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: regulation 10(1)(c) of R638 requires the person in charge to run routine assessments of whether staff training is working, and 10(1)(d) requires training programmes and records to be kept, routinely updated and shown to an inspector on request. In practice that means one training register covering every person who works on the premises, with the course each person did, when, the certificate number, when it is due for refresher, and a dated record of you checking on the floor that they actually do what they were taught. The last part is the one most businesses leave out.
What regulation 10(1) actually asks for
- 10(1)(a): the person in charge is suitably qualified or adequately trained in food safety and hygiene, with accredited training where applicable.
- 10(1)(b): “any other person working on the food premises” is adequately trained, by an inspector or another suitable person.
- 10(1)(c): routine assessments are done to determine the impact of that training.
- 10(1)(d): training programmes and records are kept, routinely updated and made available to an inspector on request.
R638 does not prescribe a form, a refresher interval or how often to assess. That is your decision as person in charge, and the environmental health practitioner (EHP) will judge whether what you do is reasonable. Note the words in 10(1)(b): any other person working on the premises. Cleaners, casuals, agency staff and the student who helps on Saturdays all belong on the register.
What to record for each person
- Name and staff or ID number.
- Role and work area, for example “prep cook, cold kitchen” or “cashier, front counter”. The role decides the course.
- Start date, to show how soon they were trained.
- Course, level and provider: Person in Charge, food handler, hygiene awareness or an in house induction, and who ran it.
- Date completed and certificate number, with a copy of the certificate on file.
- Refresher due date.
- Floor checks: date, what you observed, result and any action.
- Signature of the person in charge who updated the line.
Keep the training programme with the register too. Regulation 10(1)(d) asks for programmes, not only records, so file the course outline or, for in house sessions, a one page note of what was covered and how long it took.
A simple register layout
| Name and staff no. | Role and area | Course and provider | Completed and certificate no. | Refresher due | Last floor check and result |
|---|---|---|---|---|---|
| Example: owner, staff no. 001 | Person in charge named on the COA | Persons in Charge, accredited provider | Date and number as printed on the certificate | Your chosen date | Not applicable, does the checks |
| Example: cook, staff no. 014 | Hot kitchen, day shift | Food handler course | Date and certificate number | 12 months after completion | Date, pass on hand washing, did not know chiller limit, retrained same day |
| Example: cleaner, agency | Cleaning, all areas, nights | Hygiene awareness course plus in house chemical induction | Date, certificate number, induction note signed | 12 months after completion | Date, pass, correct dilution and colour coded cloths |
One line per person per course. When someone leaves, mark the line as left with the date rather than deleting it, so the history stays.
Refreshers: what R638 says and what I recommend
R638 sets no refresher period. My own rule for clients: hygiene basics before the first shift, the formal food handler course in the first weeks, and a refresher every 12 months. I also retrain straight away after a failed floor check, a new process, new equipment or a food safety incident. For the person in charge, I recommend retraining when the role changes or the regulations change. Write your rule at the top of the register so the EHP can see you follow it.
The register starts with the person in charge
The first line an EHP looks for is the accredited training of the person named on your COA. 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.
How to run the quarterly floor check
This is the “routine assessment” in regulation 10(1)(c). A certificate proves someone sat a course. A floor check shows whether it changed what they do. I suggest once a quarter for every food handler, and more often for new staff.
- Pick five or six behaviours tied to R638: hand washing at the moments listed in regulation 11(1)(c), no jewellery on people handling unwrapped food (regulation 10(9)), clean protective clothing (regulation 9), keeping raw and ready to eat food apart, and reporting illness (regulation 11(2)(b)).
- Watch without announcing it for ten to fifteen minutes during normal work, ideally at a busy time.
- Ask two questions, for example “What temperature must this fridge be below?” and “What do you do if you have a runny tummy before your shift?” Annexure E gives the fridge answer.
- Record the result on the register line: date, pass or needs work, and what you did about it.
- Close the loop. If someone needs work, retrain and check again within a set number of days, and record that too.
What an EHP asks to see
From inspections I have attended with clients, the requests are fairly consistent:
- The person in charge’s training certificate, from an accredited course where applicable.
- The register, and whether everyone working that day is on it. Expect the EHP to compare the register with the people on the floor.
- Certificates or attendance records behind each line.
- Evidence of assessment under 10(1)(c), meaning your floor check entries.
- The record of staff illness reports kept under regulation 10(15).
The common gaps: casual and agency staff missing, a register last updated a year ago, and no evidence of any assessment at all. If you want the register on a phone with refresher reminders, see our post on paperless R638 records. For who needs which level of training, see who needs which course, and for covering every shift, a person in charge on every shift.
Questions about the training register
Does in house training count? Yes for staff other than the person in charge. Regulation 10(1)(b) allows training by an inspector or another suitable person. Record what was covered, who gave it, how long it took and how you checked understanding.
How long must I keep training records? R638 does not set a period for training records. The 6 month rule in regulation 10(16) applies to processing, production and distribution records. I advise keeping each person’s records for as long as they work for you and for a while after they leave.
Do agency staff go on my register or the agency’s? Yours. They work on your premises, so regulation 10(1)(b) applies to you as person in charge.
Need certificates to put on your register? Enrol your team on the food handler course.
