Food Safety Culture Diagnosis Toolkit For Inspectors
Food Safety Culture Diagnosis Toolkit For Inspectors
Food Safety Culture Diagnosis Toolkit For Inspectors
This is a draft toolkit developed as part of an ongoing research project. The views
expressed in this document are those of Greenstreet Berman Ltd and its contractors and
not necessarily those of the Food Standards Agency.
Greenstreet Berman Ltd, 10 Fitzroy Square, Fitzrovia, London W1T 5HP, T: 020 3102
2110. W: www.greenstreet.co.uk
Authors: Michael S Wright, Paul Leach and Gill Palmer.
Contents
ii July 2012
1 INTRODUCTION
1.1 Application
This toolkit is intended to support the assessment of food businesses in respect of food
safety management, including management culture, the application of good practices or
„pre-requisite programmes‟, standards of hygiene adopted and the approach taken to
identifying and controlling food safety hazards. This includes control of process activities
(e.g. cooking, cooling, labelling/date code application) and application of pre-requisites
(e.g. pest control, cleaning, maintenance of the environment, prevention of cross –
contamination). The term „food safety‟ is used to embrace all aspects of safe and hygienic
processing of food and refers to practices, standards and activities that are required to
protect consumers from harm.
within the business and consider which category and element descriptors best applies to
that food business
Section 5 provides high level guidance to help initiate discussions to help categorise the
food safety culture of the food business.
This guidance covers:
A set of areas to explore each food safety culture element;
Example documentation to review as part of the inspection, to understand food
safety and hygiene practices and;
Example observations that can be made to help understand food safety and
hygiene behaviours within the business.
2 July 2012
3 July 2012
Tick which
category applies
Category
b) Doubting compliers: Doubt the significance of the hazard posed by food safety
and hygiene and the effectiveness of food hygiene regulations and requirements in
managing these hazards. May have the capability to understand requirements but
doubt the risk. May express cynical view to staff and do not promote compliance
other than for purposes of regulatory compliance.
e.g. „We‟ve never had a problem in all the time we have been trading‟.
c) Dependent compliers: Wait upon advice or instruction from regulators and other
third parties to make improvements and view food safety and hygiene as something
driven by third parties. Tend to view requirements as unfairly complex and that it is
unreasonable to expect them to take a lead in understanding and applying. May
have low levels of knowledge and training. May not have any clear perception or
knowledge of the potential issues posed by food safety and hygiene.
e.g. „Just give me a list of what you want me to do and I will do it‟.
d) Proactive compliers: Understand that hazards posed by poor food hygiene and
poor process controls are significant and accept that requirements are effective and
necessary. Wish to ensure food safety controls are proportionate and effective, and
will positively debate (internally and externally) how best to manage food safety
hazards in a cost effective and proportionate way, implementing food safety
controls after careful deliberation. Management provides a lead in encouraging
compliance for the sake of the business as well as regulatory compliance but may
not go beyond “good practice”.
e.g. „We encourage all staff to take ownership and responsibility for food safety
and we challenge non-compliance'.
e) Leaders: View food safety and hygiene as critical business issues that they must
tightly manage and offers potential business benefits through achievement of a
good reputation for food safety and hygiene. Provide visible leadership in
continually reviewing food safety and improving food hygiene.
e.g. 'We pride ourselves on the safety and hygiene practices of our business'.
4 July 2012
Table 2: Blank table for use in recording exploration of elements of food safety
culture
Category
Element a) b) c) d) e)
Calculative Doubting Dependent Proactive Leaders:
non- compliers: compliers: compliers:
compliers:
Business priorities and
attitudes towards food
hygiene
Business‟s perception and
knowledge of food safety
hazards
Business‟s confidence in
food hygiene
requirements
Business ownership of
food safety and hygiene
Competence, learning and
training in food safety and
hygiene systems
Leadership provided on
food safety and hygiene
Employee engagement in
review & development of
food hygiene practices
Communications & trust to
engage in food safety and
hygiene & report issues
Having explored the business‟s attitudes and behaviours, the cells in Table 2 that apply to
the business can be selected.
5 July 2012
6 July 2012
7 July 2012
8 July 2012
Calculative non compliers Doubting compliers Dependent compliers Proactive compliers Leaders
Business priorities and Provide examples of Use evidence to highlight Acknowledge their wish to Applaud their work and Reinforce their attitude by:
attitudes towards food business failure caused by how good food safety comply and to manage attitude and only then say
Citing other examples of
hygiene non-compliance. management can benefit food safety. they could become “best in
industry leaders and how it
the business, such as by their class” by building on
Help the business Suggest it is in their self helps their reputation.
ensuring customer their good practices.
understand how placing interest to take a lead in
confidence and loyalty. Indicate they could Citing examples of high
targets or performance managing food safety
achieve a competitive profile cases of non
pressure (i.e. profit, speed rather than be dependent
edge by including their compliance and how they
of service etc.) can conflict on other people, who
food safety performance in would not want to allow
with the prioritisation of cannot be there all the
their marketing, such as by complacency to undermine
food safety and hygiene time.
displaying Food Hygiene their good work.
and compliance with
Rating Scheme certificate
regulation.
