11 replies to this topic

[GMO]

I am sensing a feel from many members on here that food safety culture is a bit of a fad.  Yet our health and safety colleagues have been deeply embedded within understanding what drives behaviours and what drives compliance for some time.

 

My previous post around the "why" had highest results on "because the standard says so".

 

But what if we are making safe food not just what the standard says we should do?  And doesn't part of making safe food mean you have to consider that people are not robots?

 

It fascinates me that while we all know that when things go wrong a person didn't follow what they should have done is almost always part of the problem, yet I'm not seeing the engagement from Technical people to get people doing what they should do?

 

Thoughts?  What would make you believe this was worthwhile?  Or does it just feel to "woo woo"?

[Scampi]

It feels like WOOHOO because CULTURE is embedded in a company from the TOP DOWN

 

Soooooooo, unless or until the company itself thinks it's valuable to foster a proper culture, what we do makes no difference

 

Case in point----our president send notice that folks are coming from a tour----and said note explicity states that the GMPs will not apply...........how the hell is it my job to change that????

[Setanta]

I don't think you have to convince many QA people that this is important. I think having a food safe culture is important. I do not think that you can measure culture the way they are attempting. I have a hard time with that. It cuts too close to checking the boxes.

 

Culture is teachable, if you lead by example. In my opinion, it is those people who still want to buy the cheapest ingredients, who want to avoid using approved suppliers, who want to use that product from the day before, who want to 'let product go' without a date code, etc., etc., that do the most damage to culture.

 

Until THAT culture changes, the rest is window dressing. My 'beef' is mandating a culture when there are a number of people in the higher positions who think this food safety is just a way to get more customers.

[TimG]

My opinion: FSQ culture is important, absolutely.

Measuring it, reporting on it, and putting it into some metric is our industry's 'virtue signaling.' It means very little and is not indicative of the actual FSQ culture in most cases.

[jfrey123]

I like having a strong culture, and everywhere I've worked I've been fortunate that either the culture was already established or management was open minded enough to accept changes for the best.  Regular floor employees can be taught to do the right thing and speak up when they see something wrong.  Often they realize their friends and family are going to eat what they produce, someone's kids are going to eat what they produce, and when they're taught the importance of doing their job safe and clean, they'll do the right thing.

 

What I abhor is the emphasis on how to document FSC on a monthly basis.  We can document in each monthly meeting that the plant and QA managers walked the floor with dedicated time to talk to employees and observe any opportunities for improvements, recording notes and interviews with the staff, and that's not good enough because there needs to be a procedure with metrics they account for.  So we setup a form to make sure the metrics in the procedure are hit with each walkthrough and meeting, and now our program is too narrowly focused and all we're doing is "checking off the boxes".  They throw out hot ideas like, "your CEO should be putting out a monthly memo to promote employee engagement."  Well then what?  Do I need a questionnaire from each employee to prove they read the CEO's memo?  It's the required documentation of new steps you've taken every single month that drives me crazy...

 

While I typed this, TimG above called FSC "industry's virtue signaling", and I couldn't agree more.  I was tasked with researching FSC last year, and I sat through 4 different webinars with 'leaders' from huge food corporations sitting on a stage and telling the crowd what FSC is to them.  It was a bunch of self-aggrandizing feel-good crap, and I'm surprised they didn't injure each other's backs from all the patting.  If I can get employees who know the job and can tell me how they make sure their part of the job is kept clean and safe, then I think my FSC is pretty solid, and I've got no problem tossing people who won't help row the boat the correct direction.

[GMO]

So, if I can follow up the question, is it how the standards are written which is peoples' beef and then how the CB audit it?  It seems like the gripes are nothing to do with the "intent" of the clauses?  More to do with auditors and perhaps to a degree GFSI standards perhaps not understanding it well?

[Scampi]

MY beef is the actual amount of work to create/manage/evaluate/report on a food safety culture vs value for money

 

From an SQF update email

• Food Safety Culture: A new focus for a site-wide food safety culture assessment plan that includes communication, training, feedback, and measurement.

Measure???? How??  how can I accurately measure CULTURE with metrics?  Perhaps it appears that my culture is great because my plan shows an awesome culture-----but maybe 99% of my employees are working 2 jobs and literally cannot afford to lose the job----how am I supposed to know what drives my employees to follow procedure and put food safety first? 

