Creating a strong product safety culture can be challenging. But it’s critical to ensure the effective implementation of product safety management systems – and in helping to prevent product safety incidents.
Part of the inherent difficulty of trying to establish an exemplary approach to product safety is that ‘culture’ isn’t really tangible. It’s something that an organisation is, rather than something an organisation has. Culture is the ethos of an organisation, and the values felt and demonstrated by people at all levels – irrespective of the size and complexity (or simplicity) of its sites worldwide.
When an organisation has a strong product safety culture it can be assured that its employees and contractors will always do the right thing – even when they’re under pressure or when no-one is actually watching... Whether or not staff members always wash their hands after using the bathroom is a great example of this.
Conversely, poor product safety culture is a problem in itself. At best, a poor culture will prevent business objectives being achieved. At worst, it will create the conditions in which product safety incidents may occur – with potentially devastating consequences for customers and consumers, as well as for the organisation itself.
Think back to the 19 million toys that Mattel had to recall in 2007. The defects were ultimately attributed to poor management commitment, a lack of safety controls implemented by suppliers and a profit-driven culture. Two years later, Toyota was forced to recall millions of vehicles due to uncontrolled acceleration issues. This was once again attributed to a profit-driven company culture and lack of commitment to safety.
Such potentially catastrophic events can be avoided if business managers and executives become familiar with the concept of product safety culture – and how to create and manage it. This requires them to not only focus on the rules and processes necessary to meet certain standards and regulations, but also to consider the much harder to assess attitudes and behaviours that constitute the culture of their organisation.
The evolving role of culture in audit standards
Developing and continually nurturing a strong food safety culture must be a primary focus for every food manufacturer.
The absolute necessity for a positive product safety culture within the food industry has been recognised by global standards-setting authorities including Codex Alimentarius, GFSI, BRCGS and ISO, as well as national governments around the world.
“Food safety culture is important to me because I’ve learned through experiences in the real world, it’s what matters most in producing safe food. In fact, I believe that a strong food safety culture is a prerequisite for an effective food safety management system.”
Frank Yiannas - Deputy Commissioner, Food Policy & Response, US Food and Drug Administration (FDA)
Today, product safety culture is a key part of Global Standard Food Safety audits and a strong food safety culture is a major contributor to success in audits. This is why artefacts of culture have been included in the BRCGS Global Standard Food Safety since its inception, although it wasn’t until Food Safety Issue 8 that Food Safety Culture was added as a specific requirement.
BRCGS will publish Issue 9 of the Global Standard Food Safety on 1 August 2022 – with the first audits due to take place in February 2023. The associated international consultation feedback and review of emerging food safety concerns identified several opportunities for the further development of this area in the Standard. As a result, Food Safety Issue 9 takes into consideration the top 20 most commonly occurring non-conformances (NCs) from audits which accounts for only 5.6% of the total number of clauses within the Standard but almost 30% of all the NCs raised in global audits are against them.
Notably, concerns relating to an organisation’s Food Safety Culture Plan (or lack of one) have consistently featured in the top 10 of all registered NCs for the past three years. Certain core competencies help organisations to ‘get the basics right’ when it comes to creating and nurturing a culture of excellence.
In Food Safety Issue 9, the food safety culture section has evolved with the introduction of the behaviour changes required to improve product safety culture. The updated Standard includes the requirement for organisations to put in place defined activities that support the improvement of food safety and culture, with defined timescales and measurements.
Developing a culture of excellence
The auditors role is to assess evidence of compliance with the requirements of the updated Standard. This includes the site having a plan for the development, maintenance and improvement of a product safety quality culture.
As a mInimum, this plan will require:
- Clear and open communication on product safety;
- Feedback from employees;
- Behaviour changes required to maintain and improve product safety processes;
- Performance measurement on product safety, authenticity, legality and quality related activities.
A key feature of the new Issue 9 is that it builds on the requirements relating to behaviour and culture. As with all activities within an organisation, creating and maintaining a good product safety culture needs to involve everyone. It’s not just the technical manager’s role or something that happens on the production floor – instead, it must be ‘felt’ throughout the organisation. Creating an effective and successful product safety culture therefore requires input and commitment from all functions and leaders from various levels, including marketing, sales, purchasing, NPD, hygiene, HR and customer service. And because creating a culture is about expressing, nurturing and ultimately demonstrating desired attitudes and behaviours, training, communication, motivation and empowerment are absolutely critical.
Managing and improving an organisation’s product safety culture requires that business to understand where it currently stands and where it wants to be. It is therefore necessary to:
- Analyse the present product safety culture;
- Determine the desired product safety culture;
- Create a programme of culture change interventions to achieve the relevant goals.
Best practice involves setting numerical targets for improvements, so that there’s something to measure and compare over time. In this way, culture becomes like any other KPI and can be embedded into standard company processes.
Raising awareness of risk control measures, for example, would likely result in fewer product withdrawals and no product recalls.
Understandably, because it impacts on every aspect of a business, starting to look at an organisation’s culture overall can often feel overwhelming. The best approach is to break that task down into small ‘bite-sized’ pieces to identify the specific issues, attitudes or behaviours that need to be implemented.
Desired behaviours can also be identified through the results of a specific site survey, such as the BRCGS Food Safety Culture Excellence Module. This helps sites measure their current culture and identify areas for improvement, supported by an available training course explaining culture and its implementation.
The Best Practice Guide to Product Safety Culture recently published by BRCGS also includes a 10-step structure that organisations can use to break down the process of improving product safety culture across their sites. This guide covers everything from defining ‘what culture is’ and assessing current culture before identifying areas for change through to keeping momentum and assessing ongoing impact.
So, what does good look like in an organisation with a strong product safety culture? According to L. Suhanyiova et al., a safety intelligent organisation exhibits six attributes: social competence; safety knowledge; motivation; problem solving; personality and interpersonal leadership skills. Culture is a well proven concept which makes a difference to company operations and product safety management. Management is a vital step in the progress beyond the current challenges of procedural product safety
How will you create a culture of excellence in your organisation? To discover how we can help, contact the BRCGS Team today.