Part of the food safety management pillar of the TAAG Learning Center. If you are not yet familiar with the certifiable schemes, start with GFSI schemes and food safety audits.
Table of contents
The system works if people sustain it
A plant can have a flawless HACCP plan, signed Good Manufacturing Practices procedures and a well-designed sampling program, and still fail. The operator who sees a drop of condensation fall on the product and says nothing because the line is behind schedule, the supervisor who signs a temperature record that nobody took or the manager who postpones a repair because "the batch has to ship" do not appear in any flow diagram, but they decide whether the system works or not.
That set of shared beliefs, habits and priorities is called food safety culture. For years it was a conference topic. Since 2020 it has been an explicit requirement of the Codex Alimentarius, since 2021 a legal obligation in the European Union and today it is part of what all GFSI-recognized schemes audit.
What food safety culture is
The Global Food Safety Initiative (GFSI) published its first position paper on the subject in 2018, in which it defined food safety culture as the shared values, beliefs and norms that affect mindset and behavior toward food safety throughout the organization. In March 2026 it published a version 2.0, built on a review of more than 180 academic and technical sources published between 2000 and June 2025, and adjusted the definition: a concept that exists in every food company and refers to the deeply rooted beliefs, behaviors, values and assumptions, learned and shared by all employees, that together impact the organization's food safety performance.
The change has a practical consequence. The new definition starts from the premise that every company already has a food safety culture, good or bad: it is not something that is "installed" with a training session, but something that exists and can be strengthened or deteriorated. And by speaking of learned assumptions, it recognizes why it is so hard to change: new employees absorb it by watching what is actually done, not by reading the manual.
What Codex has said since 2020
In September 2020, the Codex Alimentarius Commission adopted the revision of the General Principles of Food Hygiene (CXC 1-1969), the standard that underlies HACCP worldwide. Section 5.1, on management commitment to food safety, establishes that maintaining a positive food safety culture, one that recognizes the importance of human behavior, is fundamental for any hygiene system to work. Codex identifies five elements:
- Commitment of management and all staff to producing and handling safe food.
- Leadership to set the right direction and engage all staff in food safety practices.
- Awareness among all staff of the importance of food hygiene.
- Open and clear communication among all staff, including the communication of deviations and expectations.
- Availability of sufficient resources for the hygiene system to function effectively.
The same section lists what management must do to ensure the system's effectiveness: communicate roles, responsibilities and authorities clearly; maintain the integrity of the system when changes are planned; verify that controls are carried out, work and that documentation is up to date; ensure adequate training and supervision; comply with regulatory requirements and encourage continual improvement in line with the evolution of science and technology.
The European Union made it law
Regulation (EU) 2021/382, in force since 24 March 2021, added to Regulation (EC) 852/2004 on food hygiene a new Chapter XI bis devoted to food safety culture. Its recitals link it directly to the 2020 Codex revision and to the expectation of trading partners that food produced in the EU meet at least that global standard.
The text takes up the Codex elements almost point by point, with two relevant additions. First, operators must establish and maintain an appropriate food safety culture "and provide evidence of this": declaring it is not enough, it must be possible to demonstrate it to the authority. Second, its application "shall take into account the nature and size of the food business", which means that a neighborhood bakery is not required to do the same as a multinational plant, but none is exempt.
For a Latin American company that exports to Europe, this matters even if its national legislation does not mention it: its European customers are bound by law and will pass the requirement on to their suppliers.
How GFSI schemes incorporate it
The GFSI benchmarking requirements demand evidence of senior management's commitment to the food safety management system, including culture elements that, at a minimum, cover communication, training, employee feedback and performance measurement on food safety-related activities. Each scheme translates it into its own language:
- FSSC 22000 version 6 includes additional requirement 2.5.8, applicable to all food chain categories. Senior management must define one or more food safety and quality culture objectives that address communication, training, employee feedback and involvement, and performance measurement. Those objectives must be supported by a documented plan, with targets and deadlines, that forms part of the management review.
- BRCGS requires in its clause 1.1.2 that senior management define and maintain a clear plan for the development and continual improvement of a food safety and quality culture.
In our article on GFSI audits we explain how those audits are structured; culture is today one of the points where the difference between a system that exists on paper and one that exists on the line is most noticeable.
The GFSI model: five dimensions on two levels
Version 2.0 of the GFSI document confirms the five dimensions it had proposed in 2018, but reorganizes them into two interacting levels:
Organizational foundations
- Company values, vision and mission: the purpose and strategy that set the place of food safety relative to other priorities.
- People: commitment, empowerment and accountability: the ability and motivation of each worker to act in favor of food safety.
Manifestations in daily practice
- Hazard and risk awareness: that each person recognizes the hazards of their job, understands the controls and knows when to escalate a problem.