 

So there is ZERO value in making this an auditable clause as SQF has done

 

Until or unless the actual number of recalls is reduced and the certified sites get more value from the schemes outside of needing it as a customer requirement, this is a hill i'm willing to die on

 

I will add a caveat---I have ALWAYS worked in sites where the regulatory body was either onsite all day everyday OR on a regular schedule auditing me against the federal standard, so for me SQF is a customer requirement and makes zero difference to my food safety plan-excepting this ridiculous additions

[Killian]

I do think it will be interesting to see if people will come up with measurable ways to assess the strength of their own food safety culture that pass the sniff test. Incentivizing employees to participate in food safety quizzes or activities and then measuring participation feels like it checks all the boxes of the code requirement, but doesn't feel to me like an accurate reflection of the culture. More likely an accurate reflection of the denomination of the gift card/PTO/whatever other incentive is offered.

 

I think it's frustrating because we can all accept the significance of having that commitment at every level of the organization, but accurately measuring it feels impossible. I don't anticipate being dinged on this in an audit, it feels like a very easy box to tick. But ticking boxes isn't what I want to do if I know deep down that it's disingenuous.

 

But, while measuring it feels impossible, I believe there are a lot of creative people in the industry and that someone somewhere might be able to crack this nut in a way that actually feels real. Looking forward to some collaborative brainstorming threads once we've gotten all our complaining out.

[kfromNE]

Food Safety culture is a mind set. Like Scampi said - it comes from the top down. Food safety, employee safety, quality, etc. Unless they are seen as important as profit/as getting product out the door - having extra paperwork on what you are doing is meaningless. It doesn't solve the problem. A band-aid to the actual problem. 

 

SQF did make our facility better by requiring programs that weren't as robust - like a more enhanced knife program. What made it successful - the buy-in from our upper management at my facility. Our corporate SQF person, a former auditor wrote our program and for other food manufacturing facilities in the company. She wrote them the same as she could across the different facilities. We got a great score on our second year of doing SQF. 

 

One of our other facilities almost failed the audit the last time after 4 years of being SQF certified and scoring well. The difference - they got a new president of the facility. The person saw cutting corners as a way to save money. It did safe money in the short term but not long term. They got dinged on lack of management commitment. Side note: This facility is now closed - multiple reasons. It wasn't because of a low SQF score. But factors that caused the low score didn't help it. 

Edited by kfromNE, 29 May 2025 - 08:05 PM.

[jfrey123]

MY beef is the actual amount of work to create/manage/evaluate/report on a food safety culture vs value for money

 

From an SQF update email

• Food Safety Culture: A new focus for a site-wide food safety culture assessment plan that includes communication, training, feedback, and measurement.

Measure???? How??  how can I accurately measure CULTURE with metrics?

 

We share this beef, especially with an "assessment plan" that'll be part of the SQF 10 update.  When they say an assessment "plan", I'm thinking they're going to want something written like a hazard assessment complete with critical limits and defect action levels.  "Oh, we only did two slide shows in Q1 instead of three, we'd better record a CAPA as to why we've failed our FSC limits!"  So stupid.

 

Right now, the SQFI | Code Document guidance document for FSC talks about which records they'll review:

 

The following are examples of records and/or documents to assist in the implementation and review of this topic:  Food Safety Objectives & Performance Measures, Organization Chart, Capital Project Plan, Work orders, Internal Audit Reports, GMP Inspection Reports, Recognition Programs, Disciplinary Process, FS/Q Records, Training Records, Job Descriptions.

 

Then they discuss what auditors should observe in order to determine whether a plant has a strong FSC:

 

The following are examples of observations to assist in the implementation and review of this topic: Non-verbal communications such as information boards, TV screens, and/or postings; Behaviors such as picking up trash from the floor, putting items away not in use, organization of work area and/or hand washing; Leadership by example-observing senior site managements behaviors; Employee behavior during interviews such as hesitancy to answer questions or looking to management to answer; Completion of FS/Q tasks correctly and to the correct frequency.

 

Compare that to the definition of FSC in the SQF Code, you'd never be able to surmise they're going to review your GMP Inspection reports for specific mentions that you saw an employee pick up trash from the floor.  You'd never be able to guess that auditing whether your FS/Q tasks were done on time should also be documented somewhere else for FSC.  I would happily show my auditor all the records listed above (work orders done promptly, training records complete and refreshers done on time, when we've disciplined/retrained employees for errors, etc.) and expect them to find that I have a strong FSC.  But no bs, they turn around and ask me how have we specifically measured FSC, and if I merely point at a well regulated FSQMS with records for days, it's not objective enough as evidence.  I don't know how it's measured in other GFSI schemes, but it's getting ridiculous from SQF's point of view.

