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THE BEST PRACTICE

GUIDE TO PRODUCT
SAFETY CULTURE

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A BEST PRACTICE GUIDE TO
PRODUCT SAFETY CULTURE

Copyright and Liability

BRCGS1 publishes information and expresses opinions in good faith but accepts no liability for any error or omission in any such
information or opinion, including any information or opinion contained in this publication.

Whilst BRCGS has endeavored to ensure that the information in this publication is accurate, it shall not be liable for any
damages (including without limitation damages for pure economic loss or loss of business or loss of profits or depletion of
goodwill or otherwise in each case, whether direct, indirect or consequential) or any claims for consequential compensation
whatsoever (howsoever caused) arising in contract, tort (including negligence or breach of statutory duty), misrepresentation,
restitution or otherwise, in connection with this publication or any information contained in it , or from any action or decision taken
as a result of reading this publication or any such information.

All warranties, conditions and other terms implied by statute or common law are, to the fullest extent permitted by law, excluded.
Nothing excludes or limits the liability of BRCGS for death or personal injury caused by its negligence, for fraud or fraudulent
misrepresentation or for any matter which it would be illegal for it to exclude or attempt to exclude liability for.

The Best Practice Guide to Product Safety Culture and the terms of the disclaimer set out above shall be constructed in accordance
with English law and shall be subject to the non-exclusive jurisdiction of the English Courts.

© 2022 BRCGS
ISBN: 978-1-78490-452-4

All rights reserved. No part of this publication may be transmitted or reproduced in any form (including photocopying or storage in
any medium by electronic means) without the written permission of the copyright owner. Application for permission should be
addressed to the Head of Publishing at BRCGS (contact details below). Full acknowledgment of the author and source must be
given. The contents of this publication cannot be reproduced for the purposes of training or any other commercial activity.

No part of this publication may be translated without the written permission of the copyright owner.

Warning: Any unauthorized act in relation to a copyright work may result in both a civil claim for damages and criminal
prosecution.

Published by:
BRCGS
Second Floor
7 Harp Lane
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Tel: +44 (0) 20 3931 8150

Email: [email protected]
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Design and typesetting by Vital Creative, St. Leonards-on-Sea.

1 BRCGS is a trading name of BRC Trading Ltd. BRCGS is part of the LGC Group.
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Contents
Introduction 02

Part 1 04
What is culture 04
Excellent culture 04
Improving product safety culture: where to start 05

Part 2 07
Improving product safety culture: 10 steps to success The 10-step 07
journey 1. Assessing 07
culture and identifying areas for change 2. Creating a case for change 07
3. 08
Identifying leaders and champions 4. 08
Developing an action plan 5. 09
Generating involvement 6. Reducing 12
barriers and risks 7. Adapting and 12
implementing 8. Evaluating and 12
reinforcing 9. Maintaining momentum 13
10. Assessing ongoing impact 13
13

Part 3 15
Case study: Blitz's Food Company 15
Culture excellence 15
The need for culture 15
The action plan 15

Appendix 1 19
Selecting a culture assessment tool 19

Further Reading 20

Why BRCGS? 21

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Introduction
“Culture matters... Failure to understand culture and take it seriously can have disastrous consequences for an
organization.” (Schein, 1999)

Over the last 10 to 15 years, the food, consumer products and transportation industries have come to realize the critical
role played by an organization's culture in ensuring the effective implementation of product safety management
systems, and in helping to prevent product safety incidents.

It is now well documented that to ensure people always do the right thing, even when under pressure and when no one is watching, a business must
have a strong product safety culture. A poor culture will prevent objectives being achieved and waste the time, effort and resources put into achieving
them. Worse, it will create the conditions where product safety breakdown may occur, causing potentially devastating consequences for customers
and consumers as well as for the business itself.

The necessity for a positive product safety culture has been recognized by globally significant standards setting
authorities such as Codex Alimentarius, GFSI, BRCGS and ISO, as well as national governments, and it is becoming a
key part of product safety audits.

• The Global Food Safety Initiative (GFSI), an industry-driven global collaboration dedicated to advancing food safety,
published a position paper in 2019 on embedding and maintaining a positive culture of food safety in any business,
regardless of its size or focus.
• In 2020, this was followed by an update of the GFSI benchmarking requirements to include food safety culture. This
new addition meant that all the recognized Certification Programs/commercial standards benchmarked to GFSI (eg
BRCGS, IFS, SQF, FSSC 22000) had to include this new requirement on food safety culture in their commercial
standards, which are used extensively around the world.
• Issue 8 of the BRCGS Global Standard Food Safety was the first certification program to include a requirement on
food safety culture even before it was included in the GFSI benchmarking 2020 requirements.
• In September 2020, the Codex Alimentarius Commission adopted a revision of its global standard for general
principles of food hygiene (CXC 1-1969) and introduced the concept of food safety culture.
• In March 2021, the European Union (EU) followed suit and included these new requirements in EU Regulation
2021/382, amending the annexes to Regulation (EC) No. 852/2004, the legal basis for food safety in the EU.

Best practice requirements based on these standards include the following actions:
1. Include senior management commitment to product safety culture in a documented policy.
2.Include product safety culture in senior management review meetings.
3.Create and implement a product safety culture plan, to include communication, training, feedback from employees,
behavior changes required to improve, performance measurement, and an action plan.
4.Include the review of product safety culture plans in internal audits.

Culture is something that naturally develops in an organization whether it is managed or not – it is something that an
organization 'is' rather than something that an organization 'has'. It is therefore vital that business managers and
executives become familiar with the concept of product safety culture and how to manage it.

This book is for business managers, auditors, and anyone with an interest in product safety culture in the food, consumer
product and transportation industries. It will be particularly helpful for businesses who want to better understand and
improve their product safety culture, and to demonstrate their commitment to customers and auditors.

