AIFS Guide to

Food Service to Vulnerable Persons

Vulnerable people are more susceptible to infectious diseases than the average person, and more likely to suffer with severe symptoms or to die from a food-borne infection. 
Food Service to Vulnerable Persons
AIFS Member Resource

Serving food to people safely is of utmost importance for food businesses. This is particularly true when serving people who are part of the vulnerable population. This is because vulnerable people are more susceptible to infectious diseases than the average person, and more likely to suffer with severe symptoms or to die from a food-borne infection. 

Children under five, pregnant women and unborn children, the elderly and people with weakened immune systems are considered vulnerable persons (also called ‘high-risk groups’). In particular, the elderly are very high-risk because a person’s digestive system becomes more sensitive as the body ages. Older people generally produce less stomach acid than when they were younger, and the stomach lining becomes more delicate and sensitive to irritation. This allows bacteria to sneak past the stomach and into the digestive tract where it can cause food poisoning.

Food Poisoning and Vulnerable Persons

Food contaminated by harmful microorganisms can make people very sick. Unfortunately, four million cases of food-borne illness occur in Australia every year, many of which are caused by unsafe food handling practices that allow dangerous bacteria, viruses and parasites to contaminate food. 


Bacteria are common causes of food-borne illness. Under the right conditions, bacteria can multiply rapidly, doubling in number roughly every 20 minutes. 

The most common disease-causing bacteria in Australia are Campylobacter, Salmonella, Listeria and E. coli. The foods that most commonly harbour these dangerous bacteria include meat, poultry, eggs, unpasteurised milk and cheese, shellfish and leafy green vegetables. 


Viruses need a living host to survive and reproduce, but they can travel on any type of food, including traditionally low-risk foods like baked goods and dehydrated, preserved and processed foods (e.g. biscuits, crackers, sweets). 

Viruses can survive on virtually any surface and are extremely resistant to hot and cold temperatures, which means they aren’t destroyed or rendered inactive by cooking, refrigerating or freezing. 

Viruses are most often passed to customers from infected Food Handlers who don’t practise good hygiene — such as frequent and thorough hand washing — or who do not follow safe food handling procedures to prevent food contamination. 


Parasites, such as tapeworms and roundworms, are organisms that live on or inside humans or animals. They are excreted in faeces and can contaminate meat during slaughter and fruit and vegetables grown in soil fertilised with manure. 

People get parasites by consuming contaminated food or water, though transmission is rare because the majority of farm animals are treated to prevent parasitic infections. However, parasites such as anisakiasis — caused by eating parasite-contaminated seafood — and Cyclospora, a non-native parasite linked to some imported foods, have caused a number of illnesses and outbreaks in Australia. 


Most people will begin to experience the symptoms of food poisoning quite quickly after eating the contaminated food. However, it can sometimes take days, weeks or even months for problems to arise, depending on the bacteria involved. 

Food poisoning usually causes symptoms such as vomiting, diarrhoea or bloody stools, severe exhaustion or headaches, and fever. In high-risk groups, it can lead to organ failure, coma or death. This is why proper food service to vulnerable people is so important. 

Food Safety Laws and Regulations in Australia

Health and Community organisations and food businesses that process or serve food to vulnerable persons (‘vulnerable persons businesses’) must uphold extremely high standards of food safety and hygiene to: 

  • prevent food-borne infections, complications or death 
  • comply with Australian food safety laws and regulations 
  • protect the business or organisation from legal or financial consequences of causing illness 

It’s important that businesses and community organisations that cater to vulnerable populations understand their obligations under the law and comply with current food legislation requirements. 

Under Standard 3.3.1 of the Food Standards Code, the following food businesses in Australia are required to follow the protocols listed in the standard: 

  1. Food businesses that process or serve potentially hazardous food within a facility to six or more vulnerable persons at a given time 
  2. Food businesses that process food into ready-to-eat food for service in a facility, and the processed food is for six or more vulnerable people at a time and includes ready-to-eat potentially hazardous food 
  3. Food businesses that process food into ready-to-eat food for delivery by a delivered meal organisation and the food is served to six or more vulnerable people at a time and includes ready-to-eat potentially hazardous food 

Standard 3.3.1 of the Food Standards Code lists businesses that fall into the above categories. These businesses/organisations include (but are not limited to): 

  • acute care hospitals 
  • psychiatric hospitals 
  • aged care facilities 
  • child care centres 
  • hospices 

All food businesses in Australia to which the standard applies must also comply with Standard 3.2.1. of the Food Standards Code. Standard 3.2.1 states that food businesses that serve or process potentially hazardous food for service to vulnerable people are required to implement a documented and audited Food Safety Program. 

