Who Can Train Food Handlers Under R638?

What does R638 actually say?

Regulation 10(1)(b) refers to the training of persons working on food premises being undertaken by “an inspector or any other suitable person.”

That short phrase is the starting point for any question about who may train food handlers. Importantly, the regulation does not attach a detailed list of qualifications or criteria to the words “suitable person.” Because the official text is the authoritative source, we recommend reading Regulation 10 directly.

What does “any other suitable person” mean?

R638 itself does not provide a detailed definition or a universal checklist for “any other suitable person.”

We will not invent criteria that the regulation does not contain. On its face, the phrase leaves room for interpretation, which is exactly why Foodologists approached the National Department of Health for written clarification — set out in the next section, based only on what that correspondence actually says.

National Department of Health, Directorate: Food Control — clarification

Foodologists sought written clarification from the National Department of Health, Directorate: Food Control regarding Regulation 10(1)(b). The summary below reflects only what that written correspondence states.

Internal or external persons. The Department indicated that “any other suitable person” may be an internal staff member or an external person who is able to provide appropriate food-safety training to food handlers. It noted that this could include the designated Person in Charge (PIC) or an external professional, such as a biotechnologist.

“‘Any other suitable person’ may be an internal staff member or an external person who is able to provide appropriate food-safety training to food handlers. This could include the designated Person in Charge (PIC) or an external professional, such as a biotechnologist.”

Whether specific qualifications are prescribed. The Department stated that R638 does not prescribe specific qualifications, competencies, experience or other formal criteria for determining who may be considered a suitable person to provide food-handler training.

“R638 does not prescribe specific qualifications, competencies, experience or other formal criteria for determining who may be considered a suitable person to provide food-handler training. The trainer should have appropriate food-safety knowledge and competence, supported by relevant qualifications, training and/or experience, and their suitability should be demonstrated through appropriate supporting evidence. The main aim is to ensure that food handlers receive the knowledge and skills needed to handle food safely.”

How suitability may be supported. As reflected in the quotation above, the correspondence indicates that a trainer should have appropriate food-safety knowledge and competence, supported by relevant qualifications, training and/or experience, with suitability demonstrated through appropriate supporting evidence.

National guideline or policy. Asked whether any national guideline, policy or other official document further defines or interprets the term, the Department answered: “No.”

What may help demonstrate suitability?

Drawing only on R638 and the Department's written clarification, suitability is about genuine food-safety knowledge and competence, supported by appropriate evidence — not a fixed statutory checklist.

On the basis of the correspondence, the following may help support a trainer's suitability:

These points reflect the Department's clarification and R638; they are not new legal requirements created by Foodologists.

About the Foodologists trainer

Foodologists training is led by Charnay Nefdt, whose background is in biotechnology and food technology, and who is a Registered Facilitator and Registered Assessor.

Notably, the Department's clarification gave “an external professional, such as a biotechnologist” as an example of who may be a suitable person — which is factually relevant to this background. These qualifications describe the trainer's expertise; they do not, in themselves, constitute government accreditation of Foodologists or its training.

What training does Foodologists provide?

Foodologists provides R638-aligned Basic Food Safety Training online, with structured content, assessment and a Certificate of Completion.

What about municipal requirements?

Local authorities enforce food-premises requirements within their jurisdiction, so businesses should confirm any additional local requirements with the relevant Environmental Health Services.

Requirements and expectations can differ between municipalities. While the Department's clarification addresses the national regulation, it does not override local enforcement. We do not claim that every municipality must accept a Foodologists certificate; the responsible step is to check directly with your local authority's Environmental Health Services.

Food-handler training vs formal qualifications

R638 food-handler training and formal SETA/QCTO occupational qualifications are two different things.

Food-handler training vs Certificate of Acceptability

Completing food-handler training does not itself provide or guarantee a Certificate of Acceptability.

Frequently asked questions