I actually agree. GFSI is failing. I think back in 2000, there were enough manufacturing (and other) facilities with poor basic standards. The various food safety standards which became part of that scheme helped that basic level of compliance.
But it also created something else. It created plants where passing the audit became more important than food safety. Where it all sat on Technical team shoulders. So they introduced the requirement for Senior Management Commitment. So we wrote policies and stuck them under Plant Director's noses for them to sign. They'd never written and barely read a word of them. So GFSI brought in food safety culture. It was still led by Technical. So they made it clearer it needs to be led cross functionally etc etc.
I am old enough to remember recalls which didn't happen and should have so measuring recalls only is probably not quite right. That said, I do agree. GFSI is a foundation standard trying to be more and while the intent I think for culture is good, the way GFSI standards are treated in most organisations mean that the execution is poor AND the plants executing poorly are able to get away with it.
Food safety culture is a "thing" and it does reduce error. It's basically in my head a lot of the elements of lean but for food safety. The problem with the GFSI approach to it though is that plants can get away with lip service to food safety culture, not helped by basically as long as you get a survey it being treated as tick box ok. I see the same in other parts of GFSI standards. HACCP particularly is generally poor and poorly audited. It's not about whether the food safety risks are being well managed but have you had a review in the last 12 months? Have you considered radiological hazards? Etc.
The problem is, what is the alternative? Because this is all driven by incentives isn't it? If you get a B (or even an A sometimes) on BRCGS nowadays, retailers aren't happy. You might even have an appraisal where the score on the external audit is part of your pay or bonus. And what's the point in that? It's not proving safety, it's proving compliance on the day or the perception of it. We all know we can misdirect auditors too, without out and out lying. We convince ourselves it's because "I'll sort it out later myself" but in all honesty it's really to get a better score.
While there are scores for audits, this will happen.
It takes a really mature organisation to want to improve and actually do a good job of some of the sections of GFSI not just one that ticks the box and nobody is going to hold them accountable either way. Fact is they will save money and workload in the long term isn't of interest to very short termist organisations in the main.
I don't think I have the answer. But I do think that the content of GFSI based audits isn't bad, but the schemes, the auditing and the way scores are treated are. I've always taken the view that it's my job to act as advocate for the clauses being done in the right way, in a way that really makes a difference (I have twice restarted HACCP plans from scratch for example). And where the clause is blatantly stupid, then there are occasions where I'll be honest about that internally and we'll write a risk assessment for compliance reasons. But I don't think this clause is stupid if that makes sense? More that the way it's audited is stupid and perhaps even the idea of auditing as a concept for food safety is stupid. At least where scores are part of it.
Perhaps the answer is to follow in the steps of health and safety. If high fines and imprisonment were not uncommon for food safety but at similar levels to health and safety, it might focus minds.
My last point was a senior Ops Leader. "GMO, I'd rather be in front of a judge for food safety reasons than health and safety."
My response was "what about neither."
It spoke to me of a belief in some that food safety is an acceptable risk or a "given" and that belief is common. This clause is trying to push at those beliefs and attitudes but probably from the wrong direction. Unless the consequences of poor culture are felt by ops and site directors, in many organisations they won't change.
And the best culture plans and changes I've seen? In sites who have already felt the pain of when it's gone catastrophically wrong. In others, even plants with obviously poorly controlled risk, when I'm doing general supplier auditing, I come across even Technical leaders who don't think it's even real let alone important.