In some states and territories, additional regulations or requirements must be met. In New South Wales, a vulnerable persons business must also be licensed under the Vulnerable Persons Food Safety Scheme of the NSW Food Regulation 2015. Check with your local health authorities for more information on requirements for serving vulnerable people in your state or territory. 

What are Food Safety Programs?

A Food Safety Program will help you to determine, implement and manage the critical food safety procedures and protocols required to ensure that only safe, healthy food is served to the vulnerable people in your care. 

Food Safety Programs help to protect businesses or organisations from: 

  • the financial and legal consequences of causing a customer to fall ill with food poisoning or causing a food-borne illness outbreak 
  • the financial and legal consequences of causing a customer to have a severe allergic reaction from improperly handling food allergens 
  • losing customers/clients as a result of a reputation for unsafe food handling or unhygienic premises 

In the majority of food businesses and related organisations in Australia, the Food Safety Program is maintained by a Food Safety Supervisor, who plays a critical role in safeguarding food safety and hygiene in the facility. 

In order to comply with Standard 3.2.1 of the Food Standards Code, your Food Safety Program must: 

  • systematically identify the potential hazards that may be reasonably expected to occur in all food handling operations of the food business 
  • identify where, in a food handling operation, each identified hazard can be controlled and the means of control 
  • provide for the systematic monitoring of those controls 
  • provide for appropriate corrective action when that hazard, or each of those hazards, is found not to be under control 
  • provide for the regular review of the program by the food business to ensure it is working 
  • provide for appropriate records to be made and kept by the food business demonstrating action taken in relation to, or in compliance with, the food safety program 

Building a Food Safety Program

Food Safety Programs worldwide are based on the seven principles of HACCP. HACCP, which stands for ‘Hazard Analysis Critical Control Points’, is a systematic and preventative system developed in the 1960s by NASA and a team of food safety specialists at the Pillsbury Company. HACCP principles can be applied to processes at every stage of the food supply chain, including production, preparation, packaging and distribution, and is used to manage food safety across many types of food businesses.


Think of HACCP principles as the steps you need to take to manage and control food safety risks in your business. 

The seven principles of HACCP are: 

  1. Conduct a Hazard Analysis 
  2. Identify Critical Control Points 
  3. Establish Critical Limits 
  4. Monitor Critical Control Points 
  5. Establish Corrective Actions 
  6. Establish Record Keeping Procedures 
  7. Establish Verification Procedures 


Hazard analysis is a two-step process which involves identifying and evaluating all of the food safety hazards in your food business. 

A food safety hazard is anything that causes food to become contaminated (and therefore harmful or unsafe). There are three types of food contamination: 

  1. biological contamination (e.g. bacteria, viruses) 
  2. physical contamination (e.g. pieces of broken glass, metal staples) 
  3. chemical contamination (e.g. detergent, sanitiser) 

To properly identify a hazard, you need to be knowledgeable about the food (e.g. its properties and characteristics) and the steps that it goes through on its way to your customer’s plate (e.g. receiving, storage, prepping, cooking). A flow diagram can help you to visualise your product as it moves through your business. 

First, make a list of all biological, chemical and physical hazards that could occur as a result of: 

  • ingredients or additives in the food 
  • a step in your production / preparation process (e.g. receiving food deliveries, cooking food, serving food, disposing of waste) 

For example, you may identify that the following hazards could occur during the cooling step in your food production process: 

  • biological (growth of food poisoning bacteria) 
  • biological / physical (contamination of food by objects, e.g. hair, broken glass) 

Next, evaluate each hazard based on: 

  • how likely it is to occur 
  • how serious the consequences of it happening could be (e.g. Is it a public health risk? Could somebody get hurt?) 

Setting this information out in a table can help you to visualise and structure data so that it is easy to follow and understand. 


Now that you have identified all of the food safety hazards in your business, you need to identify your critical control points (CCPs). CCPs are the steps in your process where a control measure is applied and is necessary to prevent, eliminate or reduce a food safety hazard (or hazards) to an acceptable level. 

Identifying CCPs will help you to reduce the risk of food-borne illness in your business by helping you to prevent the growth of dangerous bacteria and other microorganisms, as well as to prevent cross-contamination between different types of food, which can trigger life-threatening allergic reactions in some people. 

Some examples of CCPs could be: 

  • the sign-off step when receiving deliveries 
  • cooking food to a specific temperature 
  • checking the temperature of food before serving 

If you identify a food safety hazard at a step where a CCP is necessary but does not exist, then the process must be modified to include a control measure. 