- Consistency: uniform application of the management system (HACCP, prerequisite programs, CCPs) with measurements and records that make sense.
- Adaptability and continual improvement: the ability to learn, respond to crises and solve problems.
Among the critical components that GFSI associates with these dimensions there is one that is often left out of plans: work pressure. The document gathers evidence that production peaks lead to shortcuts in procedures, that audits themselves increase the workload, and that pressure can generate fear of retaliation and suppress problem reporting. It also underscores the need for safe and confidential communication channels.
GFSI also clarifies the scope of its role: it defines the "what" (dimensions and components), while the "how" (maturity models, diagnostic tools and interventions) is left in the hands of scheme owners, authorities, specialists and the companies themselves.
How it is evidenced in an audit
The FSSC 22000 guidance on food safety and quality culture (version 2, July 2023) is useful because it describes what the auditor looks for, and that helps to prepare the plant sensibly. Among other things, it guides auditors to:
- Interview staff on the floor, not just supervisors, to see whether each person knows what they are responsible for and what to do in the event of a nonconformity in their area.
- Verify that food safety expectations are communicated in a language the staff understand, and that training materials are translated.
- Ask when the last time was that someone raised a food safety concern, how it was handled and whether there is a confidential reporting system.
- Assess in the interview with senior management whether they can explain food safety expectations and how they weigh in their decisions, and how they react to customer complaints or supplier problems.
- Observe staff working during production and review evidence of competence in those who operate CCPs.
The guidance also mentions the specification PAS 320:2023, published by BSI, as a reference for developing and sustaining a mature food safety culture.
How to measure it without falling into the annual survey
Neither Codex nor GFSI prescribes a measurement instrument, and that leaves room to choose. A staff perception survey is a reasonable starting point, but on its own it measures what people say, not what they do. A more robust plan combines several sources:
- Surveys and interviews to learn staff perception, repeated over time to see trends.
- Direct observation of behaviors on the line, ideally by someone outside the area.
- Behavioral indicators: number of deviations or near-misses reported by the staff themselves, time to close corrective actions, repetition of findings in internal audits.
- Consistency indicators: the results of environmental monitoring and their evolution are a direct reflection of whether cleaning and hygiene are done the same way on all shifts.
A detail that often surprises: when culture improves, reports of deviations sometimes increase. It does not mean the plant got worse, but that people stopped hiding problems.
The acid test: what happens after a positive
The way an organization reacts to an unfavorable result says more about its culture than any survey. When a presumptive positive result for a pathogen on a surface arrives, a weak culture looks for someone to blame or, worse, a reason not to report. A strong culture holds the product if appropriate, investigates the cause with the team that knows the line and adjusts the program. Codex sums it up by including the communication of deviations among the essential elements: a system that punishes bad news ends up receiving only good news, even if it is not true.
Common mistakes
- Reducing culture to a poster with the food safety policy and an annual talk.
- Designing the plan from the quality department without involving production, maintenance, purchasing and senior management.
- Measuring only with surveys and not contrasting what people say with what is observed on the line.
- Ignoring work pressure: demanding strict compliance with procedures on a shift without enough staff.
- Punishing whoever reports an error, which ensures the next one is not reported.
Conclusion
Food safety culture has gone from being a management concept to a concrete requirement of Codex, European legislation and the GFSI schemes. Its logic is simple: procedures only protect the consumer if people apply them when nobody is watching, report what goes wrong and have the resources to do so. A credible plan involves management, recognizes work pressure, measures with several sources and is put to the test every time an unfavorable result arrives.
About TAAG
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Frequently asked questions
Is food safety culture mandatory?
In the European Union, yes: Regulation (EU) 2021/382 added to Regulation (EC) 852/2004 a chapter that obliges operators to establish a food safety culture and to provide evidence of it. Internationally it is included in the 2020 revision of Codex CXC 1-1969, and all GFSI-recognized schemes, such as FSSC 22000 or BRCGS, require a documented plan.
What is the difference between food safety culture and training?
Training is a tool; culture is the result. A person can know exactly what to do and still not do it if they perceive that the organization rewards speed over food safety. That is why GFSI includes, in addition to training, components such as leadership, communication, work pressure and recognition.
What does FSSC 22000 require on food safety culture?
Additional requirement 2.5.8 of version 6 requires senior management to define food safety and quality culture objectives that address communication, training, employee feedback and involvement, and performance measurement, supported by a documented plan with targets and deadlines included in the management review.
How is food safety culture measured?
GFSI does not prescribe a method. The usual approach is to combine perception surveys with direct observation on the line and behavioral indicators, such as the number of deviations reported by staff or the time to close corrective actions. Measuring over time is more useful than a one-off snapshot.