The structure of the book

1. An introduction that looks at:
• what product safety culture is and why is it important
• how to improve product safety culture
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2.A practical ten-step plan that incorporates best practices from change management, project management and culture
change theory.

3.A practical case study to bring the theory to life. The fictional case study is based on real industry experiences. Using
the example of a food company who are at the beginning of their product safety culture journey, it narrates the
reasons behind their interest, how they first measured their product safety culture, and how they used the results to
create a plan for change.

A checklist to use for evaluating a culture assessment tool

Even well-established companies can experience issues as a result of a failure within the organization to understand
the importance of a good product safety culture. Real case studies are included to show what happens when an
organization's culture fails.

Acknowledgements
BRCGS would like to thank the following for their help in writing this publication Dr Joanne Taylor, Dr Kevin Kane,
Ringaile Bulatovic and Bertrand Emond.

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Part 1
What is Culture?
Culture is a shared, learned phenomenon. In business, it is “the way we do things around here” and it directly and indirectly
highlights to new starters how to fit in, what is acceptable and how to succeed within their organization. In the context of product
safety, it is “the prevailing attitudes, values and behaviors related to product safety that are taught, directly and indirectly, to
employees” (Taylor, 2011).

Organizational culture is often described as the 'what happens when no-one is looking'. This is because culture is what really
happens, not what is supposed to happen according to policies and procedures. Over time, employees come to understand
which company rules must be followed, and which can bend or maybe even break; this leads to everyday problems and
inefficiencies as well as serious incidents and events. For example understanding the requirement to wear protective clothing
employees in certain areas in a factory, but deliberately not using it correctly. This could be due to the correct systems not being in
place, inadequate training or the availability of equipment. As an indication of poor culture this could be addressed through
changing the training procedures and policies.

It has therefore become increasingly apparent that businesses need to focus not only on the overt rules and processes necessary
to meet standards and regulations, but also on the much harder to assess attitudes, behaviors and norms that constitute the culture
of the organization.

One day, visitors were being taken to see inside a factory that was famous for the high quality of its products and the
productivity of its workforce, to discover the 'secret ingredient' that made the factory so successful. The visitors were observing
a production area where all the operators were focusing so intently on their tasks that they scarcely looked round to see them.
The visitors then moved on to see a different area of the factory, but one of them stopped out of sight and waited. 'What's the
problem?', asked the factory manager. 'Ah', the visitor said, 'I want to see what the operators do when they're not being
watched'. He waited a few minutes and then looked around the corner – the operatives were still working diligently with no
supervisor in sight. 'I see you have discovered our 'secret ingredient', replied the factory manager.

Improving product safety culture: where to start

Many organizations are beginning to realize that despite investment in food safety training or system implementation something
is still missing. This 'something' is the development of their product safety culture. Behavior-based food safety systems to
complement the risk-based, systems and processes, as they offer insight into what employees really think and understand about
product safety. Global standards request that senior management has a plan for the development, maintenance and
improvement of a product safety quality culture.

Because culture is complex and nuanced, using a structured model for assessment and communication, enables the building
blocks of a successful product safety culture to be written clearly. Before an organization embarks on a process of creating a
product safety plan there are a set of questions the senior leadership team can start by asking of their organization. We have
grouped these under the four headings used in the BRCGS Food Safety Culture Excellence module: People, Process,
Purpose and Proactivity. The more positive the responses are to the questions, the better the culture is. If an organization is
honest, they rarely answer yes to every question.

People
People are key to the success of all activities, including product safety and developing (or improving) a good product safety
culture needs to involve everyone. It is not just the technical manager's role or something that happens on the production floor -
to be effective it should involve all functions like marketing, sales, buying, NPD, hygiene, HR and customer service. Therefore
development of the desired product safety attitudes and behaviors is vital and this can only be achieved with training,
communication, motivation and empowerment.

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When culture fails: from compliance to individual commitment

In 2008, a Listeriosis outbreak in sliced cooked meat at the Maple Leaf Foods production facility caused at least 22
deaths. The outbreak was an important event in the food industry and was taken very seriously by the organization.
The story was shared extensively, contributing to industry requirements for food safety culture.
While reducing sodium levels in their product, through complacency or lack of risk awareness, they had not adapted the
food safety procedures to reflect the higher risks associated with lower sodium levels and larger packages. The
combination of less sodium and failure to follow their Listeria control policy caused the outbreak.
The investigation report indicated that the environmental testing program had not been effectively implemented.
Staff at the plant level did not look at the overall testing results to identify patterns that might indicate emerging
problems and no robust root-cause analysis was conducted. They did not challenge each other enough and share
critical information with relevant parties including senior management. The CEO and senior management did not
have oversight responsibility for ensuring that food safety was fully embedded in every level of their business.
Maple Leaf Foods recognized a failure in the 'total food safety system' inside its plants and developed its product
safety culture from one of compliance to one of individual commitment – from the chief executive officer to the company
janitor.
Reference: https://www.cmc-cvc.com/sites/default/files/files/ListeriaIndependentInvestigatorReport_July212009.pdf

Questions for senior management to ask

We have people who:
- are empowered to take appropriate action in the event of a product safety issue?
- feel encouraged and rewarded for correct product safety behaviors?
- are provided with sufficient training (on-the-job, training courses, etc.) which is relevant, practical and enjoyable?
- get regular communications on important product safety news and information? -
work well together to achieve product safety goals, with awareness and respect for the product quality team?

Process
Processes and plans keep a facility running smoothly and enable the organization to ensure safe behaviors without
compromising growth and development.

