Self-service food displays

Driven by the larger supermarket chains, industry innovation has seen the development and implementation of new market concepts in relation to self-service food displays, such as Naked Foods. These are currently being installed throughout Western Australia. The Department of Health Food Unit has received a number of enquiries and concerns regarding these new market concepts in relation to the display of unpackaged ready-to-eat food for self-service.  Some concerns raised centre around the provision of protective barriers such as sneeze guards. New market concepts include the following:

Self-service of unpackaged bakery items

  • Unpackaged bakery items will be displayed on two or three tier units
  • Each item will have a strip of wrapping paper allowing customers to handle
  • Plastic bags and serving utensils will be provided
  • At close of business or when the last staff member leaves all unsold bakery items will be bagged
  • The display will be supervised, especially when attended by customers.

Self-service of unpackaged olive bars

  • Display units vary in design and may not be installed with a sneeze guard
  • Will be supervised at all times when attended by customers
  • Be provided with separate serving utensils and various sized containers.

Guidance to Enforcement Agencies

When determining compliance of any food business displaying unpackaged ready-to-eat food for self-service against the Australia New Zealand Food Standards Code (the Code), each should be considered on a case-by-case basis. Standard 3.2.2 clause 8(2) contains multiple safeguards to ensure food safety such as effective supervision, separate serving utensils and protective barriers. Therefore all elements of the clause need to be considered collectively.

Whilst it is acknowledged this concept has the potential for wider implications, a decision which is appropriate to all situations is prevented by variations in design of the display units and the potential for inconsistent in-house management practices to exist. Local government enforcement agencies are best placed to assess and determine compliance.

The following guidance is provided to assist Local Government Enforcement Agencies in inspecting and assessing food businesses displaying unpackaged ready-to-eat food for self-service.

The Code specifies the minimum requirements when displaying unpackaged ready-to-eat food for self-service. When assessing compliance of self-service displays against Standard 3.2.2 clause 8 of the Code, consideration to the following will be useful:

Clause 8 (1) Food Display statesA food business must, when displaying food, take all practicable measures to protect the food from the likelihood of contamination’

  • Consider the potential sources of contamination to the self-service display
    • Is the unit suitably located? eg not adjacent to an entry/exit door
    • Do non-food process areas impact on the self-service display unit? E.g. dust, pests or dirt from fresh fruit and vegetable displays
    • Is there a risk of contamination from other staff work practices not responsible for the supervision of the self-service display? E.g. cleaning.

Clause 8(2) A food business must, when displaying unpackaged ready-to-eat food for self service –

(a) ensure the display of the food is effectively supervised so that any food that is contaminated by a customer or is likely to have been so contaminated is removed from display without delay;

  • How is the self-service food display being effectively supervised? 
  • Is there an adequate number of staff, particularly during busy periods of operation?
  • How is it determined that food has been or likely to have been contaminated?
  • If food is contaminated, how is the affected food handled, i.e. removed from the display without further risk of cross-contamination?
  • Can skills and knowledge commensurate with duties be demonstrated?

(b) provide separate serving utensils for each food or other dispensing methods that minimise the likelihood of the food being contaminated; and

  • Are separate serving utensils or other dispensing methods available?
  • Are these in a clean and sanitary condition?
  • How often are these cleaned and/or changed?
  • Are the utensils adequate in length to ensure their handles do not fall below the top surface of display container?
  • What is the condition of the unpackaged food?
  • Is there any evidence of cross contamination between products?
  • Are customers using the provided serving utensils?

(c) provide protective barriers that minimise the likelihood of contamination by customers

  • Do the protective barriers minimise the likelihood of contamination?
  • Is food organised in such a way as to effectively utilise the protective barrier?
  • Does the design of the self-service display unit minimise the likelihood of contamination by customers? Eg tiered display
  • Does the depth of the unit make it difficult for customers to reach display containers without leaning over other unpackaged food?
  • What is the condition of the protective barrier/s?

Further points to consider

  • All elements of Standard 3.2.2 clause 8 of the Code need to be considered as a whole when determining overall level of compliance.
  • Does the food business have any relevant management practices?
    • Are there any in-house procedures relevant to self-service displays, such as a Food Safety Program?
    • If so, are they being adhered to?
    • Are there any relevant records available? For example, staff training / safe food handling practices, cleaning and/or temperature monitoring?
  • What is the overall condition of the self-service displays?
  • Are the display unit/s in a clean condition?
  • Is there any evidence of unclean practices?
  • Is there relevant labelling information available or available upon request?
  • How often food is turned over/replaced. Are there any records which support this?  


More information

Last reviewed: 17-11-2020
Produced by

Environmental Health Directorate