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Review of the Memorandum of Understanding

1.Please let us know your Name, Position, Council and Email address(Required.)
2.Do you have any comments regarding Section 1 – Introduction?
  • Note: This section will be refreshed with updated statistics.
  • Should the MOU be consistent with other Plans?
  • It is likely that a separate Statement of Intent will be included to pick up points in this section – is this supported?
(Required.)
3.Do you have any comments regarding Section 2 – Background?
  • Note: this will be updated
(Required.)
4.Do you have any comments regarding Section 3 – Purpose?
  • Should it be more specific?
  • Should it include Objectives of the MoU – in addition to the purpose?
(Required.)
5.Do you have any comments regarding Section 4 – Principles?
  • Are these agreed?
  • Suggestions for improvement?
  • Links to other principles? For example: the SAPH Act (proportionality, prevention, precautionary?)
(Required.)
6.Do you have any comments regarding Section 5 - General responsibilities and undertakings?

  • This section describes the responsibilities of the Department and the LGA.
  • Should the role and responsibilities of councils be included?
  • Note: Department names will be updated
  • Review time frame – Currently every 3 years – would a change to 5 years be preferable and align the MoU with this?
  • References to various documents / departments – are these relevant or outdated? For example, Section 2 The Investigation Guidelines for South Australian Health Officers: Food Borne Disease Guidelines for the Inspections fees and levels of inspections? (LGA)
  • Development of model policies and guidelines (LGA) – Has this been sufficient or addressed need? Many are outdated, however would they be useful if up to date?
  • The LGA's website currently has links to policies and documents https://www.lga.sa.gov.au/eha/portfolio-resources-and-legislation/food
  • The LGA is currently responsible for “encouraging ‘consistency’ and ‘good practice’ from councils” – what does this look like?  What would councils like to see happen in this area? Some references to LGA are difficult to see line of sight to e.g. Food recalls, supporting communication with food businesses – determine the remit of the LGA, has this been done in the past?
  • Future changes: What needs to be captured here? Should this be removed?
(Required.)
7.Do you have any comments regarding 6.1 Notification of food businesses?

  • The reference to the Food Act Information System (FAIS) will be removed – this was communicated by DHW in 2013.
  • It notes “The department will develop and maintain and review effectiveness of an electronic system”.  Is the Agreement supported? Work is currently occurring in this area via the working group. Should this remain in the MOU?
  • Does Notification of food businesses still need to be a stand-alone section?
(Required.)
8.Do you have any comments regarding 6.2 Enforcement and administration of the Act?

  • A copy of the legislation is here for reference.
  • Are these still agreed?
  • Is further clarity regarding the roles and responsibilities for investigating complaints associated with allergens needed?
  • Currently DHW - s.15, s.18, s.19, s.20, s.21(3) and (4), s.22 of the Food Act
  • Currently LG – s.13, s.14, s.16, s.17, s.21 (1) and (2) of the Food Act
  • Update with recent changes to Food Standards Code.
(Required.)
9.Do you have any comments regarding 6.3 Food Safety Programs and Auditing?

  • Are these arrangements still working well?
  • DHW currently audit all public hospitals (government owned and operated), Meals on Wheels volunteer kitchens, not for profit delivered meal organisations, domiciliary care and disability services kitchens. Is this still appropriate?
  • Food safety training by DHW eg Annual Auditor Forum, Lead Food Safety Auditor Training – are others required?
  • Makes reference to Guidelines for Auditors of Mandatory Food Safety Programs 2010 (DHW) – Does it require a refresh?
  • Auditing guidelines and eg policies with EHA and LGA – Is this appropriate
  • Regulatory form – DHW Prescribed audit checklist and report – any comments on this document?
  • LGA to encourage consistent approach to management of audit and calculating fees – Is this appropriate?
(Required.)
10.Do you have any comments regarding 6.4 Other Food Safety Arrangements?

  • LGA and DHW working together share information.
  • Are there any other issues that should be clarified?
  • Should funding arrangements be explored due to expanding workloads eg Food Safety culture work, Food management tools work?
  • Any other suggested arrangements?
(Required.)
11.Do you have any comments regarding Section 7 Further work to improve food safety and the effectiveness of the Act?

  • This is the systems/administration section. Should these roles be clearer?
  • Should there be content relating specifically to engagement and communication between the DHW, councils and the LGA.
  • This section captures the joint work program - has this been communicated well to the sector?
  • Membership – currently LGA as an observer, 5 council representatives (with at least one from a rural area) and an EHA representative.
  • References the Terms of reference
  • Reporting to South Australian Public Health Council – what feedback or ability is there for reporting and evaluation - Is this appropriate and what should be reported?
(Required.)
12.Any other comments/suggestions/feedback?

  • Is this format still relevant?
  • What is working well under the MOU?
  • What is not working well?
  • Should the MOU be considered with Biosecurity SA /PIRSA due to their role in food safety?
(Required.)
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