Does a cafe have to keep food safety records?

Yes, if the cafe is a category one business under Standard 3.2.2A of the Food Standards Code, and a cafe that cooks or assembles potentially hazardous food into something ready to eat is one. The standard never uses the words temperature log, though. It requires food safety records that substantiate nine clauses of a different standard, or proof of compliance some other way.

Knowing which nine clauses is what turns a clipboard on the cool room door into checks that each mean something.

Is the cafe a category one business?

For the purposes of this Standard, a category one business means a food business that: (a) is a caterer or a food service; and (b) processes unpackaged potentially hazardous food into a food that is: (i) potentially hazardous food; and (ii) ready-to-eat food.

Section 4 of the same standard defines food service as a food business "which processes and serves ready-to-eat food direct to a consumer, whether consumed at the food premises or elsewhere". Section 2 says process "includes chopping, cooking, drying, fermenting, heating, thawing and washing". Slicing ham into a toastie, cooking eggs and filling a wrap with cooked chicken are all processing.

What the food safety records rule says

Subject to subsection (3), if the food business engages in a prescribed activity, the food business must make a record that substantiates any matter that the prescribed provisions require in relation to that prescribed activity.

The food business must keep a record required by subsection (1) for 3 months after the business makes the record.

Subsection (1) does not apply to a food business that can demonstrate to the reasonable satisfaction of an authorised officer on request that the business has complied with each of the prescribed provisions.

Subsection (3) is a real option, but it has to be demonstrated on the day an officer asks, for each provision. A written reading is usually the easier way to do that.

Section 12(4) lists the prescribed provisions, all in Standard 3.2.2: subclause 5(3), paragraph 6(2)(a), paragraph 7(1)(b)(ii), subclauses 7(2), 7(3) and 7(4), paragraph 8(5)(a), paragraph 10(b), and clause 20.

The nine clauses, and where each sits in the day

Several of them turn on temperature control. Clause 1 of Standard 3.2.2 defines it as maintaining food at "5°C, or below if this is necessary" to keep it safe, at "60°C or above", or at "another temperature" if the business demonstrates that holding it there will not affect its safety.

Deliveries: subclause 5(3)

When receiving potentially hazardous food, the business must "take all practicable measures to ensure it only accepts potentially hazardous food that is at a temperature of" "5°C or below" or "60°C or above", unless the business transporting it shows the temperature will not affect its safety. Probe the chicken and a carton from the dairy order before signing the docket, and write the reading on it.

Fridges and the cool room: paragraph 6(2)(a)

Potentially hazardous food must be stored "under temperature control". A reading of each fridge and the cool room at open and at close covers it.

Cooking: paragraph 7(1)(b)(ii)

"where a process step is needed to reduce to safe levels any pathogens that may be present in the food", the business must "use a process step that is reasonably known to achieve the microbiological safety of the food". A probe reading of the thickest piece in a batch is the record.

Prep on the bench: subclause 7(2)

For food not undergoing a pathogen control step, the business must "ensure that the time the food remains at temperatures that permit the growth of infectious or toxigenic microorganisms in the food is minimised". Note the time a tray of sandwich fillings came out of the fridge and went back.

Cooling: subclause 7(3)

Cooked potentially hazardous food must be cooled "within two hours" from 60°C to 21°C, and "within a further four hours" from 21°C to 5°C, unless the business demonstrates its own process is safe. A pot of stock or a tray of rice needs three entries: when it came off the heat, its temperature at two hours, and when it reached 5°C.

Reheating: subclause 7(4)

Food reheated to hold hot needs "a heat process that rapidly heats the food to a temperature of 60°C or above". Probe it before it goes into the bain-marie.

The display: paragraph 8(5)(a)

Potentially hazardous food on display must be displayed "under temperature control". That is the cake fridge, the sandwich display and the bain-marie, each checked during service.

Catering runs: paragraph 10(b)

When transporting food, the business must "transport potentially hazardous food under temperature control". A cafe that delivers catering platters records a reading when the esky leaves and when it arrives.

Sanitising: clause 20

"eating and drinking utensils" must be clean and sanitary "immediately before each use", and "the food contact surfaces of equipment" whenever food that touches them "is likely to be contaminated". A daily tick that the dishwasher reached its sanitising cycle, or that sanitiser was made up at the right strength, is the record.

Tie each check to something that already happens

Records filled in the morning an officer arrives fail for an obvious reason: they were not made at the time. Checks get done when they are attached to a moment nobody skips.

• Deliveries: no docket is signed until the probe reading is written on it.
• Open and close: fridge readings sit on the same checklist as the till and the alarm.
• Cooling: start a phone timer for two hours when the pot comes off the heat.
• Each shift: one named person owns that shift's checks, on the roster, not whoever is nearest.

FSANZ's guidance on the evidence tool says records "should be made each day the business is engaged in prescribed activities" and should include "the date (and time, if appropriate) the record was made and which food or activity it relates to". It accepts paper or electronic templates, data logger information, and photos or video. Its Safe Food Australia guide has templates a business may use in Appendix 8.

Diract's roster can hold one of these checks. An admin adds an end of day question, such as the cool room temperature at close, as a Number with a unit, and a Manager types the answer on the Calendar's Day view. It takes one answer a day, so it suits a closing reading rather than a delivery log.

This article is general information about Standard 3.2.2A and Standard 3.2.2 of the Australia New Zealand Food Standards Code, not legal or food safety advice. Your state or territory food authority enforces the Code and may add its own requirements. It quotes Standard 3.2.2A as registered (F2022L01589, no amendments) and Standard 3.2.2 as at compilation 8, in force from 13 August 2025, and is current as at 14 September 2026.