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In the draft copy of the BRC version 8 document, the BRC added a Food Safety Culture clause to the Senior Management Commitment section.  In this post we’re going to start working through what the BRC mean by Food Safety Culture and why they’ve added it…

The clause

The following clause was added to the draft document of version 8:

“The site’s senior management shall have a documented strategic plan for the development and continuing improvement of food safety culture. This shall include:

  • defined activities involving all sections of the company
  • an action plan indicating how the activities will be undertaken and intended timescales
  • review of the effectiveness of completed activities”

Reference:  BRC Global Standard Food Safety, Issue 8, Draft for Industry Consultation, (November 2017)

Why?

In order to understand what they mean by this clause, we need to understand why they’ve added it in the first place.

There have been a number of issues over the last few years, which has lead food manufacturers and their retail customers to hit the news.

The meat industry has been hit hard recently, with the FSA implementing increased inspections at meat sites, which has in turn resulted in a production ceasing in a number of factories.

So, it’s not surprising that the BRC have reviewed the requirements of version 7 to see if it covers this type of incident.  BRC previously launched Food Safety Culture as a new module, but it is optional.  Consequently, it seems they have decided it shouldn’t be optional, and so, have incorporated it into the main part of the standard.

Food Safety Culture Module

To understand what the BRC are looking for, it is probably a good idea to understand what was included in the Food Safety Culture Module.

The module is based on the use of a survey system.  This survey has been developed by TSI, together with a number of other bodies, called Culture Excellence.

On subscribing to the system, you are provided with a link to an employee survey.  This survey is completed by your employees and is also completed by your BRC auditor as part of your audit.

This information is then collated into a report and provides you with a culture score. The score gives an indication to the employees opinions, attitude and behaviour towards food safety.

What does the clause require?

Well let’s break it down and pick out the important aspects…

A documented strategic plan

“The site’s senior management shall have a documented strategic plan for the development and continuing improvement of food safety culture.”

Strategic means long term goals and the means of achieving them. So, a strategic plan is a set of cultural goals and the steps and actions that you’re going to take to achieve them.

The clause is also very clear that this has to be documented.  So, being able to talk through the plan isn’t enough, the auditor will need to actually be able to see it written down.

Development and continuing improvement

“The site’s senior management shall have a documented strategic plan for the development and continuing improvement of food safety culture.”

This means that we need to develop a good food safety culture, and then even once it’s good, we need to be continually monitoring it and looking for ways to improve it.  This needs to be part of the plan.  Therefore, the plan will need to include measures to be able to assess how the site is performing on food safety culture indicators.  To measure indicators, you’ll need to decide what indicators you’re going to use.

One indicator, that BRC will probably expect, given the previous food safety culture module is an employee survey.  The BRC are suggesting that the use of this is one solution, but your site may already have an employee survey in place that you can adapt, or you may want to develop and implement your own.  It doesn’t have to be an expensive solution, creating a survey on Survey Monkey could work for example.

Food safety culture

“The site’s senior management shall have a documented strategic plan for the development and continuing improvement of food safety culture.”

So, we know we need to have a documented plan. We know this plan needs to include activities to develop a good food safety culture, and that we need to define and measure the food safety culture indicators to see how we are doing.

But what do they mean by food safety culture?  In the draft document for version 8, they didn’t define what they meant by culture. So, here are my thoughts on it…

A general definition of culture would be something like this:

The thoughts, beliefs, customs and behaviours of a particular group of people.

The term food safety culture, in my mind isn’t the best – as it implies that it’s just food safety that we should be thinking about.  When in actual fact, culture affects everything we do; quality, legality and integrity.

What we need to do, I believe, is think about ‘food safety’ culture as ‘doing the right thing’ in all regards when manufacturing food.  If you had to label it, I would use the term ‘food integrity’ culture, as this covers food safety, quality, legality as well as the ethics of doing the right thing.

The culture of a factory, can be described in two parts:

  1. The mindset of the people
  2. The behaviours of the people

Mindset is made up of the thoughts and beliefs of a person.  This mindset, then causes them to behave in a particular way.  This behaviour can also be split into two parts:

  1. Unconscious behaviour
  2. Conscious behaviour

The unconscious behaviour is where you do something without thinking.  It’s second nature to you, so you don’t even have to think about it.  A bit like if you fall, your automatic reaction is to put your arms out to save yourself.