A critical limit is the maximum or minimum value to which a food safety hazard (biological, chemical or physical) must be controlled to prevent, eliminate or reduce the hazard to an acceptable level. Each CCP must have one or more critical limits for each hazard. 

Critical limits are generally concerned with parameters that are measurable with equipment or can be answered with a yes or no answer, such as: 

  • time 
  • temperature 
  • acidity 
  • best before / expiry dates

Critical limits must be assigned an actual value (e.g. high-risk foods must be cooked to a minimum internal temperature of 75°C*). Determining or assigning actual values to critical limits can be challenging, as there is such a wide variety of hazards, each with different acceptable values. Thankfully, information about critical limits can be obtained from a number of sources, including: 

If information is not available, make a judgement call — be sure to err on the side of caution, and keep a record of your reasons for making the decision and any reference materials you used in your Food Safety Program. 

*Cooking high-risk foods to an internal temperature of 75°C is a general rule, but different types of high-risk foods may have different minimum cooking temperatures. 


Monitoring must be done to ensure that food remains within the critical limits determined for each critical control point (CCP). Put simply, monitoring means performing an action to check that food is safe. 

Monitoring techniques can be broken down into four different categories: 

  • observation monitoring (e.g. checking cleaning schedules, monitoring delivery checklists) 
  • sensory monitoring (using taste, smell, touch and/or sight to check whether food is within critical limits) 
  • chemical monitoring (e.g. checking acidity levels, conducting a nutritional analysis) 
  • physical monitoring (e.g. checking food temperature, pressure, weight, etc.) 

The best way to make sure (and confirm) that monitoring is being done regularly in your establishment is by using checklists and other documentation to record the results. 


Corrective actions are the actions that must be taken if a deviation from an acceptable critical limit occurs. These are either immediate or preventative. 

An immediate corrective action is stopping a breach that is happening now. For example: 

  • throwing out contaminated food 
  • rejecting a food delivery with signs of pest infestation 
  • refrigerating food to keep it out of the Temperature Danger Zone (5°C–60°C) 

A preventative corrective action is stopping a breach from occurring in the future. For example: 

  • performing routine maintenance on equipment 
  • changing work procedures 
  • training staff to follow food safety best practices 

If corrective action must be taken, remember to record and communicate it to the appropriate person (or people) in the business.


Record keeping is essential to the effective operation of your Food Safety Program and must include an up-to-date hazard analysis and details of any corrective actions that have been taken in your food business. 

There are many day-to-day records associated with your Food Safety Program. For example: 

  • delivery checklists 
  • signed-off cleaning schedules 
  • temperature recordings 
  • pest inspection results 
  • staff training records 

All employees should know where the Food Safety Program is located, what they are responsible for doing (e.g. updating cleaning schedules, filling out temperature logs), when they need to do it and who to report issues to. It’s common for Health Inspectors to ask for these types of documentation during a food safety inspection, so be sure to store them in a safe place. 


It’s important that you perform an audit of your Food Safety Program at least once a year to verify that it is working as expected, and to identify opportunities to improve it. Once you have identified these opportunities (and you will), adjust your Food Safety Program and implement the necessary changes. 

During an audit, it is common for food businesses to: 

  • perform internal inspections 
  • enlist the services of an external auditor 
  • ask for employee feedback 

During an audit, ask yourself the following questions: 

  • Have we added any new products/dishes or changed any recipes? 
  • Have we changed any processes or food preparation steps? 
  • Have there been any changes to food safety laws or regulations that will impact operations? 
  • Are there any patterns in the records that point to an opportunity to improve? 

If you answered yes to any of these questions, you need to update your Food Safety Program.

Menu Considerations for Vulnerable Persons

There are a number of things that must be considered in a business or facility that processes or serves food to vulnerable populations. These include: 

  • control measures for potentially hazardous foods (also called ‘high-risk foods’) 
  • management of food allergies 
  • adhering to modified diet requirements 
  • controlling food brought in from outside the facility 


Some foods are more prone to contamination than others; nutrient-rich foods like meat, poultry, dairy and seafood provide the ideal conditions for food-borne bacteria like Listeria to live and multiply. 

Anyone can get sick with food poisoning from contaminated food, but vulnerable populations are less able to fight off these infections and more likely to develop serious complications like kidney failure, pneumonia or worse. In a ‘vulnerable persons business’ or facility, the menu should be designed with this in mind. 

