Culture is increasingly cited in reports and papers related to food safety incidents and outbreaks and is also being identified as a significant emerging risk factor in food quality and food fraud. Sterling Crew reviews its evolution and adoption into food safety management systems, solutions and standards.
A culture of food safety
Food safety culture has become the Zeitgeist of the food business world. It is increasingly recognised that the most significant challenge for food businesses is to introduce a positive culture of food safety into their operations and create a behaviour-based Food Safety Management System (FSMS). The safety culture of a food organisation is the product of individual and group values, attitudes, competencies and patterns of behaviour that determine the commitment to and the style of proficiency of an organisation’s food safety programme[1]. Food safety culture is governed by the behavioural science of individuals and teams and how they are conditioned by their working environment. Every food business large or small has a safety culture, be it positive or negative and whether it is recognised by the organisation or not.
Most food businesses have comprehensive and prescriptive rules for food safety practices. The challenge is to ensure that they are being followed at all times, regardless of the situation. This is where culture and understanding behavioural drivers plays an important role. For example by using techniques from nudge theory to make safe behaviour habitual and ingrained. Training on its own can give a false sense of security. Trained food handlers can still demonstrate a dangerous gap between their knowledge of food safety handling practices and their application of these principles in the workplace. Just because food handlers know why they should follow a practice does not mean they will do so. Only by understanding and influencing food handler behaviour will we be able to embed food safety in an organisation’s culture and drive behavioural improvement. A strong food safety culture will ensure that good practice is not only understood but also, more importantly, being followed. Real food safety culture is what happens when senior leaders, managers and supervisors are not present and individuals are left to their own devices. Food safety must be embedded in the business values. Priorities may well change in an organisation depending on the circumstances but values do not.
Effective management of behavioural interactions is essential to develop positive attitudes to drive food safety[2]. Unsafe behaviour simply results in unsafe food. A positive food safety culture can only be delivered as a result of concrete action; it is bespoke – not a one size fits all proposition. Standards have recently been designed to help food organisations of all sizes promote and maintain a positive culture of food safety and quality. They provide a framework for evaluating what is often perceived by food scientists as an ethereal soft science.
Effective management of behavioural interactions is essential to develop positive attitudes to drive food safety.
The Global Food Safety Initiative
The Global Food Safety Initiative (GFSI) is the pre-eminent food industry programme, which provides leadership, guidance and harmonisation on food safety management systems across the global food supply chain. Since its inception in 2000, GFSI has brought together stakeholders representing the global food industry to collaborate on advancing food safety. Its mission is to deliver continuous improvement in FSMSs to ensure confidence in the delivery of safe food to international consumers.
In 2018 the GFSI produced a high profile position paper[3] in which it defines food safety culture as ‘shared values, beliefs and norms that affect mindset and behaviour toward food safety in, across and throughout an organisation.’ This has elevated the visibility of food safety culture and has given it an important stamp of approval and credibility, signalling a clear message to the supply chain of the importance of the business safety culture in maintaining food safety standards. The GFSI position paper is broken down into five dimensions (Table 1). Each dimension explains in practical terms the importance of advancing a culture of food safety. It has been developed to help food organisations strengthen and maintain a positive and mature food safety culture and to protect global consumers. The paper will help food organisations structure, analyse and assess their progress.
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| Table 1 The GFSI position paper on culture of food safety is broken down into five dimensions |
BRC Global Standard for Food Safety
The leading GFSI-recognised certification programme in the UK is the BRC Global Standard for Food Safety[4], with over 26,000 certified suppliers in over 130 countries. Recently there have been a number of high profile food safety incidents reported in the media from sites with satisfactory BRC audit scores, indicating that the system needs to be improved. One of the responses of BRC to further strengthen the standard has been to include food safety culture in the new Global Standard for FoodSafety Issue 8. It was published for public consultation in August 2018 with the first audits starting on the 1st February 2019. The main focus has been on the development of product safety and quality culture. It is the first GFSI-recognised food safety programme to include requirements specifically for culture.
Section 1 of Issue 8 covers Management Commitment. The new requirements state ‘Thesite’s senior management shalldefine and maintain a clear planfor the development and continuingimprovement of food safetyculture. This shall include: definedactivities involving all sectionsof the site that have an impacton product safety, an action planindicating how the activities will beundertaken and measured, and theintended timescales, and a reviewof the effectiveness of completedactivities’.
It is very important to recognise that it is not BRC’s intention to actually measure an organisation’s food safety culture. Instead it is encouraging sites to consider the importance of culture and the development and creation of plans of action and the evaluation of their success. These are measurable objective requirements that can be documented and audited. Auditors will not be attempting to audit the ethos of the site but will be looking at how sites have implemented a food safety culture plan. Auditors will inevitably be spending more time with the food business’s senior leadership and management teams discussing the company’s organisational culture and how it is managed. As this is a completely novel concept, many sites might well be concerned about its implementation. However, they should see this as the first step on a journey of food safety culture continuous improvement. Linked in part to the standard is an additional clause that requires companies to have a confidential reporting system to give voice to employees.
Culture Excellence Programme
In response to demand from its membership, Campden BRI (the UK’s largest independent membership based organisation for research and development in the food and drinks industry) has developed its own Culture Excellence Programme[5]for the measurement, analysis and improvement of organisational culture. The Culture Excellence Programme was launched in 2014 and includes assessment, analysis, reporting and ongoing support to food businesses. Campden BRI developed the programme in partnership with Taylor Shannon International (TSI).
The programme’s objective is to understand and improve a business’s food safety and quality culture. The participants in the scheme are assessed by an online anonymous staff survey broken down into four main areas (Table 2) with more than 500 individual scored data points. The programme is fully aligned with the GFSI approach. It is designed to capture cultural data and use it for continual improvement. A recent global survey by Campden BRI amongst its members’ technical managers found that the respondents placed food safety culture as the fundamental factor in delivering product safety.