(if applicable).
Business‟s perception and Highlight food safety Use examples of issues Indicate that it is the duty Have positive discussions Applaud their recognition
knowledge of food safety hazards at this business that might be identified in of the business to identify about hazards and the risk of significant food safety
hazards and explain how these can the HACCP study to food safety hazards for they pose, accept valid hazards and the way in
cause serious harm. ensure the business is their operation and decide debate about these, which they have decided
aware of specific hazards how best to manage them provide information where to manage their Critical
Highlight that ignorance of
and the consequences of routinely within the the FBO is misinformed or Control Points for the
the hazards is no defence
failing to manage these business and that they are out of date. Encourage business. Reinforce their
in the eyes of the law.
effectively within the best placed to do this as them to keep their hazard perceptions and the
business. they know their business analysis and risk wisdom of taking a
better than anyone else. assessments and their proactive approach to food
Highlight food hygiene
Explain that this is a HACCP plans up to date safety, e.g. by highlighting
issues at this business and
reasonable and legal and to subscribe to useful how others have had
explain how these can
obligation. sources of food safety incidents because they
undermine the business‟s
information etc. e.g. FSA failed to recognise the
ability to consistently Provide examples and
Alerts. significance of these
produce safe, quality guidance on simple food
issues and/or have failed
products. safety hazard analysis and
to manage them
risk assessment tools.
appropriately.
9 July 2012
Calculative non compliers Doubting compliers Dependent compliers Proactive compliers Leaders
Business‟s confidence in Use examples of issues Use examples of issues Suggest that they should Acknowledge their Reinforce their confidence
food hygiene requirements that might be identified in that might be identified in (having assessed their commitment to food in the food safety controls
the HACCP study to the HACCP study to process) ensure they have hygiene management. by agreeing with their view
ensure the business is ensure the business is suitable control measures that they are critical.
Discuss how ensuring food
aware of specific hazards aware of specific hazards in place for their identified
hygiene is effectively
and the consequences of and the consequences of significant hazards and
managed is critical to the
failing to manage these failing to manage these ensure they monitor these Encourage them to keep
success of a food
effectively within the effectively within the controls throughout the food safety controls up
business.
business. business. processing to provide to date and to review
assurance that the control Encourage them to keep causes of any incidents to
Make clear to the business Make clear to the business
measures are working their food safety controls ensure arrangements
that a failure to effectively the value of taking a
successfully. Encourage up to date and to review remain effective.
manage food safety and preventative approach to
independent thought and causes of any incidents to
hygiene is likely to result in managing food safety and
decision making in order to ensure arrangements
issues that will have an the use of management
get the business to take remain effective.
adverse effect on the systems and impress
ownership for the controls Encourage them to
business, both in terms of importance of their use.
in place within the communicate the value of
reputation and commercial
business. effective food safety
success.
controls to staff.
Business ownership of Communicate legal duties Suggest that regardless of Whilst acknowledging that Acknowledge and applaud Acknowledge and applaud
food safety and hygiene and how rejection of these whether they feel that food food safety and hygiene their proactive approach. their proactive approach to
duties is regarded as safety and hygiene management can be Suggest they do not wait food safety management.
negligence, and likely to requirements are complex and that there are for new requirements to Encourage them to
lead to more severe unnecessary, that it many requirements, emerge from regulators to continue management
enforcement in the event remains their duty to emphasise individual and make improvement, but involvement in reviewing
that an incident occurs. understand and apply business responsibilities use internal reviews and systems and using the
them. Suggest that by for food safety and comparisons with other information generated by
applying good food hygiene. Provide businesses to help identify the food safety
hygiene practice and examples of how the further improvements. management systems e.g.
applying HACCP business can encourage numbers of instances
principles as required by staff to take ownership of when Critical Control
legislation, they are able to food hygiene and benefits Points have required
design a food safety this brings. Inspectors can corrective action to be
management system that help but it is the business‟s taken, consumer
10 July 2012
Calculative non compliers Doubting compliers Dependent compliers Proactive compliers Leaders
is tailored specifically to responsibility to ensure complaints etc. to direct
their business needs. With compliance. their future efforts for
a system in place that is improvement.
specific to their business,
they only need to apply the
aspects of control
required, thus taking
ownership of their
application.
