FAO/WHO Global Forum of Food Safety Regulators
Marrakesh, Morocco, 28-30 January 2002
The Development and Implementation
of the New Australian Food Safety Standards1
General Manager, Food Safety, Legal and Evaluation
Australia New Zealand Food Authority
INTRODUCTION - HOW FOOD IS REGULATED IN AUSTRALIA
Australia is a federation, and the separate State public health systems in Australia were developed prior to the formation of the federal government in 1901. The federal government steadily increased its power and influence over most areas of human activity in Australia through the course of the 20th century, not least because of the financial powers granted to it as an emergency measure in World War Two. By 2001 the federal government had become the source of funding for most public health activities in Australia, but most of the administration of public health activities in Australia continues to be carried out by the six State, two Territory and numerous local government authorities.
Until 1990 food regulation was a combination of State and Territory activity and the work of a small national advisory committee that made recommendations on food standards. The committee did not consider food safety issues2. As a result major differences arose between the States and Territories. This cumbersome state of affairs could not continue, and in 1991 a national body, the National Food Authority (NFA), came into existence. It was a statutory authority established to, amongst other things, prepare food standards, co-ordinate surveillance of the food supply and advise the Australian Quarantine and Inspection Service on imported food issues. It reported to a ministerial council, the Food Standards Council, which had the ultimate say over the content of food standards.
Australia and New Zealand have two of the most closely integrated economies in the world, so it came as no surprise that in 1996 the NFA was recast as the Australia New Zealand Food Authority (ANZFA). ANZFA is the only bi-national food regulator in existence, with two offices: one in Canberra and a smaller office in Wellington. It currently has approximately 130 staff, most of whom have a scientific or technical background, including microbiology, food technology, chemistry, genetics, toxicology and law. The ministerial council was recast as the Australia New Zealand Food Standards Council (ANZFSC), consisting of the Australian and New Zealand Ministers for Health, the 6 State and 2 Territory Ministers for Health. Under the terms of the treaty with New Zealand on joint food standards, issues of food safety were specifically excluded, and New Zealand and Australia continue to have separate food safety systems. The model of food regulation outlined in this paper applied throughout the 1990s, and it is worth noting that it is now in the process of change, however those changes are outside of the scope of this paper3.
It is necessary to note that the model I have described above is only that of a policy and standard-setting framework. Administration of food safety, and in particular inspection of food businesses, is carried out by environmental health officers employed by either a State or Territory or one of the 700 local government bodies. ANZFA consults with relevant State and Territory officials through a Senior Food Officers (SFOs) forum, and at a higher policy level with the Australia New Zealand Food Authority Advisory Committee (ANZFAAC). They can be distinguished by remembering that SFOs know what is happening on the street, and ANZFAAC members know what is happening in the Minister's office. Having the support of both groups has been critical to the successful passage of the food safety reform package.
THE PROBLEMS WITH THE EXISTING LEGISLATION
The rest of the Food Standards Code, which covers composition and labelling of food, additives and contaminants, residue levels and some microbiological standards, applies uniformly across Australian food businesses. It appeared illogical that requirements for food safety were not also uniform.
The existing State and Territory laws also created difficulties. Some of the legislation reflected recent developments in regulatory policy, however this was not true for all legislation, the oldest of which dated back to 1928, with its attendant redundancies - for example, one jurisdiction required every place where food was handled to have a manure receptacle for the daily deposit of animal droppings and stable cleanings4. The legislation could be extremely prescriptive, for example one jurisdiction had a requirement that window sills had to be at least 300 millimetres above any bench on which food was handled5. This type of legislation tended to focus on process, rather than on the desired outcome, namely a safe food business.
Australia has in the past ten years embraced the concept of `minimum effective regulation' and the area of food safety has not been immune from the trend.
ANZFA was aware that Australian legislation lagged behind that of our trading partners, and did not reflect modern food regulation, particularly in the emphasis on HACCP. In addition, there has been growing awareness of the importance of the `paddock - to - plate' approach to managing food safety, which means managing the whole of the food chain: first class handling and processing requirements are of little use where material with a high pathogenic load enters the food chain. In part for this reason, and as part of the changes to the food regulatory changes mentioned elsewhere, all Australian governments decided in 2000 that ANZFA will assume responsibility for food standards in the area of primary production, with the object of achieving an integrated regulatory approach.
