Food defence

• Food fraud

• Risk assessments for control plans

For more information refer to the Guidelines for Fresh Produce Food Safety (2019) Chapter 8 Managing people, page 72.

Food defence

Agriculture is part of Australia’s critical infrastructure, but it is also potentially

vulnerable to threats that may impact both public health and the economic

position of the individual market and wider sector, both locally and

internationally, as well as causing reputation damage.

Definition: Food Defence – the efforts to prevent intentional contamination of

food products by biological, chemical, physical, or radiological agents that are not

reasonably likely to occur in the food supply chain.

What motivates intentional contamination?

• Terrorism – intent to kill as many people as possible.

• Economic – intentional (malicious) damage to an individual business to cause

economic harm; intentional damage to an individual business to impact

product value in the market; intentional damage to an individual business to

affect land utilisation/value.

• Issue Related – interest groups seeking to damage an industry.

• Extortion – criminal effort to obtain financial gain.

How is this relevant to the fresh produce sector and/or individual Freshcare

businesses?

If there is an ability, opportunity and desire to do harm, then the ‘risk’ is present.

Eliminating opportunity is the only realistic and practical way to address that risk.

Whilst it’s obviously impossible to secure the entire supply chain, understanding

potential risks and control measures is key to control.

Are there real examples of intentional contamination in the fresh produce

sector?

• In 1978, several children in Holland fell ill after eating Israeli Jaffa oranges

contaminated with mercury. The event was attributed to Palestinian

terrorists, seeking not to harm individuals, but to damage the Israeli

economy.

• In 2007, the alleged contamination of a water contractor’s tanker with

herbicide resulted in over $1 million worth of crop damage in Queensland.

Crops not directly lost to the herbicide damage were deemed unsaleable in

consideration of detectable levels of chemical residue.

• In 2018, Strawberries were removed from the retail markets across the nation

as a needle was found in a punnet. This resulted in a social media frenzy and a

host of “copycat” claims that resulted in significant impact to the industry.

What does an individual business need to do?

A food defence vulnerability assessment needs to be completed. Identifying

specific points where intentional contamination has the greatest potential to

cause economic and/or public health harm; and documenting the likelihood and

severity should it occur and then mechanisms for control to mitigate the risk to

public health. Mechanisms that are likely to include site access and security and,

team training and awareness.

At a minimum, your Food Defense Plan should address:

• processing/ product security

• storage security

• shipping and receiving security

• water and ice security

A form template has been provided to document the vulnerability assessment

and control plan, refer to Form – F12 Food defence vulnerability assessment and

control plan.



The food defence vulnerability assessment and control plan must be reviewed at

least annually by the business and amended where additional risks identified, or

changes occur in the business that impact the plan.

Food fraud

Food fraud is considered an increasingly important issue in the overall food

supply chain, impacting all sectors including fresh produce. Food fraud has the

potential to impact both public health and the economic position of an individual

business or wider industry sector, both locally and internationally.

Definition: Food Fraud - the deliberate and intentional substitution, addition,

tampering or misrepresentation of food, food ingredients or food packaging;

and/or the mislabelling of a product resulting in economic gain and/or impact to

public health.

What types of food fraud might be encountered?

Common types of food fraud include:

• Adulteration – the addition of substances to a food product, generally for

economic advantage, making it potentially unsafe or no longer fit for purpose.

• Substitution – the replacement of a food or food ingredient with an alternate

product, with an economic advantage and potential food safety implications.

• Misrepresentation or mislabelling of a product for economic gain, with

potential associated food safety risks.

How is this relevant to the fresh produce sector and/or individual Freshcare

businesses?

The opportunity for food fraud in the fresh produce sector is potentially very real,

in consideration of both business inputs and final product, both potentially

impacting on product integrity and safety. Whilst it is recognised that an

individual grower is unlikely to have the ability to control instances of food fraud

occurring further up the supply chain, there are several aspects of food fraud that

should be considered at farm level.

Are there real examples of food fraud in the fresh produce sector?

Several examples of food fraud are directly related to the fresh produce sector.

• The marketing of cherries in key export markets as ‘Australian Cherries’ in

counterfeit packaging, well outside the Australian season of supply. The

misrepresentation presenting an assurance of quality and food safety

compliance that is not real.

• A similar misrepresentation occurs if product from non-certified fresh

produce businesses is packed by a Freshcare certified business and

represented for sale as Freshcare certified. In this instance the customer has

an expectation of food safety compliance that may not be the case.