Questions senior management could ask

We have:
- comprehensive product safety management systems with user-friendly work instructions and manageable records?
- consistently applied systems and standards, both between different people and over time?
- co-ordinated departments who share important information and work well with the product safety team?
- effective management control, in terms of oversight, discipline and the allocation of work?
- a clean and well-maintained work environment to facilitate the correct product safety behaviors?

Purpose
Product safety needs to be at the center of a site's purpose – its vision and strategy. But as discussed in the introduction
product safety culture is about the attitudes and consequential behaviors – does the site say product safety is
important to us, or does it live product safety all the time; even when the site is pressurized or challenged?

The vision should be clearly communicated and incorporated into working practices and strategic plans. Metrics and
performance measurements will help maintain desired ways of working and drive ongoing improvement.

Questions senior management could ask

We have:
- a realistic vision for product safety culture that is communicated across the company?

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- a strategy for achieving the vision in practice that is communicated and agreed with? -
inclusion of product safety within the company core values and leaders who showcase these values?
- clear departmental targets that support and do not cause conflict with product safety?
- product safety metrics that drive continuous improvement, are analyzed to predict risk, and communicated across the
company?

Proactivity
Proactively looking beyond the immediate situation can improve product safety standards. For a good product safety
culture to evolve and be nurtured a company should be aware of product safety issues (including, emerging hazards,
industry standards, external stakeholder needs), consider best practices and learn from mistakes.

Questions senior management could ask

Are we:
- aware of external factors such as customers, suppliers and global events that impact product safety?
- showing sufficient risk foresight, actively looking for, managing and communicating the main product safety risks
across the company?
- able to learn from issues and mistakes and prevent them from recurring?
- open to change and innovation?
- willing to invest in product safety to meet best practice standards and continually improve?

In reality, the majority of companies are strong in some areas and weak in others. For example, large and well-
established companies tend to be stronger in purpose and process, but lower in people and proactivity. Smaller, newer
companies tend to be the opposite. To achieve best practice in product safety culture it is not necessary to be perfect,
but to understand where the strengths and weaknesses lie, and be committed to continuous cultural improvement.

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Part 2
Improving Product Safety Culture:
10 Steps to Success
In order to manage and improve product safety culture it is necessary to know where the organization currently stands
and where it wants to be ('as is' and 'to be'). It is necessary to:
- analyze the present product safety culture ('as is'). The questions in section one will have given the senior leadership
team an idea of where they think the organization stands. Data gathered in a more focused analysis discussed in this
section will highlight where the answers were correct.
- determine the desired product safety culture ('to be')
- create a program of activities in an action plan to achieve the relevant goals.

It is worth considering the driver or motivating force for the company to begin a journey of cultural improvement. Was it
an instruction from senior management, an upcoming audit requirement, customer demand, or the result of an incident
or series of incidents that have cultural problems as their root cause? Understanding the motivating force can help in
selecting areas to focus on, choosing stakeholders to work with, and managing the process in the most effective way.

The 10-step journey

The following 10-step structure can be used to break down the process to improve product safety culture:
1. Assessing the current culture and identifying areas for change
2. Creating a case for change
3. Identifying leaders and champions
4. Developing an action plan
5. Generating involvement
6. Reducing barriers and risks
7. Adapting and implementing
8. Evaluating and reinforcing
9. Keeping momentum
10. Assessing ongoing impact

1. Assessing the culture and identifying areas for change

The first action is to assess the current culture within the organization. To do this, start by collecting data, ideally
through a survey. Leaders often have a sense of their cultural strengths and weaknesses, no doubt identified in part
1 but without objective 'hard' data there is a risk of missing hidden elements, being over-confident about certain things,
and having nothing detailed to track change over team. The more data, and the higher the quality of the data, the better
relevant goals can be set and measured.

Rather than writing your own survey there are surveys available to use. The survey needs to take many things into
account if it you are going to get dependable information upon which reliable action plans can be built. There are two
main things that any good survey must have: validity and reliability. Validity will make sure that the survey is accurate
and gives you the information that is intended for the purpose. Reliability is the ability to know that the questions
answered each time are consistent and that any change over time reflects an actual change in attitude, and not the
interpretation of the question itself.

A guide to choosing an assessment tool can be found in Appendix 1.

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Communicating the assessment

Regardless of the assessment tool selected, it is important to communicate why it is being carried out effectively to
employees at the site. Create a communication plan to outline the methods and schedule for communicating at all stages
of the process. The purpose of a culture assessment should be to get open, honest feedback from employees, so ensuring
that they understand the purpose and nature of the assessment is vital. For example, by emphasizing that it is anonymous
and confidential, and will be used to build actionable plans that will improve the company culture and by extension people's
experience at work.

Recommendations:
• The senior management team announces the assessment to show that this is something taken seriously across all
levels of the organization.
• Ask trusted and well-liked employees in the organization to support and promote the assessment as this will increase
engagement and excitement around the survey.
• Put up posters across the workplace, sending out official announcements and mentions during meetings and other
briefings. This will make sure that everyone is aware of what is going to happen and how they can participate. • Set
expectations around the time it takes to complete the survey, as well as having support present in case of any
questions.
• If the assessment has an option to select different languages, make employees aware of how to do this.

Identifying areas for change

Once the assessment has been conducted and analyzed, establish exactly what needs to be changed, and why. It's not
enough to say that the overall culture score should increase, but instead to have a specific set of goals and the reasons for
their importance.

Changing culture isn't a quick or easy fix, so it is important to choose meaningful and valuable areas for change. This might
be because leaving them unchanged would create the biggest risk, or because improving them would create the greatest
benefit. Leaders need to formulate a clear product safety culture plan – one that is built on strong foundations of clear,
objective, and measurable data – and has a strong business case.

Following the assessment, let employees know an overview of the scores and which areas will be looked at for
improvement. This will also build interest and engagement for the upcoming cultural improvement plans. It will also motivate
them to participate in future surveys.

