Building a Food Safety Culture Plan for FSSC 22000
Food safety culture used to be discussed as a soft topic. Under FSSC 22000 it is an auditable requirement with a documented plan, targets and timelines. This post explains what the scheme requires, how it connects to ISO 22000, Codex and GFSI, and how to build a plan that holds up in an audit and is useful on the floor.
What FSSC 22000 Version 7 requires
FSSC 22000 Version 7 was published in May 2026. Food safety and quality culture is one of the FSSC 22000 additional requirements, in section 2.5.8 of Part 2 of the scheme, and it applies to all food chain categories. Version 6 also included a food safety and quality culture requirement, so most certified sites already have the basics in place. Version 7 is the version to plan against now; check your upgrade audit timing with your certification body.
Section 2.5.8 has three parts:
Objectives. Senior management establishes, implements and maintains food safety and quality culture objectives as part of the management system, building on ISO 22000:2018 clause 5.1 (leadership and commitment), and provides the resources needed. At a minimum, the objectives address: Communication; Training; Employee feedback and engagement; Performance measurement of defined activities covering all sections of the organization that affect food safety and quality
A documented plan. The objectives must be supported by a documented food safety and quality culture plan, with targets and timelines, and the plan is included in management review and continuous improvement.
Commitment from everyone. The scheme states: "A demonstrable commitment from all personnel to the production and safe handling of food shall be available."
Note the word "quality." FSSC 22000 frames this as food safety and quality culture, so your plan should cover both.
How Codex and GFSI relate
FSSC 22000 did not invent the requirement. It reflects broader industry guidance:
Codex Alimentarius. The 2020 revision of the General Principles of Food Hygiene (CXC 1-1969) added food safety culture. It calls on management to be committed to establishing and maintaining a positive food safety culture and describes the commitment of management and all personnel to the production and handling of safe food as fundamental.
GFSI. The Global Food Safety Initiative added food safety culture elements to its Benchmarking Requirements in version 2020, and its 2024 Benchmarking Requirements continue that emphasis. FSSC 22000 Version 7 was aligned with the GFSI benchmarking requirements 2024. GFSI's position paper, "A Culture of Food Safety," describes culture in terms of vision and mission, people, consistency, adaptability, and hazard and risk awareness.
ISO 22000:2018 does not use the term "food safety culture," but clause 5.1 requires top management to demonstrate leadership and commitment to the FSMS. The FSSC requirement builds directly on that clause, which is why the culture plan is usually owned by senior management rather than the quality department alone.
Elements of a culture plan
A culture plan does not need to be long. It needs clear objectives, actions, owners, targets, dates and a way to measure results. Organize it around the four minimum elements.
Communication
How senior management communicates food safety and quality priorities, and how often
Channels that reach every shift and language group: huddles, boards, toolbox talks, the intranet
How incidents, audit findings and complaint trends are shared with the people who can act on them
A clear message that stopping the line for a food safety concern is expected
Training
Training that explains why controls matter, not only how to perform them
Targeted training for supervisors, who shape daily behavior more than anyone else
Onboarding content for new and temporary staff
Refresher training tied to findings, such as repeated allergen changeover errors
Employee feedback and engagement
Culture or perception surveys at a set frequency
Easy ways to raise concerns, including anonymous options
Visible follow-up, so employees see what changed because they spoke up
Involving operators in hazard analysis reviews, root cause investigations and GMP walk-throughs
Performance measurement
Pick a few measures that reflect behavior across departments, not just quality outcomes. Examples:
Survey scores and participation rates
Number of near misses and food safety concerns reported (a rising number can be a good sign)
GMP or hygiene inspection results by area
On-time completion of training and corrective actions
Repeat nonconformities
Participation of non-quality departments, such as maintenance, purchasing and sales, in food safety activities
Each measure should have a target and a review date. The scheme expects measurement to cover all sections of the organization that affect food safety and quality, so do not limit the plan to production.
Practical steps to build the plan
Get senior management ownership. Assign the plan to a named senior leader and agree on resources. Auditors will look for evidence that leadership sets direction, not just signs the plan.
Assess where you are. Run a baseline survey and review existing data: audit findings, complaints, training records and corrective actions. Talk to people on each shift.
Set a small number of objectives. Three to six objectives that cover communication, training, feedback and engagement, and performance measurement are easier to manage than a long list.
Write the plan. For each objective, list the actions, owner, target and timeline. Keep it in your document control system like any other controlled record.
Link it to the rest of the FSMS. Connect culture objectives to your food safety policy and objectives, training program, internal communication procedure and internal audits.
Review it in management review. Report progress against targets, discuss what the data shows, and update the plan. The scheme requires the plan to be part of management review and continuous improvement.
Repeat the assessment. Resurvey at a planned interval and compare results with the baseline.
Evidence an auditor may ask for
The documented culture plan with objectives, targets and timelines
Records showing actions were completed on schedule
Survey results and analysis
Communication records, such as meeting minutes or huddle logs
Training records
Management review minutes that discuss the plan
Interviews with employees that show awareness and commitment
How A.P. Lyon documents can help
The Food Safety and Quality Culture Procedure (SOP 5-003-F) describes how top management shows leadership and commitment and how the organization sets, measures and improves its food safety and quality culture through objectives and a culture plan with targets and timelines. It includes a Food Safety Culture Survey form and a Food Safety and Quality Culture Plan form. It is written to ISO 22000:2018 clause 5.1 and the FSSC 22000 additional requirements.
The procedure works alongside related documents in the Food Safety Management System, Complete, including the Food Safety Policy and Objectives, Training, Competence and Awareness, Internal and External Communication, and Management Review procedures. All files are editable Word and Excel documents that work on paper or in an eQMS, with one year of free updates. You can buy the complete system, or pick individual procedures through Build Your QMS with automatic volume discounts. Read more in our food safety system launch post.
As with any template, adapt the plan to your site, people and products. Documents support a culture program; they do not create one on their own.
Next steps
For an overview of how FSSC 22000 relates to ISO 22000 and FDA 21 CFR 117, see our Food Safety Guide. Browse the food safety documents, compare packages, or ask about consulting for help with implementation, internal audits and certification audit preparation.
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