Food safety culture in FSSC 22000 v7 — how an auditor assesses it and what they expect

‘Food safety culture’ is one of those requirements of the standard that leaves many organisations scratching their heads. You can write a procedure, fill in a register, and document training with signatures — but how do you “document a culture”? This is a question that regularly comes up during audit preparations, and the answer is by no means obvious if one treats this requirement as just another box to tick in the documentation system.

What exactly is food safety culture as defined by the standard?

Put simply, it is something that cannot be fully described in a document — it is about how people in the facility actually behave with regard to food safety when no one is watching. The standard requires the organisation to consciously build and maintain an environment in which:

• staff understand why certain rules exist, and not just that ‘they must be followed’,
• management demonstrates through their behaviour that food safety is a priority, not just a slogan on a poster in the production hall,
• reporting problems and irregularities is seen as something desirable, rather than a risk to the person reporting them,
• operational decisions (production rate, shift staffing, choice of supplier) actually take food safety into account, rather than just costs and deadlines.

This is a requirement that food safety standards have been formalising since previous versions, but subsequent updates to the FSSC 22000 standard — including the latest revision of the standard, along with the deadlines by which organisations must comply with it — systematically clarify what evidence of compliance with this requirement is expected from an organisation — and it is precisely this area that poses the greatest difficulties for companies that approach the system purely from a documentation perspective.

What evidence is the auditor looking for?

When assessing food safety culture, an auditor rarely limits themselves to simply reading the procedures. Instead, they look for consistency between what is set out on paper and what happens in practice. In practice, this usually means:

This is one of the reasons why major food brands and retail chains now regard a supplier’s system maturity as more than just basic HACCP—food safety culture is one of the factors that clearly distinguishes a facility that genuinely manages risk from one that merely has documentation in place.

Conversations with staff on the production floor. An auditor may ask a line operator why they are carrying out a particular task in a specific way — and check whether the answer demonstrates an understanding of the risks or merely the mechanical repetition of a learnt instruction.

The way in which management responds to reported issues. If the corrective action register shows that reports from front-line staff are taken seriously and lead to tangible changes, this is strong evidence of a mature culture. If the register is empty or reports come exclusively ‘from above’, this is a warning sign.

Internal communication. Noticeboards, team meetings, the way shift briefings are conducted — the auditor assesses whether the topic of food safety actually features in day-to-day communication, or only in system documents.

Consistency of management decisions. In situations where time is of the essence (urgent orders, breakdowns, staff shortages), does the facility have documented mechanisms in place to prevent food safety standards from being compromised ‘as a quick fix’?

The training programme is assessed in terms of effectiveness, not merely completion. The mere fact that training has taken place is not enough — the standard requires the organisation to verify whether the training has actually led to a change in attitudes and behaviour, rather than merely a signature on an attendance list.

Common mistakes made by businesses regarding this requirement

The most common mistake is treating food safety culture as a one-off project — for example, a series of training sessions held prior to an audit — rather than an ongoing process embedded in the company’s day-to-day operations. Auditors quickly recognise this pattern, as employees’ freshly ‘refreshed’ knowledge tends to be superficial and does not stand up to in-depth questioning.

A second common problem is a lack of commitment from senior management that is visible to the workforce. A food safety policy signed by the board but never effectively communicated to front-line staff does not build a culture — it merely creates a document.

The third mistake is treating staff reports as a threat to the plant’s reputation, rather than as a source of information for improving the system. If staff fear repercussions for reporting irregularities, the system loses its most important early-warning channel — and this is one of the areas where production facilities most often lose effective control over food safety, despite having a formally functioning system.

How to implement this requirement in practice

It is worth basing the development of a food safety culture on a few specific, repeatable actions:

1. Include the topic in regular shift briefings, rather than just in formal training sessions held once a quarter or once a year.
2. Establish a simple and secure channel for reporting irregularities, where staff know that their report will be investigated, rather than ignored or used against them.
3. Involve management in visible, regular activities — such as being present on the production floor, taking part in inspections, and communicating decisions relating to food safety directly to the workforce; at this stage, it can also be helpful to seek the perspective of an external consultant who supports organisations in implementing a food safety management system compliant with FSSC 22000.
4. Measure effectiveness, not just implementation — e.g. through surveys, on-floor observations, and analysis of the number and quality of staff reports over time.
5. Document cultural evidence, not just formal documentation — minutes of meetings, examples of improvements implemented following staff suggestions, and changes to operational decisions made for the sake of food safety.

Summary

A food safety culture is a requirement that cannot be met through documentation alone — the auditor assesses it through interviews, observation and an analysis of the consistency between the organisation’s declarations and its day-to-day practices. Companies that treat this area as an ongoing management process, rather than a one-off project ahead of an audit, find it much easier to navigate this part of the assessment — and, more importantly, they effectively reduce the risk of food safety incidents.