ISFR meeting outcome – 8 to 9 September 2021

Summary of key discussions and outcomes from the Implementation Subcommittee for Food Regulation (ISFR) meeting held on 8 to 9 September 2021.

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 face-to-face meetings (and/or virtual videoconferencing where required), 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 ISFR20

ISFR20 was held via videoconference on 8-9 September 2021. A summary of key items of interest is provided.


The Food Standards Australia New Zealand website (FSANZ website) continues to be used as the central COVID-19 communications hub for food regulation matters. Technical and communications experts, drawn from the Food Regulation System membership, contribute to identifying and developing advice to stakeholders on matters relating to food and COVID‑19. The website acts as a gateway to more specific information available from the Australian and New Zealand Governments and state and territory websites.

Australia’s foodborne illness reduction strategy

While jurisdictional capacity is currently 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 taking into account that some activities (including stakeholder consultation processes) will need to proceed at a slower pace. There remains a strong desire across the Food Regulation System to continue implementing a coordinated approach to reducing foodborne illness nationally, particularly related to Salmonella and Campylobacter. The focus will be on food safety within the most relevant parts of the food supply chain.

Local government activities and jurisdiction reports

Key matters which may be of interest to local government:

Australian Capital Territory (ACT)

Routine food safety inspections have focused on high-risk food businesses and market events. Compliance in these areas was positive given the duration of restricted engagement due to COVID-19. The 2020/21 Ready to Eat Food “End of Day Sale” survey has been completed and the survey report is being finalised. The 2021/22 sampling survey has been placed on hold, due to recent COVID-19 response priorities, however, it will commence at a later date with prewashed and prepacked leafy lettuce. Regulatory and policy resources are currently focused on ACT COVID-19 response, and lockdown is restricting routine food safety inspections and programs.

New South Wales (NSW)

As reported in the last reporting period, NSW is developing an Authorised Officer (Local Government) Food Surveillance course. The program will provide training on the regulatory framework, inspecting food businesses, enforcement, food handling practices, cleaning and sanitising, sampling, investigations and Australia New Zealand Food Standards Code requirements. NSW anticipates the program will be implemented from 1 July 2022.

NSW recently completed a stakeholder engagement survey with local council Environmental Health Officers (EHOs). The feedback has provided an opportunity to recalibrate the services NSW gives to local government under the Food Regulation Partnership.

NSW is working with local councils to better understand the retail food deliver-only sector. COVID-19 has seen a growth in businesses adapting to operating restrictions and local councils have expressed concerns about their ability to capture low-visibility operators in their food surveillance programs. The intent is to develop and roll out a voluntary survey for interested councils to research and ultimately capture delivery-only food businesses in their local government areas. This work is intended to be rolled out later in 2021.

New risk matrix guidelines, ‘Contact risk assessment for community and workplace settings’, which covers food businesses, have been developed and are available at: NSW Health Contact risk assessment.

South Australia

COVID-19 compliance activities

Local Government EHOs’ skills are being utilised to assist with monitoring COVID-19 compliance requirements. These activities are being monitored during routine food inspections and food safety audits.

Foodborne illness incidents

In April and May 2021, a Salmonella Typhimurium outbreak (16 confirmed outbreak cases) and cluster (9 cases) were investigated. The outbreak was linked to the consumption of egg products in a bakery. Local Government EHOs identified issues at the bakery around egg handling, cleaning and sanitation and inadequate skills and knowledge of food handlers. An educative approach was taken with the business, and no additional cases of illness were reported. Cluster cases mentioned consuming runny eggs in the two days prior to symptom onset. Trace back of the eggs from implicated food businesses identified a common link to an egg producer. Primary Industries and Regions (PIRSA) were made aware of the situation and are working with the farm to try and identify a possible root cause. Local Government EHOs identified poor handling of eggs at some of the implicated businesses and are working with the businesses to improve their skills and knowledge around handling eggs.

Feasibility investigation into a shared electronic platform for food businesses

A project, through the SA Health and Local Government Association working group, has been established to investigate the feasibility of a shared electronic platform for food business notification, and data collection, to manage food business notifications/licensing provisions; data to capture Food Safety Rating Scheme outcomes, enforcement actions and other Food Act reporting data; and food auditing data. A survey with Local Government was conducted to seek support about the possibility of a shared electronic platform. Thirty one (31) out of 64 councils responded (including a regional subsidiary which represents 5 councils, 9 metropolitan, 25 regional councils). Over 60% of councils are still conducting inspections using a paper-based system. The vast majority of councils (93%) responded that they would be interested in using a shared electronic platform with over 60% of respondents noting preference for a system that can integrate with existing council systems (such as property information).