2. Creating a case for change

Creating meaningful change is not possible if the people involved do not agree with it. Culture change is hard, and usually
involves time, effort, resources, fear of failure and – toughest of all – the requirement for people to unlearn old habits and
learn new ones. It is important to create a case for change, i.e. a justification that the change is necessary and would bring
sufficient benefit to make it worth the time and effort required.

The case for change must be strong, convincing, and effectively communicated. It's crucial to get all key stakeholders on
board before next steps are taken. The data from the survey will show areas of weakness or risk is invaluable to the business
case. If possible, it is very useful to show where areas of improvement associated with the site's culture are lower than
industry benchmarks.

3. Identifying leaders and champions

In organizations with large numbers of employees, identify the key leaders and champions who will be the drivers and
supporters of change.

The project is likely to require support from various key positions and departments, depending on the internal
organizational structure and who the change initiative is targeting. The selected champions should be leaders in the
organization – not necessarily because of their seniority but because other employees trust and look up to them. If senior
leaders, managers, supervisors and operatives are all involved in the development of a positive product safety culture,
there is a better chance of success.
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The leaders and champions will need to fully understand and buy into the case for change, understand the details, have input in the decisions, and
where necessary be given the resources required to support them in their roles. The company should communicate to the rest of the organization who
the champions are, what their role is going to be, and encourage other employees to come to them with suggestions or questions.

4. Developing an action plan

Cultures may have developed over years and people do not change their attitudes and what is 'taken for granted' quickly or without some
resistance. It is not possible to change everything at once and attempting to do so will almost inevitably lead to failure. It is important to think about
product safety culture change programs as incremental and to develop a practical action plan to document and manage the process.

An action plan should detail all the steps that need to be taken to achieve meaningful and lasting change in the most important areas that have been
identified. Not all the areas identified in the survey need to be included in the action plan. The site needs to decide the most important areas that could
potentially have a significant impact on its product safety procedures. An effective action plan will consider other company-wide initiatives, as well as
company vision and strategy, and ensure these are integrated and complementary. It is important to set clear objectives and concrete steps on how they
should be achieved and measured.

Action plans can take various forms and it is recommended that these should be specific, measurable, achievable, relevant and time-bound.

• Specific: Select a specific area of culture to be improved. This should be done based on the risk the issue poses and a cost-benefit analysis of its
improvement. It is more valuable to find specific elements (attitudes or behaviors) to focus on, rather than a general theme (eg reward or
empowerment). These are more actionable and focused. For example setting a specific intention to raise awareness of the risk control process,
or the importance of protective clothing. Defines the behaviors that will be expected in order for product safety culture to improve.

• Measurable: Set a clear numerical target for improvement so that there is something to measure and compare over time. In this way, culture becomes
like any other KPI and can be embedded into standard company processes. For example, by raising awareness of risk control measures there
would be fewer product withdrawals and no product recalls.

• Achievable: Set targets and activities that are realistic and attainable. They need to be big enough to generate the appropriate amount of change,
but not so challenging that people will be demotivated or likely to fail. Part of this process involves working with the people who will be involved to
make sure their feedback and commitment is gained from the start.

• Relevant: Put areas for improvement into the context of the broader business and what is most relevant to its needs.
The relevant goals are likely to be the ones that pose the biggest risk if left unchanged or have the potential for the biggest positive impact once
improved upon.

• Time-bound: Set a deadline for each step along with monitoring activities to make sure that things are progressing
and are on track. Regular monitoring is an often-neglected step, but it helps in identifying any potential barriers along the way and lets companies retry
if something is not working as expected.

The action plan

Companies can use a template like the one shown in diagram 1 to create their own product safety culture action plan.
A description of each section of this example is provided below and a practical example of how it can be implemented can be found in Part 3. An action
plan template can be downloaded from the BRCGS website or BRCGS Participate.

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Areas for Instruction: Describe the current status of lowest Dimension(s) and Element(s)*, issues and qualitative goals for the future.

Improvement

*Element results would be accessible to customer on the premium FSCE product, or who have upgraded from the standard module

Lowest culture Current Score Target Next Planned Activities Person(s) Deadline Monitoring
Element(s) (%) Year (%) Responsible

Instruction: Select Instruction: Instruction: Instruction: Identify and Instruction: Instruction: Instruction:
the lowest culture Enter the score Enter the score list all actions and activities Identify Set reasonable Identify
Dimension(s) and/or that will be initiated to person(s) deadline (pilot if monitoring
Element(s) that are facilitate responsible. necessary). steps to see if
necessary to improvement. actions are
improve working.

Barrier Instruction: Identify barriers and how they can be reduced/mitigated/considered for action plans to be successful.

Areas for
Planned Activities Person(s) responsible Deadline Monitoring
Improvement

Instruction: Instruction: Identify positives and how they can be used/considered to increase the success of the action plan

Positive
Planned Activities Person(s) responsible Deadline Monitoring

Diagram 1: Action Plan Template

Area for improvement

When starting a plan, document the overall areas for improvement to clarify the 'what' and the 'why' before getting
into the detail of targets and actions. This can be derived from the lowest scores and to specific survey questions
and considering the goal going forward. The selection will be based on the scores in the assessment and impacted
by events/non-conformities and priorities in the company. For example, if empowerment is one of the lowest scores,
especially related to people raising issues and challenging others, this could be the main area to focus on. If it supports
known issues in the company, it adds a further rationale for the selection. The goal might be to create a culture in which
people feel empowered to speak up whenever they see a product safety issue, big or small.

