We provide meals for a social day care centre, are we required to have a license with the NSW Food Authority?
Our Meals on Wheels service receives and delivers chilled and frozen meals, are we required to have a license with the NSW Food Authority?
Our Meals on Wheels service reheats 5 meals per day on average, are we required to have a license with the NSW Food Authority?
What are potentially hazardous and high risk foods?
How can your organisation substitute high risk foods?
Minimum Standards Required When Using Temporary Kitchens
Is sanitising of fresh fruit and vegetables mandatory?
What are the labelling requirements for Meals on Wheels services?
How should we label meals with allergens? Is this the same as dislikes or intolerances?
Which foods do not have to be labelled?
Nutrition Panels

We provide meals for a social day care centre, are we required to have a license with the NSW Food Authority?

Social day care centres are not required to have a license with the NSW Food Authority as they do not provide personal or patient care. If the primary activity of the day care centre is to provide social activities, even if these are regarded as therapeutic, the day care centre does not require a NSW Food Authority license.

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Our Meals on Wheels service receives and delivers chilled and frozen meals, are we required to have a license with the NSW Food Authority?

If your MOW organisation does not alter the meals in any way (i.e. reheat or refreeze), you are not required to have a NSW Food Authority license.

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Our Meals on Wheels service reheats 5 meals per day on average, are we required to have a license with the NSW Food Authority?

If your MOW organisation only prepares or reheats less than 6 meals per day on average you are not required to have a NSW Food Authority license. However, it would be best to work out the average number of meals prepared per week as while some days you might only prepare less than 6, on average you might actually prepare 6 or more on average and this would require your service to have a license.

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What are potentially hazardous and high risk foods?

Potentially hazardous foods are those foods which must be stored under temperature controlled conditions in order to minimise the growth of harmful pathogens such as bacteria and moulds.

High risk foods are foods which can easily make vulnerable persons sick if not handled correctly.

Those organisations providing meals to vulnerable persons who fall under Standard 3.3.1: Food Safety Programs for Food Service to Vulnerable Persons, must implement a Food Safety Program if they handle potentially hazardous foods.

The NSW Food Authority requires that an organisation;

• Must address high risk foods through the businesses food safety program
• If a business wishes to serve an identified high risk food, must demonstrate appropriate control measures
• Where control measures are not available – alternative foods or meals may have to be served

High risk foods include foods such as;

• Seafood - Raw oysters, sushi, smoked salmon/ trout, ready-to-eat prawns;
• Cold meats – Unpackaged ready-to-eat deli meats such as ham and salami and packaged, sliced ready-to-eat meals;
• Cheese – Soft and semi-ripened cheeses such as camembert, ricotta, feta, brie, blue cheese;
• Fruit and vegetables – Strawberries, melons, sprouts, lettuce, cabbage; and
• Eggs – Raw egg products (e.g. mousse, trifle), cooked eggs

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How can your organisation substitute high risk foods?

Safer Alternatives for high risk foods
Special care must be taken when designing menus to eliminate these foods from the menu and substitute them for safer alternatives.

Safe alternatives include:-
Seafood – Freshly cooked seafood, all seafood products such as oysters must be cooked (e.g. mornay), canned seafood etc.;
Cold meats – Meat freshly cooked and sliced on the premises and pre-packaged whole products which have been cooked in the bag (e.g. whole ham);
Cheese – Hard cheeses such as cheddar and tasty, processed cheese, cheese spreads and plain cottage cheeses;
Fruit and vegetables – Only use fruit and vegetables which can be thoroughly washed and sanitised, avoid using sprouts and melons, canned and pickled fruits and vegetables;
Eggs – Cooked eggs, boiled eggs should be used with 24 hours of cooking

Special Handling Practices for high risk foods When handling these foods special care must be taken to ensure that staff and volunteers have the skills and knowledge to handle high risk foods in a way that prevents contamination, use clean hands, utensils and equipment and keep them at safe temperatures (below 5°C and above 60°C when hot).
Source: NSW Food Authority presentation

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Minimum Standards Required When Using Temporary Kitchens

Many meals on wheels and community based services operate out of food premises which they do not own or lease on a regular basis. Examples of this might include a community hall, a church hall or a council building not designed for food service. Some premises might not have a kitchen, might have no hand wash basin, no refrigeration facilities and might be wooden buildings or rooms which are very difficult to clean. In other circumstances the “premises” might be in the outdoors, for example a community picnic or BBQ.

This means that from week to week the standards of cleanliness and hygiene that a service might find can vary. The NSW Food Authority will need to know which food premises that each Meals On Wheels Service operates out of, even those premises that may only be used occasionally or at the very most once a week. The Food Authority also needs to know that when your service uses these premises that food safety standards are maintained at all times.

