Dairysafe’s auditor, QCONZ, has now been auditing transporters, farms and processors since February 2018. In some instances, where non-compliance with national food standards and conditions of accreditation has been identified during the audit, the auditor has issued a corrective action request (CAR).
CARs are used by food safety regulators in all jurisdictions for addressing non-compliance, and have been applied by Dairysafe for many years.
CARs vary in terms of seriousness depending on the nature of the non-conformance. They are recorded as either critical, major or minor, and each classification has specific meaning and mandatory completion timeframes.
Minor Non-conformance: Low risk situation
‘A non-conformance with the approved food safety arrangement where the potential impact of the non-conformance is not likely to compromise food safety.’
A minor non-conformance must be corrected prior to the next scheduled audit.
Major Non-conformance: Medium risk situation
‘A non-conformance with the approved food safety arrangement where the potential impact of the non-conformance is likely to compromise food safety and suitability if no remedial action is taken to correct the non-conformance within a specified period.’
A major non-conformance must be corrected within 30 days and is subject to follow-up audit.
Critical Non-conformance: High risk situation
‘A high risk non-conformance with the approved food safety arrangement where the potential impact of the non-conformance is of substantial and/or immediate significance to food safety and suitability warranting immediate corrective action.’
The need for Dairysafe to initiate compliance action may arise from reports of non-compliance with standards, the production of unsafe or unsuitable food, and foodborne illness investigations.
As with all Australian food safety regulators, Dairysafe applies a graduated response to drive compliance. Dairysafe uses a range of compliance options to encourage compliance with food safety standards without placing undue cost on industry.
Dairysafe will follow up the correction of major CARs at or after the standard 30 day timeframe provided to correct the non-compliance. As has previously been the case, an additional charge of $100 per hour will apply for follow-up visits.
Failure to sufficiently address a critical non-conformance immediately will result in strict sanctions being applied, which in some instances can lead to a Compliance Order (restricting the operation of the business, in order to manage the food safety risk), suspension or cancellation of an accreditation, or prosecution. The suspension or cancellation of an accreditation is considered to be a very severe measure and will only be considered as the final consequence when other compliance strategies have been ineffective.
Dairysafe is developing a Compliance and Enforcement Policy to ensure compliance measures are clear, consistent and available to stakeholders. The policy will follow the principles of a national Enforcement Policy applied by all jurisdictions.