All high-risk foods and ingredients should be received through approved suppliers, and specific control measures must be implemented when handling potentially hazardous foods to minimise the potential risks. 


Food allergies are on the rise in Australia. According to Allergy & Anaphylaxis Australia, food allergy affects 2% of adults and 4 – 8% of children under five. Recent data indicates that 10% of children aged under one year have a proven food allergy. 

Microscopic amounts of a particular food allergen can cause a life-threatening reaction. ‘Vulnerable persons businesses’ and facilities must implement effective controls to manage food allergies and train food handling employees to prevent cross-contamination. 

This is especially important in any facility where food is served to young children, who are at greater risk of dying from a severe allergic reaction. 


Where modified diets are required — to manage certain medical conditions, improve health outcomes or increase quality of life — clinicians should be consulted on dietary recommendations. 

For highly susceptible persons, a low microbial diet may be required. Low or no-sodium diets are frequently recommended for persons with high blood pressure, heart disease, diabetes or kidney disease. 


Vulnerable persons businesses and facilities should implement effective policies and procedures to manage food that is brought into the facility. 

This could be food that is brought in by friends and family of the person in the facility’s care, or it could be food that is sent into a controlled environment by parents or caregivers. A nut-free policy in a child care centre would be an example of this. 

Once you have developed your policy, you must also consider how you will: 

  • communicate the policy; 
  • enforce the policy; 
  • handle any transgressions; and 
  • regain control of the hazard. 

Top 10 Tips for Handling High-Risk Foods for Vulnerable Persons

Tips for managing high-risk foods for vulnerable persons include (but are not limited to): 

  1. Cook all meat, poultry and seafood thoroughly. 
  2. Buy packaged, whole portions of ready-to-eat meats and slice in a central processing unit or purchase meats pre-sliced from a licensed manufacturer with a Listeria management program. 
  3. Serve dairy products made from pasteurised milk. 
  4. Do not use any cracked or dirty eggs. 
  5. Cook eggs until the white is firm and the yolk thickens. 
  6. Use pasteurised egg in dishes which will not be cooked. 
  7. Inspect all fresh produce prior to use and remove dirty, cut, mouldy and bruised stock. 
  8. Wash all fruit and vegetables under running potable water. 
  9. Serve seed sprouts only if they are cooked. 
  10. Use any foods that could support the growth of Listeria monocytogenes (e.g. luncheon meat, soft cheeses, pre-cut vegetables, fruit and salads) within seven days. 

Of course, this is not an exhaustive list of all the food safety controls that must be in place to protect vulnerable groups from food poisoning and other health risks. 

The best way to ensure food safety in any food business or related organisation is to commit to food safety training and education. 

Food Safety Training

In most food businesses and related organisations in Australia, especially those that serve vulnerable persons in a private or public facility, food service employees complete nationally recognised food safety training. 

Food safety training teaches food workers about critical food safety concepts, such as: 

  • causes of food-borne illness 
  • time and temperature control of food 
  • safe food handling practices 
  • preventing cross-contamination 
  • managing food allergies 
  • health and hygiene requirements 

In most states and territories, at least one Food Safety Supervisor must be on staff at each of the business’s locations and ‘reasonably available’ to be contacted during all hours of operation. 

Food Safety Supervisors must complete a nationally recognised Food Safety Supervisor course, such as the Australian Institute of Food Safety (AIFS) online Food Safety Supervisor course

In New South Wales, Food Safety Supervisors must also obtain a Food Safety Supervisor certificate (also known as ‘the green certificate’) from a Registered Training Organisation, such as AIFS. There is no substitute for a skillful, engaged and well-informed staff when it comes to protecting your customers and your business from food safety risks. 

Fundamental food safety concepts and safe food handling procedures must be taught and repeated until they become second nature. Visual aids like posters, videos and checklists are a great way to reinforce food safety training. 

Contact the Australian Institute of Food Safety for details about our extensive library of food safety resources. 

About the Australian Institute of Food Safety

As Australia’s largest provider of food safety education, the Australian Institute of Food Safety is dedicated to helping organisations protect their business and their customers from food-borne illness. As a community focused organisation we deliver public health information to food businesses and consumers in order to improve food safety throughout Australia. AIFS delivers nationally recognised training that meets all federal and state compliance requirements related to food safety. This includes Food Safety Supervisor and Food Handler compliance training. The mission of the Australian Institute of Food Safety is to reduce food-borne illness within Australia by educating, advocating and promoting food safety.

Login to read more

Log in to read more.

To access this resource, become a AIFS Member today.

Already a member? Log in to continue reading.