Contents

Revision History

01 · Purpose

Purpose

This eBook exists to help food businesses look beyond the annual Food Safety & Quality Culture survey and interpret the much wider body of evidence already generated by their Food Safety Management System (FSMS). It translates the themes of Entecom’s “Food Safety & Quality Culture: Beyond the Annual Survey” webinar into a structured, referenced guide that quality, technical and senior management teams can use directly, and revisit as culture is discussed at management review.

It is written to support — not replace — the culture-related requirements of BRCGS Global Standard Food Safety Issue 9 and FSSC 22000 Version 6, and to align with the Global Food Safety Initiative’s (GFSI) Position Paper on a Culture of Food Safety (Version 2.0, 2026).

02 · Introduction

Beyond the Annual Survey

When organisations talk about Food Safety & Quality Culture, the conversation often moves quickly to an annual employee survey, an action plan, a measurable objective and a review date. Those activities can absolutely form part of a culture programme — but they rarely give the complete picture.

Culture is not something that exists only in a questionnaire. It is present every day: in the concerns people report, in the issues they choose not to report, in the way supervisors respond to mistakes, in whether corrective actions prevent recurrence, and in what people do when production pressure increases.

“The survey is only the tip of the iceberg.”

This guide is not about abandoning surveys — they remain a genuinely useful way of understanding employee perceptions at a point in time. It is about placing the survey in its correct context, and exploring the wider evidence that already exists throughout the FSMS: audits, non-conformances, corrective actions, near misses, training records, complaints and employee feedback. None of these records proves culture on its own. But when the evidence is connected, patterns identified and better questions asked, it can reveal where further investigation and improvement is needed.

03 · Scope

Scope

This guide applies to any certificated or certifying food business seeking to strengthen how it evidences and improves Food Safety & Quality Culture under BRCGS Issue 9 (clauses 1.1.1 and 1.1.2) or FSSC 22000 Version 6 (Additional Requirement 2.5.1, Food Safety Culture). It is intended for Quality Managers, Technical Managers, site leadership teams and anyone chairing management review, and can be used alongside — not instead of — the site’s existing culture plan, survey and objectives.

This guide does not replace certification requirements, does not constitute an audit tool, and does not prescribe a maturity model or software system. It is a practical framework for interpreting evidence that most FSMS already generate.

04 · Standards Requirements

Standards Requirements

Neither BRCGS nor FSSC 22000 treats Food Safety Culture as a once-a-year survey exercise. Both schemes expect culture to be actively planned, evidenced, monitored and continually improved — and GFSI’s global position paper reinforces the same view.

4.1  BRCGS Global Standard Food Safety, Issue 9

Clause 1.1.1 requires the site to hold a documented policy, signed by the person with overall responsibility for the site, that includes a commitment to continuously improve the site’s food safety and quality culture and is communicated to all staff.

Clause 1.1.2 goes further: senior management must define and maintain a clear plan for the development and continuing improvement of food safety and quality culture, including measures needed to achieve positive culture change. As a minimum, the plan must be built around defined activities covering:

• Clear and open communication on product safety
• Training
• Feedback from employees
• The behaviours required to maintain and improve product safety processes
• Performance measurement of activities related to safety, authenticity, legality and quality
• An action plan indicating how activities will be undertaken and measured, with timescales
• A review of the effectiveness of completed activities, at least annually

BRCGS’s own interpretation guidance is explicit that culture “relies not just on measurables and specifics but an ethos and values felt by people at all levels of the site,” and that analysis of root causes across many non-conformities shows a proactive, positive culture “can make all the difference in the effectiveness of the food safety and quality plan and its consistent implementation.” This is precisely the evidence-based, whole-system view this guide is built around.

4.2  FSSC 22000 Version 6

FSSC 22000 requires organisations to establish, implement and maintain a Food Safety Culture Plan that includes objectives, activities addressing communication, training, feedback and performance measurement, and an evaluation of the effectiveness of those activities, reviewed and updated at defined intervals. As with BRCGS, the requirement is deliberately outcome-focused rather than prescriptive about the exact mechanism used — allowing the diagnostic approach in Section 5 of this guide to sit comfortably alongside an existing FSSC culture plan.

