Since its inception, the concept of food safety culture has been somewhat amorphous. Within the industry, we often characterize food safety culture as how the members of an organization behave “when no one is looking.” While that generally describes the concept, it does not explain how one goes about objectively managing and measuring the level of food safety culture in any organization. Although tools and approaches are available to assist companies with the implementation of culture-oriented programs, having a measurable “food safety culture” is not yet mandated by USDA or FDA.

Or, is it?

During a recent FDA inspection of a food facility that manufactures a ready-to-eat product, FDA found high levels of Listeria monocytogenes contamination in the environment. Following the inspection, FDA issued a Form 483 to the company containing the agency’s inspectional observations. Of the multiple observations which were critical of the company, one observation stated pointedly that the company had no food safety culture. While I scoured the FDA regulations looking for any reference to culture, it led me to think about what the world might look like if “food safety culture” were, in fact, regulated.

Imagine, for a moment, if USDA or FDA published a new regulation, or even guidance, titled “Food Safety Culture.” In 483s and otherwise, FDA is already speaking about the importance of culture to food safety. FDA’s “New Era of Smarter Food Safety Blueprint,” by way of an additional example, is centered around four core elements: tech-enabled traceability; smarter tools and responses for prevention and outbreak response; new business and retail models; and food safety culture.

In the "Blueprint," FDA states that it will strengthen communications from FDA on the importance of food safety culture, develop tools that can be used to assess food safety culture, and consider how a positive food safety culture could be used as a factor to reduce the frequency of inspections. Conversely, if FDA’s statement is true, it would be logical to assume that companies which FDA determines to have a poor food safety culture would be inspected with increased frequency. Certainly, as we move into the future, the "Food Safety Blueprint" signals FDA will be looking for ways to measure and quantify the level of food safety culture within the organizations it regulates.

So, what does this mean for the industry? The future remains to be seen. For those companies that already have a strong food safety culture, this is likely good news. For those companies with a poor food safety culture, this is also likely good news. The leadership in those companies will be given a new incentive to invest resources targeted at building and maintaining a strong food safety culture.

Either way, the culture club is coming, and it will likely be in every company’s interest to get on board.

Regulating food safety culture?

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