Lowest culture element(s)

When looking at culture overall it can seem overwhelming, so to work effectively with improvement plans break culture
down into small 'bite sized' pieces to identify the specific issue(s), attitude(s) or behavior(s) that needs to be improved .
It is also important to focus on one thing at a time to make sure that plans are clear and achievable. For example, one
of the lowest scoring questions might be the specific behavior of the workforce challenging their colleagues and/or
managers when they see a product safety non-compliance. This is more focused, attainable and measurable as the basis
for an action plan than simply wanting to improve 'empowerment'.

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The number of elements selected to work on depends on: • the resources

available
• the scale of the elements
• how integrated they are with each other. For example, if an area to improve includes communication frequency and communication effectiveness
they can be combined into a single action plan activity.

Current score
It is important to have 'hard data' for culture improvement plans, so the first step in defining a target is to identify the current average score for each
question and clarify what that means. For example, if a score of 60 reports to frequency, does that mean something happens on average once a day, a
month or a year? Or if a score of 80 relates to an attitude, does it mean agreement or strong agreement?

Current hotspots
There are culture surveys with advanced features that show results for sub-groups across a company and the distribution of responses.
Both sets of information are valuable to consider here. The response distribution will show the variance of responses – if the score is 50, are most
people scoring close to 50, or are half the group scoring 20 and half 80? If the response distribution is varied, the next step is to look for where the
lowest sub-groups are. For example, a group of supervisors in a specific department, or who have worked with the company for a long time, may have
developed a specific way of thinking or behaving that is not representative of the company as a whole. Locating the lowest and highest hotspots
helps to create more detailed and focused action plans, so if this information is available, it should be added here.

Target
Culture should be treated as any other numerical key performance indicator (KPI) - it allows people to understand it in more concrete terms and work with
it in ways they are used to with other company goals. Setting a numerical target for the future is therefore a crucial part of action planning. When setting
targets, it is necessary to consider not only what is desirable but also what is realistically achievable. It is important to keep in mind that it takes time to see
if the change has become properly embedded in the organization, which is why it is recommended to run assessments on a yearly basis.

Planned activities
The planned activities should be specific to the goal that has been set and appropriate in the context of the broader business. There is often a lot of
expertise that companies can draw on internally, which is also why it is important to make sure that the appropriate departments are communicating
with each other so that the work is not duplicated.

Persons responsible
To ensure that any action plan is successful, identifying who will be the champion leading the project and giving that person appropriate authority to
do so is a vital step. Depending on the activity and the area targeted for improvement that person can be anyone from marketing to HR to quality
control. It helps if the leading person is already a figure of authority in the organization and is well respected, so that employees feel the gravitas of the
task at hand.

Deadline
The time frame for achieving an activity will invariably depend on the selected task for improvement. Changing culture takes a long time, as shifting
ingrained attitudes and behaviors is a difficult process. It can therefore be useful to break down the deadline to smaller time frames for specific goals that
need to be achieved at given times.

Monitoring
Setting monitoring activities is very important at this stage, as it allows companies to see whether they are on the right track and if something needs to
be amended along the way to make the process more effective.

Barriers and positives

Culture assessments should provide data on the main challenges identified by the employees (from their perspective) but also, the things they feel
positively about. Looking at barriers can reveal whether something may be a potential hindrance to the action plans. Positives can be used as part
of an initiative to improve culture, by building on existing strengths and successes.

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When culture fails: Risk awareness and complacency

In 2010, there were at least 11 deaths and the largest accidental marine oil spill in history when the BP oil rig
Deepwater Horizon exploded off the shores of Mexico.

The Deepwater Horizon disaster could have been prevented and highlights the costs of a culture of complacency
and of a business culture succumbing to a false sense of security. Recurring themes in the investigation report
include missed warning signals, failure to share information, poor communications between parties and a general lack
of appreciation of any risks. The decision-making process on the rig was excessively compartmentalised, so
individuals frequently made critical decisions without fully appreciating just how essential the decisions were to
safety, singly and in combination. As a result, officials made a series of decisions that saved BP and the other parties
time and money, but without full appreciation of the associated risks. The Commission that investigated the
disaster believed their findings highlighted the importance of organizational culture and a consistent commitment to
safety by industry, from the highest management levels down.

Reference: https://www.govinfo.gov/content/pkg/GPO-OILCOMMISSION/pdf/GPO-OILCOMMISSION.pdf

5. Generating involvement
After the culture assessment data has been gathered and analyzed, share it with all employees so they feel their voice
was listened to and generate interest and involvement in any on-going activities. This can be done in different ways all
depending on the focus points and priorities.

Recommendations:
• Find highs to celebrate as well as lows to improve so that culture messaging sent to employees is well balanced. •
Invite feedback from employees for improvement and ask them for suggestions, which may be useful for the action
plan.

When the first draft of the action plan has been completed, any group of people that are affected by the change should have an opportunity to give
feedback and share ideas because they have first-hand knowledge of the impact it could have.

6. Reducing barriers and risks

When managing change it is important to know where barriers and risks may lie. These could be practical (eg resources)
but there may be psychological aspects that companies need to address. People can be resistant to change for many
different reasons (feeling overworked, not sufficiently incentivized, etc.), and it is important to understand and mitigate
these through active communication and analysis of available information.

Identify barriers and risks from the data along with discussions and feedback from employees, and then cover them in
the action plan. For example, if people have mentioned time constraints, any activities that take up people's time will
have an immediate hurdle which needs to be mitigated, or the plan adapted.

7. Adapting and implementing

Feedback from a wide range of people, and detailed consideration of barriers and risks, will likely create opportunities to
improve the action plan. It is important to spend sufficient time on adaptations before implementation begins.

Once the action plan is ready, the colleagues leading the project need to communicate it to everyone involved and co-
ordinate its implementation over the months ahead. The good news is that the implementation of culture action plans
will strongly resemble the implementation of any other improvement plans within an organization, so managers and
leaders will likely already have the necessary expertise.

