R638 for a butchery: the COA, the training and the hazards that trip butchery owners up

By Mthokozisi Nkosi, Food Scientist, SAATCA Registered R638:2018 Lead Implementer (SAATCA register RG003), Lead Auditor registered with Exemplar Global and IRCA, Founder of ASC Food Safety Consultants. Updated November 2026.

Short answer: a retail butchery is a food premises under R638, so it needs a Certificate of Acceptability (COA) from the municipality, issued in the name of a trained person in charge, and every butcher, packer and cashier needs food safety training. R638 also has butchery specific rules: daily cleaning of the bandsaw, mincer, filler, tenderiser and vacuum packer (Annexure F), chill limits for meat, offal and poultry (Annexure E), and rules on where your meat may come from (regulation 12). Those three are where I see owners caught out.

Meat Safety Act or R638: which one covers your shop?

Owners often assume the vets who inspect the abattoir also cover the butchery. They do not. The Meat Safety Act, 2000 deals with slaughter. Section 7(1) says animals may only be slaughtered at an abattoir, and meat may only be sold if it was slaughtered at one. Abattoirs are registered under section 8, and the Act is run by national and provincial veterinary services.

Once the carcass reaches your shop to be cut, minced and sold, you are under R638: a COA from the municipality and inspections by its environmental health practitioner (EHP). R638 links the two laws in three places:

• R638 defines “meat” as meat from an animal slaughtered at an abattoir registered under section 8 of the Meat Safety Act.
• Regulation 12(1)(a): you may not handle meat from an animal slaughtered in contravention of the Meat Safety Act. Section 7(2) of that Act allows slaughter for own consumption or for cultural or religious purposes, but that meat may not be sold to anyone.
• Regulation 12(1)(b): if your premises cut or store meat from such an exempted animal, for example a customer’s ceremonial sheep, you must display a notice to that effect in letters at least 18 mm high.

Keep every abattoir invoice. Regulation 10(18) requires traceability and a recall procedure, and for a butchery that starts with showing which abattoir each carcass came from.

The equipment an EHP opens up

Regulation 6(8) points to Annexure F, which sets out how the bandsaw, tenderiser, filler, mincer and vacuum packer must be cleaned: at least once a day, with detergents and disinfectants registered with the National Regulator for Compulsory Specifications (NRCS), the machine dismantled, parts scrubbed in hot water at 40 to 60 °C with detergent, then washed with disinfectant and rinsed.

In an audit I check the bandsaw top wheel and scrapers, the mincer plate and its seat, and the filler nozzles first. For a machine not listed in Annexure F, regulation 6(9) allows your own documented cleaning procedure showing how it is taken apart.

Temperatures: offal and chicken are colder

Annexure E sets the core temperature for chilled food in storage, display and transport:

• Edible offal and poultry meat: 4 °C or colder.
• Other perishable food, which covers your beef, pork and lamb cuts, mince and wors: 5 °C or colder.
• Food sold as frozen: minus 12 °C or colder.

Regulation 8(4)(a)(ii) adds that chilled or frozen food may not be sold if the core is above the limit or the surface is more than 2 °C above it. Every chiller, freezer and display needs a readable thermometer (regulation 6(5)(a)). Mince warms up first in a display fridge opened every minute on a Saturday morning. Check it then, not at 7am.

If you collect carcasses yourself, regulation 8(4)(b)(iii) relaxes the chill limit during delivery for one hour at most, with the surface no warmer than 25 °C. Regulation 12(4) requires a vehicle used only for meat, with an impervious lining, carcasses hanging from stainless steel hooks clear of the floor, and no tarpaulins or cloths.

About the provider: ASC Food Safety is an Exemplar Global Recognised Training Provider, with 28 of its auditor, HACCP, GMP and ISO courses recognised.

Habits R638 names that only butchers have

Regulation 11(3)(f) reads as if written for butchers. It forbids spitting on whetstones, putting meat skewers, labels or other tools in your mouth, and blowing up sausage casings or bags by mouth. Regulation 11(1)(c) requires hands to be washed after handling money and after handling raw meat and before handling ready to use food.

That matters if you sell biltong or polony from the same counter as raw mince. The World Health Organization lists deli meats and ready to eat meat products among the high risk foods for Listeria, which can grow at fridge temperatures. South Africa’s 2017 to 2018 listeriosis outbreak, with 1 060 cases and 216 deaths, was traced to ready to eat processed meat. Keep a separate slicer, tongs and display for ready to eat products, and never let someone go from raw meat to biltong without washing hands.

Labelling applies too. Under the R146 labelling regulations unpacked raw meat needs no label, but for raw processed meats such as boerewors, patties and marinated cuts the list of ingredients, including allergens, must be available at the point of sale on request. If your wors contains rusk or a spice blend with soya, someone behind the counter must be able to say so.

Who in a butchery needs which course

• Owner or manager named on the COA: the Persons in Charge course.
• Head butcher or foreman who runs the shop when you are off: also Persons in Charge. Team seats are 5 for R7 645 or 10 for R14 440. See a person in charge on every shift.
• Butchers, sausage makers, packers and biltong staff: the Basic Food Safety Practices for Food Handlers course.
• Cashiers and cleaners: at least the Basic Food Hygiene Awareness course (R420, about 4 hours).

Keep those training records for the inspector (regulation 10(1)(d)). The general split is in who needs which course.

Before you apply

Use the COA application checklist and our municipal COA guide. Buying an existing butchery? The seller’s certificate does not pass to you (regulation 3(9)(a)), so read what to do as a new owner. To have the shop checked before the EHP comes, book a pre-COA audit.

Questions butchery owners ask

The abattoir I buy from is registered. Does that cover my shop? No. The abattoir’s registration under the Meat Safety Act covers slaughter at the abattoir. Your shop needs its own COA under R638.

We make biltong on site. Anything extra? Biltong is ready to eat, so keep the drying, cutting and packing apart from raw meat work. Regulation 10(14) says ready to eat food may not be touched with bare hands unless it cannot be avoided.

Ready to train the person on your certificate? Enrol on the Persons in Charge course.