Finally, and of greatest importance, has been the need to reduce the incidence of foodborne illness in Australia. Figures on the level of foodborne illness are notoriously imprecise, due to widespread under-reporting, however ANZFA has estimated that there are approximately 4,000,000 cases of foodborne illness every year in Australia, or one case for every 5 Australians6. This is slightly lower than reliable estimates of foodborne illness in the United States.
This particular objective was given particular impetus by some widely reported individual outbreaks of foodborne illness which have galvanised public and political opinion on the issue.
In summary, the Food Safety Standards were developed for the following reasons:
- to provide more effective food safety regulations and reduce the level of food-borne illness in Australia;
- to provide nationally uniform food safety standards for Australia so businesses operating in more than one State or Territory have only one set of requirements;
- to replace existing food hygiene regulations that were sometimes significantly out-of-date; and
- to introduce less prescriptive regulations, that are simpler to comply with and give businesses more flexibility to determine the best way for them to comply with the requirements - providing food safety is not compromised.
FOOD SAFETY REFORM - EARLY YEARS
Efforts to create a set of uniform, simple and flexible food safety laws have a long genesis. In 1975 Health Ministers endorsed a proposal for a Model Food Act and complementary food standards, including on food hygiene. A Model Food Act was released in 1980, however its acceptance was limited. Between 1981 and 1986 Model Food Hygiene Regulations were drafted, however again there was little acceptance.
ANZFA becomes involved
The current round of food safety reform can be said to have begun in 1994 with the release by the NFA (now ANZFA) of a discussion paper, Safe Food Handling - Australia, which advocated a more preventative approach to food safety. It suggested national food hygiene legislation and supporting codes of practice and guidelines. In particular, it advocated food safety programs based on HACCP principles.
An early issue in framing the food safety standards arose out of the heterogeneous nature of the food industry in Australia. At one end of the spectrum are a small number of large corporate conglomerates who are well aware of the importance of food safety in protecting their brand. They understand the outcomes that must be achieved and have the technology and resources to achieve those outcomes in a variety of ways. At the other end of the spectrum are a very large number of small businesses who prefer a highly prescriptive approach to regulation - `just tell us what we have to do'. The obvious dilemma for the policy maker is: which approach to adopt. Eventually ANZFA opted, correctly, for a mix of the two. The standards contain a mix of prescription and a general proviso that, if an alternate method can guarantee the same level of safety, it could be utilised.
Following the release of the discussion paper for public comment, the NFA held consultation meetings in each Australian State capital between October and December 1994.
Fate then intervened. In early 1995 there was an outbreak of Escherichi coli 0111 from contaminated mettwurst. One hundred and seventy people became ill, of whom 23 children developed Haemolytic Uraemic Syndrome and one child died. The public demand for something to be done about improving food safety became deafening. In June 1995 the ministerial council, ANZFSC, asked ANZFA to develop, in consultation with the States and Territories, new standards for food safety which would then be implemented in a nationally uniform way. The following year ANZFSC asked ANZFA to draft a new Model Food Act, to, amongst other things, ensure uniform application and enforcement of the food safety standards. This eventually bore fruit in a model Bill, divided into a Part A which every jurisdiction had to adopt without amendment, and which contained critical material, such as definitions of food and `sell'; and a non-mandatory Part B, which contained desirable but not essential elements. This dual approach was eventually adopted by the jurisdictions in 2000 and the Model Food Act is now in the process of enactment in the States and Territories.
In September 1996, having reviewed the results of its previous round of consultation on food safety, and having consulted widely with various stakeholders, ANZFA released an Information Paper, Proposal to Develop a National Food Hygiene Standard, and invited comment on the proposals outlined. This was regarded by ANZFA as the commencement of a formal process under the ANZFA Act to amend the Food Standards Code to, for the first time, explicitly incorporate food safety requirements through separate food safety standards. Again, ANZFA raised the prospect of mandatory food safety programs, which would require all food businesses that could identify one or more potential safety hazards to develop and implement food safety programs based on HACCP principles. The details and scope of the programs would vary according to the size and nature of the business and the level of risk it posed to the community. It was proposed that the standards would be phased in over 6 years.
