4 FOOD SAFETY CULTURE – Food and Drink – Good Manufacturing Practice, 7th Edition

4
FOOD SAFETY CULTURE

Principle

An effective food safety culture, in combination with a comprehensive food safety management system (FSMS) built on hazard analysis critical control point (HACCP) principles, embeds the planned and formal aspects of food safety through the shared values and operational norms of individuals and groups working in the business.

Background

4.1 There is much academic and food industry interest in food safety culture: what it is, how to identify the type of culture that exists within an organisation and how to measure its effectiveness. Following the work of Deming, Juran, Feigenbaum, Ishikawa, Shingo, Crosby and others, quality culture as a topic in itself has been considered within manufacturing businesses for over half a century. This short chapter can only be an introduction to the subject and aims to signpost elements of food safety culture that should be considered within manufacturing operations. Food safety culture as an element of good manufacturing practice (GMP) sits within an overall consideration of organisational culture not only with regard to the scope of the manufacturer’s activities, but also the wider supply chain. Again, organisational culture is a topic that has gained much interest in terms of academic, industry and contemporary writing and can only be touched upon in this chapter.

An organisation’s formal food safety culture is built upon a set of values and intentions, often formally defined in the mission statement or associated policies. The formal culture is then implemented based on the attitudes and exhibited behaviour of the staff that work for that organisation. These formally espoused values and intentions sit alongside both shared and individual informal values, beliefs and intentions that influence attitude and behaviour and it is the combination of the formal and informal aspects that create the organisation’s overall food safety culture. Food safety culture is influenced by, and in turn influences, how the FSMS is adopted and its efficacy.

Food safety culture has to be led from the top, by the person with overall responsibility for the manufacturing business, and be a central factor in all their communications and decision making. The senior management team need to show ownership of food safety and identify the need for accountability at all levels of the organisation and provide the resources and environment to ensure that food safety controls can be adequately and consistently implemented. If staff perceive that it is acceptable within the organisation to consider food safety as being less important within a whole raft of issues that can arise, profitability, allocation of resources, rewarding of individual for actions they have taken, operational performance targets, and so forth, then that will potentially lead to a food safety incident. Food safety culture, as with an organisation’s quality culture, has been classified in the past as good or bad, positive versus negative and the aim of this chapter is not to state what these terms look like in practice. Instead this chapter has been written to create awareness of food safety culture and its influence on consistently manufacturing safe food for the consumer. The formalised aspects of food safety have been addressed in depth in other chapters of this Guide so it is the informal aspects that are considered here.

Communication and Messaging

4.2 Food safety values are communicated within a manufacturing organisation through information sharing and messages given to, and received from, staff. Some of these communications are visible within the FSMS and others operate at an invisible level in terms of verification activities (see Chapter 11). Visible communications include emails, information sheets, training materials, procedures, work instructions and more formal policies. Training of staff relies both on information and the need to demonstrate relevancy of that information to a given job role or set of responsibilities. Increasing knowledge and greater understanding of risks alone will not necessarily lead to an attitudinal or behavioural response. Individuals may, faced with a series of barriers or constraints, and conflicting messages about business priorities and expectations, simply filter out what they believe is achievable in their work environment or simply comply with the cultural norms of the organisation. In fact, the given formal and informal elements of culture of a manufacturing organisation can either empower individuals or conversely can fail to provide adequate resources to enable adoption of appropriate practices. This can reduce the motivation of staff to improve what they do and minimise food safety risk or just simply encourage staff to comply with prescribed procedures even when they know they could be improved.

Perceived or actual conflict in the prescribed aims and objectives of specific job roles, e.g. between senior management and other levels of management, or between engineering, quality and production staff, means that multiple cultures can exist within a manufacturing organisation and indeed may also flourish, often causing internal conflict and reducing the effectiveness of the FSMS. Griffith’s model of food safety culture1 has three concentric (as in an onion) levels of culture:

  • Level 1 – Food safety climate: The outermost layer of food business culture that is considered during verification, auditing and inspection activity and is observable. This level of food safety culture can be modified depending on the situation and the internal and external conditions or constraints, e.g. lack of resources, people, or even the presence of the auditor/inspector.
  • Level 2 – Underpinning culture: The middle layer includes the organisation’s espoused values (often unspoken) and guides the employees’ behaviour and attitudes to authority and legislation. Depending on the depth of verification activity, this level of culture can be examined and measured. (The depth of audits is considered more fully elsewhere in the Guide, see 11.8.)
  • Level 3 – Core culture: The innermost layer that contains all the beliefs and assumptions by staff as individuals or groups about what the organisation stands for. This level includes core values that are invisible and often assumed. Depending on the depth and scope of any verification activity this level may remain hidden (see 11.8).

Each manufacturing business will be different in terms of the exact combination of these levels of culture and thus will have a unique food safety culture that influences the degree of effectiveness of the FSMS. The type and quality of the verification activity will determine the level of understanding of the overarching food safety culture in the manufacturing organisation and the types of subcultures that may exist and the impact of this dynamic on the effectiveness of the FSMS.

4.3 The link between the effectiveness of the FSMS and the associated food safety culture of the organisation is clear. The British Retail Consortium (BRC) Standard for Food Safety (Issue 7) states that it is through the use of unannounced audits that there can be greater confidence in the food safety culture of the manufacturing organisation. In partnership with Campden BRI and Taylor Shannon International (TSI) the BRC have developed a food safety culture module adopted alongside the annual BRC Global Standard for Food Safety verification audit. This is just one of a growing number of food safety culture assessment tools.

Food Safety Culture Assessment Tools

4.4 A number of tools have been developed to assess food safety culture, including food safety culture questionnaires, behavioural observation and the development of tools that underpin system review and the development of performance indicators. Assessment tools such as the BRC Food Safety Culture module are based on two questionnaires, one completed by staff and the other by a third‐party auditor. As a result the site will receive a score based on the overarching food safety culture and then supplementary categories: people, process, purpose and proactivity. A manufacturing organisation is graded based on the score achieved as a result of the assessment. An action plan can then be implemented to address weaknesses and areas where corrective action is required.

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