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: yes, the kitchen in a care home, old age home or frail care unit needs its own Certificate of Acceptability (COA) from the municipality, in the name of a trained person in charge, and that is separate from the facility’s registration with Social Development. Every cook and kitchen assistant needs food safety training, and so do the carers who serve trays and help residents eat. Care home kitchens carry more risk because the people eating are the most likely to become seriously ill: the World Health Organization names the elderly among those at greatest risk of severe listeriosis.
Two registrations, two different inspectors
Section 18(1)(a) of the Older Persons Act, 2006 says no one may operate a residential facility for older persons unless it is registered. That registration is with the Department of Social Development. It does not cover the kitchen under food law.
The kitchen is a food premises under R638, so regulation 3(1) requires a valid COA, issued after an inspection by the municipal environmental health practitioner (EHP). Regulation 3(5)(c) also works the other way: a COA does not approve anything under other laws. You need both.
If a contract caterer runs your kitchen, settle in writing who the person in charge is. R638 defines the person in charge as a natural person who is responsible for the food premises, or its owner. The COA is issued in that person’s name (regulation 3(5)), and if they change, the municipality must be told in writing within 30 days (regulation 3(8)). When the catering contract changes hands, so does that duty.
Why the menu matters more here
The WHO says Listeria can survive and multiply at normal fridge temperatures, that invasive listeriosis has a mortality rate of 20 to 30%, and that high risk foods include deli meats and ready to eat meat products, soft cheeses and cold smoked seafood. South Africa’s 2017 to 2018 outbreak, with 1 060 cases and 216 deaths, was traced to ready to eat processed meat.
That shapes the menu. Polony sandwiches for supper, soft cheeses and smoked salmon at a birthday tea are exactly the foods the WHO lists. Your fridge must hold at 5 °C or colder (Annexure E of R638), but cold storage slows Listeria and does not stop it. I advise care home kitchens to cook or buy these foods for the meal they are served at, and to discard opened packs quickly rather than keep them for the week.
The steps a care home kitchen adds
Texture modified meals. Minced, soft and pureed diets add steps after cooking: blending, portioning and often cooling and reheating. Each step is extra handling of cooked food. The blender must be taken apart and cleaned like any other food contact equipment (regulation 6(4)), and blended food must not stand at room temperature. The City of Cape Town’s Five Keys guidance, based on the WHO’s, says cooked food should not be left at room temperature for more than two hours and should be held at 60 °C or hotter if served hot.
Tray service to wings and rooms. Food leaves the kitchen hot and travels down corridors and in lifts. Hot food must be kept at 60 °C or hotter (Annexure E). Regulation 8(4)(b)(i) does allow food eaten on the premises within four hours of preparation to be outside those limits, but for frail residents I set a much tighter target. Cover every tray (regulation 8(3)) and check the temperature of the last tray served, not the first.
Individual diets and allergies. Residents on diabetic, low salt, allergen free or texture modified diets need a current diet list in the kitchen, updated when the nursing team changes it. R638 treats unintended allergens as contamination (regulation 5(2)(b)).
Food brought in by families. Visitors’ cakes and takeaways end up in lounge and room fridges. Set a written rule for labelling, dating and discarding them, and check those fridges.
Who is the person in charge of your care home kitchen?
Whether it is your catering manager or the facility manager, regulation 10(1)(a) requires that person to be trained, with accredited training where applicable. The ASC Food Safety Practices for Persons in Charge course is on the SAATCA register for R638 Person in Charge training, is HPCSA CPD accredited and is run by a FoodBev SETA accredited training provider. It is fully online, self paced, and ends in a video proctored assessment.
About the provider: ASC Food Safety is an Exemplar Global Recognised Training Provider, with 28 of its auditor, HACCP, GMP and ISO courses recognised.
When staff or residents fall ill
Stomach bugs move fast through a residential facility. Regulation 11(2)(b) says a person who has reported, or is suspected of, a condition likely to be passed on through food, including diarrhoea, vomiting, fever, jaundice or a sore throat with fever, may not handle food until a medical practitioner certifies them fit. Regulation 10(15) requires those reports to be recorded and kept for the inspector.
In a care home, the risk is not only in the kitchen. A carer who has just helped a resident with diarrhoea and then carries a lunch tray is handling food. Regulation 11(1)(c) lists when hands must be washed, and your care staff need to know that list as well as your cooks do.
Who in a care home needs which course
- Catering or food service manager named on the COA: the Persons in Charge course.
- Weekend and evening kitchen leads: a care home kitchen runs every day of the year, so train a second and third person in charge. Team seats are 5 for R7 645 or 10 for R14 440. See a person in charge on every shift.
- Cooks and kitchen assistants: the Basic Food Safety Practices for Food Handlers course.
- Carers, nurses and volunteers who serve trays, make tea in the wing pantries or feed residents: at least the Basic Food Hygiene Awareness course (R420, about 4 hours). R638 defines a food handler as anyone who directly handles food or food contact surfaces in their normal work.
Record all of it. Regulation 10(1)(d) requires training records to be kept and shown to an inspector on request. The general rules are in who needs which course, and the application steps in the municipal COA guide and the COA application checklist.
Questions care home managers ask
We are registered with Social Development. Is that enough? No. Registration under the Older Persons Act and a COA under R638 are separate requirements from separate authorities.
Our caterer says the COA is in their name. Are we covered? If the caterer’s manager is the person in charge of the kitchen and the COA is current for your premises, yes. If that manager leaves or the contract ends, the municipality must be told within 30 days and a new COA issued.
Do the carers really need food training? If they serve food, make drinks or help residents eat, they handle food. Regulation 10(1)(b) covers every person working on the premises.
Ready to train your kitchen and care team? Enrol your person in charge.