Responses to the Information Paper indicated that there was support for development of standards on both general food hygiene requirements and for the design and construction of premises, to replace existing regulations in the area. As a result, ANZFA decided to progress work on these two areas (which eventually became Standards 3.2.2 and 3.2.3 of the Food Standards Code) as a matter of urgency, as implementation of these two standards was regarded as a necessary precursor to the introduction of a requirement for mandatory food safety programs (which eventually became known as Standard 3.2.1). A preliminary paper on the draft standards was released for public comment in July 1997.
ANZFA formed a Working Group, mainly consisting of officials from the food area of State and Territory Health Departments, to rework the draft standards that had been in the preliminary paper. A further draft of the revised standards was released to a meeting of officials and industry and consumer representatives on 15 October 1997, and following further consideration by the Working Group, a further revised version of the standards was released for public comment in March 1998. Following receipt of 280 formal submissions, ANZFA held 17 workshops across Australia with approximately 600 attendees to discuss the standards. Although ANZFA had intended to only have one formal round of public consultation, in light of the level of interest a further round of public consultation was held in October 1998, when it released a further revision of the general standards (which had in the interim grown to three, to include a standard on application and interpretation). By now the consultation document had grown to over a hundred pages in length, although the standards themselves remained commendably short. In retrospect, it can be seen that this seemingly endless process of consultation was invaluable in creating a constituency in favour of reform, which understood the issues and became committed to the proposed new approach to regulating food safety.
The three general standards were endorsed by the Board of ANZFA in November 1998 - ANZFA is an independent statutory authority, and at the time major policy and strategic decisions for ANZFA were taken by a ten member Board7, consisting of a number of academics with a background in public health, food science and public administration, as well as representatives of consumers and industry, together with three New Zealand nominees. The Board approved the revised standards and recommended their adoption together with a food safety program standard, to the ministerial council, ANZFSC.
At its December 1998 meeting, ANZFSC agreed to the standards in principle, subject to the completion of a Regulatory Impact Statement, and further discussions with State and Territory officials on implementation. ANZFA completed a Regulatory Impact Statement and released it for comment in May 1999. The Regulatory Impact Statement estimated that foodborne illness cost Australia $A2.6 billion a year.
THE FOOD SAFETY PROGRAM STANDARD IN TROUBLE
By this stage, there was considerable unease in some sectors of the food industry concerning the introduction of mandatory food safety programs, i.e. Standard 3.2.1. Although the major food processors supported the food safety reforms, including food safety programs, and the Australian Food and Grocery Council and major retailers in particular were and remain prominent champions of the reform package, the food service sector in particular grew increasingly strident in its criticism of the proposed food safety program requirement. The Australian Hotels Association and the Restaurant and Catering Association were particularly prominent critics. They claimed that many of their members were small businesses who would have to contend with an expensive and cumbersome bureaucratic system that would not deliver better food safety outcomes. They also claimed that ANZFA's Regulatory Impact Statement had overstated the extent of foodborne illness in the Australian community. There was also concern from the primary industry sector that, despite their current exemption, the requirement for mandatory food safety programs would eventually be imposed `on farm'. ANZFA only became belatedly aware of the high-level lobbying that had been occurring on this issue.
By October 1999 the food safety program standard was in deep trouble. At its meeting at that time, ANZFSC recommended to the Council of Australian Governments (a committee commonly known as COAG, and which consists of the Australian Prime Minister, the Premiers of the 6 Australian States and the Chief Ministers of the Australian Capital Territory and the Northern Territory) that it defer consideration of the food safety program standard until the federal Department of Health and Aged Care (ANZFA's `parent' department) had obtained better data on the incidence of foodborne illness, and the cost and impact of the mandatory food safety program standard. The federal government allocated over $A4 million for this exercise. At the same time, ANZFSC recommended that the other three general standards be endorsed by COAG. The three general standards were endorsed by COAG and ultimately approved by ANZFSC in July 2000. They were gazetted into the Food Standards Code, as a new Chapter 3, on 24 August 2000. States and Territories were required to begin the process of incorporating the standards into their own food hygiene laws from February 2001, and New South Wales was the first to do so, in May 2001. A table on implementation dates is attached as Appendix One to this paper.