The conscious behaviour is where you are faced with something that isn’t second nature, so you have to actually decide what you’re going to do. When making this decision you use your mindset (thoughts and beliefs) and you also take into consideration any pressures of the situation; which may be persuasion or intimidation from other people around you.

So, when BRC say food safety culture, what they mean by this that the people at your site display the correct unconscious behaviours and also when faced with a decision, they display the right conscious behaviour.

Sounds simple?

Err no, definitely not!  There are so many problems with this clause, that are going to make it difficult to achieve, but over the next few articles I’ll work through what issues I think we need to overcome.
I’d love to know what you think about the clause in the draft version of BRC 8 and what issues it will cause – please just put your comments in the comments box below.  You don’t need to add your name if you don’t want to (you can put a fake name or even avatar name if you like) and your email address won’t be shared with others – so you’re safe to say exactly what you think!
culture survey

If you’d like a download of our 10 Culture Survey Questions, just complete the form below and we’ll email it to you. You will then be added to our BRC Culture list so we can update you about our solutions for this area of compliance within BRC Issue 8.

23 Comments

  • Food safety culture in an organisation is one of those areas where there is no grey middle ground, the staff are either engaged with it and it being part of their mindset, or they dont have it at all. The KPI for this is the quality of your products, the customer complaints, even the GMP audits. If you are going around your own site and you can see people just not bothering to follow procedure, or showing a reduced level of care in their work, then you need to seriously look at the ehole ethos of food production. When your staff have a pride in their jobs and their products and the company, you wont find a better workforce for producing quality and safe food. So maybe the answer is a survey but not just about how they feel or understand food safety, but by also looking at morale boosting projects and ways of involving the staff in new products or developments on site. Make them feel part of the company and that they not only matter but can make a difference and the majority of them will reward that effort with dedication and pride.

    • Kassy Marsh says:

      I agree, I think the sites that will immplement this effectively are those that will probably have the ‘right’ culture anyway. My main concern is that we are using this to tackle those that don’t want to do the right thing. The few that don’t do it right – are causing more work for the majority who do. And, at present I struggle to undestand how a survey will change the mindset of the top management at these few sites. I’m keeping a very open mind though – I am looking to be enlightened! 🙂

  • Tech Mrg says:

    Hi Kassy,

    Once again, great article and certainly makes us TM think about the reality of HOW to demonstrate compliance to this clause. We all like to think that we work in an environment that already embraces the Food Safety Culture but how do we show this?? My immediate thoughts are:

    1. Would the auditor be satisfied with speaking to employees in the factory, like a verbal questionnaire?
    2. Is there any real value in spending money on surveys when we only have <50 staff? Surely there must an alternative?
    3. Is this going to be like Section 5.4 – we spend months debating the best way to capture and implement and come audit date, it is simply looked over and the box ticked ?
    4. The plan itself sounds very much like quality KPI's – do you think that this approach would be enough? Currently I have targets and measures which are assessed monthly and presented to site and Management.

    I certainly do like change for the better but I really do hope this clause doesn't become the nemesis of Version 8 – afterall we have enough to do in the day job !

    Great that we are discussing now.

    • Kassy Marsh says:

      Thank you! I think the auditor may make their own mind about the culture of the site, by talking to employees and what they find on the audit. But, they will be looking for a documented plan because that’s what the standard asks for. It doesn’t seem to state a survey HAS to be the way to go, so I’m thinking we can be creative in how we gather evidence on the culture. I think this subject is more complex than section 5.4, so if the auditors are not trained properly (like 5.4) it may turn into a tick box audit. I don’t think our current KPIs will be enough, we’d have to add some culture KPIs. Let’s keep talking about it, we need to be prepared!!!

  • Michael Nuernberger says:

    Hi Kassy
    As always a great pleasure to read your article.
    I somehow would doubt that compliance to this section will depends on how it will be measured and how as a company you will be able to demonstrate that. I would almost lean towards the NSF International Maturity Model in order to map out where the company sits and over time “hopefully” moves forward.
    A key feature of the model is that it maps where a business sits in terms of the standard and robustness of its food safety systems, against where it aspires to be.

    • Kassy Marsh says:

      Hi, oh I’ve not heard of that before! I’ll take a look into that, thank you for sharing this with us all!

