MPI Update S39-0004 Detailed Changes

This article will outline the detailed changes in MPI for version S39-004 that link to changes in Safe Food Pro


MPI has released new changes to the Food Control Plan changing from version S39-0002 to S39-0004. The new template food control plan can be Simply Safe and Suitable S39-0004, highlighting the changes that have been made in this new version. There will be changes in the Food Control Plan template that affect your business, so please ensure you review it to stay up to date with the latest updates. 

We've broken down the changes that will affect how you use Safe Food Pro in this article below. 

In this Article


Reheating Food and Cooling Food 

Previously you had to record cooling every time that you did it. Under the changes, you can prove your cooling (and reheating) methods and once you have proven your process you only need to carry out a batch check once a week, rather than checking the process every time.

What form does this relate to in Safe Food Pro?

You can schedule these forms based on your chosen method. 

  • Proving your Cooling Method 
  • Cooling Food - Batch Check (This is adapted from our original form Cooling Food Check) 
  • Cooling Food Every Time 
  • Reheating - Proving reheating method
  • Reheating - Batch Check (This is adapted from our original form Cooling Food Check) 
  • Reheating - Every Time

Managing self-supply water

If you supply your own water for the business then there has been a change of what you need to record for your Verifier. 

You now need to show your verifier any chemical hazards you have identified and how you control these. 

What form does this relate to in Safe Food Pro?

We have updated the information panel to match these changes in the water supply check - roof or "non-secure" water system

Check out the MPI Managing self-supply water information here.


Knowing what's in your food and how to label it 

There are now 21 Allergens that must be declared. The Separating Food Green Card identified you must "know what allergens are in the food you sell - you must be able to tell customers, using the required allergen name, if they ask or include this information on the packaging. "

"Your verifier may ask you and your staff to explain how you/they know whether the foods made or served contain allergens, and the required allergen name to describe them."

This means you can no longer use general terms like shellfish, seafood, tree nuts, nuts, cereals containing gluten, or dairy to describe an allergen. You must use one of the allergens below: 

  • Eggs
  • Peanuts
  • Milk
  • Soy
  • Sesame
  • Lupin
  • Gluten (barley, oats, rye, wheat)
  • Wheat
  • Fish
  • Crustacea
  • Mollusks
  • Sulfites
  • Almonds
  • Brazil nuts
  • Cashews
  • Hazelnuts
  • Macadamias
  • Pecans 
  • Pine nuts
  • Pistachios
  • Walnuts

There are some other allergens that you may need to declare on your product, These have special rules for how to declare them. These are Royal jelly, Bee pollen, and Propolis. 

What form does this relate to?

  • Allergens on the Menu form which is found in the Ad Hoc list to identify what menu items have one of the above allergens. 
  • Beginning of Day - Opening Checks which are scheduled for Daily by default list the 21 allergens and ask if staff are trained in the allergens. 

Labelling Food

Where you declare your allergens depends on what type of label your product is required to have. 

Here's a summary of what to do under the new rules: 

  • Use required allergen names 
  • List allergens in bold font
  • Use mandatory contains statement
  • Use individual nut names of the 9 specified tree nuts
  • Use fish or mullusc or crustacea as appropriate
  • List wheat as a separate allergen to gluten 

What form does this relate to?

We have a form called Labelling Checklist found in the Ad Hoc list to walk you through the requirements when labeling food. 

Check out the MPI Allergens Labelling information here.


Recalling your food

As of 1 July 2023 (for existing businesses) you must test your recall procedures using a likely scenario once every 12 months. 

What form does this relate to? 

You will find a form  Mock Recall on the This Month tab every July. You can change the schedule of this form to suit your business mock recall process. 

Check out the MPI Recalling your food link to learn more.


Making Sushi

You can now make sushi with acidified and non-acidified rice. Sushi made with non-acidified rice cannot be kept for as long as sushi made with acidified rice. 

  • If rice is too acidic with a PH of less than 3 you may harm your customers 
  • If rice is not acidic enough with a PH of more than 4.3 bad bugs can grow 
  • When making non-acidified white or brown rice you must follow the 'Cooling freshly cooked food' card to cool cooked rice

What form does this relate to? 

We have updated the PH range to notify you if the PH exceeds the range of 3 - 4.3. 

  • Sushi rice - batch check
  • Sushi Rice - Proving the cooking method 

Check out the MPI Making sushi link to learn more.

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