There has been one further development concerning the food safety program standard. The decision in October 1999 to defer its adoption caught a number of jurisdictions by surprise. One State, Victoria, had already begun to introduce a food safety programs requirement, following a serious episode of foodborne illness that killed two people. Other jurisdictions were considering the introduction of mandatory food safety programs in high-risk food businesses, such as hospitals and nursing homes. There was a danger that jurisdictions would introduce differing versions of food safety programs, undermining one of the key elements of the reform package, namely uniform legislation. Therefore ANZFA proposed as a compromise approach, and ANZFSC accepted in October 2000, that although the food safety program standard would not be compulsory, if a jurisdiction did choose to introduce food safety programs, it would have to comply with the requirements of Standard 3.2.1. The Department of Health and Aged Care has commissioned external consultants to advise it on the cost and efficacy of food safety programs and has funded, with the co-operation of ANZFA, the creation of Oz Food Net, to improve the epidemiological data on foodborne illness. Consideration of the outcomes of these exercises will be a lengthy process.
Out of that convoluted policy and political process, what emerged? Has it been worth it? To answer that question requires, amongst other things, an examination of the standards themselves.
Standard 3.1.1 Interpretation and Application
This is the introductory standard. It explains the main terms that are used within the Food Safety Standards, such as the meaning of `safe and suitable food'. It also applies the standards to all food businesses in Australia, with the exception of primary food production businesses, unless those businesses are also involved in the processing or retail sale of food. It requires food businesses generally to comply with the standards and in addition requires food handlers to comply with those requirements which are relevant to them.
Standard 3.2.1 Food Safety Programs
If a food business is required to have a food safety program, it must examine all of its food handling operations in order to identify those food safety hazards that might reasonably be expected to occur and prepare a written food safety program to control these hazards. The program must include controls for the identified food safety hazards, ways to monitor that the controls are working and steps to be taken when a hazard is not under appropriate control. Records must be kept by businesses to ensure that there is evidence that the business complies with the program requirement. Finally, each food business's food safety program will be regularly audited by a suitably qualified food safety auditor to ensure compliance. Auditing lies at the heart of the new approach of the food safety program standard. Instead of an occasional inspection by an environmental health officer to determine whether prescriptive requirements are being complied with, the auditor is considered someone who assists a food business to identify possible hazards, controls and monitoring mechanisms. The standard is silent as to whether this auditor is an environmental health officer, i.e. a public servant, or a qualified industry food safety auditor, as approaches to enforcement are likely to differ on this issue. In conjunction with a number of stakeholders, including the Australian Institute of Environmental Health, which represents environmental health officers, ANZFA has developed a national audit system for food safety programs. This sets out the requirements for the approval of auditors, including a three-level auditor system, the audit process and methodology, mechanisms for determining audit frequency and finally the development of policies and procedures to ensure the integrity of the audit system.
To assist in determining audit frequency, ANZFA has also developed a national priority classification system for food business, which classifies businesses into risk categories, based on the type of food, the activity of the business, the method of processing and the customer base. The three levels (high, medium and low) then determine the initial frequency of audit. The system may also be used by government when considering the phased introduction of a food safety program requirement.
One further document which should be considered when considering Standard 3.2.1 is that of ANZFA's framework for the development of food safety program tools. A frequent criticism of the concept of mandatory food safety programs is the cost involved in having to write an individual plan for each food business. The framework document addresses this criticism by providing a guide for the production of tools, such as templates, models, software and printed materials which can be utilised to create individual food safety programs.
Standard 3.2.2 Food Safety Practices and General Requirements
This standard sets out specific food handling controls related to the receipt, storage, processing, display, packaging, transportation, disposal and recall of food. Other requirements relate to the skills and knowledge of food handlers and their supervisors, the health and hygiene of food handlers, and the cleaning, sanitising, and maintenance of the food premises and equipment within the premises. There are also requirements to have a thermometer on the premises (a new requirement, so that the food handler can utilize time/temperature controls), controls on single use items, and of pests. If complied with, these requirements should ensure that food does not become unsafe or unsuitable. The standard applies to all food businesses, whether operating from a permanent building, a vehicle, boat or plane or at temporary market premises.
A notable new approach is that the standard permits food businesses to deviate from temperature requirements provided they can demonstrate they have a safe alternate system in place. For example, the standard requires potentially hazardous food to be either 5°C or colder, or 60°C or hotter when it is received, displayed, transported or stored. However, businesses can safely deviate from these temperature requirements by using time to control the safety of the food, provided the total times does not exceed safe limits and records are kept. This would, for example, enable food to be displayed, unrefridgerated, for short periods.