• The use of second hand packaging without completely obscuring the original

grower’s details presents a potential food fraud scenario. Product presented

to the marketplace as the original grower may provide direct commercial

advantage for the second grower, it may also present an assurance of food

safety compliance which may not be correct.

• The supply of counterfeit (copy) agricultural chemicals can also be considered

as food fraud. This key input into most fresh produce businesses, can

introduce significant business risk if counterfeit chemicals are used

(efficacy/crop impact) and has the potential to directly impact food safety and

human health.

What does an individual business need to do?

A food fraud vulnerability assessment needs to be completed, identifying a

business’s food fraud vulnerabilities that have the potential to cause economic

and/or public health harm; and documenting the likelihood and severity should it

occur and documenting the mechanisms for control to mitigate the risk to public

health. Mechanisms for control are likely to include supplier management

(business inputs and fresh produce), product identification and traceability (raw

material and finished product) and team training.



A form template has been provided to document the vulnerability assessment

and control plan, refer to Form – F12 Food fraud vulnerability assessment and

control plan. The food fraud vulnerability assessment and control plan must be

reviewed at least annually by the business and amended where additional risks

identified, or changes occur in the business that impact the plan.

Risk assessment for control plans

When developing your food defence and food fraud vulnerability assessment and control plans undertake a risk assessment utilising the significance matrix below to help you identify the significance of the threat and establish control measures to manage and mitigate potential risks.

Significance matrix

Severity Likelihood

Consumer Business

1. Fatality 1. Closure of Business A. Common

occurrence

2. Serious sickness/ Hospitalisation

2. Major Financial loss B. Known to occur

3. Product recall/ Minor Harm

3. Minor Financial Loss C. Could occur

4. Customer complaint/ Repulsion or Disgust

4. Disruption to Normal Operations

D. Not expected to occur

5. Not significant 5. Not significant E. Practically

impossible

Likelihood

Severity A B C D E

1 High High High Medium Medium

2 High High Medium Medium Low

3 High Medium Medium Low Low

4 Medium Medium Low Low Low

5 Low Low Low Low Low

Factsheet – F13 Product identification and traceability

FRESHCARE FOOD SAFETY & QUALITY EDITION 4.1 – FACTSHEET REF1906 F13 PRODUCT IDENTIFICATION AND TRACEBILITY – PAGE 1 OF 2


• Product identification and traceability

• Product Release

For more information refer to the Guidelines for Fresh Produce Food Safety (2019) Chapter 17 Product identification, traceability and recall, page 84.

Product identification and traceability

One of the most important parts of a food safety and quality system is the ability

to trace produce ‘one step up and one step back’. When all members of the

supply chain, from paddock to plate, have strong identification and traceability

systems, unsafe or unsuitable produce can be easily identified and removed from

sale.

Identification and traceability relies on having ‘batches’. A batch needs to be a

manageable quantity of produce (i.e. tracing fruit to the particular tree is not

likely to be an effective way to run a commercial orchard) and should relate to

the inputs or treatments applied. A paddock may be a good batch if it includes

only one type of produce and the same chemicals and fertilisers are applied

across the paddock.

If batches are too large, the business risks having to recall more produce in the

event of a significant problem occurring. If batches are too small, the business

can spend more time recording traceability details than is necessary. Ultimately

the batch size relates to risk and the level of risk a business is prepared to take.

Growing produce

The location of separate growing sites/areas must be identified on a property

map to enable traceability to where the produce is grown. Identification used to

distinguish separate growing sites/areas should be documented on all records

used for the production of the crop.

Harvested produce

For harvested produce, the batch identification should be linked to harvest date

and destination, and where on the farm the produce was grown. This

information can be recorded in a diary, a harvest record, or on a delivery docket.

One way of doing this is to number the container or trailer and record the

number on the delivery docket along with harvest date, destination and growing

area identification.

Cross referencing the harvest date and growing area identification to farm

records, allows for traceability of each batch of produce during production.

Packed produce

For packed produce, a batch can be all the produce packed on the same day and

treated the same before and after harvest. The batch can be identified by

marking the packed container with business name and packing date or other

coding.

It is recommended to mark each package, as traceability can be lost when

packages are removed from pallet loads. Depending on the destination of the

packed produce, there are legislative and customer specific requirements

regarding identification and labelling.