Competence, learning and Suggest that customers Talk through the Provide advice and Acknowledge their Applaud and acknowledge
training in food safety and and other stakeholders will competence requirements examples of how they commitment to training their commitment to
hygiene systems lose confidence in a for the business to could develop their food and learning. Suggest they training. Encourage them
business which appears to effectively manage food safety and hygiene subscribe to newsletters or to check out new
be incompetent. Suggest safety issues as detailed in competence and other channels for being opportunities for training
that being competent the business‟s HACCP confidence by, for kept up to date with latest and learning.
should help the business plan and relevant example, attending issues and requirements.
avoid costly incidents and legislation. training, reading or talking
business disruption. to other businesses.
Suggest that being
competent should help the
business avoid costly
incidents and business
disruption.
Leadership provided on Explain how it is the duty Explain how staff tend to Emphasize that staff will Applaud their leadership Applaud their leadership
food safety and hygiene of the business operator to follow the example set to follow the lead of on food safety and on food safety and
ensure staff are complying them by their managers management on a day to hygiene and suggest they hygiene and reinforce it by
with food safety and and hence the importance day basis and cannot rely build on this by giving examples of where
hygiene requirements and of ensuring that they set a on inspectors to influence acknowledging instances they have succeeded in
that this includes effective good example in words staff. of good practice amongst encouraging good food
leadership to staff and actions. staff. safety and hygiene
Use the outcome of the
regarding application of behaviour amongst staff.
Use examples to HACCP study,
relevant standards and
demonstrate the benefit of observations and Ask if they have plans for
procedures etc.
providing leadership to documentation to highlight new ways of offering
11 July 2012
Calculative non compliers Doubting compliers Dependent compliers Proactive compliers Leaders
staff. to the food business that leadership.
they have a framework in
place for food safety
management and need to
take initiative and provide
leadership to their staff.
Using examples relevant
to the business,
demonstrate what is
expected and encourage
the business to actively
promote positive food
safety practices and
challenge poor practices.
Employee engagement in Suggest that staff can help Provide examples of Provide examples of how Suggest they ask staff Applaud their engagement
review & development of prevent costly incidents by problems that staff may be they can engage staff in a whether there are more of staff and ask about
food hygiene practices being encouraged to help able to help resolve. simple and effective effective ways to manage plans for future staff
to ensure food safety and Discuss the value in manner. food hygiene than those engagement.
hygiene procedures are encouraging staff prescribed by law.
For example:
effective. involvement and the Suggest encouraging staff
positive aspects of staff Asking staff for input when to be innovative in
motivation. reviewing/developing food developing new/better
safety practices. procedures and records in
Encouraging staff to offer relation to food safety
feedback and ask management.
questions surrounding
changes to food safety
practices.
12 July 2012
Calculative non compliers Doubting compliers Dependent compliers Proactive compliers Leaders
Communications & trust to Highlight how in the event Emphasise the business Provide examples of how Applaud their approach to Applaud their open and
engage in food safety and of an incident, if staff knew benefit of communication communication and trust communications. trusting way of working
hygiene & report issues of problems but did not and trust, such as alerting can be enhanced in a with staff. Agree on the
Suggest they proactively
communicate these to business operators to simple and effective importance of this. Note
encourage staff to report
management (e.g. as a problems. manner. that trust is “hard to earn,
any issues and offer
result of concerns about easy to be lost” and urge
For example: suggestions. Suggest they
how management might them to always be
applaud staff who do
react), the business would Encouraging and praising receptive to staff feedback.
provide feedback, report
be considered to be at staff who report hygiene
problems and suggestions.
fault for failing to rectify a issues.
Highlight to other staff how
known problem. Leaders making being alerted to problems
themselves approachable is good for the business
and available for staff to and something they
report issues. encourage.
13 July 2012
Category
Element
a) Calculative non- c) Dependent
b) Doubting compliers: d) Proactive compliers: e) Leaders:
compliers: compliers:
Consider food hygiene to Food safety given low Consider food safety to be Set food hygiene as one Considers food hygiene to
be a nuisance. priority as business fails to of low priority in relation to of several business be a top priority, a critical
see the benefit or other business priorities. priorities. business success factor &
Food safety requirements importance of food safety. something at which they
are rejected for reasons of (Focus on getting the job Display no interest in food Accept that food hygiene wish to be excellent
self interest. done) . safety/hygiene unless is important. Food safety is a shared
caught out by inspection. value across the business
Productivity and profit FBO resistant to engage Receptive to suggestions prioritised by
always take priority. in discussions about food Productivity and profit from Local Authority management and staff.
safety with others. frequently take priority. Inspector.
e.g. 'I never bother Frequent reference to
wasting time on Evidence of misplaced e.g. „I have a business to Evident acknowledgement food safety/hygiene, and
something that will cost complacency. run, VAT return to of compliance within the enthusiasm for prevention
Business priorities and
me time but not make me complete etc „. business. rather than cure e.g.
attitudes towards food
money'. e.g. „We‟ve never actively adopting planned
hygiene
poisoned anyone‟. e.g. 'We try to keep on top preventative maintenance
of the requirements for for equipment rather than
managing food safety'. repair after breakdown.
