CLAUSE REQUIREMENTS

The policy statementis only a summary and canusually beexpressed inasingle page. Although it
does not need tobedated, it must becurrent andshould thereforebe updated when significant
policies or senior management change. The policy forms the foundation for the site's ways of
working and the auditorwill expect to seehow the site management ensure staff understanding and
engagement. This may include:
• communication tostaff (e.g. through display onnoticeboards, inclusion in the induction
process, availability onthe company intranet, andthe use of appropriate languages where the
locallanguage is not the firstlanguage of all employees. The use ofduallanguages improves
andspeeds up understanding and action
• inclusion of allstaff, includingtemporary and contract staff, in the communication and
engagement processes.

1.1.2 The site'ssenior management shall define andmaintain aclear plan for the developmentand
continuing improvement of a foodsafety and quality culture.This shall include:
• defined activities involving all sections of the site that have animpact onproduct safety
• an actionplan indicating how the activities willbe undertaken andmeasured, and the
intended timescales
• a review of the effectivenessof completed activities.
Interpretation Food safety culture
A proactive, positive culture within acompany can make all the differenceinthe effectiveness of the
food safety and quality plan andits consistentimplementation throughout the site.Culture must be
ledbysenior management and 'felt' throughoutthe organisation, so that allaspects of the business
areinformed and involved.

Culture canbe challenging. It relies not just on measurables and specifics but an ethos and values
felt by people atalllevels ofthe site.The size and complexity (or simplicity) of the siteshould not be
abarrier toa successful culture. Good culture isalso expressed through the ease ofmovement
ofinformationbetween different levels of the company.

The siteisrequired to developandimplement aclear plan orprogramme for developing andimprovni g

its food safety culture. Such a plan would bebased on the natureof the organisation, anddependent
onits size, seasonality and the overall aimsit hasidentified as important for its own culture.

The plan does not need to beannual. A strategicplancould, for example, cover 5years, with
activities designed to measure current culture, implementchanges andassess improvements(or
where improvement was not evident, a review of why). Some aspects of theplan 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 incorporatedinto aculture development plan,some of which the
company may already beconducting. For example:
• a staffsurvey focusing onvaluesand culture
• annual staff reviews(one-to-ones)andrecognition programmes
• feedback mechanisms(e.g.staff concerns)
• training review andstaff development
• teamwork (e.g.staff involvement insetting 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, andevidence of the site
completing the activities in its action plan. This will be determined through interviews andby viewing
objective evidence of the steps taken.

Interviews may beconducted across alllevels of personnel onaninformal basis. They willbe
expectedto find anawareness of foodsafety culture, how individualscan impact onit, and the
company's objec tives.
BRC Global Standards operates a module inproduct safety cultureexcellence whichsites canelectto
add totheir BRC Global Standards audit.It willpublish aguideline onproduct safety culture which may
be purchased from theBRC Global Standards bookshop (www.brcbookshop.com) or viewed online
at BRC Participate (www.brcparticipate.com).
12 WWW.BRCGLOBALSTANDARDS.COM

CLAUSE REQUIREMENTS
 Objectives or targets around foodsafety culture canbemanaged separately from, or together with, targets
concernedwith product safety, legality andquality. How they are managed depends onthe nature of
the foodsafety culture objectives andhow they link with the site's other objectives.
Example Food safety culture strategic plan
A large company iscreating a foodsafety culture plan.Senior management have recognised that
employee attrition isacontinualconcern; eachyear they replace up to35% of the totalproduction
staff. Thismeans that productivity and on-time delivery are reduced because of the required upskilling
of the new employees, and thesitereceives regular complaints from itscustomers of
latedeliveiresandof non-conforming product.
The site'splan starts out quitesimply by stating its intention to increase staffretention. Senior
management start by surveying their employees anonymously totryto understand employee
concerns. The site also starts toimplement exitinterviews for employees already leaving the company,
andselected volunteers take part in one-to-one interviews withan external consultant.
Following thesesurveys, thesiteidentifies that employees donot feelintegral tothe business, have
difficulty in understanding how their actions impact onthe company, anddonot feelrecognised by
the management team.
The company decides to implementplans,including enhancement of training, communications,rewards
andrecognition. This includes:
• enhanced training- beyondjust managing criticalcontrol points(CCPs), toanunderstanding of the
reasons for the current product safety processes andinvolvementincorrective actions
• communications- regularstaff updates inaddition to the traditional internal message boards.
Updates are used tocommunicate production, incidencesofnon-conformingproduct, customer
complaints and their correctiveactions, andimprovements inproduct quality. They also focus
oncompany strategy antj
product safety objectives fl
• aclear feedback process- to initiate communication 'up·to management, so that communication is
not just seen as management 'telling staff' ·
• recognition - management instigate·employee of themonth' awards asrewards forsuccessful
process improvement ideas.
1.1.3 The site's senior management shallensure that clear objectives are defined tomaintain andimprove
the safety, legality and quality of products manufactured, inaccordance with thefood safety and
qualitypolicy and this Standard. These objectives shall be:
• documented andincludetargets orclear measures of success
• clearlycommunicated torelevantstaff
• monitored andresults reported at least quarterlytosite senior managemetn.
Interpretation Food safety andquality objectives
Senior management must set objectives concerning foodsafety andqualitywhich help toachieve the
stated policy (seeclause1.1.1). The objectives mustbecommunicatedso that therelevant staff (i.e.
those whose roles can affect product safety or quality)understand what isrequired from them. The
setting of these objectives alsohelps the allocation of suitable budgets andresources. Auditors
willlook for evidencethat the objectives are inplace andhave been communicated to staff.
Good objectives are usually:
• specific - clear and directly related to the site's aimsor goals forproduct safety andquality
• measurable- so that thesite can assess progress
• achievable- targets that stretch the company are acceptable but it is important that they are
realisticand that sufficient resources willbeavailable
• relevant- designedto maintain andimproveproduct safety andquality
• time-bound- eitherlongterm (e.g. throughout the period of certification)orshorter term (e.g.
within the next 3 months); however, the timescales or deadlines shouldbeclear toenable the
site toreview progress and,if necessary, amend activities.

WWW.BRCGLOBALSTANDARDS.COM 13