Whilst the service may not be able to spend money on improving a temporary kitchen or convince the owner of the premises to change the food facilities, there are some practical ways to demonstrate to the NSW Food Authority that your service is aware of food safety and takes steps to minimise the risk to vulnerable persons in your care. This will include using the regular food safety monitoring forms that are used in the main kitchen premises (e.g. monitoring times and temperatures).

Here are some basic tips to help your service when operating from such temporary kitchens:-

Tip 1. Take a Basic Food Safety Toolkit

Using a large lidded container or cleaners bucket to create your own “Food Hygiene Kit”. Include basic items such as:-

• Sanitiser spray
• Detergent
• Washing up equipment
• Disposable cleaning wipes
• Disposable paper toweling
• Sanitising hand washing soap
• 2 clean chopping boards
• Cockroach baits for use between your visits to prevent cockroaches
• Portable fridge thermometer to check fridge temperatures
• Probe thermometer to check temperatures of food being prepared/ served
• Disposable crockery and cutlery
• Serving equipment (tongs, long handled spoons)
• Waste bags/ bin liners
• Basic hygiene signage (Wash Hands etc.)

Before using any equipment that you do not maintain yourself, it is important that all utensils, equipment (including benches and boards) and serving equipment (spoons, tongs, crockery etc.) are thoroughly cleaned. No assumptions should be made that equipment on arrival is clean or pest free, even if it looks clean.

Tip 2. Conduct a quick visual inspection of the minimum basics required by law.

If you conduct a quick assessment of the premises you may be able to argue with the owner/ leassor of the premises that some basic improvements may be required to bring the premises up to a legal standard in the Australian Food Standards Code.

If this is not possible, your service might have to make modifications to the menu should be made to minimise food handling and preparation or in some extreme cases, alternative premises might have to be found that comply with the minimum standards.

• There is a working hand wash or wash up basin with hot and cold running water;
• There are screens on all windows and external doors in the kitchen area;
• Clean bins with lids;
• No open external door from the kitchen area;
• No pest infestation;
• Walls, doors, windows, ceilings and floors do not have gaps in them that could allow pests to enter the kitchen area;
• The food handling benches and bench tops are “cleanable”; and
• There is hot water for washing up and hand washing.

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Is sanitising of fresh fruit and vegetables mandatory?

Fresh cut fruit and vegetables are high risk foods and must therefore be washed and sanitised in 100ppm chlorine as per the NSW Food Authority Guidelines.

Washing raw produce with a bleach solution (sodium hypochlorite) of 100 parts per million has been shown to reduce the number of micro-organisms. If you are not currently using a chemical sanitiser, contact your chemical supplier and request them to provide your service with a sanitising product. The levels of sanitiser must be checked every time it is used. Your supplier will provide you with a colour dosage chart which clearly references the 100ppm and a monitoring record. This is done easily by using pH strips to check the level of solution.

For example, 100 parts per million is the equivalent to 1 ml per 1000ml of water. So in a 10L sink, 10 ml of solution would need to be used.

Once product has been washed in sanitiser it must not be rinsed.

If a fruit or vegetable cannot be sanitised without affecting the texture or flavour the item should not be served to vulnerable persons (e.g. raspberries, strawberries, fresh herbs, salad sprouts etc.).

For further information refer to the NSW Food Authority web site under industry programs, food service to vulnerable persons; “Cleaning sanitising fresh produce” (2006).

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What are the labelling requirements for Meals on Wheels services?

Current labelling requirements exempt some food items from carrying a label for meals delivered for immediate consumption. However this only applies to hot meals as chilled meals and frozen meals will be consumed at a later time/ date.

Despite what many services believe, there are currently no specific exemptions which apply to meals supplied by DMOs. The Code requires foods (including meals delivered by DMOs) that are delivered packaged at the express order of the purchaser, but are not ready for consumption, to be fully labelled.

All chilled and frozen meals should have the following information on them:-

Source: NSW Food Authority web site (Food Labels, March 2009)

A recent review of the Australian Food Standards Code for labelling states that under the current legislation:-

Where it is required, packaged meals supplied by DMOs and not ready for immediate consumption (e.g. a frozen meal) must bear a label setting out all the information prescribed in:-
(a) Standard 1.2.2 – Food Identification Requirements; and
(b) Standard 1.2.3 – Mandatory Advisory Statements and Declarations; and
(c) Standard 1.2.5 – Date Marking of Packaged Food; and
(d) Standard 1.2.6 – Directions for Use and Storage.

If a Meals on Wheels service is supplying meals to another organisation, including a DMO, it is regarded as a commercial supplier of meals and must therefore comply with the requirements of the Food Standards Code.