Draft Tourism Regulation Review – impact on local government

The South Australian Productivity Commission (SAPC) has publicly released a draft report on tourism regulation on 6 August 2021. Draft Recommendation 8.7 is specific to SA Health, that the remit of the SA Health food safety regulation function be expanded to:

  • build on the regulatory capability of local government, with specific attention to environmental health officers, by providing on-going professional development advice and support;
  • establish a central and independent process for receiving feedback on, and reviewing, the enforcement of food safety regulations by local government, and responding to complaints from businesses; and
  • provide advice to local government on improving their regulatory practice arising from analysis of the feedback.


The Department of Health Food Pantry website is now live. This initiative provides a simple and user-friendly way for food businesses and consumers to find information about general food safety, legislative, licensing and training requirements. It contains several new interactive online tools to assist food businesses and contains links to free training.


Work to progress a minor amendment to section 133 of the Food Act 2003 has nearly been completed with the amendment now having passed both houses of parliament in Tasmania. The amendment will enable the rollout of the mobile food businesses database which has been developed to support and simplify the regulation of mobile food businesses in Tasmania.


The Moodle™ training program, for council Food Act Authorised Officers to undertake risk based food safety assessments, is now live, with access in Victoria via the Public Health Hub.

A survey of Victorian councils was undertaken in July 2021 seeking qualitative information as to whether ‘lockdowns’ had had an impact on compliance issues with food businesses. The survey revealed that:

  • Businesses are trying to pivot in order to stay afloat from the pandemic conditions which has led to introducing new processes/products (takeaway);
  • Food handlers not washing hands but using sanitiser instead. This was due to hand-wash basins being found to be inaccessible and not having a supply of soap and paper towel;
  • The focus on ‘COVID cleaning’ has been for customer area;
  • Proprietors of food businesses are confusing COVID-safe cleaning for general cleaning practices in their food handling area; and
  • There has been a significant growth in unregistered (or registration status being unknown) home-based business who are selling takeaway food online. Many of these businesses are difficult to track down as they are posted on multicultural websites, such as Tiffin and WeChat, and not using the more mainstream platforms (such as UberEats) for delivery.

The Department of Health (Victoria) intends to follow up with councils as to how it can assist councils improve compliance for these issues.

Northern Territory

Amendments to the Food Act were passed on 12 August 2021, through the omnibus Statute Law Revision Bill. The amendments cover two areas:

  • Introduce a 30-day time frame for processing of a food business registration; and
  • Allowing for the appointment of an organisation as well as an individual as an analyst.

Western Australia

The Play it Food Safe campaign is an ongoing campaign and local governments are encouraged to participate and utilise the campaign materials available from the Department of Health website.

Information concerning the updated regulatory food safety audit arrangements and revised food webpages has been provided to local government for consideration and action where necessary.

New Zealand

The Food Act 2014 Co-regulatory Priorities Panel (the Panel), formed in 2018, promotes development of a collaborative and consistent working relationship among co-regulators. This is a key task for the implementation of the Food Act’s co-regulatory model.

Membership of the Panel is made up of regulatory managers from Ministry for Primary Industries (MPI), and Territorial Authorities , plus an independent chairperson. The Panel uses national data across the Food Act system to recommend priorities to the MPI governance group. The Panel is also responsible for defining an actionable pathway to address these priorities. The Panel meets quarterly.

Since its formation, the Panel has identified and agreed on the first set of priorities and developed an action plan to address these priorities. The first priorities will focus on: ensuring verification and enforcement data is reported accurately; assessment of the mandatory verification topics; and ensuring the right balance is struck between verifying records and verifying food safety behaviour.


FSANZ reported it continues to support the Food Regulation System priorities through its work on data sharing and data analytics; Proposals P1052 – Primary Production and Processing Standard for Horticulture and P1053 – Food Safety Management; the review of the Egg Primary Production and Processing Standard; Health Star Rating system, Branded Food Database, as well as its work on FSANZ modernisation.

FSANZ also reported on its continuing work on Health Claims, and updates to the COVID-19 information hub on the FSANZ website.

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