  • Clem Griffiths says:

    I am assuming you are from the UK and if you are correct then I applaud you folks on that side of the pond, however I am in North America and I have a different perspective .
    I belive there is work to be done in this area in about 60 to 70 percent of all food companies and the objective evidence is seen in the fact that the FSMS is retained only because it is mandated by the customer, is executed properly on a part time basis only generally the last 4 months prior to a recertification visit and food safety champions have not emerged to fill the gap in each processing area to the extent needed to deliver product safety qality and legality.
    The solution is not this clause but rather to better utilize the instruments we have to deliver food safety to the public. The mandate and activities of regulatory authorities federal and provincial or state wide should be integrated . One example, there is no need for unannounced visits because after your BRC audit your federal and local authorities show up unannounced and working with BRC can adjust your BRC audit standing if I you arenot “walking the talk “. Think of the implication of that “AA” being dropped to a “C” or annual visits being downgraded to semi -annual and the culture will improve rapidly.
    What are my qualifications to say this you may ask ? 35 years QC/QA across multiple food sectors and 3 years auditind to SQF,FSSC and 9001.

    • Kassy Marsh says:

      Hi,
      Thanks for your insight into what it’s like in America. Combining audits and inspections is an interesting thought and one that’s been recommended too here by Professor Chris Elliott. He thinks we should share our supplier audits too. It does make you wonder why the results of our audits are such a secret, what are we trying to hide them for? If we’re doing things right, we should be happy to show the results of our audits…

  • IMHO says:

    I think BRC has stepped out of the observation and documentation auditing process and into the Sociology attitude and feelings audit. A company’s food safety culture is evident in the score that facility receives after an audit. If you don’t have a good culture of accountability for food safety/quality, it will become evident during the audit (Murphy’s law). IF this clause is in the final version of the new BRC criteria, I will be very creative in demonstrating how our management commitment, history of scores, and employee interviews during the audit meet the criteria. I am very hopefully that BRC standards are not based on the economic return for food safety culture survey companies!

    • Kassy Marsh says:

      I totally agree that this is all about sociology, psychology and where it moves into real corruption; criminology! I think the BRC are trying to tackle the corrupt sites, but I don’t see how an audit can uncover that…

  • Carol Walker says:

    Perhaps BRC have finally realised that food safety being properly robust is created not by a technical team who work l o n g hours and have sleepless nights but by the site leadership team? It’s about time! Food safety/integrity/quality can only really be tested when the s**t hits the fan and STILL the right decision is made, not just the one to protect the bottom line, but to protect that 1 customer who may have had a product that was not of the quality expected. As far as I’m concerned I’d happily work through defining what this means because it puts responsibility for food safety properly on the desks who should be leading on it.

  • Mark G says:

    The grapevine here says that it will not appear in the final version of BRC i8, but remain a voluntary module. We’ll see…

    If it becomes part of the main standard I hope that what BRC demands in order to demonstrate cultural development will be somewhat flexible (see Tech Mrg’s comments above) so that companies can manage it in the best way for them, rather than requirements being too prescriptive. Flexibility doesn’t seem to be the BRC standard’s strong point, though.

    We will continue to develop a food safety culture (call it what you will) as we know that a large number of our ‘near misses’ are caused by employees’ actions or omissions, and as Carol W says above, the more people thinking about food safety & quality the better.

    • Kassy Marsh says:

      Oh that’s interesting! I’ll email BRC and see if they will confirm this. Would be nice to know we don’t need to stress about it now, rather than worrying about until August.

  • James Flynn says:

    Ultimately, culture of any kind, including food safety, is driven by the people at the top who hold the purse strings and do the hiring and firing and compliance monitoring.

    For me, unless the management invest in a fully integrated food safety management system where everyone in the business (including purchasing, production, engineering, technical and HR) are working off one management system the a food safety culture is very difficult to implement, monitor and improve.

    Simply having employees take tests and questionnaires is not by itself going to demonstrate a good food safety culture, it has to be demonstrated by the every day actions of all in a food business and this is only driven by integrated, measurable commercial and compliance processes.

  • JN says:

    It falls squarely on senior management shoulders to assure food safety. They are the first culprits when it comes to breaking the rules. They give the directives and the shop floor team simply follow. A food safety culture should be directed towards top management first.

  • I’m concerned about how this clause will be quantified and measured.
    Surveying a diverse staff base can lead to it’s own set of problems, especially if there are some language barriers. Also, surveys can be manipulated and doctored. What better way of proving a good culture of food safety than using measurable data already available?

