What is culture?

Culture is a set of beliefs, attitudes and expectations found within a society of people. What you have inside your company is like a smaller version of this society, with a culture of its very own.

Culture is like the bloodstream of the body. The departments are the organs, with the bloodstream flowing through each one. Culture affects every aspect of the body, and how it’s run.

If the bloodstream or the culture, gets contaminated or becomes toxic, it can have a detrimental effect on the entire site and the staff who work there.

This is why culture is so important and why it’s now is a key aspect to all food safety Standards.

Which Standards does culture apply to?

Culture is a requirement in the following Standards. The BRCGS Standards have one particular clause that requires culture, whereas both FSSC22000 and IFS use clauses that are already within the Standards. In the FSSC22000 Standard there are many clauses that need culture to be taken into consideration, all of which are within the ISO 22000 Standard.

BRCGS Food Safety Issue 8 1.1.2 Culture
BRCGS Packaging Issue 6 1.1.2 Culture
BRCGS Agents & Brokers Issue 2 AB211 Position statement
Storage & Distribution Issue 4 1.1.2 Culture
FSSC22000 Version 5.1 No specific clause, but culture should be applied through ISO 22000:2018:

4.1, 4.2
5.1d, 5.2.2a 5.2.2b, 5.3.1, 5.3.2, 5.3.3
7.1.2, 7.3c, 7.4.3, 7.5.1b
6.1.1, 6.2, 6.3
8.9.1
9.1.2, 9.3, 9.3.2
10.2, 10.3

IFS Food Version 7 No specific clause, but culture is mentioned in:

1.1 Policy
1.4.1 Management review

SQF Edition 9
2.1.1.2 Culture

FSSC22000

FSSC haven’t specifically added anything to the Standard to cover culture. However, they have created a guidance document which explains how clauses from the ISO22000 Standard can be applied to cover culture.

The FSSC have added the requirement for culture, as it’s now part of the GFSI Benchmarking 2020, which states:

Evidence of the senior management’s commitment to establish, implement, maintain and continuously improve the Food Safety Management System shall be provided.  This shall include elements of food safety culture, at a minimum consisting of:

  • Communication
  • Training
  • Feedback from employees
  • Performance measurement on food safety related activities

The guidance provides a set of questions that an auditor may ask, and explains of how to evidence them.

IFS Food

IFS also haven’t added in a specific clause for culture, but instead have added it as a requirement for the quality policy and also for management review.

They have also added a definition for culture to the glossary, which comes from the GFSI Benchmarking 2020.

SQF

There is a culture clause now within the SQF Food Manufacturing Standard, as follows:

“2.1.1.2 Senior site management shall lead and support a food safety culture within the site that ensures at a minimum:

  1. The establishment, documentation, and communication to all relevant staff of food safety objectives and performance measures;
  2. Adequate resources are available to meet food safety objectives;

iii. Food safety practices and all applicable requirements of the SQF System are adopted and maintained;

  1. Employees are informed and held accountable for their food safety and regulatory responsibilities;
  2. Employees are positively encouraged and required to notify management about actual or potential food safety issues; and
  3. Employees are empowered to act to resolve food safety issues within their scope of work.”

The SQF requirement goes beyond stating that a culture plan is required, and starts to define what a ‘good’ culture would look like by stating:

Employees are:

  • informed and held accountable for their food safety and regulatory responsibilities;
  • positively encouraged and required to notify management about actual or potential food safety issues
  • empowered to act to resolve food safety issues within their scope of work.

BRCGS

The BRCGS Food Safety, Packaging, Storage & Distribution and Agents & Brokers Standards all have a specific clause to cover culture.

The most up to date version of this clause is in BRCGS Storage & Distribution Issue 4, which is:

The site’s senior management shall define and maintain a clear plan for the development and continuing improvement of a product safety and quality culture. This shall include:

  • defined activities involving all sections of the site that have an impact on product safety.

As a minimum, these activities shall be designed around:

  • communication
  • training
  • feedback from employees
  • performance measurement on product safety related activities
  • an action plan indicating how the activities will be undertaken and measured, and the intended timescales
  • a review of the effectiveness of completed activities.

All Standards Summary

Whether the Standard is prescriptive like BRCGS and SQF, or vague like IFS and FSSC the requirements are the same. There must be a system in place to ensure that the culture of the site promotes product compliance to safety, quality, legality and authenticity.

Why does culture apply to Packaging, Storage & Distribution and Agents & Brokers?

The aim of culture is to ensure that the workforce has a food safety mindset, but it also applies to packaging, storage, distribution businesses and agents and brokers – because of the impact they can have on the final food product.

