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Food Safety Culture – Now an Audit Requirement, But Proceed with Caution

By Linda Jackson

On 3 November 2020, the Foundation FSSC 22000 published Version 5.1 of its FSSC 22000 certification Scheme. The main reasons for an updated version are compliance with the latest benchmarking requirements of the Global Food Safety Initiative (GFSI) and strengthened requirements for Certification Body (CB) performance as part of continuous improvement.

According to the official FSSC press release, the updated requirements are to bring the scheme in line with the GFSI requirements of multi-site certification, product design & development, and food safety culture.

So, what does this mean to you?

In my opinion, the addition of product design is way overdue. This requirement is covered extensively in Iso 9001 and its omission from a food safety standard has finally been corrected. It is in product development that we can design food safety into a product or create significant obstacles for food safety. Please note this was ALWAYS implied in the ISO 22000 requirements – internal communication and in the 2018 version, also in the management of changes. The more prescriptive requirements will no doubt close a loophole.

2.5.13 Product development

A product design and development procedure shall be established, implemented and maintained for new products and changes to products or manufacturing processes to ensure safe and legal products are produced. This shall include the following:

  • Evaluation of the impact of the change on the FSMS taking into account any new food safety hazards (including allergens) introduced and updating the hazard analysis accordingly
  • Consideration of the impact on the process flow of the new product and existing products and processes
  • Resources and training needs
  • Equipment and maintenance requirements
  • The need to conduct production and shelf-life trails to validate product formulation and processes are capable of producing a safe product and meet customer requirements.

Your NPD team will now be joining in the audit to show how they interface with the FSMS which is a great thing for food safety and integrating your systems towards a common goal.

And now to food safety culture:

This guidance document is intended to guide the auditor as they evaluate the GFSI guiding questions in relation to senior management’s commitment, communication, training, feedback from employees and performance measurement on food safety-related activities. While I appreciate the efficient approach on behalf of FSSC, I do think that some of the sentiments of food safety culture cannot be carried through the ISO 22000 standard requirements.
One example – there are many, would be the GFSI guidance question:

Is your documentation designed to support employees’ food safety decisions and behaviours?

The FSSC guidance document links this to Clause 7.5.1, b)

“The organisation’s FSMS shall include documented information determined by the organisation to being necessary for the effectiveness of the FSMS”
(The auditor is guided to specially review the NOTE in this regard, which is not an auditable requirement.)

This requirement does not address the intent of the question. We all know that having a procedure does not guarantee there will be safe food or even compliance with that procedure. Our daily challenges are getting people to follow procedures. We can have them but that does not mean we have a strong food safety culture. Having more procedures can even deter our employees from engaging and this is supported by the findings of behavioural researchers such as Schein. In fact, the structure of the Iso 22000:2018 standard removes the emphasis on documented PROCEDURES (although FSSC are certainly outing them back and some) and stresses documented information.

So how does an auditor evaluate this? Having a cleaning schedule is necessary for the effectiveness of the FSMS but that cleaning schedule may be completely ineffective in engaging employees. How would you know? How would you assess this? And do you have the time to do this on your audit?

My fear – including food safety culture requirements as part of an audit, that is based on hard science principles and is usually conducted by an analytical science-trained auditor, may not give us the soft science outcomes we need in an assessment of an organisation’s culture. But hey we will tick all the right blocks, won’t we?