Edition 9 of the SQF Code was implemented this past May and is now being audited at food facilities across the globe. Prior to this edition, the concept of Food Safety Culture had not been defined nor required to be part of a company’s SQF program.

Now, however, the concept of Food Safety Culture is part of the required Management Commitment and Management Review clauses. So, it is no wonder that I have been receiving calls asking, “what is meant by Food Safety Culture, and how can we demonstrate it in our facility?”

The SQF Code now defines Food Safety Culture as the set of “shared values, beliefs and norms that affect mindset and behavior toward food safety in, across, and throughout an organization.” In other words, it is an overarching philosophy of food safety, where leadership is forever encouraging and empowering their employees to make the right food safety choices, all the time, regardless of who is watching, and that these values should be demonstrated at all levels of the company, regardless of job title or role.

Keep in mind that SQF Auditors are trained to look at records, to conduct interviews, and to make observations. So, I tend to do the same when preparing my clients for an upcoming Audit. Knowing what counts toward “Food Safety Culture” can help you adequately demonstrate compliance to this new requirement. Something as simple as posting signs in break rooms, hallways, and other common areas, can visually encourage a food safety philosophy, letting employees know that they are responsible for food safety and that food safety is priority.

Through employee training and discussion, management can encourage employees to report events that could impact food safety, or to share ideas on how to reduce the likelihood of food safety occurrences. For example, I have seen Employee Comment Boxes being utilized for this purpose, as well as weekly five-minute team meetings to discuss any food safety topics of relevance. Providing employee recognition for a job well done, a food safety choice well made, or for going above and beyond in food safety related actions, can also help to demonstrate an overall culture of food safety.

Something like “Employee of the Month” recognition or rewards drawings could be utilized for this purpose.

When looking at records, one can find evidence for or against the concept of a Food Safety Culture. We can verify that critical control points (CCPs) are being met, and that corrective actions are being applied where needed to ensure food safety before the product leaves the facility. By reviewing the utilization of a HOLD program or Positive Release program, and by referencing microbial results, sanitation logs, and environmental monitoring programs, we can assess whether food safety has been made a priority based on how much effort is placed on those programs.

Other records worth referencing for the assessment of Food Safety Culture include Internal Inspection Reports and their associated corrective action plans. I like to see corrective action plans include both a short and a long-term plan to avoid recurrence. Training records can demonstrate whether training has been prioritized, performed regularly, and on time. Capitol Project Plans and/or Work Orders can demonstrate Food Safety Culture by showing that future improvement plans are in the budget, on a near-future schedule, and that funds are being allocated for food safety related needs.

As consultants and auditors, we are trained to interview various employees to assess whether a culture of food safety is being encouraged “from the top, down”. Interview questions that employees may receive might sound something like this: “Does upper management also follow GMPs in production and storage areas? What happens when someone violates a food safety procedure? Can anyone describe a time when a food safety issue occurred and what management did about it? Can anyone provide an example of a time when additional resources were needed, and were those resources provided in an appropriate time frame?” Having mock interviews with employees before your audit will not only prepare them for potential interview questions but will also demonstrate that management makes time to educate employees about what food safety means and how everyone plays a role in it every day.

While interviewing employees, most auditors will simultaneously be making observations. I encourage the SQF Practitioners and Management to do the same in their daily routines. The auditor may look for proper labeling of chemicals, ingredients, packaging, in-process and finished goods, and then interview employees about traceability to assess their understanding of why lot code tracking is important.

When talking to employees who come into direct contact with food, they may ask about what they would do if they dropped product on the floor, or if they got cut and started bleeding onto equipment or product.

They may also compare the employee’s answers to the verbiage used in the SOPs to assess the adequacy of the training program.

So when preparing for your next audit, ask yourself, “How can we show Food Safety Culture? Are employees being encouraged to react appropriately during food safety situations? And if so, how could we show that? In what ways can we recognize employees for positive food safety decisions made? Is management providing an overall message that encourages food safety from the top, down? How can we show that? Can we add more signage to break rooms? Are Capitol Project Plans being documented for upcoming food safety related needs? If my employees were asked about the food safety objectives at our facility, would they know what to describe?” etc.

I believe, with a little preparation and understanding of what counts toward “Food Safety Culture”, that you can adequately demonstrate compliance to this new requirement in the Edition 9 of the SQF Code.

Brandis Wasvick

Brandis Wasvick is an SQF Implementation Consultant and Project Manager for Blue Compass Compliance LLC. Blue Compass Compliance LLC offers personalized advice, assistance, templates, training and guidance to help clients through the SQF Implementation Process.

For more information, visit BlueCompassCompliance.com, call (651) 271-0822 or email BlueCompassCompliance@gmail.com

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