There are two further major changes introduced by this standard that do not formally commence until after February 2002.
Firstly, there is now a requirement on each food business to notify the relevant authority, usually the local government council, of its existence. The notification requirement applies to almost every food business in Australia. A food business is any business or activity that involves the sale of food or the handling of any type of food for sale in Australia, with the exception of some primary food production activities.
This means that the notification requirement applies to activities undertaken for charitable or community reasons, as well as to commercial ventures and once-off projects that involve the handling and sale of food. It includes businesses that may not think of themselves as food businesses, like cinemas, corner stores, petrol stations and swimming pools, if they sell packaged or any other type of food.
The second new requirement is that the owners of food businesses will be responsible for ensuring that people who handle food or food contact surfaces in their business, and the people who supervise this work, have the skills and knowledge they need to handle food safely. The only exception to this requirement is for charitable or community fundraising events, which sell food that is not potentially hazardous or that will be properly cooked and then eaten straightaway.
Standard 3.2.3 Food Premises and Equipment
Standard 3.2.3 specifies requirements for the:
- Overall design and construction of food premises, including water supply, sewerage, garbage, ventilation and lighting
- Floors, walls and ceilings of food premises;
- Fixtures, fittings, and equipment within buildings, including handwashing facilities; and
- Food transport vehicles.
If food businesses comply with these requirements, they will find it easier to meet the food safety requirements of the food practices standard. Again, these requirements apply regardless of which particular structure the businesses is housed in.
SUPPORT MATERIAL AND ACTIVITIES
ANZFA has produced a wide variety of material to explain both the intent and the content of the new standards. In particular, it has published two editions of Safe Food Australia, a 200-page guide to the three general standards. As the new standards are more outcome - based than the hygiene regulations they replaced, Safe Food Australia emphasises the choices available to food businesses, within the overall requirement to produce safe food. There have also been a number of technical and general fact sheets on the new standards and how to apply them. ANZFA staff have been regularly invited to present workshops, particularly to the environmental health officers who are responsible for putting the new standards into effect. Many environmental health officers at the local level are very comfortable with a high level of prescription, and many food businesses (particularly small businesses) likewise. In these circumstances, ANZFA has prepared a wide variety of written material (most of which is on the ANZFA website) in order to ease the transition into amore outcomes-based system. Small business has been a particular focus of ANZFA's support activities, in view of its limited access to resources. ANZFA has also convened an Implementation Working Group of Senior Food Officers from all jurisdictions, to discuss issues which have arisen from implementation and ensure a common consistent approach. Given that there are usually only 8 staff in the food safety area at ANZFA, and there are other calls on their time, the output has been considerable.
LESSONS FOR OTHER COUNTRIES - GOOD AND BAD
The intention of this Forum is to allow us to compare experiences, and there is a wealth of material lessons learned the hard way from ANZFA's work on the food safety standards. First, it is not a quick process. The idea of creating a single, uniform and simpler system of food safety laws was not a radical one. It had widespread community and political support, and most elements of the food industry supported it. It promised to reduce the regulatory burden on industry while generally raising the standard of care in the industry. Nevertheless, the process took 6 years just to get the least controversial elements introduced, and the future of mandatory food safety programs is still uncertain.
Secondly, if change is to be introduced, lengthy consultation is essential. The consultative process was exhaustive, but certainly succeeded in enlisting critical support in the jurisdictions, in industry and among the community at large. ANZFA's use of a number of consultation documents, working groups and public forums ensured that there was significant stakeholder support for the standards when they finally reached the approval stage.
Thirdly, advocating the widespread introduction of mandatory food safety programs is a very problematic activity. ANZFA failed to build a strong constituency for HACCP, for food safety programs generally and the approach we were advocating. ANZFA always considered the introduction of food safety programs to be a long-term objective, requiring years of work on implementation of the general food safety standards before moving to food safety programs. This was not understood by those who feared the overnight introduction of a bureaucrat-driven change that would only involve more paperwork for overstretched small business. The timing was not helpful, in that the Australian government was at the time introducing a value added tax which applied to most Australian businesses, which resulted in much higher sensitivity than usual about the introduction of a new regulatory requirement.