Some common batch identification codes used include consignment note

number, pallet number, random number, or a date code. Examples of codes for a

packing date of the 1 July 2016 are:

• 010716

• 160701 (first and last 2 numbers reversed)

• 071601 (day of the month last)

• 182 (the 182nd day of the year).

The packing date or batch identification code (if used) must be linked to the

growing area and destination. This information can be recorded in a diary,

packing record, delivery advice, or consignment note.

Factsheet – F13 Product identification and traceability

FRESHCARE FOOD SAFETY & QUALITY EDITION 4.1 – FACTSHEET REF1906 F13 PRODUCT IDENTIFICATION AND TRACEBILITY – PAGE 2 OF 2

If produce packed on the same day comes from different growing areas that have

been treated differently, marking the growing area identification on the package

will help traceability.

Cross-referencing the packing date, growing area identification and harvest date

to farm and packing records allows the chemical treatment(s) of each batch

before and after harvest to be identified. For example, chemicals applied to the

produce will be recorded in the spray record and postharvest chemical record.

Sourced produce

Product and traceability records must also be maintained for all product sourced

from suppliers. This includes packing product from another business, or providing

other services such as packing, product sorting, grading etc. for other businesses.

Product Release

Checking product that is ready for dispatch is essential to prevent sending non-

conforming product into the supply chain. Having the right processes in place at

dispatch can prevent product being rejected by your customers or pick up an

issue that could result in a food safety incident.

Your business should have a documented procedure in place that includes an

assessment of product before it leaves. The product release procedure is to

ensure all in-process and finished product controls relating to product safety,

quality, regulatory and customer requirements have been completed and product

compliance verified prior to product dispatch.

Where a customer has provided a written specification, produce should be

assessed and checked to confirm that the product and handling specifications

have been achieved. If produce does not meet the written specification, the

customer (processor, retailer, exporter) should be informed before dispatch, refer

to variations for further guidance.

It is also essential that any product that has been identified as non-conforming is

clearly labelled and segregated to prevent accidental use. A corrective action

record should be generated to investigate the cause of the failure and put steps in

place to prevent it from happening again.

Businesses should be on the lookout for the following when checking product

• Is it labelled correctly?

• Is it traceable?

• Has it been packed according to customer requirements?

• Is it at the right temperature or had the correct treatment applied?

• Is there any evidence of contamination?

• If it is being sold by weight, does it meet the requirements?

Factsheet – F14 Incident Management, Recall and Withdrawal.

FRESHCARE FOOD SAFETY & QUALITY EDITION 4.1 – FACTSHEET REF1906 F14 INCIDENT, RECALL, WITHDRAWAL – PAGE 1 OF 3


• Incident Management (Business continuity) (Crisis Management)

• Incident management plan

• Responding to an incident

• Recall and withdrawal

• Conducting a recall

• Trade level recall

• Consumer level recall

External Resources:

Department of Industry, Innovation and Science – Business: The continuity plan section www.business.gov.au

Guidelines for Fresh Produce Food Safety (2019) Chapter 17 Product identification, traceability and recall, page 84.

Incident Management

With food safety-related recalls becoming more commonplace, it is essential for

businesses to understand and implement processes that will help manage these

events in the most transparent and effective ways possible. How your business

chooses to function in the middle of a crisis, especially during the early stages

when communication is most critical, will undoubtedly affect your entire business

going forward.

Proper planning and preparation by your business is key to avoid and reduce the

risks associated with events or incidents that could result in major disruptions to

operations; and preparing a plan to ensure services to customers can continue.

Incident management planning will help detail the steps to be taken before,

during and after an incident or event to maintain the financial viability of the

business. It helps you to anticipate, prevent or prepare for disruptions such

as fire, flood or storms, transport issues, computer or system crashes, or illness,

product contamination (micro, allergens, chemical residues) and supply chain

interruptions, and how to respond and recover from them.

Preparing effectively for incident management makes your business more likely to

survive an emergency or critical disruption.

Incident management plan

An incident management plan should be developed in consideration to identify

ways to:

• reduce the likelihood of an incident occurring

• ensure product food safety and quality is not compromised

• respond to, and recover from, an incident.

