Culture and management commitment

A HACCP plan is a set of decisions. Culture decides whether people carry them out when nobody is watching, when the order is late, and when the chiller is full.

Codex says that fundamental to the successful functioning of any food hygiene system is a positive food safety culture, which acknowledges the importance of human behaviour. It names five important elements: commitment of management and all personnel; leadership to set the right direction and engage people; awareness of the importance of food hygiene by all personnel; open and clear communication, including about deviations and expectations; and sufficient resources.

Codex also says management should ensure that roles, responsibilities and authorities are clearly communicated; maintain the integrity of the system when changes are made; verify that controls are carried out and documentation is up to date; and ensure that appropriate training and supervision are in place.

Check the legal position before you describe culture as a legal duty, because it differs across the UK. The assimilated version of Regulation 852/2004 that applies in Great Britain has no chapter on food safety culture. In 2021 the EU added one, requiring operators to establish, maintain and provide evidence of an appropriate food safety culture, taking account of the nature and size of the business. Because the EU version applies in Northern Ireland, businesses there should treat this as a legal duty and check the position with their district council. In all four nations it is what Codex recommends, and it is what makes HACCP work.

Culture shows in decisions, not posters. Does a manager follow the handwashing rule when walking through? Is a warm delivery refused even when the kitchen needs it? Can a junior worker stop the line without fear? Is there enough time in the rota to do the checks properly? Are instructions in a form that everyone can follow, including agency staff and people who read little English?

Separate honest mistakes from reckless choices. If people are punished for reporting an error, they will stop reporting. Reserve discipline for deliberate falsification or reckless behaviour, and treat honest reporting as a contribution.

Learn to read the warning signs: managers overruling a hold to meet an order, checks being filled in as a batch, 'we always do it this way', no near misses reported, and audit actions left open month after month.

You can measure culture, within limits. Watch how people work. Talk to them, particularly on late shifts. Use short anonymous surveys. Track near misses reported, the time taken to close actions, and how often the same finding repeats.

As a leader, explain why. People follow a check more willingly if they know what it protects. Tell the cook that the cooling limit protects a resident in a care home. Share the results of audits. Thank the person who raised the problem. A plan that is owned by the whole team will still work when you are not in the building.