How to comply with food safety and quality culture

BRCGS Food Safety Issue 9 and BRCGS Packaging Issue 7 – changes

The changes to culture are:

1. The addition of behaviours.
2. An annual review of culture.
3. A senior manager must present the culture plan during the audit.
4. Culture is referenced throughout the standard.

Food safety and quality behaviours

When defining the culture you want the business to have, you must now define what behaviours you would expect to see from the team. How to define your culture and develop a set of aligned behaviours is taught in our mini training – Product safety and quality culture.

Annual review

Management must complete an annual review of the food safety and quality culture plan, as a minimum. This is to ensure that actions are on track for completion.

Senior management

Throughout the standard, BRCGS now drives a team approach to the implementation of culture. This means that the senior management team must understand the requirements of the standard sufficiently, so that they can present the culture plan at audit.

Referenced throughout the standard

This is a subtle change, but it’s the most important. You now need to think more holistically about culture – as it needs to filter through to every part of your management system.

Training for BRCGS Food Safety Issue 9 and BRCGS Packaging Issue 7

Food safety and quality culture behaviours

The mini training for product safety and quality culture is compliant to the BRCGS Standards and makes this tricky subject super simple by teaching you an easy-to-follow process to define your culture, required behaviours and develop your plan.

Senior management’s commitment to culture

To comply with BRCGS Food Safety Issue 9 and BRCGS Packaging Issue 7, the management team must understand the requirements of culture, so that they can present the culture plan at audit.

The senior management team must be involved in the development, implementation and management of the plan. The product safety and quality culture mini training provides the training required, so that the team can work together to meet the requirements.

To speed up the process you can also purchase the senior management commitment eDocs which includes the procedure and templates you’ll need to comply.

What are auditors looking for and what does a positive food safety and quality culture look like?

When your auditor carries out your audit, they’ll be constantly looking for signs of culture. A positive culture is one where every person within the business, understands how they contribute to compliance to the standard.

This means, that engineering must understand the maintenance aspects of the standard and present how they comply to them, to the auditor.

The procurement or buying team, must understand what is required for supplier management and present this to the auditor.

Operations, must be accountable for process control and present how they take responsibility for it, to the auditor.

The auditor will want to see that compliance to the standard is a team effort and that the audit isn’t lead by just technical.

What is the purpose of food safety and quality culture?

Culture is a relatively new subject, which has been introduced in response to recent incidents in the media. These incidents have given the public a perception that the food that they buy isn’t produced in a safe or ethical manner.

Certification standards are keen to ensure that the culture of the workforce, doesn’t negatively impact the food we produce or consumer confidence. Which is why they’re introducing culture requirements into their standards.

The slippery slope

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 businesses go bad.

Given the right situation or environment, a person can be driven to make a decision which they know to be wrong.  They may feel uncomfortable about it at the time but if it goes unnoticed, or is accepted by those around them, the discomfort will mellow.

The next time the situation arises, it won’t feel as wrong and it’ll be less of a challenge to do the wrong thing. If behaviour again goes unnoticed or is accepted, it becomes an accepted practise. With repetition this eventually becomes the norm and they slip down the slippery slope.

The next time staff are faced with a situation which is more severe, it will feel less of a challenge to make the wrong, more severe decision. Ultimately, the further down the slippery slope the person slips, the easier it is for them to make the wrong decision.

When behaviour like this is accepted, or in the worst-case it’s driven by management, it happens more often –  impacting on the culture of the business.

Food crime

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?

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

However, the specification that you agree with your customers is a contract. Legally, if you purposefully break a contract – that’s defined as fraud, which is a crime.

The Global Food Safety Initiative (GFSI) released a Position Statement in 2018, to provide 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 within it. It defines how they perceive situations and the decisions that they make.

How behaviour impacts culture

Staff which believe in ‘doing the right thing’, will not only struggle with making what they think is the wrong decision, but it wouldn’t even enter their heads to do it.

Staff within a business 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, staff within a business 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.

Culture, may be at different levels within the business. The ‘wrong’ culture may be driven from the top down. Or, the management may have the right attitude, but they’re values may not be passed on to their teams – which means that the culture throughout the business, doesn’t mirror the intentions of the senior management.

What is the aim of food safety and quality culture?

“The purpose of a culture plan is to establish what culture is in place, at all levels of the company. To check to make sure that the mindset and behaviours 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.”

This is an extract from our mini training for culture. If your business is looking for a simple and effective system to implement for culture, that meets all BRCGS standards, including BRCGS Food Safety Issue 9 and BRCGS Packaging Issue 7 – then look no further. This mini training on culture is perfect. 

What is a food safety and quality culture survey?

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

It’s up to you how you do this, one way is using a questionnaire-based survey to do this. You can be as imaginative as you like, as long as you achieve the aim – which is to get staff feedback.

When carrying out your survey, staff 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 Google Forms which even has free options.

What questions should you put in your survey?

Think about what you’re trying to achieve; you want to know if the culture of the business, at all levels, is ‘right’. But what does ‘good culture’ mean?  You have to be clear on this, in order to be able to ask your staff if they think the business is meeting the requirements of the ‘right culture’.

What is the ‘right food safety and quality culture’?

Let’s tackle what culture means first.  Culture is like the personality of the business. Your business’ personality consists of values and beliefs, which it believes are important. You may already have a set of values that your business 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

You need to define what culture your business would like to work towards, in order to then ask your workforce, how far away they think you are from your defined culture. The easiest way to do this is to establish what the values are for the business 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 staff to see if they think the business is meeting them.

An example of a food safety and quality culture survey

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

• We want to add value to the industry by providing training that’s relevant to today’s 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 straightforward information, which is accessible to all.

We’ve then used these vision statements to create questions:

Vision: We want to add value to the industry by providing training that’s relevant to todays Standards and the learner’s role.

Thinking about the above vision, tell us how true you think each statement is.