Passing BRCGS Certification requires a Culture of Excellence Plan (CEP). The updated Issue 9 of the BRCGS Food Safety Standard has required clauses relating to this.
Food businesses need to know what a CEP is and how to integrate this into their food safety systems in order to achieve audit success.
What is a Culture of Excellence?
Analysis of the causes of food safety failures shows that a positive and proactive product safety culture in a food business can make a significant impact on the effectiveness of food safety systems at all levels. This quality culture must come from the senior management team and demonstrated throughout the business.
Safety Cultures are an intangible management process which are also continuous. They reflect the values and behaviours of a business.
It is sometimes easier to focus on what behaviours can be identified, changed and/or adopted throughout the business which will have a positive impact on food safety systems.
BRCGS Certification Demands?
Adopting a safety culture is challenging! It takes commitment from all parts of a business. This is about planning what resources are needed for what and when to ensure audit success. So what does the BRCGS Certification body require from a food business?
As part of the accreditation process, a food business must produce a Culture of Excellence Plan or CEP. If they fail to do this, it will be seen as a major non-conformance at the audit. It is much more than a statement of intent.
Timescales are important and the plan could be a five year one but this needs to be clearly outlined showing how safety cultures can be built over that time period. As a minimum, a CEP must be reviewed annually.
Clearly setting out what tasks will be undertaken, responsibility for them and timings for their completion are required. Reviewing how successful these activities are as part of a product safety culture is also required.
KPIs are a fundamental part of a CEP. They are measured in numbers which means thinking of suitable KPIs in an intangible process can be a challenge. However, things like incidences of cross contamination can be lowered if colour coding is introduced for equipment. Measure before and after their implementation.
Creating a Culture of Excellence Plan (CEP)
Starting is the most challenging because the topic can seem nebulous and all encompassing!
Begin simply, look at small tasks which can be easily identified. Examples include, staff training on the wearing of correct PPE. These can be identified at HACCP Team meetings.
Obtaining more detail for the CEP can include a confidential staff survey trying to capture their views on what is good or not regarding product safety but also their own knowledge in order to identify training needs.
Clear communication across all levels and departments of a business can result in a much more clearer and detailed CEP. The auditor will also want to see evidence of communication across the business.
Focus on about what measures will be needed to achieve a positive outcome to improve safety culture.
Build the framework of CEP from these measures.
Successful BRC Certification with CEP
An auditor will not look at a product safety culture as such during their audit but they will be look at clear evidence of how the CEP can be demonstrated across the whole business at all levels.
Compliance to the relevant clauses in the Standard is the key.
Many food safety processes, such as, HACCP, food safety policy, staff training, product recall procedures and resourcing for safety etc can be seen as indicators of a product safety culture. They are not the culture itself but they can show evidence of the attitudes and behaviours prevailing at a site.
An auditor can also discuss safety cultures, informally, with staff across the business and look for evidence of an awareness and knowledge of an on-going safety culture.
Minor non-conformances from audit day can include factors, such as, a lack of detail in the CEP e.g. timescales, lack of implementation etc.
Guidance
BRCGS, the certification body itself, produces guidelines and materials to help with the process. These can be ordered from their website store.
The challenges faced by a business when starting certification can be daunting. Safety culture, along with, processes such as HACCP can be the most challenging. Seeking outside expert help from a Food Safety Consultant who can provide expert interpretation of the Standard can be a positive move.
