CLAUSE REQUIREMENTS

The policy statement is only a summary and can usually be expressed in a single page. Although it does not
need to be dated, it must be current and should therefore be updated when significant policies or senior
management change. The policy forms the foundation for the site’s ways of working and the auditor will
expect to see how the site management ensure staff understanding and engagement. This may include:

• communication to staff (e.g. through display on noticeboards, inclusion in the induction process,
availability on the company intranet, and the use of appropriate languages where the local language is
not the first language of all employees. The use of dual languages improves and speeds up
understanding and action
• inclusion of all staff, including temporary and contract staff, in the communication and engagement
processes.

1.1.2 The site’s senior management shall define and maintain a clear plan for the development and continuing
improvement of a food safety and quality culture. This shall include:

• defined activities involving all sections of the site that have an impact on product safety
• an action plan indicating how the activities will be undertaken and measured, and the intended
timescales
• a review of the effectiveness of completed activities.
Interpretation Food safety culture
A proactive, positive culture within a company can make all the difference in the effectiveness of the food
safety and quality plan and its consistent implementation throughout the site. Culture must be led by senior
management and ‘felt’ throughout the organisation, so that all aspects of the business are informed and
involved.
Culture can be challenging. It relies not just on measurables and specifics but an ethos and values felt by
people at all levels of the site. The size and complexity (or simplicity) of the site should not be a barrier to a
successful culture. Good culture is also expressed through the ease of movement of information between
different levels of the company.
The site is required to develop and implement a clear plan or programme for developing and improving its
food safety culture. Such a plan would be based on the nature of the organisation, and dependent on its size,
seasonality and the overall aims it has identified as important for its own culture.
The plan does not need to be annual. A strategic plan could, for example, cover 5 years, with activities
designed to measure current culture, implement changes and assess improvements (or where
improvement was not evident, a review of why). Some aspects of the plan may occur more frequently than
others and the tools, metrics and measures for monitoring the plan should be demonstrable.
A wide range of activities could be incorporated into a culture development plan, some of which the
company may already be conducting. For example:

• a staff survey focusing on values and culture

• annual staff reviews (one-to-ones) and recognition programmes
• feedback mechanisms (e.g. staff concerns)
• training review and staff development
• teamwork (e.g. staff involvement in setting product safety objectives)
• effective communication strategies
• activities to demonstrably maintain product safety standards.
The auditor will expect to find evidence of a plan with objectives, and evidence of the site completing the
activities in its action plan. This will be determined through interviews and by viewing objective evidence of
the steps taken.
Interviews may be conducted across all levels of personnel on an informal basis. They will be expected to
find an awareness of food safety culture, how individuals can impact on it, and the company’s objectives.
BRC Global Standards operates a module in product safety culture excellence which sites can elect to add
to their BRC Global Standards audit. It will publish a guideline on product safety culture which may be
purchased from the BRC Global Standards bookshop ([Link]) or viewed online at BRC
Participate ([Link]).

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 PART II GUIDANCE ON THE REQUIREMENTS
CLAUSE REQUIREMENTS
Objectives or targets around food safety culture can be managed separately from, or together with, targets
concerned with product safety, legality and quality. How they are managed depends on the nature of the
food safety culture objectives and how they link with the site’s other objectives.
Example Food safety culture strategic plan
A large company is creating a food safety culture plan. Senior management have recognised that employee
attrition is a continual concern; each year they replace up to 35% of the total production staff. This means
that productivity and on-time delivery are reduced because of the required upskilling of the new employees,
and the site receives regular complaints from its customers of late deliveries and of non-conforming
product.
The site’s plan starts out quite simply by stating its intention to increase staff retention. Senior management
start by surveying their employees anonymously to try to understand employee concerns. The site also
starts to implement exit interviews for employees already leaving the company, and selected volunteers take
part in one-to-one interviews with an external consultant.
Following these surveys, the site identifies that employees do not feel integral to the business, have
difficulty in understanding how their actions impact on the company, and do not feel recognised by the
management team.
The company decides to implement plans, including enhancement of training, communications, rewards
and recognition. This includes:

• enhanced training – beyond just managing critical control points (CCPs), to an understanding of the
reasons for the current product safety processes and involvement in corrective actions
• communications – regular staff updates in addition to the traditional internal message boards. Updates
are used to communicate production, incidences of non-conforming product, customer complaints and
their corrective actions, and improvements in product quality. They also focus on company strategy and
product safety objectives
• a clear feedback process – to initiate communication ‘up’ to management, so that communication is not
just seen as management ‘telling staff’
• recognition – management instigate ‘employee of the month’ awards as rewards for successful process
improvement ideas.

1.1.3 The site’s senior management shall ensure that clear objectives are defined to maintain and improve the
safety, legality and quality of products manufactured, in accordance with the food safety and quality policy
and this Standard. These objectives shall be:

• documented and include targets or clear measures of success

• clearly communicated to relevant staff
• monitored and results reported at least quarterly to site senior management.
Interpretation Food safety and quality objectives
Senior management must set objectives concerning food safety and quality which help to achieve the
stated policy (see clause 1.1.1). The objectives must be communicated so that the relevant staff (i.e. those
whose roles can affect product safety or quality) understand what is required from them. The setting of these
objectives also helps the allocation of suitable budgets and resources. Auditors will look for evidence that
the objectives are in place and have been communicated to staff.
Good objectives are usually:

• specific – clear and directly related to the site’s aims or goals for product safety and quality
• measurable – so that the site can assess progress
• achievable – targets that stretch the company are acceptable but it is important that they are realistic and
that sufficient resources will be available
• relevant – designed to maintain and improve product safety and quality
• time-bound – either long term (e.g. throughout the period of certification) or shorter term (e.g. within the
next 3 months); however, the timescales or deadlines should be clear to enable the site to review
progress and, if necessary, amend activities.

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