14 July 2012
Category
Element
a) Calculative non- c) Dependent
b) Doubting compliers: d) Proactive compliers: e) Leaders:
compliers: compliers:
Disregard potential for Do not believe that the Largely unaware of food Understand the food Believe that food
harm to people or issues associated with safety issues and safety and hygiene issues poisoning or other similar
presume it is acceptable their food products legislative requirements. associated with the incidents could result in a
regardless of the level of justifies applicable food activities of the business. major adverse impact on
non-compliance. safety practices. May have a neutral or the business as well as
undeveloped view of the Place importance on harm to many people.
No action taken to evident Fail to understand the potential issues posed by mitigating risk in line with
pest infestation. potential severity of non- food safety. food hygiene legislation. Management and staff
compliance with food fully understand the food
No effort made to identify safety/hygiene Perceive their Make a dedicated effort to safety and hygiene issues
or understand food requirements. management of food remain up to date with associated with the
safety/hygiene safety & hygiene as changes in food safety activities of the business
requirements. Perceive it unlikely that adequate once they have legislation. and know how to mitigate
their food safety practices complied with the most against these.
e.g. Encouraging may adversely affect the recent inspector‟s e.g. 'We review our
Business‟s perception and personnel to re-use food health and wellbeing of requirements. practices when there is a Continual and on-going
knowledge of food safety that should be categorized customers. change in the regulations review of food safety and
hazards as waste (food dropped e.g. “I am not sure what to make sure that our related information that
on the floor, passed the e.g. „We‟ve never had a the hygiene issues are”. business is compliant and may have some relevance
use-by date or returned problem in all the time we practicing safely'. to their operations and
uneaten by consumers). have been trading‟. e.g. „It‟s up to the consideration of how this
inspector to tell us what may be incorporated in
e.g. „People are not the problems are‟. the business‟s food safety
seriously harmed by food management system.
poisoning”.
e.g. 'We are never
e.g. „Food safety risks are complacent when it
exagerated‟. comes to food safety and
make sure that all
significant food safety
issues for our business
are actively managed to
exceed regulatory
requirements'.
15 July 2012
Category
Element
a) Calculative non- c) Dependent
b) Doubting compliers: d) Proactive compliers: e) Leaders:
compliers: compliers:
Do not care whether food Doubt whether food May not have an opinion Understand the benefit Believe that systems such
hygiene systems are hygiene requirements on whether the food and importance of as HACCP when properly
effective. would effectively prevent hygiene requirements are complying with food applied are essential for
food poisoning and doubt effective or not, but will hygiene legislation. the sake of the business
Make no effort to update their proportionality or still comply. (and that they do
any systems in place over necessity. Confident that the use of effectively control the
time. Compliance with food HACCP identifies the significant food safety
Fail to understand how hygiene requirements is controls required for food issues).
Take no responsive action food hygiene systems the result of instruction safety management within
when food safety issues help reduce the likelihood from the regulator and the business. Staff and managers
are reported & evident, of food poisoning. other third parties. understand the different
(i.e. fridge breakdown, Express agreement that food safety and hygiene
faulty thermometers etc.) See HACCP as a No verification or review is food safety and hygiene systems and value their
bureaucratic burden. undertaken to ensure the requirements are importance in mitigating
Business‟s confidence in e.g. 'I‟m not wasting time effectiveness of food food safety concerns.
effective.
food hygiene and money in fixing hygiene systems.
requirements May lack documentation,
something which I don‟t have HACCP Plan „on the e.g. 'We are confident that e.g. „HACCP and related
use anyway'. shelf‟/un-customised copy e.g. 'I have always done the control requirements hygiene procedures are a
of Safer Food, Better what the local authority cited in our HACCP will critical part of how we
Business. have asked me to do'. prevent food safety prevent incidents‟.
problems‟.
e.g. „Paperwork doesn‟t e.g. „It is not for me to say
make food safe‟. „We‟ve whether these food
been doing this job for 20 hygiene systems are
years‟. necessary‟.
