ISFR meeting outcome – 19 August 2020

Summary of key discussions and outcomes from the Implementation Subcommittee for Food Regulation (ISFR) meeting held on 19 August 2020.

Food regulation authorities in Australia and New Zealand work together to ensure food regulations are implemented and enforced consistently. This work is done through the Implementation Subcommittee for Food Regulation (ISFR), through in-session meetings, out-of-session business and separate collaborations. ISFR was set up by the Food Regulation Standing Committee (FRSC) to foster a consistent approach across jurisdictions to implementing, monitoring and enforcing food regulation. ISFR’s role applies equally to imported, exported and domestically produced food.

ISFR members are either heads of agencies or senior operational experts who can make and implement decisions about compliance and enforcement issues in their jurisdictions.

ISFR is not an enforcement authority in its own right. It allows Australian and New Zealand food regulators to discuss common approaches to implementation and develop agreed strategies to achieve a consistent approach to the way food regulations are implemented, interpreted and enforced across jurisdictions.

While all jurisdictions involved in food regulation work together on implementing and enforcing food regulation, there are sometimes differences in the way jurisdictions administer food law. Due to ISFR’s consultative nature, it helps jurisdictions to minimise the impact of these differences as much as possible.

Summary of key matters of interest to local government discussed at ISFR18

ISFR18 was held via videoconference on 19 August 2020. A summary of key items of interest is provided.


ISFR continues to assist FRSC to provide stakeholders with coordinated and consistent information regarding COVID-19 in the context of food safety and food business operations. The Food Standards Australia New Zealand website (FSANZ website) is being used as the central COVID-19 communications hub for food regulation matters. The website acts as a gateway to more specific information available from the Australian and New Zealand Governments and state and territory websites.

Food regulators including local government environmental health officers (EHOs) have been contributing to the COVID-19 pandemic response. ISFR members acknowledged the skillset of food regulators, and ability to adapt and respond to the pandemic.

Australia’s foodborne illness reduction strategy

  • While jurisdictional capacity is reduced due to the COVID-19 pandemic, key areas of work to implement the Strategy continue to be progressed. Where necessary timelines are being revised to take into account that some activities (including stakeholder consultation processes) will need to proceed at a slower pace.
  • Key recent achievements include:
    • The Data Sharing Working Group has completed its work to lay the groundwork for progressing data sharing within the Food Regulation System. A framework and principles to guide data sharing have been developed. Regular OzFoodNet reports are now being produced, providing a summary of trend data associated with foodborne illness to support the Strategy. Proposed next steps are to establish a mechanism to continue the collation of data and focus on data analysis to enrich and integrate knowledge.
    • The Food Safety Management Implementation Working Group and Horticulture Implementation Working Group are progressing work using the Integrated Model for Standards Development to support two FSANZ proposals:
      • Proposal P1053 – Food Safety Management tools, which relates to the general food service and closely related retail sectors; and
      • Proposal P1052 – Primary Production and Processing Requirements for High-risk Horticulture.
        The project plans have been aligned with FSANZ processes and timelines and will take into account that some sectors are heavily impacted by COVID-19.
  • ISFR considered the revisions to the national compliance plan for Primary Production and Processing Standard for Eggs and Egg Products (Standard 4.2.5 of the Australia New Zealand Food Standards Code) in line with current best‑practice and recognising the emerging risk of locally acquired Salmonella Enteritidis (SE) in the domestic egg supply. Revisions are nearing completion and stakeholders will be given an opportunity to provide input.
  • Stakeholder Engagement activities across all aspects of the Strategy will continue to be managed via the Priority 1 action leads group. The timing of consultations will need to be managed carefully with COVID-19 impacts on industry.

Local government activities and jurisdiction reports

Jurisdictions reported the following information and challenges as a result of the COVID-19 pandemic:

