Foodologists — Food Science Safety

R638 Knowledge Centre

R638 Food Handler Training Requirements Explained

A practical look at what Regulation 10 means for food handlers, the Person in Charge, assessments and training records.

Regulation 10 of R638 places responsibilities on the Person in Charge of a food premises concerning appropriate food-safety and hygiene training for food handlers, assessment and follow-up where necessary, and keeping training programmes and records available.

It is important to be clear about what this does — and does not — mean. R638 does not create a single nationally prescribed “Foodologists-style” course that every food handler must complete. Instead, Regulation 10 frames training as a responsibility to be met appropriately for the people and the premises involved. This guide explains those responsibilities in practical terms and points you to the official regulation so you can read it for yourself.

Prepared by Foodologists · Reviewed by Charnay Nefdt (BSc Biotechnology; Food Technology; Registered Facilitator; Registered Assessor)

What does Regulation 10 of R638 require?

Regulation 10 deals with the training of food handlers. In accessible terms, it makes the Person in Charge responsible for ensuring food handlers receive appropriate food-safety and hygiene training, that assessment and follow-up happen where necessary, and that training programmes and records are kept and available.

Rather than reproducing the full regulation here, we summarise its practical thrust: food handlers should be trained appropriately for the work they do, and a business should be able to show that the training happened and had an effect. For the exact wording — including short phrases such as “an inspector or any other suitable person” — read Regulation 10 directly in the official text.

READ THE OFFICIAL R638 REGULATION

Who is responsible for food-handler training?

Under Regulation 10, the Person in Charge of the food premises carries the responsibility for food-handler training and the related assessment, follow-up and record-keeping.

The Person in Charge does not necessarily deliver the training personally, but is responsible for making sure it happens appropriately. The flow below shows how these responsibilities fit together in practice.

PERSON IN CHARGE

Appropriate food-safety training

Food handlers

Assessment / follow-up

Training records

What does “adequately trained” mean?

In practical terms, training should be appropriate to a person's work and their food-safety responsibilities — not a one-size-fits-all quantity.

We do not invent a statutory definition where the regulation does not provide one. The sensible reading is that a food handler should understand the food-safety matters relevant to what they actually do — someone preparing raw ingredients, someone plating food and someone cleaning food-contact surfaces may each need emphasis on different points. The goal is genuine, relevant understanding rather than simply ticking a box.

Does R638 prescribe a specific course duration?

R638 does not set a specific universal number of hours that every food-handler course must run for.

We will not invent a prescribed duration. What matters under Regulation 10 is that training is appropriate and effective for the people and premises involved. A course should cover the relevant food-safety content properly rather than meet an arbitrary time figure.

Does R638 prescribe a single national curriculum?

R638 does not set out a single, fixed national curriculum that every provider must deliver identically.

Regulation 10 frames training as a responsibility to be met appropriately, rather than prescribing one uniform syllabus for all food handlers across the country. Training content should be suited to the food-safety responsibilities of the people being trained. For the precise wording, refer to the official regulation.

Does R638 require SETA or QCTO accreditation for every food handler?

R638 does not, by itself, state that every food handler must hold a SETA- or QCTO-accredited qualification. These are distinct things and should not be conflated.

It helps to keep three separate ideas in mind:

R638 food-handler training requirements

The responsibilities set out in Regulation 10 for appropriate food-safety training, assessment and records.

Formal occupational qualifications / skills programmes

Separate formal qualifications or skills programmes offered through systems such as SETA or QCTO. These are their own frameworks, distinct from R638.

Additional local-authority requirements

Any further requirements a relevant local authority may impose or communicate for businesses in its area.

Because requirements can differ from place to place, we encourage businesses to confirm the applicable local requirements with the Environmental Health Services of their relevant local authority.

Who can provide the training?

Regulation 10(1)(b) refers to training being provided by “an inspector or any other suitable person.”

This short phrase raises understandable questions about who counts as a “suitable person.” We examine it carefully — and avoid over-interpreting it — on a dedicated page.

Who Can Train Food Handlers Under R638?

Why is assessment important?

Assessment matters because training is not merely attendance — Regulation 10 addresses assessment to help determine whether training has had an impact, and follow-up where necessary.

Sitting through a session is not the same as understanding and applying food-safety practices. Assessment helps confirm that a food handler has actually absorbed the relevant knowledge, and it highlights where a refresher or additional support may be needed. This is what makes training meaningful in day-to-day practice.

Training records

Businesses should keep clear training records so they can demonstrate what training their food handlers have received and when.

Useful information to capture in a training record includes:

Learner name
Training date
Subject / course
Assessment outcome
Follow-up / refresher activity where applicable
Supporting certificate or completion record

This list is a practical suggestion to help with good record-keeping. It is not itself a prescribed national R638 form — for any specific record-keeping requirements, refer to the official regulation and confirm local expectations with your local authority.

Certificate of Completion vs Certificate of Acceptability

A Foodologists Certificate of Completion is evidence that a learner completed training and assessment. A Certificate of Acceptability relates to the food premises and is issued through the local authority. One does not replace the other.

Foodologists Certificate of Completion

Evidence that a learner successfully completed the specified Foodologists training and assessment. It relates to the individual and their training.

Certificate of Acceptability

Relates to the food premises and is issued through the relevant local authority under R638. It concerns the premises, not an individual's training.

A Certificate of Completion does not replace a Certificate of Acceptability, and vice versa. They are separate things.

Complete Guide to the Certificate of Acceptability

How Foodologists approaches training

Foodologists offers online R638-aligned Basic Food Safety Training — structured, assessed, and designed to give food handlers practical knowledge and businesses clear training records.

100% online

Complete it from anywhere, at your own pace.

Approximately 3 hours

A focused, practical programme.

12 months access

Revisit the material for a full year.

Structured modules

Clear, step-by-step food-safety content.

Assessment

Confirm understanding, not just attendance.

Certificate of Completion

Issued after successful completion.

Digital training records and business tools are available where applicable, making it simpler to keep your team's records in order. The training is R638-aligned; it is not government-, SETA- or QCTO-accredited, and completing it does not, on its own, address the separate matter of a Certificate of Acceptability for a premises.

Are you a food handler?

Build your practical food-safety knowledge with Foodologists Basic Food Safety Training.

START YOUR TRAINING

Do you own or manage a food business?

Train your food handlers and simplify your staff training records.

TRAIN YOUR TEAM

Frequently asked questions

Does R638 require food handlers to be trained?
R638 addresses food-handler training in Regulation 10, which places responsibilities on the Person in Charge regarding appropriate food-safety and hygiene training for food handlers. Businesses should read Regulation 10 in full and confirm how it applies to their premises.
Who is responsible for training?
Regulation 10 places responsibilities on the Person in Charge of the food premises. The Person in Charge is responsible for ensuring food handlers receive appropriate training, that assessment and follow-up take place, and that training programmes and records are kept and available.
Who can train food handlers?
Regulation 10(1)(b) refers to training being provided by “an inspector or any other suitable person.” We explore what this phrase means, and what it does and does not imply, on a dedicated page.
Does training have to be SETA accredited?
R638 food-handler training requirements are distinct from formal occupational qualifications or skills programmes offered through SETA or QCTO systems. R638 does not, by itself, state that every food handler must hold a SETA-accredited qualification. A relevant local authority may communicate additional requirements, so businesses should confirm what applies with their Environmental Health Services.
How often should food handlers be trained?
R638 does not set out a single universal frequency that applies identically to every business. Regulation 10 addresses assessment and follow-up where necessary. Businesses should provide appropriate initial training, follow up as needed, and confirm any specific local requirements with their local authority.
Do businesses need training records?
Regulation 10 addresses keeping training programmes and records available. Maintaining clear records makes it much easier for a business to demonstrate what training its food handlers have received.
Is an attendance certificate enough?
Regulation 10 addresses assessment, not merely attendance. Training is intended to have an impact on how food is handled, so assessment and, where necessary, follow-up matter. A record that shows successful completion and assessment is more meaningful than proof of attendance alone.
Does training guarantee a CoA?
No. Completing food-safety training does not constitute or guarantee a Certificate of Acceptability. A CoA relates to the food premises and is issued through the relevant local authority. Training and a CoA are separate matters.
Can R638-aligned training be completed online?
Foodologists provides online R638-aligned Basic Food Safety Training that can be completed online. Completing training is one part of a food business’s wider food-safety responsibilities.

Are you a food handler?

Build your practical food-safety knowledge with Foodologists Basic Food Safety Training.

START YOUR TRAINING

Do you own or manage a food business?

Train your food handlers and simplify your staff training records.

TRAIN YOUR TEAM

This information is provided for general educational purposes and should not be regarded as legal advice. Requirements may vary according to the nature of the food premises and applicable local-authority requirements. Businesses should confirm requirements with the Environmental Health Services of the relevant local authority.