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8. Evaluating and reinforcing

When the action plan is underway, evaluate how things are progressing at set check points throughout the process.
If there are areas that need to be improved or adapted, do this as soon as possible. Gathering feedback on positive outcomes allows short-term
successes to be shared straight away, people involved to be rewarded, and others motivated.

If there has been a measurable impact on any key metrics these can be shared and celebrated. For example, if there have been fewer incidents or
complaints because of a change that was implemented, or high feedback scores after a training course was first implemented, this can be shown as
evidence of success and the people involved can be recognized for their efforts. If there has been an insufficient impact, this can give insight into where
improvements might be required.

One valuable method of evaluating the plan's impact is to build relevant questions and observations into existing internal audit plan, which also
helps to meet best practice standards in terms of building and maintaining a product safety culture.

9. Keeping momentum
Change needs ongoing attention and reinforcement to turn it from something temporary into something habitual, and this needs to be planned from
the start. After an initial reaction any change can return to the previous 'normal'.
Any desire for a permanent change should be included in the objective. It is therefore necessary to make sure the key people stay interested by keeping
in touch with the main stakeholders and remaining consistent in communication and recognition strategies.

Culture change requires consistent and continuous messaging and focus over the long term. If developing a positive product safety culture is seen as
just another management fad, then it is not a surprise if the plan loses focus and the confidence of the workforce. The messages need to be
reiterated continually so that they become embedded in the underlying culture, from top management to temporary employees. It is recommended
that relevant assessment and monitoring updates are presented at senior management meetings and company events such as conferences and
workshops, as well as induction training and routine communications.

Leading by example
Plans to improve product safety culture will come to nothing if leaders are not fully committed to the goal. They must 'lead by example' so that role
models of good practice are available to managers and operatives. Leaders and champions need to show enthusiasm for the action plan and provide
resources to enable goals to be achieved, celebrated, and maintained.

10. Assessing ongoing impact

Once the change has been embedded into routine practices track its ongoing impact over time. Simply expecting it to continue positively without ongoing
evaluation and renewed efforts, when necessary, could lead to a drop in impact and even a reversal back to how things were.

As well as monitoring and evaluating the activities as they happen (eg through feedback or other methods), there should be a repeat assessment
after an appropriate amount of time has passed, to see whether the change has really permeated company culture and is now part of the new norm. It
is recommended that the culture assessment is taken annually to assess improvement and identify any new issues or weaknesses that may emerge
over time.

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When culture fails: No clear product ownership

Takata, a manufacturer of airbags for cars distributed airbags that could rupture resulting in shrapnel release. The faulty inflators attached to the
airbags caused deaths, many injuries and millions of vehicles had to be recalled worldwide.

The panel that investigated the issue found that Takata's program for monitoring the quality of its airbags, installed in
tens of millions of cars worldwide, was poorly designed and structured, and relied too much on an ineffective quality
control system. The panel pointed to other key weaknesses in Takata's corporate organization including that it can
move product designs to production even with outstanding unresolved questions and it has no clear 'ownership' of
a product. There was no individual or team responsible for checking handover from new product development to
production.

Takata's own investigation recommended cultural change and the need for Takata to take steps to drive product
safety and quality into its culture including: •
increasing leadership support for and involvement in quality initiatives and increasing Takata's global leadership's
involvement in quality issues
• linking quality performance and compensation at the individual level. Compensation and quality-related key
performance indicators—appropriately structured—would provide strong incentives for employees to raise quality-
related issues as soon as they are identified and allow Takata to hold its employees accountable for quality-related
lapses
• guaranteeing sufficient resources in quality critical areas.

References:
https://www.industryweek.com/operations/quality/article/21968802/takata-told-to-improve-quality-culture
http://cdn.gonorthwebsites.com/849924ae5f53e170e674a17a200c467e5f1f0dae/panel_report.pdf
https://knowledge.wharton.upenn.edu/article/dasher-macduffie-takata-airbags/

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Part 3
Case Study: Blitz's Food Company
Culture Excellence
One example of an assessment tool that meets the eight requirements of the checklist in part 2 is the Culture
Excellence assessment. It has been used by thousands of companies around the world and provides analysis into
product safety culture, as well as having optional modules in quality, employee health and safety, environmental
sustainability, and engagement.

For companies in the food industry, BRCGS partnered with Culture Excellence to create a special version of the Food Safety Culture Excellence
assessment - focusing solely on food safety and standardized to create a cost-effective package. This tool forms the basis of the fictional case
study in part 3. Details of the food safety culture module can be found on the BRCGS website.

The need for culture

Blitz's Food Company is a large manufacturer with several sites across Europe. The technical manager in charge of the
food safety team has been told the company needs a product safety culture plan to pass their BRCGS audit.

The team found out that their business needed to create and implement a food safety culture plan not just to pass their
certification audit but to meet the requirements of other global standards.

Getting started
The food safety team looked through their latest audit scheme to see the detailed requirements they would need to
adhere to and made a note of the references to food safety culture.

Using the structure outlined in this book, they came up with a list of tasks for their culture plan.

1. Select and implement a valid and reliable food safety culture assessment.
2. Create an evidence-based business case for culture improvement and present to senior management to secure the
necessary budget.
3. Build a team of people who will champion and support the necessary changes.
4. Using the assessment data, create action plans for specific cultural improvement.
5. Generate involvement with the key stakeholders involved in the plans and get their feedback.
6. Identify and mitigate barriers and risks to the plan's success.
7. Review the plan and start implementation.
8. Add a review of culture action plans into internal audits to monitor their progress.
9. Communicate action plans and their progress to all employees and integrate with routine food safety training and
recognition schemes.
10. Re-assess food safety culture every 12 months to monitor changes and schedule the presentation of data at annual
senior management meetings.

