BRCGS Food Safety F837: Position Statement

BRCGS has issued a position statement to ensure expectations relating to compliance with clause 1.1.2; its consistent application at certificated sites, and assessment during audits are understood.

In summary, the clause requires sites to: Define and maintain a clear plan for the development and continuing improvement of food safety culture.

This plan must include:

Clearly defined activities that will be completed

Involve all sections of the site that have an impact of product safety (whilst specific activities may be relevant to certain departments or roles, overall the plan must ensure that all relevant section/roles are covered)

An action plan indicating how the identified activities will be undertaken/completed

Measurement of the activities (i.e. where they completed, where the correct people involved, were activities successful, any other learnings)

Intended timescales for the completion of the activities

A review of the effectiveness of completed activities

Where sites are non-compliant, the non-conformities will be graded as follows:

Major Non-conformity

Where the site does not have a documented plan for food safety and quality culture. In this context a plan is more than a short statement of intent, but documentation incorporating the requirements of the clause (as summarised above).

Minor Non-conformity

Where a documented plan exists, but is: of poor quality (e.g. insufficiently detailed, for example missing timescales for completion or absence of clear action plans), does not cover all the relevant areas or staff and is not fully implemented (e.g. some activities not implemented or not completed to predefined schedule).

Site review of the effectiveness of completed activities

The third bullet point in the clause requires sites to undertake a review of the effectiveness of completed activities.  As audits to the Standard only commenced in February 2019 it is possible that this review of the success of the programme, would not always be implemented in year 1 and therefore non-compliance with this bullet point is not considered a nonconformity until the site’s second audit to Issue 8.


The non-conformance shall be included in the calculation of the site grade.

Effective date: 1st June 2019

Source BRCGS News here:

How our Implementation Packages Assist in Compliance


Our Implementation Packages include tools and procedures to assist in complying with all the clauses of the BRCGS standard. As an example, for planning and developing a food safety culture we provide a template for Senior Management to use, below are some extracts and examples:

Food Safety Culture

The company recognizes that a successful food safety culture is the product of individual and group values, attitudes, competencies and patterns of behaviour that determine the commitment to, and the style and proficiency of the food safety management system. The site’s senior management plan for the development and continuing improvement of food safety culture.

Senior management are responsible for delivering a “It is how we do things here” food safety culture by:

Leadership – starting from the top

Demonstrating visible commitment

Effective communication of company philosophy and policy

Ensuring there is accountability from the top of the organisation to the bottom

Developing employee confidence and mutual trust

Developing reward schemes including ‘Employee of the Month’ award

Ensuring all employees are accountable, engaged and understand the value of integrity and proactivity

Developing an action plan for the development and continuing improvement of food safety culture

Monitoring Food Safety Culture

Senior management monitor and measure through individual reposts and trend analysis the degree of development of the food safety culture by analysing information including KPIs from:

Hygiene & Housekeeping Audits

Internal Audits

External Audits

Non-conforming products

Environmental monitoring

Review of implementation plan and numbers trained

Employee reviews

Staff surveys on values and culture

Customer Complaints

Staff Turnover

Staff Exit Interviews

Results of monitoring are shared throughout the organisation.


Senior management are responsible for reviewing the effectiveness of completed activities at the monthly Management Review meeting

Individual Food Safety Culture Development Table

All employees will undergo the following briefings and stages:

Food Safety Policy

Food Safety Objectives

Food Safety Management System Overview

Job Descriptions

Job Training

Employee Briefing

Individual Objectives

CCP Controls – Training Procedures & Record Completion

PRP Controls – Training Procedures & Record Completion

Employee Review


QM 1.1.2 Food Safety Culture Planning: