R638 for a shisanyama or takeaway: the COA, the training and the hazards that trip shisanyama 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: yes, a shisanyama, braai stand or takeaway needs a Certificate of Acceptability (COA) from the municipality. R638 defines food premises to include a building, stall, stand, vehicle or “place” used for handling food, so an open air braai area counts. The certificate is issued in the name of a trained person in charge, and everyone who works there needs food safety training, including weekend casuals. The hazards that trip owners up are specific to the trade: raw meat moving between customer, braai and plate, chicken browned outside and raw inside, pap left standing for hours, and too few toilets for a full Saturday crowd.

How food moves through a shisanyama

A restaurant keeps raw meat in the kitchen. A shisanyama puts it in front of the customer. People choose meat from a display fridge, staff carry it to the braai, and it comes back cooked on a platter with pap and chakalaka. Each hand over is a chance for raw juice to reach cooked food.

• Use colour coded trays and tongs for raw and cooked meat, so a new casual can follow the rule.
• Regulation 11(1)(c)(vi) requires hands to be washed after handling raw meat and before handling ready to use food. The braai staff need a hand basin with soap and disposable towels or another hygienic way to dry hands close to the fire, not only in the kitchen.
• If you cut, mince or make your own wors, you are running a butchery as well, and Annexure F of R638 sets daily cleaning steps for the bandsaw, mincer and filler.

Your meat must also come from a legal source. Regulation 12(1)(a) of R638 forbids handling meat from an animal slaughtered in contravention of the Meat Safety Act, 2000, and section 7(2)(b) of that Act says meat from an animal slaughtered for own consumption or for cultural or religious purposes may not be sold. Keep your supplier invoices. Regulation 10(18) requires traceability.

Temperatures on the braai and in the pots

R638 sets limits for food in storage, display and transport, not cooking temperatures. Annexure E requires:

• Raw chicken and offal (such as livers and mala mogodu before cooking): 4 °C or colder.
• Other raw meat, wors, salads and coleslaw: 5 °C or colder.
• Hot food on display, such as pap, gravy, stews and chips in a bain marie: 60 °C or hotter.

For cooking, I use the World Health Organization’s Five Keys to Safer Food, which the City of Cape Town publishes on its website: cook meat and poultry thoroughly, make sure the juices of meat and poultry run clear, not pink, bring soups and stews to the boil so they reach 70 °C, and ideally use a thermometer. A probe thermometer is cheap. Push it into the thickest part of a chicken quarter, close to but not touching the bone.

Regulation 8(4)(b)(i) allows perishable food that is sold or eaten on the premises within four hours of preparation to be kept outside the Annexure E limits. That makes a busy service possible, but you must be able to show the environmental health practitioner (EHP) when each pot was made. Write the time on tape on the lid. Raw meat in the display fridge gets no such allowance. The same guidance says cooked food should not stand at room temperature for more than two hours, so leftovers at closing go into the fridge, not onto the counter until Sunday.

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

The premises: smoke, toilets and the yard

Smoke and soot. Regulation 5(2)(b) requires food to be protected from smoke, soot, dust and insects, and regulation 5(3)(e) says a food room may not connect directly with an area where fumes or soot could contaminate the food. Place the braai so smoke does not blow over the salads or open pots.

Toilets for customers. Regulation 5(3)(d)(i) and Annexure D set the number of toilets, urinals and hand basins by population, which means staff plus the most customers eating on the premises at one time. For a population of up to 60, Annexure D asks for 2 toilets, 3 urinals and 3 hand basins for men, and 5 toilets and 3 hand basins for women. Plan for a packed Saturday, not a quiet Tuesday.

Waste. Bones, fat and food scraps need liquid proof bins with close fitting lids (regulation 5(3)(d)(iii)), and regulation 10(4) to 10(6) require refuse to be removed often and bins to be cleaned. Do not pour braai or fryer fat down the drain. Regulation 10(7) requires waste water to be disposed of to the municipality’s satisfaction.

Takeaway packs. Regulation 7(5) requires perishable food served to the customer to be packed in a container that protects it, except meals eaten on the premises. Lidded containers, not an open plate covered with a serviette.

A COA does not replace your liquor licence, zoning or business permits. Regulation 3(5)(c) says the certificate does not approve trading without meeting other municipal requirements and laws.

Who at a shisanyama needs which course

• Owner or manager named on the COA: the Persons in Charge course.
• The weekend floor manager or head braai master: also Persons in Charge, because the owner is often not on site at the busiest hours. Team seats are 5 for R7 645 or 10 for R14 440. Read why in a person in charge on every shift.
• Braai staff and the cooks making pap, stews and salads: the Basic Food Safety Practices for Food Handlers course.
• Waiters carrying platters, cashiers and cleaners: at least the Basic Food Hygiene Awareness course (R420, about 4 hours).

Regulation 10(1)(b) covers “any other person working on the food premises”, so the extra hands you call in for month end weekends count too. Put them on your training register (regulation 10(1)(d)). For the general rules, see who needs which course, and before you apply, work through the COA application checklist and the municipal COA guide.

Questions shisanyama owners ask

I braai at events from a trailer. Do I need a COA? Yes. R638 includes a stand, caravan or vehicle used for handling food. Our post on starting a food truck business covers mobile set ups.

The EHP found problems on my last visit. Where do I start? See what the person in charge must do after an inspection.

Ready to get your certificate in order? Enrol on the Persons in Charge course.