For example, if a packaging manufacturer supplies a packaging product that doesn’t meet the specification – that could have a safety, quality or authenticity impact on the food that’s packed into it. If food, or food packaging is not handled correctly while in storage or in the distribution chain, it can also have a negative safety, quality or authenticity impact on the product. Agents and brokers also have an impact, as they can be responsible for the manufacture, storage and distribution of food products, and so they need to have the right culture internally and throughout their supply-chain.

Therefore product safety and quality culture is important, because it has an impact on the food safety and quality of the final food product.

What is the purpose of culture?

Culture is a new subject, which has been introduced in response to incidents that have been highlighted in the media in recent years.

Although the media, the public, or even we for that matter, don’t know the ins and outs of what actually happened in these incidents, it has given the public a perception that the food that they buy isn’t produced in a safe or ethical manner.

Certification Standards are obviously keen to ensure that the culture of the workforce at sites, doesn’t have a negative impact on the food that we produce and also on consumer confidence. Which is why Certification Schemes are introducing culture requirements into their Standards.

Food crime

Andy Morling, who is the Head of the Food Crime Unit for the Food Standards Agency, has spoken a number of times at conferences about his theory of the ‘slippery slope’. He believes that food crime is where good companies go bad.

Given the right situation or environment, a person can be driven to make a bad decision, which they would typically believe to be wrong, as it’s breaking the rules. They may feel uncomfortable about it at the time and struggle with it, but if it goes unnoticed, or if it is accepted by those around them, the discomfort mellows.

The next time, they’re faced with that situation, it won’t feel as wrong to them. This time it will be less of a challenge to come to the same decision, to do the act that they originally felt was wrong. If it’s noticed by others around them, this instils in others that this is an accepted practise. So, with repetition this eventually becomes the norm and they slip down the slippery slope.

It follows that the next time they are faced with a situation which is even more severe, they would feel that it was less of a challenge to make the wrong, more severe decision. Ultimately, the further down the slippery slope you slip, the easier it is to make the wrong decision; to break the rules.

When this behaviour or mentality is accepted, or even in the worst case is driven by management, it happens more often. This has a massive impact on the culture of the business.

You may think the term ‘food crime’ is a bit strong, when we’re talking about food safety and quality culture.  But like Andy Morling says, it’s a slippery slope from doing something that may not be quite right, to committing food crime. And, it depends on what we mean by food crime.

Is letting product out on purpose, that doesn’t meet the quality agreed in the customer specification – food crime?

Our first thought, may be, well if it’s not quite right, but we think it’s just on the cusp of being ok, then surely that’s not too wrong – is it?

But the specification that we agree with our customers is a contract. Legally, if we purposefully break a contract, that’s defined as fraud. Which is a crime.

The GFSI who are the Global Food Safety Initiative released a Position Statement in April 2018, where they provided their view on food safety culture. They defined food safety culture as “shared values, beliefs and norms that affect mindset and behaviour toward food safety in, across and throughout an organization.”

The values, beliefs and mindset of a business, has a massive impact on those that work in the company. It defines how they perceive situations and the decisions that they make.

Employees within a company with high values for ‘doing the right thing’, will not only struggle with making what is seen to be the wrong decision, but it wouldn’t even enter their heads to do it.

Employees within a company who have less value for doing the right thing, perhaps because they feel that they have a justified reason, such as their customers are pushing them, due to cost, to ‘bend the rules’ a little, may have less issue with making the wrong decision.

And at the extreme, employees within a company who feel that they can’t do the right thing, because it’s not actually viable, due to cost for example, wouldn’t think twice about doing ‘the wrong thing’. This is where it becomes the norm. And this, is where the food safety Standards want to use the principle of food safety culture, to highlight this issue before it gets this bad and resolve it.

The ‘wrong’ culture, may be at different levels within the company. It may be driven from the top down. Or, the management may have the right attitude, but it may not be dissolved down, as they would hope, into middle management. Meaning that the culture on the shop floor, doesn’t mirror the intentions of the senior management.

What is the aim of culture?

The purpose of a culture plan is to establish what culture is in place, at all levels of the company. And then, to check if that the mindset and behaviour of all employees, at all levels, match that of the defined culture. To work out what employees are thinking, an assessment needs to be carried out, usually this is done using a survey. The results of the survey give a clear picture of what the culture is like at different levels of the business and therefore, allows management to set in motion any actions needed for improvement. This, in turn, should then improve the culture of the business.

What are the benefits of culture?