• ensure all communications from your business

The Freshcare Food Safety & Quality Standard requires an incident management

plan to be documented and identify:

• potential risks to business continuity, and should consider different sources of

information

• strategies and practices to manage the identified risks

• a list of workers responsible for incident management

• details of internal contacts that need to be contacted in the event of an

incident

• external stakeholder contacts that need to be contacted in the event of an

incident or to get help to manage an incident

• name of the person developing and documenting the plan

• date the plan was developed.

A test of the incident management plan must be conducted at least annually with a record kept. The incident management plan should be tested using different incidents/scenarios each time to aid in identifying any updates that may be required of the plan.



Responding to an incident

When responding to an incident, the critical aspect for any fresh produce supply

chain business is ensuring that product food safety and quality has not been

compromised.

When an incident occurs, the incident management plan must be followed to

ensure:

• product safety and quality are not compromised

• affected product is identified and isolated (placed on hold)

• compliance with food safety and quality requirements is verified, prior to

product release.

If an incident has occurred requiring the incident management plan to be

actioned, a record of protocols undertaken must be kept.

Following an incident, a review of the event and incident management plan

should be undertaken by workers responsible for incident management and the

management of the business. A record of the review and any updates to the plan

must also be documented.

Recall and withdrawal

Product recall

A product recall is defined as an action taken to remove from distribution, sale

and consumption, food which may pose a health and safety risk to consumers.

A recall may arise from:

• internal reviewing of records e.g. spray records show incorrect rate applied

• adverse test results e.g. residue test results show MRL exceeded

• customer complaint/feedback

• notification of a problem from a raw material supplier (such as a chemical

manufacturer or seed supplier)

• government authorities such as local government or Food Standards Australia

New Zealand (FSANZ) indicating there is an issue with a product.

More information on product recalls can be sourced from Food Standards

Australia and New Zealand (FSANZ) by visiting the food recall section of the FSANZ

website: www.foodstandards.gov.au/industry/foodrecalls.

Product withdrawal

A product may be withdrawn from sale for two reasons:

• the product has a quality defect (e.g. colour or texture); is underweight or has

labelling irregularities that do not pose a potential risk to public health and

safety

• as a precaution, produce may be withdrawn from distribution and/or sale

pending further investigation — if a risk to public health and safety is

established, the product must be recalled.

Withdrawals do not require notification to statutory authorities or media.

Conducting a recall

If a batch of produce has been identified as being contaminated or potentially

contaminated, you need to carry out a product recall as a corrective action. This

involves using your product identification and traceability system to:

• identify where produce from the same batch has been sent and notify your

customers to remove it from sale

• trace affected produce using records to identify the cause of the

contamination and prevent it from occurring again.

It is recommended that the Food Standards Australian New Zealand (FSANZ) Food

Industry Recall Protocol booklet be used as a reference when conducting any

recalls. This booklet as well as other resources on conducting a food recall can be

found on the FSANZ website: www.foodstandards.gov.au/industry/foodrecalls.

There are two levels of recall: trade level recall and consumer level recall.

http://www.foodstandards.gov.au/industry/foodrecalls

http://www.foodstandards.gov.au/industry/foodrecalls



Trade level recall

A Trade level recall involves recovery of the produce from businesses in the

supply chain that are not controlled by the primary supplier of the produce (i.e.

grower or packer). It does not involve recovery of produce from consumers.

When conducting a Trade level recall, as much information as possible is obtained

on the batch or batches of produce that may be affected, the source of the

produce, and the cause of the problem. Information is then recorded on the

Trade level recall form (refer to Form – F14 Trade level recall template).

Consumer level recall

A Consumer level recall involves recovery of the produce from consumers and

businesses in the supply chain.

A determination must be made on whether the situation requires a recall (carried

out if there is a food safety or potential food safety risk to consumers) or a

withdrawal (carried if there is a quality defect or regulatory breach). Withdrawals

are managed using a corrective action record.

As much information as possible must be obtained on the batch or batches of

produce that may be affected, the source of the produce, and the cause of the

problem. Information is recorded on the A&NZ Product Recall/Withdrawal form.

If produce is supplied to the consumer level, a ‘mock’ recall is completed

annually, using the A&NZ Product Recall/Withdrawal form. It is not necessary to

notify customers of the mock recall. A record of this activity should be kept as

part of your Freshcare Food Safety & Quality Program records.

Updated copies of the A&NZ Product Recall/Withdrawal form can be found on

the Australian Food and Grocery Council website: www.afgc.org.au/publications.

http://www.afgc.org.au/publications