Does Standard 3.2.2A apply to food manufacturers?
Short answer: generally no. But there are exceptions, and manufacturers still have record-keeping obligations of their own. Here’s how to tell where you stand.
4 min read
Standard 3.2.2A applies to food service, catering and retail businesses that handle unpackaged, potentially hazardous, ready-to-eat food. It has applied since December 2023. In Victoria, the Department of Health lists manufacturers in every premises class as not captured by the standard. If your site also runs food service or retail, such as an on-site café or a factory shop selling unpackaged ready-to-eat food, that part of your business may be covered. Check with your council.
What Standard 3.2.2A requires, and of whom
It sorts businesses into two categories. Each category needs a different set of the three “food safety management tools”.
| Category | Who it covers | Food safety supervisor | Food handler training | Records to show key controls |
|---|---|---|---|---|
| Category one | Caterers and food service businesses that make unpackaged potentially hazardous food ready to eat and serve it to consumers | Yes | Yes | Yes |
| Category two | Retailers selling unpackaged potentially hazardous ready-to-eat food not made on site (apart from slicing, weighing, repacking, reheating or hot-holding) | Yes | Yes | No |
| Manufacturers | Businesses making food for sale to other businesses or packaged for retail | Not captured by Standard 3.2.2A in Victoria. Covered by the Food Act, Standard 3.2.2 and their food safety program instead. | ||
Sources: FSANZ overview of the food safety management tools; Victorian Department of Health on Standard 3.2.2A. Other states apply the standard through their own laws, so check with your state regulator if you operate outside Victoria.
When a manufacturer might be caught
The exemption covers manufacturing. It doesn’t automatically cover everything else you do on the same site. Ask your council about any of these:
- An on-site café, canteen open to the public, or tasting kitchen serving food you prepare ready to eat.
- A factory shop or market stall selling unpackaged potentially hazardous food that’s ready to eat.
- A catering arm that delivers prepared meals to events or customers.
If one of these applies, the standard may apply to that activity, with a food safety supervisor, trained food handlers and, for category one, records showing your key controls.
What manufacturers still have to do
Being outside Standard 3.2.2A doesn’t mean fewer records. In Victoria, most manufacturers are Class 2 premises, which brings its own obligations:
An independent food safety program
Class 2 manufacturers need their own (non-standard) food safety program, rather than a council template.
Audits by an approved auditor
That program must be audited by a food safety auditor approved by the Department of Health.
A food safety supervisor
Class 2 premises must nominate a food safety supervisor, whatever Standard 3.2.2A says.
Standard 3.2.2 and recall
Food safety practices, plus a recall system for businesses that manufacture, wholesale or import food.
Sources: Class 2 fact sheet (Department of Health, via Ararat Rural City Council); Bass Coast Shire on food business classes. Dairy, meat, poultry and seafood businesses are licensed by Safe Food Victoria instead of council. General guidance only, not legal advice.
The records your program needs, either way
Whether you’re Class 2 under the Food Act, working toward a GFSI scheme, or running a café alongside production, the evidence looks similar: temperature and CCP checks, supplier records, cleaning, training and corrective actions. EthicalHub keeps it in one place, so your audit pack is ready whichever auditor walks in.
Check your obligations in practice
The free assessment shows which records an auditor or EHO would question.
Standard 3.2.2A: common questions
Does Standard 3.2.2A apply to food manufacturers?
When did Standard 3.2.2A start?
What is the difference between category one and category two?
Do Victorian manufacturers need a food safety supervisor?
Know your obligations, then prove them.
See which records you’d be asked for, and how quickly you could show them.