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| Table 2 The Campden BRI Culture Excellence Programme is broken down into four dimensions |
Regulation
There are no requirements in UK food legislation relating directly to culture. However the Food Standards Agency (FSA) developed a Food Safety Culture Diagnostic Toolkit in 2012 for inspectors[6]. This investigative tool is for the use of local authority personnel undertaking food hygiene inspections to help identify aspects of food safety cultures prevailing in food businesses and as a framework to influence business values. Food businesses can adopt some of the tool’s exercises to help determine what level of culture exists in their organisation. This would have the added benefit of a shared nomenclature with inspectors.
For regulators, it can help to support enforcement decisions and the provision of advice. It aims to help inspectors understand and categorise the ethos of a business by classifying food safety culture into a series of groups (Table 3). Food Standards Australia and New Zealand have also produced useful self-assessment tools with a guide to what good safety culture looks like. It is clear that successful and sustainable food safety must go beyond formal regulations. A behavioural based approach will help to drive compliance.
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| Table 3 The FSA has classified various food safety cultures inbusiness into five groups |
The key requirements of UK food legislation, found in The Food Safety Act 1990, are to ensure food business operators do not include or remove anything from food or treat food in any way which means it would be damaging to the health of people eating it. Food must meet consumers’ expectations in terms of nature, substance and quality and must not be misleadingly presented. The Act covers activities throughout the food distribution chain, from primary production through distribution to retail and catering.
A defence which is available to the strict liability in the Act is one of due diligence. The Act states ‘It shall be a defence for theperson in charge to prove that hetook all reasonable precautionsand exercised all due diligence to avoid the commission of the offence by himself or by a person under his control’. Food businesses do not have to establish their case beyond all reasonable doubt. They need only persuade the court that they exercised due diligence on the balance of probabilities. Being able to demonstrate an effective food safety culture could play a part in a potential due diligence defence and may contribute to the decision made by regulators on the appropriate course of legal action. They would be more likely to prosecute ‘calculative noncompliers’ than ‘leaders’.
The current economic climate has resulted in budget cuts at both the FSA and local authorities. Therefore it is likely that greater emphasis will be placed on earned recognition and autonomy, whereby businesses can demonstrate their ability to comply with food law. Enforcing authorities are likely to reduce the number of visits and focus on organisations that present a higher risk. A strong focus on food safety culture could be a key part in building confidence in any future inspection programme, as a behavioural based approach will support compliance. Businesses that can demonstrate strong FSMS’s will have the advantage of reducing the frequency of inspections.
A key influencer in the development of national and global legislation is the Codex Alimentarius, or ‘Food Code’. This forms a global rule book that everyone in the food supply chain can follow. It is a collection of standards, guidelines and codes of practice adopted by the Codex Alimentarius Commission. The Commission is the central part of the joint FAO/WHO Food Standards Programme and was established to protect consumer health and promote fair practices in food trade. Currently there is discussion on the value of a behavioural based approach; if this is incorporated into Codex, it is likely that legislators will implement the food safety culture method into statute.
Evolution and drivers of food safety culture
The landscape of food safety has gone through a paradigm shift, where principles of behavioural science now blend seamlessly with food science and technology and success is measured through behavioural consistency, organisational culture and team dynamics. There is a new appreciation that a positive food safety culture is an essential component of an effective FSMS. In many ways the evolution of behavioural based FSMSs is analogous to that of Hazard Analysis Critical Control Point.
Certification bodies have made a significant contribution to enhancing food safety, quality and the fight against fraud[7]. Such certification is frequently a condition of trading for many food businesses and lack of certification can even be a barrier to entry into some market places. Compliance is often a fundamental requirement for leading brands, retailers, manufacturers and food service organisations. The compulsory adoption of food safety culture standards by BRC will undoubtedly stimulate the global uptake of the behavioural-based FSMS approach. Other stakeholders, including shareholders, insurance companies and venture capitalists, are likely to influence uptake of the standard. These organisations are used to using culture as a measure of capability and resilience that can be linked to an improved financial position and the mitigation of risk. Legislators also increasingly recognise that successful and sustainable food safety must go beyond formal regulations.
The concept of culture is relatively new to global food organisations but it is quickly gaining traction. It is no longer a case of ‘if’ business culture impacts food safety but ‘how’ it does and how best to achieve behavioural-based FSMS implementation and improvement. Food safety culture has come of age and 2019 may be the year of delivery driven by the increasing need to meet customer requirements and international standards. This will play a major role in ensuring confidence in the delivery of safe food to consumers.
Sterling Crew FIFST, FCIEH, FRSPH, CEnvH, CSi.
Managing Director SQS Ltd. Strategic Advisor Shield Safety Group and Dynamic Risk Indicator, Chair of the IFST Food Safety Group, Independent Scientific Advisor and Board member of Campden BRI, Audit Governance. Board member Eurofins auditing
Emailsterlingmcrew@aol.com
References
1. Crew, S. Journal of the IFST volume 28 issue 4 December 2014.Delivering a food safety culture. – Presented at the IFST Golden Jubilee Conference.
2. Yiannas, F. Food Safety Culture, Creating a Behaviour Based Food Safety System (Springer, 2009).
3. A culture of food safety: A position paper from the Global Food Safety Initiative. V1.0-4/11/18.
4. BRC Global Standard for Food Safety. Issue 8.2018.
5. Building strong food safety cultures with effective training programs. Campden BRI.2017
6. The Food Standards Agency .Food safety culture diagnostic toolkit for inspectors. 2012.
7. Crew, S. Journal of the IFST volume 31 issue 1 March 2017. Food safety through recognised certification.
