Hygiene Management Personnel and Certified Professionals: Who a Food Factory Must Appoint

Legal Basis and Scope

Article 11 of the Act Governing Food Safety and Sanitation requires food businesses of categories and scale designated by the central competent authority to appoint hygiene management personnel; details follow the Regulations Governing the Appointment of Hygiene Management Personnel in Food Manufacturing Factories (食品製造工廠衛生管理人員設置辦法), whose current text found at the time of writing was last amended on April 9, 2019.

Article 2 of the Regulations states the scope directly: food manufacturers required to register a food factory under the Factory Management Act and related rules. Article 3 requires such food manufacturing factories to appoint a full-time hygiene manager who actually carries out GHP or HACCP work at the factory.

Do Frozen Food Factories Need One?

It depends on whether the factory is "required to register as a food factory." As long as a frozen dumpling or frozen bun factory reaches the scale requiring factory registration, it must appoint a full-time hygiene manager under Articles 2 and 3 of the Regulations; this doesn't depend on product category. For the factory scale threshold, see Standards for Food Factory Buildings and Equipment.

Businesses below factory scale that make and sell in a shop are outside the scope of these Regulations, but GHP Annex 2 still requires food businesses to designate a "hygiene supervisor" to fill in hygiene management records daily. The two names are similar, so keep them distinct: the former is a full-time position with qualification requirements that must be filed with the health bureau; the latter is a daily management requirement GHP places on all food businesses.

Qualifications

Under Article 4 of the Regulations, anyone with one of the following qualifications may serve as a hygiene manager:

1. A graduate of a relevant department or institute (food, nutrition, home economics, applied life sciences, animal husbandry, veterinary medicine, chemistry, chemical engineering, agricultural chemistry, biochemistry, biology, pharmacy, public health, etc.) at a public or registered private junior college or above (or a foreign junior college or above recognized by the Ministry of Education).
2. Passed the senior civil service examination or an equivalent special examination in a relevant field above.
3. Passed the junior civil service examination or an equivalent Grade C special examination in a relevant field above, with at least 3 years of documented work related to manufacturing food or food additives.

There are also two special provisions:

• Central kitchens or meal box food factories (Article 5): May be filled by someone holding a Class B Chinese Cuisine Cooking technician certificate who has completed at least 120 hours of hygiene training and holds a certificate from a recognized institution.
• Food manufacturing factories with capital under NT$30 million (Article 6): May be filled by someone meeting all three conditions: graduated from a designated vocational high school program such as food science, food processing, baking, or food service management; at least 4 years in manufacturing or process quality control at a food factory of the same business entity; and a certificate of at least 60 hours of HACCP training from a recognized institution. This article took effect on July 1, 2020.

Additional Training for HACCP Sectors

If the factory is among the businesses required to implement HACCP by TFDA notice under Article 8, Paragraph 2 of the Food Safety Act, then under Article 7 of the Regulations, the hygiene manager must, in addition to meeting Article 4, have one of the following:

• At least 60 hours of HACCP training; or
• A food technologist, animal husbandry technologist, veterinarian, aquaculture technologist, or dietitian license, plus at least 30 hours of HACCP training.

Filing and In-Service Training

• Filing (Article 8): When appointing a hygiene manager, submit the declaration form, personnel data card, qualification documents and ID, a copy of the contract, and factory registration documents to the municipal, county, or city health authority for filing; resubmit when personnel change.
• Duties (Article 9): Implementing and supervising GHP; drafting, implementing, and supervising HACCP; other food hygiene management and employee training.
• In-service training (Article 10): At least 8 hours of hygiene training per year held by the competent authority or a recognized institution.

Certified Professionals and Technicians

Article 12 of the Food Safety Act is a separate system: food businesses of designated categories and scale must employ a certain proportion of food, nutrition, food service, and other professionals holding professional or technical licenses, under the Regulations Governing the Appointment and Management of Professional or Technical Certified Personnel in Food Businesses (食品業者專門職業或技術證照人員設置及管理辦法, last amended November 6, 2020). The proportion of certified cooks in the food service sector is also set by these regulations. Applicability likewise depends on the designated categories and scale.

Under Article 47, Subparagraph 4 of the Food Safety Act, violating Article 11, Paragraph 1 or Article 12, Paragraph 1 is punishable by a fine of NT$30,000 to NT$3 million.

FAQ

Q: Do frozen food factories need a hygiene manager?
A: Under Articles 2 and 3 of the Regulations Governing the Appointment of Hygiene Management Personnel in Food Manufacturing Factories, every food manufacturer required to register a food factory must appoint a full-time hygiene manager.

Q: What qualifications does a hygiene manager need?
A: Article 4 of the Regulations: a junior college degree or above in a relevant field such as food, nutrition, chemical engineering, or biology; or passing the senior civil service exam in a relevant field; or passing the junior exam plus 3 years of relevant work experience. For factories with capital under NT$30 million, Article 6 also allows someone with a relevant vocational high school diploma, 4 years of experience, and 60 hours of HACCP training.

Q: Does the hygiene manager have to attend training every year?
A: Yes. Under Article 10 of the Regulations, at least 8 hours of hygiene training per year.

Q: Does a small eatery need a hygiene manager?
A: The appointment regulations apply only to businesses required to register a food factory; but GHP Annex 2 requires all food businesses to designate a hygiene supervisor to fill in hygiene management records daily.