Fourthly, the area continues to be bedeviled by a paucity of high- quality data. There is a general scientific consensus on what pathogens are likely to contaminate food. There is much less known about the method and patterns of transmission to humans, and the extent and cost of preventable foodborne illness.
Fifthly, major and well-publicised outbreaks of foodborne illness can transform the climate on the issue of food safety reform. Major outbreaks of foodborne illness, particularly involving fatalities, have driven a large part of the political response to food safety issues in Australia. When polled, Australian consumers have regularly cited foodborne illness as their major food issue, rather than, as some have suggested, genetically modified or irradiated food. The general food safety standards were, in retrospect, assured of passage because otherwise there would have been an outcry that years of work on new national laws on food safety had achieved nothing.
Finally - the exercise is worth it. Although we are still a long way from full implementation of the entire food safety reform package, Australia now has a single set of food safety laws which are shorter, clearer, more flexible, more fairly allocate responsibility and set a new bench mark for food safety.
Current position in relation to each State and Territory in implementing the Model Food Bill and the Food Safety Standards
||Model Food Bill
||Standards 3.1.1, 3.2.2 and 3.2.3
||Standard 3.2.1 (Food Safety Programs)
||The proposal for a new Food Act will need to be considered by the new Territory Government. Aiming for Autumn 2002 sittings.
||The Standards will not be enforceable prior to the introduction of a new Food Act.
||Awaiting outcome of Federal government's Department of Health and Aged Care (DHAC) study on costs and benefits of food safety programs.
||The new Food Act is likely to be considered during the Autumn session of 2002.
||The Standards will become enforceable following the passing of the new Food Act and will operate in conjunction with the existing food hygiene regulations until they are repealed. Consultation with stakeholders groups is currently taking place on the legislative changes.
||WA is not opposed to the introduction of mandatory food safety programs and is likely to initially require programs for producers of smallgoods, the dairy sector and food businesses within public hospitals.
Stakeholders groups are strongly pushing for the new Food Act to obligate the Minister to consult with industry sectors and obtain substantial agreement prior to requiring food safety programs within a sector.
||Amendments to the Qld Food Act on Annex A are pending. Public consultation on Annex B is expected Feb/Mar 2002.
||Came into effect by amendment to existing regulations on 1 July 2001.
||Awaiting outcome of DHAC study on costs and benefits of food safety programs, but may be further announcement before that date.
||A new Food Act has received Royal Assent and proclamation date early 2002.
||Will commence on proclamation i.e. early 2002.
||Awaiting outcome of DHAC study on costs and benefits of food safety programs.
||Model Food Bill
||Standards 3.1.1, 3.2.2 and 3.2.3
||Standard 3.2.1 (Food Safety Programs)
|New South Wales
||Amendments to the NSW Food Act are likely to be considered either Spring 2001 or early 2002.
||Came into effect by regulation on 16 May 2001 with a modification to exempt funding raising events from the notification requirement.
||Proposing to require 3.2.1 for high risk businesses. Comment on this approach is currently being sought through a NSW Information Paper, A new approach to Food Safety in New South Wales, June 2001.
NSW Health is also conducting, with DHAC funding, a National Risk Validation project. The project will utilise outbreak data together with data from Food Science Australia and cost/benefit analysis to asses the hazards associated with industries and the potential food safety risks to the consumer.
||New Food Act to be considered at the end of 2001 or early 2002.
||Came into effect by regulation on 24 Sep 2001.
||Awaiting outcome of DHAC study on costs and benefits of food safety programs.
||The new Food Act was gazetted on 10 September but has not yet taken effect. Expected to take effect early 2002 but no later than 10 March 2002
||Expected to commence early 2002 but no later than 10 March 2002.
||Awaiting outcome of DHAC study on costs and benefits of food safety programs.
||Model Food Bill
||Standards 3.1.1, 3.2.2 and 3.2.3
||Standard 3.2.1 (Food Safety Programs)
||Amended Food Act passed April 2001. It will take effect from 2 Jan 2002.
||Will apply from 2 January 2002.
||Has not yet applied Standard 3.2.1 to any food business.
All food businesses with the exception of minimal risk businesses are required to have a food safety program by 1 Jan 2003 in accordance with the Vic Food Act.
High risk businesses are required to have an independently developed and audited food safety program (referred to as an Independent System).
Moderate risk businesses have the choice of an Independent System or a food safety program developed from a DHS registered template and compliance checked by local government.