BUSINESS FSANZ

On 12 February 2025, the FSANZ Primary Production and Processing Standards for Leafy Vegetables, Melons and Berries commenced.

Words Joel Dinsdale, Quality Assurance Coordinator, vegetablesWA

IN WA the structure and roll-out plan have differed slightly from some of the other states and territories, based on a collaborative approach between WA Health and industry that was set in motion early.

In this article, I’m going to focus on and drill into some FAQs to clarify the facts and remove doubts/ rumours that are (pardon the pun) currently on the grapevine.

Above: Herb microbial food safety risks are elevated as they are grown in close proximity to growing medium and can be eaten uncooked.

Q: “I grow herbs — they aren’t a leafy vegetable, so am I exempt from this?”

A: No, you are not. Under the interpretation of this legislation, herbs are included. This is because they are grown in close proximity to the growing medium and they can be eaten uncooked. These factors elevate their microbial food safety risks. Examples include basil, mint, coriander, watercress.

Q: “I’m Freshcare certified for the crops included in the legislation, so I meet the criteria and don’t need to take any further action?”

A: This is partially true. The fact that you (the producer) are certified to a GFSI scheme (like Freshcare) means that you will already have systems and records in place to successfully demonstrate compliance to the legislation. However, all affected producers MUST notify their local government by completing the necessary food business registration forms. Access forms here: www.health.wa.gov.au/articles/n_r/primary-produc-t-ion-and-processing-standards-forleafy-vegetables-melons-andberries

If you are yet to complete this step, please reach out to the LG (where your farm / processing facility is located) ASAP to notify them of your activities. You will need to contact your local government directly. You can do this using the following link: https://walga.asn.au/your-l-ocal-government/local-governmentdirectory

Q: “I only grow the leaf lines, and they are sent to another business for processing and packing. Does this mean I do not need to meet the legislation?”

A: In this example, the “grower” is conducting a “primary production activity” (growing). This means that the grower will need to meet the requirements of the legislation by registering with their LGs and either supplying the required GFSI documents or they will need to establish and implement a Food Safety Management System that will be assessed by their local Environmental Health Officer (EHO).

WA Health defines Primary Production as activities that include, “Growing and harvesting, including management and risk mitigation of inputs such as soil, fertiliser, water, seeds, seedlings, soil amendments, and, weather events.”

Primary Processing businesses would also be required to meet the criteria outlined in the new legislation as a minimum.

To take this example further, WA Health defines Primary Processing as “washing, trimming, sorting, sanitising, storing, combining, packing, transport between processing facilities” as ‘in scope’ for the PPP standards. This means that the processing business that the grower (in the example) is sending to, would also be required to meet the criteria outlined in the new legislation as a minimum.

Also, both the Primary Producer and the Primary Processor will need to be able to demonstrate that they have systems in place to address traceability, premises and equipment hygiene, control of animals and pests, and worker skills, knowledge, health, and hygiene.

Q: “My business produces across multiple local government regions. I have notified the LG where the main production activities occur. Do I need to notify the other LGs given that I may/may not be in production each year at other sites?”

A: This is a great question! There is an element of “it depends” given that not all the important details may have been disclosed in the question. If you are in doubt, I’d strongly advise that you engage with the EHOs in those areas to discuss your circumstances in greater detail. They will advise you on the best course of action from there.

To answer the question on face value, you only need to advise the relevant LGs when you are in production at those sites. It’s a good idea to notify the relevant LGs prior to the commencement of activities at those locations so be proactive where possible.

Q: “I’m not commencing melon production until I plant in September 2025. When should I notify my LG?”

A: If you are not currently producing any melons then you are not in breach of the legislation, but the registration process doesn’t happen overnight. This probably means that you should get on the front foot and start to open the lines of communication between your LG and your business. Let them know what your intentions are, and they will provide you with a timeline of what they require and when they will need it.

If you can submit required documents prior to the commencement of activities (covered under the legislation), that shows a level of proactivity and it could help to speed up the registration process, leaving you more time to focus back on the production elements.

Finally, the EHOs and the LGs are looking to “partner with all producers” to work towards the food safety objective of a reduction in food borne illness (via compliance to the new legislation).

They are looking to measure compliance and are only looking to police the legislation when all other actions have not led to an improvement in food safety.

If you communicate and engage with your EHO then they will be looking to help and support, to assist your business.

Q: What is your Food Safety Objective?

A: Over to you…

Please note that this advice is general in nature, and it may not consider all elements.