4.3  GFSI Position Paper on a Culture of Food Safety (V2.0, 2026)

GFSI’s updated position paper defines food safety culture as “a concept existing in all food businesses relating to the deeply rooted beliefs, behaviours, values and assumptions that are learned and shared by all employees, and which integrate to impact the food safety performance of the organisation.”

The paper organises culture into five dimensions across two interdependent tiers:

GFSI is explicit that culture and formal systems are not separate concerns: “in high-performing organisations, systems and culture operate in concert to sustain food safety outcomes.” This is the same principle this guide applies throughout Section 5 — reading FSMS evidence as a window into culture, rather than treating the two as separate programmes.

05 · Guidance for Implementation

Guidance for Implementation

5.1  Systems vs Culture: Why the Survey Is Not Enough

Consider two food manufacturing facilities. Factory A passed its audit, completed its annual culture survey, has an action plan, reviews its objectives and has trained its staff. Factory B has done exactly the same. Which factory has the stronger Food Safety & Quality Culture?

The honest answer is that it cannot be determined from this information — not because of missing experience or a missing audit report, but because none of it describes how people actually behave. Both organisations have shown that a management system exists. Neither has shown what its culture is.

The two are not competitors. A strong management system creates the structure for good culture, and a strong culture helps people consistently apply that system. The more useful question is therefore not “Do we have a good system?” or “Do we have a good culture?” but: “Is our system helping to create the culture we want?”

5.2  The Food Safety & Quality Culture Iceberg

The iceberg is one of the clearest ways to picture this distinction. Above the waterline sit the things that are easy to observe and audit: the survey, policies, training records, objectives, management review, and internal and external audit findings. All of this is necessary — the standards expect it — but it only tells us what has been planned.

Below the waterline sit the characteristics that are harder to see, but which strongly influence what happens on the floor: leadership, trust, communication, reporting, decision-making under pressure, ownership, psychological safety, recognition, behaviour and continuous improvement. Two factories can have identical procedures, training records and audit scores, and even similar survey results, and still have very different cultures — because those activities describe what was planned, not what people do every day.

5.3  The Eight Diagnostic Lenses

Food Safety & Quality Culture is not measured through a single instrument. It is diagnosed — in the same way a doctor does not diagnose health from one number, but looks at multiple indicators, asks questions, identifies patterns and considers history before reaching a conclusion.

This guide organises the evidence already sitting inside most FSMS into eight diagnostic lenses. A lens does not supply an answer; it changes the way the evidence is looked at. The eight lenses are not isolated — a breakdown in communication affects reporting, poor reporting reduces learning, and weak recognition discourages ownership, so they should be read together rather than scored individually.

• Leadership
• Behaviour
• Reporting
• Communication
• Recognition
• Learning
• Trust
• Continuous Improvement

Figure 2 — The Eight Diagnostic Lenses of Food Safety & Quality Culture.

5.4  From Evidence to Action: The Diagnostic Cycle

Evidence does not equal culture — evidence reveals culture. Three repeat non-conformances do not automatically mean a poor culture, just as a small number of reported near misses does not automatically mean a healthy one. Evidence tells an organisation where to become curious, not what conclusion to reach.

1. Step 01 Evidence
2. Step 02 Patterns
3. Step 03 Questions
4. Step 04 Conversations
5. Step 05 Actions
6. Step 06 Improvement

Figure 3 — The diagnostic cycle: from raw FSMS evidence to sustained improvement. Improvement generates new evidence — the cycle returns to Step 01.

• Evidence: Non-conformances, near misses, audits, training records, complaints and suggestions the FSMS is already generating.
• Patterns: Are the same findings recurring? Is one department under-reporting? Are corrective actions repeatedly overdue?
• Questions: Not “who caused this?” but “what is our system trying to tell us?” — is this a training, communication, leadership or trust issue?
• Conversations: Structured, curious discussion — not blame — connecting the pattern to a plausible cultural driver.
• Actions: Actions that remove the underlying barrier, not actions that simply close the finding.
• Improvement: Verified reduction in recurrence — which itself becomes the next cycle’s evidence.

This is not a straight line — it is a cycle. Every improvement creates new evidence, which is why Food Safety & Quality Culture should be treated as a continuous process of observing, interpreting, discussing and improving, rather than a once-a-year exercise.

