Despite the ‘AQIS approval’ having been discontinued about 9 years ago, we still get quite a number of enquiries about this subject. This update might be useful explaining what happens now with chemical compounds approvals.

Please feel free to call our technical department for advice. We are always delighted to help.

AQIS Approvals for Chemical Compounds
August 2020

1. Background

Until 2011, AQIS (Australian Quarantine and Inspection Service, part of the Australian Government Department of Agriculture, Fisheries and Forestry (DAFF)) issued documents called ‘Instruments of Approval’ (IOA) and ‘letters of acceptance’ for chemical compounds used in AQIS inspected premises, such as those that export meat to the USA.

AQIS instruments of approval and letters of acceptance are no longer issued by AQIS for any chemical compounds.

The AQIS approvals process was a means of assuring that the chemical compound complied with the requirements of the US FDA (Food and Drug Administration of the United States of America).

In addition, some food companies ask for AQIS approvals for chemical compounds such as cleaning liquids, lubricants and pesticides as a way of checking that the product is ‘food safe’.

2. AQIS/DAFF requirements for chemicals used in export meat establishments

The old AQIS approvals system has been replaced by a new system for Department of Agriculture Export Registered Establishments.  This new system only applies to export registered establishments.

The new system relies on declarations of suitability from the manufacturer of the chemical compound.

2.1 Requirements for food businesses

Before using a hazardous substance (including but not limited to cleaning and sanitising chemicals, hand soaps, pesticides and lubricants) the export establishment must obtain[1]:

  1. i) A declaration of assurance from the supplier or manufacturer of the substance, which has been signed and dated by a qualified chemist.
  2. ii) A copy of a Safety Data Sheet (SDS) for each hazardous substance used at the establishment.

iii) Any necessary evidence to substantiate fit for purpose of any hazardous substance

such as list of ingredients, instructions for use and/or evidence of general acceptance.

2.2 Requirements for suppliers of chemicals

The chemical manufacturer must make their own declarations as to the suitability of substances for use in food export establishments.

 3. AQIS approvals and food safety audits

AQIS approvals (also called DAFF approvals) for chemical products, including cleaning chemicals, hand soaps, lubricants and pesticides are NOT, in themselves, a requirement for food safety audits, unless the business being audited is exporting meat[1].

Most commonly, auditors will look for an auditable due diligence process, conducted internally or through third party certification. This is to satisfy themselves that products that present a food safety risk have been appropriately assessed and found to be fit for purpose.

If a product is not AQIS/DAFF approved, that does not mean that it is not safe.  It could mean that the chemical supplier has not submitted it to AQIS for approval or that its previous approval has expired.

Food businesses need to be able to demonstrate to food safety auditors and regulatory inspectors that the chemicals used in their facilities are food-safe and fit for purpose.  There are a number of ways to demonstrate this.

If you require assurances about the food safety aspects of a chemical compound, ask the supplier or contractor.  They should be able to provide you with an independent assessment or registration such as a HACCP International certificate or a certificate of compliance to ISO 21469:2006 (lubricants).

[1] Information about Hazardous Substances – Version 2 – February 2017 – (Australian Department of Agriculture and Water Resources)

[2] Department of Agriculture Export Registered Establishments.  See Section 4 of this document for requirements for these establishments.

4.  More information

For further information on the AQIS/DAFF programs and the new manufacturer’s declaration requirements for export meat establishments, visit the page below:

https://www.agriculture.gov.au/export/controlled-goods/meat/elmer-3/new-chemicals

For advice about third party certification from HACCP International, this or any other food safety matter contact HACCP Australia on 02 9956 6911 or info@haccp.com.au