A workforce with the right culture where everyone is working towards the same aim, is an efficient workforce. This type of workforce will ensure that the product is produced and handled safely, and to the right quality first time. A vigilant workforce – when things do go wrong, won’t be worried about raising the alarm. This means the issue will get picked up quickly, minimising disruption, wastage and cost.

What are the requirements?

The site’s senior management must have a defined clear plan in place for the development and continual improvement of the product safety and quality culture of the site. This plan needs to be maintained.

The plan must include:

  • An assessment of the current culture through employee feedback
  • Defined communication, training and activities that involve all sections of the site and could have an impact on the product safety and quality culture.
  • An action plan which details how the activities will be carried out and measured, and the intended timescales for carrying out the activities. Activities must include product safety related activities.
  • Reviews of how effective completed and ongoing activities have been. The reviews should be carried out and reported to senior management at least quarterly.

What do you need to do to meet the requirements?

The requirements state that you need to:

  • Create a culture plan
  • Define the activities required to improve culture
  • Implement the plan
  • Review the plan

Culture plan

The site needs to have a plan in place, that’s defined and maintained in order to improve the safety and quality culture of the site as a whole. But what does this actually mean?

It means an auditor would expect to see something documented, and the fact it has to be defined, indicates it needs to involve detail and cannot just be a vague statement.

A culture plan includes details of what the company would like their culture to be, how they’ve carried out a culture survey, what the survey said, the weaknesses it highlighted and a set of actions for improvement.

Culture improvement activities

A part of defining your plan is to include what activities and measures are going to be used. Therefore, you need to include specific details. This should include how you are going to assess the culture.

Are you going to use a survey, or lunch time polls or carry out discussion groups? You could implement extra staff reviews, training days and teambuilding activities. You can even introduce incentives.

How are you going to measure your progress? Quite a lot of the aspects of culture are not measurable, but you need to try and incorporate some measurable aspects, whether this is based on a scoring system, or maybe a general shift in people’s feelings.

How it’s implemented?

The plan needs to include how the activities that were identified are going to be implemented. This involves details of how the activities are going to be introduced, or if they are already in place – how often will they be carried out.

If you are going to carry out regular staff reviews, what will the frequency be? It could include what teambuilding activities will be used and how it will be determined who takes part.

Make the plan really clear; detail what is being done, when, by who and how each action is being managed.

Review the culture plan

You need to have reviews in order to monitor the plan. As your plan is to improve the culture you need to monitor the progress. How often you do this is up to you.

You might start out with an initial baseline review. Then allow the activities and actions to be implemented and then review again. At this time, you might decide to increase the frequency of the review, if you want to monitor it more closely as the plan is settling in.

What is a culture survey?

A culture survey is a questionnaire which asks employees if they think the company is meetings the values and vision statements that it has defined.

A questionnaire based survey is the typical way of doing this, but there are no rules to say it has to be done this way. You can be as imaginative as you like, as long as you achieve the aim – which is to get employee feedback.

When carrying out your survey, employees need to feel that they can speak freely, so it’s best to allow them to complete the survey anonymously. You can buy expensive tools to do this, but it doesn’t need to cost a lot. A paper based questionnaire is fine, or you can use a simple survey tool, such as SurveyMonkey which even has free options.

What questions should you put in your survey?

Think about what we’re trying to achieve; we want to know if the culture of the business, at all levels, is ‘right’. But what do we mean by a ‘good culture’? We have to be clear on this, in order to be able to ask our employees if they think the business is meeting the requirements of the ‘right culture’.

What is the ‘right culture’?

Let’s tackle what we mean by culture first.  Culture is like the personality of the business. Your company’s personality will be made up of things that are important to it, it’s values and beliefs. Your company may already have a set of values that it works to, or vision statements.  This defines the culture that the business would like to work towards.  This is what the business defines as the ‘right culture’.

Culture questions

We need to define what culture that the business would like to work towards, in order to then ask the workforce, how far away they think you we are from this defined culture. The easiest way to do this is to establish what the values are for the company and then define these values into a set of vision statements.

Once you have your values and vision statements, then you can develop a set of questions to ask employees to see if they think the business is meeting them.

A culture survey example

At Techni-K we have put together the following vision statements.

  • We want to add value to the industry by providing training that’s relevant to todays Standards and the learner’s role.
  • We want to save techie’s time by providing best practice compliance documentation.
  • We want to make keep techie’s up to date with expert straight forward information, which is accessible to all.

We’ve then used these vision statements to create questions. We’ve put these questions into Surveymonkey, so you can take our survey and see how we’ve done it.

Need help?

If you would like our help to meet the requirements of culture we have a documentation pack for senior management commitment, which includes culture and, we have a training course that teaches you everything you need to implement culture at your site.

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