16 July 2012
Category
Element
a) Calculative non- c) Dependent
b) Doubting compliers: d) Proactive compliers: e) Leaders:
compliers: compliers:
Consciously do not Food hygiene Place ownership and Understand the Self-evaluation of the food
comply unless requirements seen as responsibility for food importance of food safety and hygiene
enforcement obliges them burdensome. hygiene compliance on hygiene compliance and systems to identify
to. the regulator and other take ownership of meeting opportunities for
Business rejects third parties. the requirements. improvement e.g. active
Lack of presence within ownership of food safety use of scheduled internal
the business with no practices as these are Reliant on sources Clearly understood audits.
delegation of believed unnecessary. external to the business to organisational structure
responsibility for food update them to legislative and defined See food hygiene as a
safety. e.g. „We don‟t need to changes and highlight responsibilities for food fundamental business risk
worry - the staff know what, if anything, needs to safety. and one that must be
e.g. 'I won't change what they are doing – it‟s change. actively managed.
anything (with regards to common sense‟. e.g. 'We encourage all
food safety unless they e.g. Just tell me what you staff to take ownership Evidence of active
Business ownership of [the regulator] can show want me to do…(with and responsibility for food management of food
food safety and hygiene me evidence that I have regard to food safety)‟. safety and challenge non- safety and completion of
to'. compliance'. records, timely reaction to
e.g. „Just give me a list of issues.
what you want me to do
and I will do it‟. e.g. „The food safety lead
will regularly communicate
a review of food safety
practice standards across
the business to highlight
best practice and areas
for further
monitoring/improvement'.
17 July 2012
Category
Element
a) Calculative non- c) Dependent
b) Doubting compliers: d) Proactive compliers: e) Leaders:
compliers: compliers:
Any knowledge is not Doubt the benefit of Basic competence Competent and Very well informed about
applied. attending training and displayed with regards to knowledgeable about food hazards and latest
developing competence in food hygiene. hygiene legislation and methods of control.
Staff/management have food safety. how to manage relevant
no wish to improve Knowledge is derived hazards. Highly trained and
competence with regards Do not perceive training to from interactions with the knowledgeable
to food safety. be relevant or important to regulator and other third Undertakes standard food management, with
their business. parties. safety training for food regards to food safety.
Demonstrate lack of businesses.
interest in guidance, e.g. „Don‟t need to train e.g. 'They [the regulator] Awareness of current food
negative attitude to staff – it‟s common told me to use different Staff have received safety issues and
suggestions that training sense‟. chopping boards for raw instruction in food hygiene legislative changes with
is undertaken (self or and cooked meats so I and safety requirements regard to food safety is
staff). do'. and are evidently evident.
Competence, learning and
knowledgeable.
training in food safety and
e.g. 'I don‟t care about e.g. „Just tell me what you Knowledge of food safety
hygiene systems
getting a certificate, as want me to do‟. Those monitoring Critical goes over and above
long as the customer Control Points display legislative requirements
keeps coming back' . good understanding. (i.e. strive for „best
practice‟).
e.g. 'We make sure that
all staff receive training on e.g. 'All our staff receive
basic/Level 2 food safety'. formal food hygiene
training annually and
e.g. „It is very important internal reviews to ensure
that everyone knows what they know what they are
they need to do to prevent doing‟ .
incidents‟.
e.g. „It is essential that
staff are competent to
avoid incidents‟.
18 July 2012
Category
Element
a) Calculative non- c) Dependent
b) Doubting compliers: d) Proactive compliers: e) Leaders:
compliers: compliers:
Management advocates Leaders fail to act as a Leadership surrounding Leaders aim to provide a Frequently encourage
non-compliance except role model of good food food hygiene is good example and staff to apply food hygiene
where there is a risk of safety behaviours and inconsistent and follows encourage the food procedures, explain why
enforcement. express cynicism to staff. instruction from the hygiene behaviours this is necessary and
(e.g. FBO/Managers not regulator. desired from their staff as applaud good practice.
No attempt to provide adhering to protective per the regulations.
suitable equipment clothing rules). Lack of initiative and drive Evident active interest in
/facilities to enable staff to demonstrated by the FBO. Leaders challenge poor food safety; leadership
work correctly e.g. hand Poor food hygiene food hygiene practices through good examples.
wash facilities. practice remains Little presence of/direction which fail to comply with Recognition of
unchallenged and from the FBO in legislation. achievement i.e. „scores‟
e.g. 'It‟s not my problem - feedback is not provided workplace with regard to for compliance with
they can't fine the boss if with regards to hygiene food safety, except e.g. 'I wash my hands standards.
Leadership provided on the kitchen staff don't behaviours. following LA inspection. when entering the kitchen
food safety and hygiene wash their hands'. and I expect my e.g. 'I think it‟s important
e.g. 'I‟m not going to wash e.g. 'The inspector told employees to do the to give recognition for
my hands every time I go them [staff] to tie their hair same'. when staff are
in and out of the kitchen - up so I tell them to do that implementing best
what a waste of time'. now'. practice with (regards to
food safety) as well as
challenging when they are
not'.
19 July 2012
Category
Element
Minimal staff engagement. Low employee Low employee Employee engagement is Actively seek employee
engagement as doubt the engagement as accepted to help comply views on how to improve
Dictatorial approach to significance of the development and with regulation. food hygiene.
