Compliance depends on objective evidence. Without objective evidence, it is impossible to demonstrate compliance or non-compliance at audit. The notion of compliance is only meaningful if it can be challenged and measured.
Today, various compliance standards require the development and improvement of the food safety and quality culture; requiring sites to measure objectively the affect of improvement initiatives on the food safety and quality culture. From a systems and compliance perspective, this one makes for an interesting kind of problem because you have to try to ascribe objective metrics to what seems like an inherently subjective topic.
Staff surveys can provide an insight, but you could say they’re actually the opposite of objective evidence – they’re subjective evidence. Each survey respondent is able to offer their individual, subjective answers; but it isn’t any individual’s point of view that needs to be measured – it’s the culture of the business. This can be mitigated for by averaging the responses of a number of individuals, but the nature of the data being processed is still subjective rather than objective.
Interestingly, subjective survey results can’t be objectively relied on even when the surveys are anonymized. People are just not accurate when it comes to self-reporting.
If you ask motorists how good their driving is, practically every respondent will self-report that they are above-average drivers. This Wikipedia article on Illusionary Superiority shows 93% of American drivers put themselves in the top 50%. They’re not lying, either. A laughably impossible proportion of drivers firmly believe that they stand above their peers when it comes to their driving ability.
Illusionary superiority isn’t the only bias acting on respondents, but it’s a useful case example for why it isn’t possible to completely mitigate for subjectivity of self-reporting by trending results from numerous participants.
This is what makes the measurement of food safety and quality culture interesting. How can you objectively measure something subjective?
First, let’s define what’s being measured.
‘Culture’ = Shared values, beliefs, motivations, social influences, expectations, rationales, standards, and ethics held by a group.
Culture cannot be directly measured, but you can make observations about the behaviour of the group that can give you meaningful information about its culture. Certain activities like handwashing are frequently cited as indicating a good quality culture, for example.
Of note, the activity of ‘handwashing’ is probably regarded as an indicator of positive food safety and quality culture because it demonstrates that the staff understand that there is a food safety and quality reason for performing the activity, and that reason is compelling enough to be expressed in their actions. Performing the activity is an expression of the regard the staff have for food safety and quality.
Systematically, compliance with the site’s quality management system can be used as a metric applied to an organisation’s quality behaviour, just as handwashing is seen as an indicator for attitude at individual-level. Relatively high compliance would be seen as organisational quality behaviour indicating that food safety and quality is highly influential on the culture, whereas relatively high non-compliance would indicate that food safety and quality are of low importance to the organisational culture.
Of course, compliance can’t be a stand-alone KPI for food safety and quality culture. This raises the question: if an organisation had an ideal food safety and quality culture, what sort of behaviours would be expected?
Fault-reporting would be a measurable performance indicator. You can categorise fault reports as 'proactive' or 'reactive', based on the source of event information. Customer complaints are reactive, whereas audit nonconformities are proactive, for example. The ratio of proactively-reported weaknesses in your QMS versus reactive incidents can give an objectively measurable indicator for that organisational behaviour. The argument here is that proactive/preventative fault-reporting is organisational quality behaviour that indicates that being proactive/preventative about risks to product safety, quality and legality is of high importance to the organisational culture.
The key difference between this kind of measurement and observations of individuals is that the behaviour of the organisation is being monitored collectively. Statements can be made as to the ratio of proactive to reactive escalations carried out by the organisation over a given period.
It follows that root cause analyses should yield significant indicators for food safety and quality culture, too. Every instance of non-compliance can be examined for common influencers that are causing non-compliance.
Similarly, there may be cultural factors that can contribute into the root cause for non-conformance – so for example, if a high staff turnover is causing functional instability and competence issues due to lack of experience and training, staff retention could be looked at as a cultural root cause.
Responsive actions can also provide metrics for organisational quality behaviour. The ratio of corrective actions versus preventative actions carried out over a given timeframe can be used as an indicator for cultural values. If an organisation carries out 5 preventative actions for every 3 corrective actions one year, and the following year the same organisation carries out 6 or 7 PAs for every 3 CAs, then that would be a useful metric to demonstrate quality culture development over time.
It’s the ability to apply objective performance metrics here that’s interesting. The BRCGS Food standard V8 places a real importance on being able to measure and improve the food safety and quality culture:
“The site’s senior management shall define and maintain a clear plan for the development and continuing improvement of a food safety and quality culture. This shall include:
•defined activities involving all sections of the site that have an impact on product safety
•an action plan indicating how the activities will be undertaken and measured, and the intended timescales
•a review of the effectiveness of completed activities.”
Measurement and the review of effectiveness of actions taken are significant for compliance, but ‘culture’ is such an intangible thing.
This is such a new and unfamiliar requirement; there’s a lot of scope to approach the problem with new solutions. Food safety and quality culture isn’t reduceable to a series of performance metrics because the nature of the subject is far more complex and nuanced than that. For all that (even anonymous) surveys suffer from subjectivity and self-reporting biases, I think auditors are going to expect to see some kind of survey included in the measurement of quality culture no-matter what else you measure. The ideal compliance system would probably trend as many quantifiable performance metrics as possible, supplemented by human/psychological/subjective inputs in the form of anonymous surveys etc.
This is an area where integrated quality systems are key. Integrated quality systems such as the incident management system on Food Portal can yield objective metrics on a site’s organisational behaviour – a facsimile for food safety and quality culture.