Food safety culture: how to build it, measure it and show the auditor
Practical answers on BRCGS clause 1.1.2 culture plans, measuring culture, night shifts, reporting concerns and low-cost culture activities.
Food safety culture has been in the BRCGS standards for years, yet it is still one of the hardest areas to get right and to audit. These answers come from our forum and our Senior Management Commitment webinar with Cathy and Oskar.
▶ Watch: Senior Management Commitment webinar, 29/01/26 (STC & QTC Explains)
Q: Is our staff survey our culture plan?
No, and this is one of the most common misunderstandings. The survey or questionnaire is the research: it identifies strengths and weaknesses. The culture clause (1.1.2 in Food Safety Issue 9, with an equivalent in each BRCGS Standard) is looking for the plan that follows the research: separate activities, such as ongoing communication focused on product safety. Many sites use the survey as their "communication" activity, which isn't the intention.
BRCGS trains auditors to look for four things: an initial assessment, a documented action plan, implementation started, and annual reviews. BRCGS explains the intent of clause 1.1.2 in the Issue 9 Interpretation Guideline, available from the BRCGS Store.
Q: What are the most common culture NCs?
Actions that aren't SMART. The clause expects measurable actions with timescales; without them, sites usually can't show whether the actions worked.
Q: Is it enough to point to our normal training and management meetings?
Our auditors' view is that culture activities should go beyond "business as usual". Simply referencing your standard section 7 training or your monthly management review is unlikely to show a real plan. In practice, auditors see everything from minimal plans to highly structured programmes, so a clear, live action plan that covers every bullet point of the clause (which is also value adding to your business) is your safest route.
Q: What do auditors look for on site?
Behaviours as well as documents:
- staff understand their food safety responsibilities and follow GMP without prompting
- food safety is discussed regularly and people feel safe to raise concerns
- managers model the standards, challenge non-compliance and take part
- people can show what they learned in training, not just that they attended
- staff feel empowered to stop production or report an issue
A tick-box culture shows when staff can't explain procedures, behaviour changes only on audit day, or leadership is absent. One telling sign: how the site reacts to NCs. Sites that say "bring it on" and want to improve usually have a great culture.
Q: How can we measure culture?
Measure indicators and trends over time, for example:
- near-miss reporting (more reports often means people feel safe speaking up)
- staff turnover and absenteeism
- repeat non-conformities
- short quarterly surveys of 3 to 5 questions on a 1 to 5 scale ("I feel comfortable reporting a food safety concern")
- themes from management floor walks
- training effectiveness: quiz results, observations, and whether procedures are followed afterwards
Q: How do we encourage people to report concerns?
Build trust: make it clear reports are encouraged, not punished; keep reporting simple, with an anonymous option if possible; act on what is reported and tell people what changed; lead by example; and say thank you. There must be no fear of retaliation. Our free confidential reporting tool is available to any site. Issue 9 requires a confidential reporting system (clause 1.1.4), and so do the other BRCGS Standards.
Q: How do we reach night shifts and weekends?
Presence. Compliance staff and managers showing up on a night shift now and then, not to catch people out but to show genuine care and support, does more than any poster.
Q: We have no budget. What can we do?
Culture takes time more than money. Toolbox talks on real site issues, short in-house workshops, managers coaching on the shop floor, team huddles, noticeboards, one-to-one check-ins, peer coaching, quizzes and recognition schemes all cost very little. Involve shop-floor teams in decisions, not just management.
Q: Do senior managers need to be in the audit?
Not all of them all the time. But managers present day to day, especially in production, should take part and speak for themselves rather than leaving it all to the technical manager. Commitment also shows in their behaviours and whether staff feel supported. Issue 9 section 1.1 expects senior management to take part in the opening and closing meetings.
Q: Can NCs elsewhere count against senior management commitment (clause 1.1)?
Not automatically. For example, if management hasn't provided enough resource and maintenance falls behind, the auditor raises the NC against what they actually saw (the maintenance clause), not against management for the lack of resource: that is the root cause, and finding it is your job. Repeated or systemic problems can be used as supporting evidence of weak senior management commitment, but it's context-dependent. Be honest in your own root cause analysis when the root cause is resource or commitment.
Q: Is QA really "the sales prevention department"?
Our community said a firm "NO". QA protects the business and supports sales in the long run. Explaining why a product can't go out, and helping the whole business understand the cost of quality, builds trust between QA and production.
More short videos on our STC & QTC Explains channel: https://youtube.com/@stcandqtc
Reviewed by Cathy Gladwin, Director & BRCGS ATP Trainer, STC · November 2026
These Q&As share general best practice from our trainers and auditors. They aren't consultancy advice for your site. For support specific to your site and systems, we can refer you to our sister company QTC.
Learn more: the BRCGS Product Safety Culture course and QTC's onsite Culture Fest both help sites build a plan that works. See the course calendar.