„managing‟ staff or simply hazards posed by poor application of practices
do not seek staff opinion. food hygiene and the and procedures is driven Develops food hygiene Evident active interest in
effectiveness of food by the regulator and other practices with some staff continual improvement in
e.g. 'I expect my staff to hygiene regulations/ third parties. involvement and offers the food safety –
do what I say'. requirements. opportunity for employees incentives/rewards for
Staff are left to get on with to comment once compliance and
Employee what they are paid to do complete. (e.g. following consistent achievement of
suggestions/input offered and behave in a way that review of HACCP Plan or internal standards;
is not considered by they think is appropriate. Safer Food, Better encouragement of
management or actively Business). suggestions for
encouraged. e.g. 'Our food hygiene improvement.
Employee engagement in practices would only be e.g. 'It is important to get
review & development of e.g. „We‟ve always done it changed in response to representation from staff e.g. 'Employee
food hygiene practices this way…‟ recommendations when reviewing the involvement is key to the
following inspection'. practices they are development of practical
e.g.‟ Staff lack the expected to implement and effective food hygiene
expertise to help improve e.g. „It is not realistic for and it needs to be practices'.
food hygiene procedures‟. us to engage staff in practical'.
reviewing how we do e.g. ‟Employees can help
things here‟. solve problems‟.
20 July 2012
Category
Element
a) Calculative non- c) Dependent
b) Doubting compliers: d) Proactive compliers: e) Leaders:
compliers: compliers:
Either no trust or actively Management make Employees not Communications focus on Employees feel
discouraged from derogatory comments encouraged to report poor promoting food hygiene in completely free to report
reporting concerns. about food safety/hygiene food hygiene. line with regulation. issues and trust
requirements. management to respond
e.g.‟ I would not report Very little communication Staff are encouraged to positively. Evident
issues, its more than my No action taken when about food hygiene. report examples of poor communication of food
job‟s worth‟. issues are reported or food hygiene practice to safety matters (i.e. staff
actions taken are not Staff left to get on with the ensure compliance. „notice board‟, display of
e.g. „It is not the job of timely. job and work around any any complaints and
staff to say something is issues. Staff indicate they can actions taken).
wrong‟. Staff have to raise issues influence food safety Management receptive to
several times to get a e.g. 'Any communication practice within the suggestions for
e.g. „If someone makes a response. about food safety will business. improvement.
mistake they deserve to come from the inspector
Communications & trust to Involvement of staff in
be blamed for it‟. e.g. „People worry too when they visit'. e.g. 'We have an open
engage in food safety and resolving issues and
much. If I followed up door policy so staff can
hygiene & report issues providing support in taking
every staff concern raised e.g. „I would not know how flag any points of concern
agreed actions.
I would never get any to solve a problem if staff in confidence that they will
work done'. reported one to me‟. be investigated'.
e.g. 'Suggestions for
improvement and
e.g. „We are a small e.g. „When we implement
highlighted issues are
business, so I do not need new procedures or
logged with details of
people to tell me what is working practices, we ask
follow up. This log is freely
going on‟. staff to tell us if they work
accessible to all staff to
well or not‟.
track the progress and
contribute to the final
outcome'.
e.g. „We applaud and
thank people when they
report problems‟.
21 July 2012
The exploration and categorisation of the food safety culture should be based on
observations of the business and behaviour.
This section provides guidance on:
The areas to explore during discussion with the food business and staff;
Observations of staff and owner behaviour;
Documents that can be reviewed as part of the inspection.
All of which can help support exploration and categorisation, on the part of the inspectors, of
the food business attitudes and behaviour towards food safety and hygiene.
5.2 Areas to explore
Each element, detailed below, has a selection of issues the inspector can explore to help
profile the attitudes and behaviours of the business.
This information can be used to support categorisation, on the part of the inspector, of the
food business attitudes and behaviour towards food safety and hygiene.
Not all issues need to be explored. Rather these are example areas to explore during
discussions, within the inspection, to help understand the food business attitudes and
behaviour towards food safety and hygiene.
Element 1: Priorities and attitudes
1. To what extent is food safety and hygiene seen as a critical success factor for the
business?
2. What are the things that are seen as most important for the business to succeed?
Element 2: Food hygiene risk perceptions & knowledge
3. To what extent does the business think that not complying with food hygiene and
food safety regulations would create a significant possibility of customers getting food
poisoning?
4. To what extent does the business think that the risk to their customers of food
poisoning or other forms of harm justify current food hygiene and safety regulations?
5. What does the business believe are the key things that can make their products
unsafe for consumers to eat? How do they think this could affect their business?
What effect do they think this could have on consumers?