Further information will be provided regarding the labelling review through the NSW Meals on Wheels Association.

For further information refer to:-
NSW Food Authority
http://www.foodauthority.nsw.gov.au/consumers/food-labels/
Phone: 1300 552 406
E-mail: contact@foodauthority.nsw.gov.au

FSANZ (Food Standards Australia New Zealand)
FSANZ has general information on labelling requirements for food businesses and a summary of the Food Standards Code:- www.foodstandards.gov.au/monitoringandsurveillance/labellingandinformat4170.cfm

FSANZ has a useful power point presentation/ pdf on labelling requirements for businesses:- www.foodstandards.gov.au/_srcfiles/Webinar3_Labelling_10092007.pdf#search=%22labelling%22

NSW Meals on Wheels Association
www.nswmealsonwheels.org.au
NSW Food Authority Help Line 1300 552 406

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How should we label meals with allergens? Is this the same as dislikes or intolerances?

It is mandatory for a service to clearly label meals containing ingredients which are defined as “an intolerance” or an “allergy”. If your service has clients with either an intolerance or an allergy, this must be clearly noted on their client file, the delivery list and on the client’s meal. This information should be separated from “dislikes”. This may be done through a colour coding system for allergies (red) and dislikes (yellow) to separate personal food preferences from potentially harmful ingredients that may cause an allergic reaction.

The menu list should also be available with information that clearly indicates which meals have which allergenic ingredients in them. For example a matrix may be produced such as the one below:-

Sample Allergen Declaration Form

Conduct a review of how you handle allergens and ask yourself whether the wrong meal could potentially be delivered. What if volunteers think that Mr Jones doesn’t like egg but think that “a little bit in dessert” won’t hurt him. If Mr Jones has a dislike to egg he probably wont notice its in the dessert but if he is allergic to egg he could end up in hospital or worse.

The Australian Food Code outlines requirements in terms of labelling meals for allergenic ingredients. This is clearly outlined in Standard 1.2.3:

The allergenic ingredients which must be made available to clients and customers include:-

1. Sources of Gluten – Wheat, Oats, Barley, Rye, Spelt and their hybrids. (But excludes their presence in Beer & Spirits)
2. Crustacea and their products
3. Eggs & Egg Products
4. Fish & Fish products
5. Milk and Dairy Products
6. Nuts & sesame seeds and their products
7. Peanuts & Soybeans and their products
8. Added Sulphites of a concentration of 10mg/kg in the end product)
9. Royal Jelly as a food or in a food, Bee Pollen and Propolis

During production procedures are in place to prevent cross contamination from allergens such as; egg and nut products. Products using these ingredients are prepared separately and items are clearly labelled with Allergen Warning Statements.

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Which foods do not have to be labelled?

Some of the healthiest foods may be unlabelled – fresh fruit, vegetables, nuts, lentils, beans, fresh meat and fish are all important foods that contribute to good health.

Not all foods have to be labelled. Here are a few exceptions:

Unpackaged foods such as fresh meat, fruit, vegetables and nuts or food sold in a restaurant.

• Food delivered packaged at the customer’s request, for example home delivered pizza.
• Food made and packaged on the premises from where it is sold, for example at a bakers.
• Food packaged in the presence of the customer, for example at a delicatessen or a take-away food shop.
• Packaged whole or cut fresh fruit and vegetables (but not bean sprouts) where you can see the fruit or vegetables through the package.
• Food sold at a fund raising event for charitable purposes like a school fete.
• Individual serve packages that are sold in a large package such as a 12 pack of corn chips, although the information has to be on the outer package.

Meals on wheels services fall under the first exemption, but as stated earlier this only applies to hot meals for immediate consumption.

Also, nutrition information panels do not have to be on very small packages that are smaller than 100 sq cm (about the size of a large chewing gum package) or on foods with minimal nutrition like herbs, spices, tea or coffee.

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Nutrition Panels

Nutrition labelling
Nutrition information helps clients keep track of what they are eating and enables customers to choose between different products to get the best one for them based on nutritional information. The nutrition information panel (NIP) helps a customer compare key nutrients and serving sizes whilst some food labels will also include information on percentage daily intake and nutrition claims too.

These panels enable a customer to compare the key nutrient contents, e.g. salt (sodium), sugar, carbohydrate and fat, of a meal to make sure they get the best balance for dietary needs.

There is a nutrition panel calculator available from Food Standards Australia New Zealand (FSANZ) on their web sites. These are easy to use and involve inputting recipe and ingredient information into a template which calculates the nutritional panel data.

Source: NSW Food Authority web site (Food Labels, March 2009)

www.foodstandards.gov.au/thecode/nutritionpanelcalculator/index.cfm

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