Selecting the assessment

Blitz's now needed hard data on product safety culture to measure the 'as is' of the organization's product safety culture and
to measure change over time.

The company selected the BRCGS Food Safety Culture Excellence assessment tool, using the challenge questions
listed in Appendix 1. They noted the background and benefits of the tool and found this to be a good match to the
company's requirements.

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The Food Safety Culture Excellence assessment:

Determines strength and weakness in their food safety capability
Provides insight into staff opinion, attitude and behavior
Identifies the most important targets for resource allocation
Evaluates the return on investment of budget and effort
Measures the impact of training, systems and other initiatives
Provides visibility of what is happening outside of audits.

Blitz's Food Company upgraded their package to receive a more advanced set of views and support after the survey was completed. This gave them
flexibility so they could start small and have the option to do a more in-depth analysis later.

Implementing the assessment

The technical manager filled out a couple of questions about the site, including the number of employees and received a link to the survey. The link was
forwarded to everyone who had a company email address, with a personal message about how valuable their feedback was. The manager held a
meeting with shift leaders to discuss the best time to get the operators away from the production line to do the survey, as it was important to make sure
they did it during working hours.

The survey took around 15-20 minutes per person to complete, so a rotational system was agreed with the shift leaders that would minimize disruption
to the production line. The announcement of the survey was communicated both from senior leadership as well as during the daily departmental
meetings, emphasizing the importance of honest feedback.

The company achieved its minimum targets for completion set by BRCGS but wanted to go above that and so set an internal target of 70% participation
across all employee levels. Once the target was reached, which took 4 weeks, the company closed the survey and received access to the results.

The results
The manager received a report that provided a total score out of a maximum of 100, and a Grade. The company scored 69 which meant a grade of B.
This put them slightly below the industry average (the combined average of the thousands of workplaces that have taken the assessment across 90+
countries), which was 73 at that time.

Category and dimension scores

Blitz's got a score for each of the four categories in the culture assessment, as well as the 20 dimensions. They scored 66 for People, 62 for Proactivity,
72 for Process and 75 for Purpose.

Highest and lowest elements

The manager found that their highest scoring elements (questions) came from the Purpose Category. They were 'Food safety excellence being part of
company vision', which scored 80, and 'Perception that senior managers value food safety very highly', which scored 78. In contrast, the two lowest
elements came from the Proactivity Category. These were 'Knowledge of Food Safety Risk', which scored 53, and 'Risk and weaknesses are actively
looked for', which scored 58.

Barriers and positives

The company received an overview of their top barriers (identified by employees as the main challenges and weaknesses at the site) and their top
positives. In their case the top barrier was time, and the top positive was employee commitment.

Next steps
The manager shared the high-level results with all employees in the company, along with a message thanking people for their involvement and a 'watch
this space' message for upcoming changes. The results were discussed in detail within teams and with colleagues at various levels to get an idea of
what the results meant in practice and what they could do to improve. The assessment tool enabled the team to explore what the data said about
employee knowledge of hazards and risks.

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To get a budget for the project to be launched following the survey, the manager's first step was to write a business case.
This document puts forward: •
objectives
• goals
• activities
• benefits
• cost
• demands any changes would make on the team and the wider business.

The manager sought assistance from key people who could give her useful feedback and support the process of improving
product safety culture. This included Supply Chain, Marketing, Operations and HR. From these departments a team was put together
of colleagues with expertise in an area that affected product safety culture and with detailed knowledge of the company.

Following their input, the business case was sent to senior management to get it signed off and a budget allocated.

The action plan

With the business case signed off, the team created a detailed action plan based on the assessment data. They downloaded
the BRCGS template to assist them.

Area for improvement

The team were particularly concerned with the lower scores for the Risk Foresight dimension, with low scores in multiple
elements - knowledge of risks, risks being actively looked for, and risks being taken seriously. They decided that it was important
to work on increasing the level of knowledge and understanding of food safety risks across the
company.

Lowest culture element(s)

They decided to focus first on the 'knowledge of risk' element, which was one of the lowest scores and something they felt was vital to
improve first. This allowed for focused, concrete planning. They were aware that they also had lower scores for training and
communication effectiveness, so they planned to work on these elements within the same action plan.

Current score and hotspots

The company had an average score of 53 for knowledge of food safety risks at the site, out of a maximum of 100. In the context of
the survey this meant that the majority of people who answered the question selected either being only 'a little' or 'partly' informed.

The team also identified that the response distribution was quite varied. To dig deeper, they looked at the lowest hotspot score
which was 24 for operators who had been at the company for less than one year. This meant that in that group, most people did not
feel they had been informed about food safety risks at all.

Target
The team decided that their score of 53 for knowledge of food safety risks at the site should increase to 70 by the next year. In
particular, the sub-groups that scored less than 40 needed to score 60 or more, meaning that everyone felt at least partially informed,
as well as a higher number of people feeling well informed. Activities would need to particularly focus on the group of operators who
had been at the company for less than one year.

Planned activities
The team decided that the best way to achieve their goal was to revamp their existing product safety communication and training,
and enhance their internal audit, in the context of food safety risks. As they were particularly focused on operators who have been
in the company for less than a year, communication materials would be updated to include audio and visual materials and delivered
at an increased frequency, making sure that people received it from their first

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day on the job. For training, they decided to create improved activities that would specifically focus on food safety risks, using their own company
culture data. The technical manager acknowledged that their training materials were somewhat out of date and included references to products and
processes that the company did not actually use. In the future the training would be much more interactive with real examples from the shop floor. To
turn the messaging into real-life examples, internal audit would be enhanced to include questions and discussions on risk at key points in the

company process.

