7.3 Awareness

Hi everyone,

I would like to ask for your input on the interpretation of two specific clauses in ISO 22000:2018, which I believe refer to different levels of engagement regarding the food safety policy:

• Clause 5.2.2 – Communication of the food safety policy, which states that the policy shall be communicated, understood, and applied at all levels of the organization.

• Clause 7.3 – Awareness, which requires that persons doing work under the organization’s control shall be aware of the food safety policy, relevant FSMS objectives, their individual contribution to the effectiveness of the FSMS, and the implications of not conforming to FSMS requirements.

In my view, there is a meaningful difference between these two clauses. Clause 5.2.2 focuses on communication within the organization, while clause 7.3 goes further by requiring active awareness, particularly for those under the organization's control.

My interpretation is that this phrase does not only refer to directly employed staff or full-time workers, but may also include external persons such as contractors, subcontractors, temporary personnel, or technical consultants, if their activities can impact the Food Safety Management System.

A fellow auditor disagrees, arguing that such awareness is not necessary for external parties and should only apply to direct internal personnel.

Do you consider my interpretation valid – that persons under the control of the organization includes external personnel who perform tasks that could affect the FSMS?

I appreciate your feedback and experiences on this topic.

I would interpret 7.3 that anyone doing work which could impact food safety under your control would be in scope.  So to my mind that would include agency staff, engineering contractors, canteen staff, people like that who might not be directly employed but are covering a role a directly employed person could or would do if staff were available.

I think that clause sounds quite onerous but all it really means is that they need to be trained on the policy and aware and able to demonstrate their training and awareness of what they do for food safety and the implications on food safety of not doing it correctly.  That should be included in onboarding of agency and contract staff.

But I'm not an ISO expert so will welcome opinions of others.