[GMO]

Hmm.  Really interesting.

 

There is research out there on how to measure culture and it's not a home made incentivised questionnaire.

 

Stop foodborne illness has a downloadable toolkit to get you started.  The Food Safety Culture Toolkit | Alliance to STOP

 

You could use a combination of your own or commercially available surveys (I'd recommend the latter but look into it to see if they've actually validated the results), focus groups, looking at records.  I wouldn't personally just look at audit results because they're so laggy but the kind of things I'd look at in records would be non cons completion / close out.  Involvement in HACCP.  Where food safety "sits" in your meeting structures etc.

 

There are some nice examples in that tool above.  I've seen this done REALLY badly where one site had four questions built into the engagement survey about food safety.  In no way were they validated as accurately getting under the skin of culture.  They painted a glowing picture and yet when I counted up all of the food safety outstanding non cons across the various systems they logged them in, it came to over 1000.  That's why I think some of you might be turned off by culture measurement because the system you've tried has been poorly designed and you know in your gut it's wrong.  Trust your gut.

 

But also all of you seem to be seeing this as your job.  I don't think it is.  Obviously Technical need to be part of a team delivering this but if the site director isn't seeing this as their role to improve, you will a) get nowhere and so just be ticking the audit box and b) just be wasting your time.  The Site Director should be accountable and to my mind probably Ops Manager or HR Manager responsible to lead.

 

Genuinely, Health and Safety, at least in the UK "got this" decades ago.  We will not make food safety better by a solely compliance based approach.  

[GMO]

We share this beef, especially with an "assessment plan" that'll be part of the SQF 10 update.  When they say an assessment "plan", I'm thinking they're going to want something written like a hazard assessment complete with critical limits and defect action levels.  "Oh, we only did two slide shows in Q1 instead of three, we'd better record a CAPA as to why we've failed our FSC limits!"  So stupid.

 

Having read the document you've linked, I don't think that's what they're asking for at all.

 

What I'd interpret this as is you've done some measurement, as per above.  You've identified a limited few things to work on and created an action plan with SMART objectives.  Showing progress and evidence against that plan will be step 1.

 

Records

The following are examples of records and/or documents to assist in the implementation and review of this topic:  Note all of these could be reviewed internally as part of your own culture measurement.

 

Food Safety Objectives & Performance Measures - what are you measuring and in what interval of control?  This is about the fact you a) do measure food safety and not just by exception but the things you measure will improve results.

Organization Chart - this to my mind is checking that you have the right resources in place and that reporting lines do not create conflict.  E.g. there is some level of independence for food safety SMEs.

Capital Project Plan - This will give indicators as to whether the site are trying to improve for food safety.  Firstly are you considering food safety as you plan your capital projects or are you even going further and investing because of food safety?  E.g. into fabrication, barcode verification etc.

Work orders -This will give indicators as to whether food safety actions are planned and prioritised.

Internal Audit Reports - Personally I think these are less useful but one thing which could be interesting about this is if the internal audits are not very challenging.  I had one site where one auditor raised 1 non conformance across 10 audits.  I knew then she was ticking a box.  Other indicators may also be repeat non cons.  

GMP Inspection Reports - Ditto for above.  

Recognition Programs - This is REALLY revealing.  What do people get rewarded for?  In lots of factories it's for "saving the day" which normally means getting a line back up and running.  Not food safety.

Disciplinary Process - This might be interesting but not in the way you think.  Yes of course, sometimes people do need to be held accountable for food safety but what would be REALLY positive to hear is an investigation actually found there was insufficient resource (or similar) and the team reacted.

FS/Q Records - Less interesting for me.  Personally I think these show very little apart from when you're walking the plant and you find them pre completed.

Training Records - Not "are they trained" but "how are they trained, is it specific to their role" and probably more importantly "how are they assessed".  

Job Descriptions - More of a tick box exercise but you'd want food safety to be in everyone's job description and also what it means to them in their role.

 

I think the other two sections are more self explanatory.  But they will to my mind look at what visuals you share.  What's on boards, notices, SIC boards etc.  Is that as important as the conversations people have?  Probably not.  But that's what they'll get out of employee interviews.

 

What you could do from time to time as a team is sit in on short interval control meetings and listen to what is discussed about food safety and by whom.  That's always a short cut for me to find out cultural norms.  Difficult to do though as a leader on site.  That's where an independent set of eyes might help.