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1
http://wales.gov.uk/ecolidocs/3008707/summaryen.pdf?skip=1&lang=en
2
Sara Mortimore, Vice President, Quality Assurance and Regulatory Affairs, Land o‟Lakes, USA Global Food
Safety Conference 2011
3
Chris Griffith, Editor British Food Journal and Head of Food Research and Consultancy Unit, University of
Wales, UK and Technical Director of Von Holy Consulting, South Africa Global Food Safety Conference 2011
4
http://www.prnewswire.com/news-releases/ul-launches-new-food-safety-initiative-128001093.html
5
Ungku Fatimah Ungku Zainal Abidin, Susan W. Arendt, & Catherine H. Strohbehn. Department of Apparel,
26 July 2012
“upon an analysis of existing safety climate surveys, expert reviews, and pilot testing”. They
report that the “measures developed from this study may be used in future research to
better understand the impact of climate for safe food handling on organization food safety
outcomes”.
Frank Yiannas6, author of ‘Food Safety Culture. Creating a Behavior-Based Food Safety
Management System‟, argues that:
“Achieving food safety success in this changing environment requires going beyond
traditional training, testing, and inspectional approaches to managing risks. It requires a
better understanding of organizational culture and the human dimensions of food safety. To
improve the food safety performance of a retail or foodservice establishment, an
organization with thousands of employees, or a local community, you must change the way
people do things. You must change their behavior.…”
Educational Studies, and Hospitality Management Iowa State University. Organizational climate for promotion
of safe food handling practices: Development and validation of measures in foodservice organizations.
6
Yiannas, Frank. Food Safety Culture: Creating a Behavior-Based Food Safety Management System. 2009.
Series: Food Microbiology and Food Safety.
7
Cited within F. Yiannas, (2009). Food Safety Culture: Creating a Behavior-Based Food Safety Management
System (Food Microbiology and Food Safety). Springer science.
8
http://www.foodsafetymagazine.com/article.asp?id=4099&sub=sub2
9
Yiannas, F. (2009). Food Safety Culture: Creating a Behaviour-based Food Safety Management System.
Springer. New York:USA.
10
Powell, D., Jacob, C. & Chapman B. (2011). Enhancing food safety culture to reduce rates of foodborne
illness. Food Control. 22 (6) , 817-822.
11
Griffith, J., Livesey, K.M., Clayton, D. (2010) The assessment of food safety culture, British Food Journal,
Vol. 112 Iss: 4, pp.439 – 456.
12
Evidence review on regulation cultures and behaviours, Institute of Employment Studies Cardiff Work
27 July 2012
culture, namely:
By defining types of organisational culture, such as reactive versus proactive, and;
By defining the elements that comprise or influence a culture, such as leadership.
The recent studies outlined above suggest that food safety culture can be said to have the
following elements:
1. Priorities and attitudes – Food business‟s attitudes towards food safety and the
degree to which food safety is prioritised within the organisation.
2. Business’s perceptions and knowledge of food hazards- Food business‟s
(management and staff) perceptions and knowledge of the hazards associated with
food hygiene (and whether they are significant enough to justify the requirements).
3. Business’s confidence in food safety requirements- the extent to which the
business perceives the food hygiene regulations and requirements to be valid and
effective.
4. Business’s ‘ownership’ of their food safety responsibilities - The extent to which
they see food hygiene to be the responsibility of the regulator and adopt a reactive
approach, as opposed to accepting that the business is responsible for taking a lead
in food safety.
5. Business’s competence - Knowledge and understanding of the hazards and
subsequent hazard management throughout the organisation.
6. Business’s internal leadership – The extent to which there is clear and visible
commitment and leadership of food safety from management.
7. Employee involvement - The extent to which there is involvement, ownership and
accountability for food safety across staff at all levels of the business.
8. Communications within businesses - The extent to which there is open
communication and freedom to challenge and discuss practices.
Moreover, the recent studies outlined above suggest that businesses‟ food safety culture
(across the elements) can be categorised, as follows:
a) Calculative non-compliers : Intentionally breach regulations for the sake of financial
gain, disputing or disregarding the potential impact on consumers – without assessing
the potential impact on people and making decisions without due deliberation or
consideration of regulations or other requirements;
b) Doubting compliers: Doubt the significance of the hazard posed by food safety and
hygiene and the effectiveness of food hygiene regulations and requirements in
managing these hazards. May have the capability to understand requirements but
doubt the risk. May express cynical view to staff and do not promote compliance other
than for purposes of regulatory compliance.
c) Dependent compliers: Wait upon advice or instruction from regulators and other third
parties to make improvements and view food safety and hygiene as something driven
by third parties. Tend to view requirements as unfairly complex and that it is
unreasonable to expect them to take a lead in understanding and applying. May have
low levels of knowledge and training. May not have any clear perception or knowledge
of the potential issues posed by food safety and hygiene.
d) Proactive compliers: Understand that hazards posed by poor food hygiene and poor
process controls are significant and accept that requirements are effective and
necessary. Wish to ensure food safety controls are proportionate and effective, and will
positively debate (internally and externally) how best to manage food safety hazards in
28 July 2012
a cost effective and proportionate way, implementing food safety controls after careful
deliberation. Management provides a lead in encouraging compliance for the sake of
the business as well as regulatory compliance but may not go beyond “good practice”.
e) Leaders: View food safety and hygiene as critical business issues that they must tightly
manage and offers potential business benefits through achievement of a good
reputation for food safety and hygiene. Provide visible leadership in continually
reviewing food safety and improving food hygiene.