    Reductions in customer complaints
    Increase in turnover
    Maintenance of high levels of product quality

    All of the above are KPIs for a thriving company taking food safety seriously.

    Personally, if I was the one implementing this clause, I would introduce it as part of the Senior Management Commitment. I would look at ways to improve the understanding and culture towards food safety of the entire senior management team as a requirement of the standard. By improving understanding of food safety at higher levels across the entire business, you stand a much better chance of improving a business-wide culture.

    No matter what size of company or business you look at, when it comes to Food Safety, it isn’t embraced by the entire senior management team like it is with Technical. Sales Managers often refer to Technical as ‘sales prevention’. Engineers can have a view of ‘we need to get this machine going ASAP’. By driving higher standards of embracing Food Safety at the senior level, it can naturally cascade down.

    This could be easily achieved with a dedicated Food Safety Culture Course/Certificate. Renewable every # years, and updated to include some of the biggest issues facing the food industry. With data available from sources such as the FSA regarding recalls and issues, the courses can show any improvements made in the industry, and highlight areas of concern. It keeps it real, it keeps it relevant, and it puts the onus straight where it belongs – Senior Management.

  • mark says:

    CMR,

    As previous posters have suggested. It is a senior management responsibility and unfortunateley the good sites will take this forward and improve their “culture” and the sites that are driven by having a Certificate as a commercial marketting tool will develop documented evidence of their “culture” for the audit. Having worked as a supplier auditor for many years and having flexibility to biase audits to shopfloor time rather than document review then it is was much easier to determine the culture of the site and you can get a feel within an hour of being on site. I would also imagine many experienced auditors having dilemas that they know that the a site subjectively “isnt quite right” but ticks all the boxes for the audit.

  • Mark Chapman says:

    Interesting debate. I am not sure the BRC will take the leap to including the food safety culture clause in the final version and then get auditors to audit compliance thoroughly. However, it is about time the standard realised food safety is not just for an audit it’s 24 hours a day 365 days a year.

    Food safety is all about the three hundreds. 100% of the employees need to comply 100% of the time with 100% of the procedures. This has to be driven from the top and by involving employees in generating the strategy and then implementing it. To achieve this successfully all departments have to get involved with either HR or Production leading this it’s not another job for Technical. The food safety culture clause has the feel of being the new threat analysis which ended up in the majority of cases with Technical because it’s BRC.

    We need to remember that having the strategy displayed on a wall or on a bit of paper does not mean it’s ingrained, in fact it’s probably not. Therefore, if the food safety clause is to be assessed thoroughly the auditors of the standard need to learn from how a number of the retailers have their auditors operate and ask probing questions.

    Final point if the food safety clause is included how will this sit within GFSI benchmarking and will it help drive global food safety culture.

  • Gerry McNally says:

    Whether it appears in the final BRC v8 standard or not it is already a hot topic for a number of blue chip customers so it’s not going away. It starts with induction, a commitment from the outset. Those companies whom have embraced Lean thinking, 6’S and kiazen approaches to continuously challenge and improve will be ahead of the curve because a culture of involvement to improve is visible. But is got to be pushed down the hill from the senior team not up it by the tech teams. Get this right and a company will have a great competitive edge given the negativity the industry has suffered with recent events.

  • Gill Wright says:

    Food safety culture must be led from the top and is really the fundamental point of senior management committment. A passion for quality and excellent customer service will drive sales and ensure clients return so it is very much in the interests of all BRC sites to engage with this and not just have the strategic plan with easy to achieve targets. Best to have challenging objectives and exciting targets to get everyone fired up. I sometimes think that BRC is seen as a tick box exercise rather than a tool to generate business and retain loyality from customers. If senior managers believe in it others will too.

  • Stephen Anderson says:

    I fully agree with Gareth Parkinson and his comments about measurable standards which i believe are

    Reductions in customer complaints
    Increase in turnover
    Maintenance of high levels of product quality

    I would however include internal audits as any improvement (or deterioration) to site, whether it is procedural, structural or environmental, will impact on the scores these audits show. I might also include staff turn over as an indicator.

    But most importantly this must come from the top management in words and deeds.

    But have read the BRC interpretation guide to cause 1.1.2 i still feel it is ambiguous enough to state that at the end of the day its going to be an auditors interpretation which will either give us the results we aim for or not

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