Food Safety for your employees – is your canteen R638 ready?

By guest Linda Jackson, BSc. Chemistry; M.Tech Environmental Health, Food Safety


As you are more than likely selling food to your employees at a subsidized rate, the requirements of Regulation 638 of 2018 of the Foodstuffs Cosmetics and Disinfectants Act, Act 54 of 1972 apply. These general hygiene requirements are mandatory for your canteen or staff restaurant. If you own the premises and it is operated by a third party, it is your responsibility to ensure they comply - even if this is a street vendor you have allowed to operate on your premises.

In addition to the kitchen and serving area being constructed and maintained hygienically in accordance with the legal requirements, you should be able to answer “YES” to all of the following questions:

1. Do you have a valid certificate of acceptability (COA) for the premise?

Regardless of whether this is owner managed or outsourced, a valid COA should be in place reflecting the person in charge. If it is out of date then now is a good time to renew it. Most municipalities are requiring a re-issue of the certificate for the new version of the regulation, despite this NOT being legally required. You should co-operate as any inspections are better than none and it will give you the opportunity to interact with the local municipality.


2. Do you have records to demonstrate that the person in charge is appropriately qualified in food safety?

The new regulation makes it compulsory for the person in charge to be trained in food safety and food hygiene to ensure they understand the risks associated with the food they are preparing. If they have not been trained how can you trust them to ensure your staff will not be sickened?

3. Do you have records to demonstrate that everyone working in the kitchen handling food has also been trained in food safety?

Everyone including cleaners will need an understanding of food safety. This training can be conducted in-house by an external provider. There should be records of training and these records must be available You are also required to reassess the kitchen staff on a regular basis to make sure they are still aware and practicing the right habits. The training programme you used and the records of their training must be available in your kitchen.

Please note that this training must be accredited training and should be in sufficient depth to ensure they can effectively manage food safety.

4. Do you have records of receiving, storage of food, cooking, chilling, reheating…and more?

The law NOW requires that you can prove that all the processes in the kitchen are under control. This will need to start from the receiving of your ingredients to show that they were received at the correct legal temperatures whether chilled or frozen. Once you store them, can you show how you manage stock to ensure effective rotation like date coding on packages? When you use them can you show which food was used on which day in case there is a problem to traceback? Cooking and chilling temperatures are critical to ensure the harmful microorganisms are controlled. Finally when you serve the food, is the buffet at the right temperature according to law? How are leftovers handled?

The law requires all these records now and a traceability system. Keep it simple but keep it.


5. Do you control your allergens?

Although controlling allergens in a kitchen can be tricky this is now a legal requirement. You must inform your staff of the allergens you use. Make sure the menu is kept up to date and any replacements checked for hidden allergens. Do you know if anyone working for you suffers from a food allergy? You might want to change the menu to rather eliminate the risk altogether.

If you have a creche on-site feeding employees children, you should exercise even more care in this area.



By putting these 5 controls in place, your compliance with Regulation 638 will improve significantly. The attention to this detail will hopefully also go a long way in helping you to prepare and serve tasty nutritious and safe food to your staff to help them help you achieve your business objectives.

Contact us today to find out more about:

Using our Ariscu audit module to conduct a self-check on R638 (FS Suite required)

Having a Food Safety consultant come on-site to assess your R638 readiness

+27 (0) 12 362 6500 | info@ariscu.com | www.foodfocus.co.za