The elements and categories of food safety culture can be presented as a matrix.
The matrix, which forms the basis for the exploration and categorisation of food safety
culture assessment (section 2 and 3), consists of 5 categories and 8 elements.
Category
Element a) b) c) d) e)
Calculative Doubting Dependent Proactive Leaders:
non- compliers: compliers: compliers:
compliers:
Business ownership of
food safety and hygiene
Employee engagement in
review & development of
food hygiene practices
Communications & trust to
engage in food safety and
hygiene & report issues
The food safety culture matrix is presented in Section 4, Table 5 and provides descriptions
of each element per category.
It should also be noted that there is insufficient research in the area of food safety to
indicate whether businesses progress through these categories in a sequence over time, or
whether it is necessary to move businesses through the categories from “calculative non
compliers” to “leaders”.
Therefore, they are presented in the food safety culture matrix as categories by which a
business may be categorised.
29 July 2012
13
www.food.gov.uk/multimedia/pdfs/codeofpracticeeng.pdf
30 July 2012
motivate businesses to move towards self motivated self compliance. The advice includes
„messages‟ and voluntary actions that might influence or help to change the attitude of
businesses.
In addition, when deciding on the issue of hygiene improvement notices, the officer should
consider whether they have “reason to believe that an informal approach will not be
successful” (p53). The food safety culture category of a business may inform this
judgement.
14
Jensen P and Jensen J. Carrots and sticks – inspection strategies in Denmark, July 2003. National research
centre for OHS regulation. Online publication http://ohs.anu.edu.au/publications/pdf/wp%2012%20-
%20Jensen%20and%20Jensen.pdf
15
Business perspectives on approaches to securing compliance - BR0103, Greenstreet Berman Ltd 2011.
http://randd.defra.gov.uk/Default.aspx?Menu=Menu&Module=More&Location=None&Completed=0&ProjectID
=17702
31 July 2012
model of responsive regulation whereby the prior attitudes of businesses are taken into
account in enforcement decisions.
This research also suggests that a range of approaches to securing compliance need to be
matched to the attitudes and capacity of businesses. Therefore along with supporting
potential enforcement strategies, the assessment of attitude and culture should be used to
decide on other interventions that can be applied to help influence attitudes and behaviour.
For example, Powell et al (2011) 16, indicate that interventions, such as advice, guidance
and recommended training etc... that encourage the development of the following will help
to create a good food safety culture:
Know the significant hazards associated with the foods they handle and how these
should be managed;
Dedicate resources to evaluate supplier practices;
Stay up-to-date on emerging food safety issues;
Foster a value system within the organization that focuses on avoiding illnesses;
Communicate compelling and relevant messages about hazard and risk reduction
activities, and empower others to put them into practice;
Promote effective food safety systems before an incident occurs; and
Do not blame customers, including commercial buyers and consumers, when
illnesses are linked to their products.
Some of the research (Frank Yiannas 200917; Powell et al 201118; Griffith et al 201019 and
Institute of Employment Studies 201020) also suggests that introducing a positive safety
culture incorporating the elements outlined in the food safety culture matrix, should ensure
that businesses have an understanding of food safety requirements as well as the
knowledge, motivation and skill to effectively manage significant food safety hazards.
This is particularly important for micro and small enterprises where compliance is often
driven by the regulator and motivations to change are commercially, as opposed to safety,
driven.
16
Powell, D., Jacob, C. & Chapman B. (2011). Enhancing food safety culture to reduce rates of foodborne
illness. Food Control. 22 (6) , 817-822.
17
Yiannas, F. (2009). Food Safety Culture: Creating a Behaviour-based Food Safety Management System.
Springer. New York:USA.
18
Powell, D., Jacob, C. & Chapman B. (2011). Enhancing food safety culture to reduce rates of foodborne
illness. Food Control. 22 (6) , 817-822.
19
Griffith, J., Livesey, K.M., Clayton, D. (2010) The assessment of food safety culture, British Food Journal,
Vol. 112 Iss: 4, pp.439 – 456.
20
Evidence review on regulation cultures and behaviours, Institute of Employment Studies Cardiff Work
Environment Research Centre. http://www.food.gov.uk/science/socsci/ssres/crosscutss/ssculturereview
32 July 2012