The Implementation Sub-Committee (ISC)

Page last updated: 19 September 2013

The Implementation Sub-Committee (ISC) is a sub committee of the Food Regulation Standing Committee. Its role is to develop and oversee a consistent approach across jurisdictions to implementation and enforcement of food regulations and standards, regardless of whether food is sourced from domestic producers, export-registered establishments or from imports.

In achieving the above, ISC shall develop, or assist in developing, guidelines and other tools to aid in the consistent implementation of food regulations and standards.

The remit of ISC is to consider consistent approaches to implementation matters for food regulation or food standards across Australia, and where appropriate New Zealand. See the ISC Terms of Reference for more information.

ISC is not a food regulation policy body, a standards setting body or a regulatory authority in its own right. ISC is a mechanism whereby Australian and New Zealand food regulators may discuss common approaches to the implementation of food regulation or food standards and develop tools to assist in achieving consistent implementation. However, there will always be matters of detail in implementation that are solely the responsibility of jurisdictions (e.g. fees and charges), as the drivers for these issues are outside the remit of the current national food regulatory system (e.g. regional, economic and policy matters unique to jurisdictions).

The outcome to be achieved by jurisdictions in the food regulatory environment through ISC is national consistency in the implementation of benchmarks provided by national standards or regulations. This means that all jurisdictions agree that all food standards and regulations will be implemented, However it does not mean that all matters if details concerning how national benchmarks are implemented must be uniform.

ISC, through comprehensive evaluation tools, employs a system of continuous improvement to the tools and frameworks that it creates to assist in achieving national consistency in implementation of national benchmarks. These tools are supported by performance indicators to allow the value provided by ISC to the food regulation system to be measured and reported against.

ISC is also committed to on-going communications and engagement with its key stakeholders, to this effect, key discussion and outcomes arising from ISC meetings are provided on this website.

Implementation Sub - Committee Terms of Reference

Printable Version of ISC Terms of Reference (PDF 75 KB)

1. Membership

The Food Regulation Standing Committee (FRSC) shall have an ImplementationSub-Committee (ISC), with membership from each State/Territory jurisdiction andNew Zealand with cross representation with the Regulator’s Forum and AQIS, as wellas a representative of local government. These members will be either heads of theiragencies or operational experts at senior level with capacity to make and implementdecisions about enforcement issues in their jurisdictions. The membership willcomprise:
  • One Commonwealth representative from each of the following;− Department of Health -and Ageing (DoHA)− Department of Agriculture, Fisheries and Forestry (DAFF)− Australian Quarantine and Inspection Service (AQIS)
  • Food Standards Australia New Zealand (FSANZ)
  • One representative from New Zealand
  • Maximum of two representatives from each State/ Territory
  • One representative from Australian Local Government Association (ALGA)
The Chair is to rotate every 24 months and only State/ Territory and New Zealandrepresentatives are eligible for the position. FRSC will appoint the Chair

2. Terms of Reference

ISC is to develop and oversee a consistent approach across jurisdictions toimplementation and enforcement of food regulations and standards, regardless ofwhether food is sourced from domestic producers, export-registered establishments orfrom imports.
ISC will develop, or assist in the development of guidelines on consistentenforcement of food regulations, which will also be aimed at minimising cost toindustry and meeting the objective of minimum effective regulation.
ISC will be the Health Claims ‘Watchdog’. Its role as the Watchdog will be to:
  • assist FSANZ in the creation and maintenance of the guideline document;
  • provide recommendations to FRSC regarding proposed amendments to thestandards or guideline document;
  • receive consumer/industry complaints via ‘mailbox’;
  • forward evidence received on complaints to relevant jurisdictions for analysisand enforcement action;
  • monitor and record all complaints received and actions undertaken byjurisdictions; and
  • provide periodic reports to FRSC.
In undertaking its work, ISC will be required to consult with FSANZ to ensure thatthe ISC’s work is consistent with FSANZ’s statutory objectives for standards and toensure that FSANZ receives high level practical advice in relation to the potentialimpacts of its regulatory options.
ISC’s primary task is to develop and implement a national approach to enforcement,endorsed by FRSC, which will:
  • gain cross-jurisdictional agreement on the key elements of compliance andenforcement systems;
  • ensure consistent approaches, across jurisdictions, to the implementation ofboth domestic and export food regulations and standards, includingharmonisation to the extent possible;
  • develop a framework for implementation which clearly identifies therespective roles of industry and regulators, with appropriate protocols toensure consistency;
  • facilitate the integration of compliance verification services and the crossdesignationof public and private sector service providers, including localgovernment, through mutual recognition of compliance verificationprocedures such as inspection and audit; and
  • provide evaluation and verification mechanisms, including management ofindustry complaints of anomalies in enforcement, to monitor progress andfacilitate continuous improvement.
The national approach should also identify means to:
  • encourage cost-effective approaches to compliance and enforcement; and
  • ensure consistent interpretation of regulations and standards with appropriatecommunication to stakeholders; this will include processes to facilitate andmaintain on-going stakeholder engagement.
The engagement of local government authorities in development and implementationof the national strategy, through the ISC’s local government representative, is of highimportance.
The priority action for ISC will be to develop a draft of the national approach toconsistent implementation and enforcement for presentation to FRSC. When theapproach has been endorsed by FRSC, ISC will develop a detailed work plan forimplementation. The work plan, as agreed by FRSC, will form the basis for regularreporting by ISC to FRSC.