5.5  Symptoms and Possible Cultural Drivers

The same symptom can have several plausible cultural explanations, which is exactly why it should prompt a conversation rather than a conclusion:

The discipline here is to keep asking the standard root-cause question (“What caused this event?”) and add a second, complementary question: “Which cultural lenses should we also investigate?” The first explains the event; the second explains why the organisation was, or was not, able to prevent it recurring.

5.6  Practical Scenario: Reading the Evidence

An operator notices that incorrect labels have been delivered to the production line. Nothing has been packed yet; nothing unsafe has left the factory. Two things can happen next.

The operator’s decision in Scenario B does not reveal one cultural characteristic — it reveals several at once: reporting, trust, ownership, leadership, communication and learning. A single everyday moment can be a genuinely rich piece of cultural evidence.

The story does not end with the report, either. If both organisations report the same incident, but one supervisor thanks the operator for speaking up while the other asks why they are “creating more paperwork,” the identical event tells two very different cultural stories. This is why evidence should always be read in context, never in isolation.

5.7  Turning Insight into Action

A dashboard, KPI report or trend chart does not improve culture on its own — conversations do, and actions do. The value of any culture-related data lies entirely in the questions it prompts management to ask next:

None of these questions have a single correct answer. Their purpose is to move the conversation from “we have a number” to “we understand what is driving the number” — which is where meaningful, sustained improvement begins.

5.8  Culture Is Everyone’s Responsibility

Food Safety & Quality Culture does not belong to the Quality department. Quality and Technical teams can facilitate, analyse trends and coordinate investigation — but they cannot build culture alone. Culture is built through thousands of everyday decisions made across the organisation.

Quality manages the system. People create the culture. Leadership decides which behaviours become normal.

5.9  Five Practical Actions for Tomorrow

Improving Food Safety & Quality Culture rarely depends on one large initiative — it depends on small, consistent actions repeated over time. None of the following require a new standard, a new software system or a major culture programme:

1. Review one recurring non-conformance every month — not simply to close it, but to understand why it keeps returning.
2. Verify whether corrective actions were actually effective, not only whether they were completed.
3. Give one cultural lens a few minutes at every management review, asking: “What evidence are we seeing, and what is it telling us?”
4. Recognise employees who speak up — reporting a near miss or flagging a concern before it becomes a problem.
5. Share one lesson learned every month; continuous learning does not require lengthy presentations.

06 · Alignment

Alignment with BRCGS, FSSC 22000 and GFSI

The diagnostic approach in Section 5 is not an additional standard or a replacement for certification requirements. It is a practical way of organising evidence that BRCGS, FSSC 22000 and GFSI already expect food businesses to generate, review and act on.

In short: this guide does not change the standards. It helps organisations get more value from the requirements they are already certified against.

07 · Key Takeaways

Key Takeaways

• A survey, an audit score or a single KPI can never tell the complete story of Food Safety & Quality Culture on its own.
• Evidence does not equal culture — evidence reveals culture. It provides clues and context, not verdicts.
• Eight interconnected lenses — leadership, behaviour, reporting, communication, recognition, learning, trust and continuous improvement — offer a practical way to read existing FSMS evidence.
• The diagnostic cycle (Evidence → Patterns → Questions → Conversations → Actions → Improvement) repeats continuously; culture is not assessed once a year.
• Culture belongs to everyone in the organisation, not solely to the Quality department.
• Small, consistent actions — reviewing one recurring finding, verifying one corrective action, recognising one report — build culture more reliably than a single annual initiative.

Food Safety & Quality Culture isn’t another programme. It’s the way we use the programmes we already have.

08 · References

References

• BRCGS. Global Standard Food Safety, Issue 9 Interpretation Guideline. August 2022. Clauses 1.1.1 and 1.1.2, Senior Management Commitment.
• FSSC 22000. Scheme Version 6, Additional Requirements — Food Safety Culture (2.5.1).
• Global Food Safety Initiative (GFSI). A Culture of Food Safety — Position Paper, Version 2.0. February 2026.
• Entecom. “Food Safety & Quality Culture: Beyond the Annual Survey” webinar, presented by Lyndri Fourie, Food Safety Consultant & EO Builder, Entecom.

This eBook was developed by Entecom for organisations working toward BRCGS and FSSC 22000 certification. It is intended as practical guidance and does not replace the official text of any certification scheme, which should always be consulted directly for compliance purposes.

www.entecom.co.za