  • Jurisdictions are responding to the fast paced, rapidly changing space of COVID-19 including supporting Chief Health Officers, other state/territory government agencies, local governments and industry in the implementation, monitoring and enforcement of public health directives issued to help keep everyone in the community COVID-19 safe; engaging with the food businesses around COVID-19 safe measures; patron contact tracing and franchise agreements; and responsibilities around contact tracing and COVID-19 safe measures.
  • Jurisdictions have prepared guidance to ensure adequate COVID-19 safety procedures are in place to protect local government EHOs during food business inspections and developed COVID-19 contact tracing toolkits. Some jurisdictions are working through the challenges of remote EHO inspections and consequently have developed remote auditing guidance. Jurisdictions are also assisting local governments understand the additional cleaning and sanitation practices required from retail food businesses to trade in a COVID-19 safe manner. This is a constantly evolving space requiring frequent dialogue.
  • In the current COVID-19 environment, more food businesses are being established including many commencing operations in the home environment. Some of these food businesses operating out of the home are not aware of their food regulatory requirements, and require assistance from regulatory authorities to help them understand their food safety obligations. Jurisdictions and local government EHOs are working with these food businesses to help address critical knowledge and skills gaps.

Other key matters which may be of interest to local government:

New South Wales (NSW)

  • Adapting to COVID-19 restrictions, the NSW Food Authority has moved its engagement with local government to online platforms. This has included, so far, NSW Food Authority scheduling a regional food group meeting, authorised officer training, professional development, and COVID-19 Safety Plan sessions. Attendance remains strong.
  • The Food Regulation Partnership Retail Campylobacter Reduction Strategy has been completed. The survey involved 22 local councils, 169 retail food premises, 281 food samples and taking 593 environmental swabs. Only 1% of food samples taken had Campylobacter. The results also found strong food handling practices, but also identified room for improvement among food handlers in areas such as adequate sanitiser use, temperature control of higher risk foods, and poor handler skills and knowledge. Whilst a final report has been completed for authorised officers, a public facing summary version is pending.


  • Queensland Health is continuing with the development of a small business regulatory reform initiative to create a digital food safety hub, known as the Food Pantry. The project has now moved into the development phase for the agreed online resources which includes a tool to help small to medium businesses create a food label and a self-assessment checklist for businesses to ascertain compliance with the Food Safety Sta The resources are expected to be released in early 2021.


  • Guidelines for the Safe Manufacture of Smoked Fish: Focus on Listeria Management have been developed in consultation with industry to provide businesses and auditors with risk-based tools for Listeria management that have clear, scientific underpinning. The implementation of these tools is supported via provisions for accreditation and approved food safety programs in the Primary Produce Safety Act 2011 and Primary Produce Safety (Seafood) Regulations 2014. To support the requirement for accreditation, ‘smoked and preserved fish’ has been determined by the Chief Inspector of Primary Produce Safety to be ‘regulated fish’.
  • A biosecurity advisory has been issued to Tasmanian poultry and egg producers in response to interstate outbreaks of Highly Pathogenic Avian Influenza and SE. A questionnaire associated with the advisory has been prepared seeking information from producers about their purchasing of day old chicks and point of lay birds, spent hens, importation of eggs from interstate producers and SE monitoring.
  • Following an issue with the detection of elevated patulin levels in apple juice, leading to the recall of some apple juice products, the Tasmanian Department of Health has been reviewing the patulin management systems of all juice manufacturers in Tasmania. Departmental officers have been working with local government EHOs to raise awareness in small manufacturing and wholesale food business about the need to have effective recall management systems.
  • A minor amendment to the Food Act 2003 (Tasmania) is currently being progressed. This will alter the ‘disclosure of information provisions’ and better align the Tasmanian provisions to those used in other states. The amendments to the Food Act 2003 will enable the recently developed information system (accessible by local government EHOs) for the management of mobile food businesses to be rolled out across the state.


  • In mid-September 2020 Victoria is expecting to go to market for FoodTrader, an online food premises registration/notification and compliance system that all councils can choose to use to manage their regulatory requirements under the Victorian Food Act 1984.
  • In addition, a food safety risk management policy is being finalised which councils can choose to customise. It is expected to be launched in late September.

Western Australia

  • Assessments and audits of food businesses have returned to pre COVID-19 levels and arrangements.


  • On 31 July 2020, the Australia New Zealand Food Standards Code was amended to include new requirements for pregnancy warning labels on packaged alcoholic beverages as a result of Proposal P1050 – Pregnancy warning labels on alcoholic beverage Businesses have three years from 31 July 2020 to implement these requirements. FSANZ will be providing public health groups, consumers and industry with information about the labelling requirements. To assist businesses with the pregnancy warning label requirements, FSANZ has prepared a document that is available on the FSANZ website, outlining the design elements of the label and containing downloadable labels.
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  • Food regulation system