Persons responsible
The technical manager was the project lead and took responsibility for several of the actions linked to the training.
The senior marketing manager, who was already part of the culture team, agreed to develop an appealing and easy to digest communication package.
The operations manager took on the task of integrating the messaging into their routine internal audits.

Barriers and positives

Time was identified as the biggest barrier to addressing product safety culture by employees, so the team knew any enhancements should not take
up more time. The biggest positive at the site was shown to be employee commitment.
The operations manager decided that this was a great message to communicate to all employees to boost morale and count on people's engagement.

Adapting and implementing

Specific goals were agreed for the training and communication activities. They decided that they needed 3 months to develop their first set of materials,
which would then launch as a pilot first, with feedback from their audience gathered and used for continued improvement. Risk-based enhancements
would be added to the internal audit after 4 months to give time for the communications to begin.

A communication plan was created and revised following a focus group meeting. The feedback asked for more realistic images and more examples of
outbreaks in other companies and that it would be useful to receive information on their mobile phones. The focus group suggested creating a company
WhatsApp group.

The company was then set to repeat the culture assessment after 12 months to measure the overall impact of these new initiatives on all aspects of
culture. They hoped to see improvements in risk foresight, training and communication, but were interested in seeing how it would cascade across
other areas.

With everything agreed and colleagues on board, the strategy was implemented across all sites.

Monitoring and maintaining

To monitor the progress the technical manager used information from the training and internal audit questions and quizzes to see the impact that
the new activities were having on people's understanding. To make sure that positive changes were embedded the most successful trainers and the
employees that scored highest were recognized. The ones with the best understanding of risk would get mentioned at departmental meetings and once a
month the technical manager would send out a short newsletter highlighting the trainers and their efforts in teaching employees about risk.

The team presented the outputs of the culture assessment and project at the company's senior management meeting and annual workplace conference.
The initial plan was completed, and long-term maintenance was now the new goal.

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Appendix 1
Selecting a Culture Assessment Tool
A culture survey takes time and resources to implement and build action plans from. It is therefore a false economy to not
invest careful consideration in the selection of the survey itself. The following checklist can be used to evaluate potential
culture assessments and assist in finding one that is effective.

Question Yes/No
Was it developed by qualified professionals?
The survey should be written by qualified people who have experience in product safety, management,
psychology, organizational culture, and risk management as well as expertise in research and survey design.
Is it published in academic literature?
Check whether a survey has been published in peer-reviewed, academic literature. This means that it is
sufficiently valid and reliable to meet academic standards.

Does it have a psychological design?

There are many different ways a question can be asked and, depending on how it is done, the answers can
be closer or further away from reality. For example, a survey question trying to establish whether people
follow good hygiene practices may ask the participants if they wash their hands before handling food. Research
shows that the majority of the people will answer yes, regardless of the fact whether it is true or not. A
psychological design overcomes 'social desirability bias'.
Is it comprehensive?
Many people believe that if an engagement survey gives the company a high score then it is synonymous with
having a good culture. However, while engagement is certainly an important part of culture, it only gives one
dimension of it. Product safety culture is a broad topic, and focusing on one narrow area means that vital parts
will be missed. Assessing people, purpose, process and proactivity in the context of product safety culture
gives a fully rounded overview of the organization and the areas in which product safety plays a key role.
Is it anonymous and confidential?
Anonymity and confidentiality are essential to ensure honest responses are gained. Personal data should not
be collected, and with demographic information it is important to balance this with the number of employees
(the smaller the site, the fewer demographic questions should be used).
Is it accessible to a representative sample of people?
It is important that culture surveys are taken by a representative group of employees to give the best quality
data. A research study from the food industry found that managers scored significantly higher than supervisors
and operators when evaluating the product safety culture of their companies (Taylor and Budworth, 2018). The
assessment needs to be provided in such a way that every employee can read and understand each question
with ease. This means that the questions need to be clearly written and translated into all relevant languages.
Are there mixed question types?
Question types should be both quantitative and qualitative, and sufficiently varied to cover a broad range of
cultural issues. The quantitative questions will give data that is measurable over time, while the qualitative
questions provide insight into employee feelings and opinions that can give a topic more depth. A variation in
question types, from ranking, to scoring of facts and opinions, as well as open ended questions, provides the
user with a more engaged experience and more depth to the data.
Does it provide industry benchmarking?
An assessment that gives an insight into how a company compares to others allows companies to compare
their scores with like-for-like organizations.

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Further Reading
• A Culture of Food Safety – a position paper from the Global Food Safety Initiative (GFSI) 2018
• A tool for enforcement officers to diagnose cultures in good business operators (FBOs), UK Food Standards Agency, 2012
• An Approach to Product Safety Culture, BRCGS training course
• BRCGS Food Safety Culture Excellence
• BRCGS Food Safety Culture Excellence, Action Plan template
• BRCGS Global Standard Food Safety, Interpretation Guidelines – the latest issue can be purchased from the BRCGS
website or downloaded from BRCGS Participate
• Culture Excellence
• The 'A' in Culture: A Toolbox to Drive Positive Food Safety Behaviors, Laura Dunn Nelson, Julia Bradsher, and Bertrand
Emond, Food Safety Magazine, October 2018

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Why BRCGS?
BRCGS is a market-leading global brand that helps build confidence in the supply chain. Our Global Standards for food
safety, packaging, storage and distribution, consumer products, agents and brokers, retail, gluten-free, plant-based, and
ethical trade and responsible sourcing set the benchmark for good manufacturing practice, and help provide assurance
to customers that your products are safe, legal and of high quality.

We provide help to brands through our publications, certification programs, events, training and online information library,
BRCGS Participate.

Our message is clear – we have the most rigorous schemes and the highest trained auditors to give you the best results
possible.

Find out how we can help you further by visiting brcgs.com or emailing [email protected]

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