Regulatory agency investigations of foodborne illness outbreaks and recalls often conclude that the root causes involved human error in implementing food safety programs. In recent years, there has been heightened emphasis within the industry on strengthening food safety culture as an important way to advance public health goals, through improved risk awareness, behavior and personal accountability.
In July 2020, FDA released its New Era of Smarter Food Safety blueprint, a 10-year plan that builds on the Food Safety Modernization Act (FSMA). The blueprint has four core elements: tech-enabled traceability; smarter tools and approaches for prevention and outbreak response; new business models and retail modernization; and food safety culture. FDA emphasized that “a strong food safety culture is a prerequisite to effective food safety management.”
Frank Yiannas, FDA’s deputy commissioner for Food Policy and Response, has stated that “you can have the best policies, written procedures, rules and laws on the books but if they're not put into practice by people, they are absolutely useless.”
No food safety culture criteria are included in the blueprint, and FDA did not propose to develop and impose specific food safety culture requirements. Instead, FDA will identify tools and strategies to assist companies in adopting criteria that are consistent with existing regulatory requirements and internal business cultures, and that are flexible with respect to the nature and size of each company.
There is industry consensus that establishing a successful food safety culture requires a top-down approach, with the leadership team prioritizing the identification and maintenance of practices to influence attitudes and modify behavior, in all areas of a company. Promoting a collective mindset of greater vigilance and individual responsibility can improve performance in a supportive environment.
Although employee feedback can reveal vulnerabilities in a food safety system, there may be reluctance to express concerns due to fear of job repercussions, despite FSMA whistleblower protections. Thus, the use of confidential or anonymous surveys can alert management to potentially serious food safety problems that might not have been raised without the assurance of privacy.
Board oversight of risk, as a component of food safety culture, is also an area of heightened attention. A 2019 Delaware Supreme Court decision permitted a shareholder derivative lawsuit to proceed against directors of Blue Bell Creameries (linked to a serious listeria outbreak in 2015), concluding that directors would be liable for breach of fiduciary duty if, as alleged, “no system of board-level compliance monitoring and reporting existed” for food safety oversight.
Frank Yiannas praised the decision: “Food safety culture starts in the boardroom - not on the plant floor.”
Internationally, food safety culture was defined by a Global Food Safety Initiative (GFSI) technical working group in a 2018 position paper as “shared values, beliefs and norms that affect mindset and behavior toward food safety in, across and throughout an organization.”
Version 2020 of the GFSI Benchmarking Requirements, issued in February 2020, includes elements of food safety culture (“at a minimum consisting of: communication, training, feedback from employees and performance measurement on food safety related activities”). FDA intends to work with GFSI and recognized standards regarding harmonization of food safety culture approaches.
In October 2020, the Codex Alimentarius Commission of the United Nations (Codex) revised its standard on General Principles of Food Hygiene (CXC 1-1969) to add food safety culture: “Fundamental to the successful functioning of any food hygiene system is the establishment and maintenance of a positive food safety culture acknowledging the importance of human behaviour in providing safe and suitable food.”
In March, the European Union (EU) Commission, noting that trade partners and consumers expect food produced in the EU to comply with Codex, amended the Annexes to Regulation (EC) No 852/2004 to incorporate food safety culture as a general principle (Commission Regulation (EU) 2021/382).
Concerns have been raised that it may be premature to include food safety culture in standards because the concept is based on vague criteria. Another position, however, is that there are identifiable risks which can be measured presently by established metrics in order to assess food safety culture.
It is unclear whether the current food safety culture approaches by FDA, Codex, the EU and GFSI are inconsistent, but the trend is for companies to incorporate food safety culture as a component of food safety management systems. Timely clarification is needed to enable the food industry to understand the implications of the growing global focus on food safety culture.