PAS 320:2023

9 Embedding the change plan of the organization’s food

safety culture into the existing FSMS

9.1 Managing and embedding change 9.2 Managing disruptions and crises
The guiding coalition team should lead the process The organization should determine the actions needed
of embedding the change plan (see 7.7) of actions to to increase its resilience and anticipate and respond to
address food safety risks and opportunities into the disruptions and crises.
existing FSMS.
The organization should conduct post-crisis reviews to
The guiding coalition team should: identify corrective actions. The organization should
a) launch the change plan (see 7.7); document the learning and results of the review.
b) establish the desired behaviour as a social norm NOTE BS 65000 provides guidance on organizational
(see 5.4.5); resilience.
NOTE 1 Social norms can be a valuable driver for
effecting a positive and meaningful change of
the organization’s food safety culture since they
influence human behaviour.
NOTE 2 Social norms are driven from the
organization’s principles and beliefs (values).
c) include all organizational levels and functions
involved in the changes to empower people to
have autonomy to drive positive changes in the
food system;
d) make the support team ready to spread new and
best practices across the organization;
e) provide training to raise awareness (see 8.3)
regarding all aspects of the actions needed to
address food safety risks and opportunities (see 7.7)
at all organizational levels and functions;
f) consistently communicate changes and progress
status, and take into account feedback from
employees and other interested parties;
g) support employees during the process of change;
NOTE 3 A change curve (e.g. Kubler-Ross Model)
can be used as a tool to support employees to deal
with changes.
h) reinforce the change (nudging, see 8.4) and
employee accountability with consequences for
compliant and non‑compliant food safety behaviors;
i) work with interested parties, change champions
and influencers;
j) integrate food safety into other functional
responsibilities;
k) adopt collaborative mindset at all organizational
levels, functions and departments;
l) apply data-driven (see Clause 10) actions aligned
to the organization’s vision, mission and values
(see 5.2); and
m) recognize people and celebrate gains (see 11.4).

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 PAS 320:2023

10 Evaluating the performance of the organization’s

food safety culture

10.1 Monitoring and measuring e) the expected use of data by all related interested
parties;
The guiding coalition team should establish, document,
f) the consequences associated with achievement and
implement and maintain a performance monitoring
non-achievement of objectives;
and measuring system of the organization’s food
safety culture, aligned with food safety priorities and g) the expected course of actions when objectives are
connected with the communication system (see 8.4). not met;
NOTE 1 A monitoring and measurement system can h) responsibilities, accountabilities and authorities
support the organization’s decision-making process, [see 5.4.1f)1)]; and
indicate trends to support early-risk identification, i) frequency of monitoring.
and provide a basis for intervention and continual
improvement. The established objectives should be measurable,
specific, risk and time-based, achievable and aligned
The monitoring and measurement system with the organization’s mission, vision, values and
should include: policy of food safety culture.
a) what will be measured and why, and the relationship
to the dimensions of food safety culture; The guiding coalition team should validate the
monitoring and measurement system prior to its use.
b) the objectives related to the food safety culture,
systems, products, processes, norms and employee
The guiding coalition team should provide training
behaviours, and development and performance at
and information for employees at all organizational
organizational, functional and individual levels;
levels and functions on the monitoring and
c) a combination of a range of leading and lagging measurement system.
indicators for the established objectives;
NOTE 2 An effective use of both leading and 10.2 Verifying
lagging indicators allows the organization to
analyse trends for ongoing adjustments to support 10.2.1 Assessing behaviour
the change process (leading) and determine if
The guiding coalition team should establish a method
outcomes were met (lagging).
for assessing behaviour (including, among other food
NOTE 3 Leading indicators as stand-alone metrics safety aspects, employees’ food safety hazard and risk
focus on short-term performance and anticipate awareness) at all organizational levels and functions.
potential issues; however, they do not allow the
NOTE Methods for assessing behaviour include, but are
organization to confirm whether the objective
not limited to, observation of employees during their
has been achieved. Lagging indicators as stand-
normal daily operation, surveys and interviews.
alone metrics confirm whether the organization’s
objectives have been achieved; however, they
The guiding coalition team should:
do not provide information for organizations on
whether they are on track to achieve their goals. a) measure the behaviours against current
expectations (see 7.4);
NOTE 4 Examples of leading indicators are near
miss event counts, number of people trained and b) give feedback (see 8.4.2) to the employee(s) whose
behaviour observations. Examples of lagging behaviour is being assessed; and
indicators are food recalls, customer complaints, c) apply interventions (see 11.3) when behaviours
environmental monitoring results, inspections and are not meeting expectations and set continual
audit outcomes. improvement actions when positive behaviours
d) the data collection process (including which data are are observed.
to be collected, the reason for collecting the data,
the method and frequency of collection, how data
will be stored and how the data impact the related
dimension of food safety culture);

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PAS 320:2023

10.2.2 Assessing the food safety culture 10.4 Management review

The organization should assess (see Clause 6) the
Top management should include in the existing FSMS
effectiveness and suitability of its food safety culture
management review programme:
at regular scheduled intervals and establish a plan
(see Clause 7) to achieve the next level of maturity. a) the organization’s food safety culture maturity level
(see 6.1);
Organizations should map improvements to its food b) the status of the strategic change plan to achieve
safety culture against its maturity matrix. the desired food safety culture (see Clause 7);
c) the effectiveness of communication (see 8.4);
10.2.3 Internal audits
d) the effectiveness of learning and competence
The guiding coalition team should include the audit
programmes (see 8.3);
criteria related to the recommendations of this document
in their existing FSMS internal audit programme. e) any near miss data (see 11.2);
f) the performance of the organization’s food safety
culture (see Clause 10); and
10.3 Analysing, evaluating and reporting
g) the outcomes from the recognition programme
The guiding coalition team should establish a
(see 11.4).
method and frequency to collect, analyse, evaluate
and report the performance of the organization’s food
safety culture.

When the data from the monitoring and measurement

system and verification activities indicate a need for
interventions, the guiding coalition team should lead
the process of defining, implementing and verifying
actions to address them.
NOTE 1 Visual information connected with real lives
can attract people’s attention, create an emotional
connection and impact the way people think and
feel (attitudes), which in turn influence their actions
(behaviours) and therefore affect the food safety culture.
NOTE 2 Examples of data reporting connected with real
life through storytelling are:
a) negative real-life story (consequence):
organization’s listeria contamination data report
connected to a case of a child who died after eating
a contaminated salad; and
b) positive real-life story (consequence): organization’s
progress in implementing food safety practices
connected with a case in which the organization
was recognized for having significantly advanced
food safety practices.

The guiding coalition team should make information

available to employees on the reporting system adopted.

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 PAS 320:2023

11 Sustaining the continual improvement of the

organization’s food safety culture

11.1 Continual improvement The organization should incorporate interventions

into the non-conformity system of its current FSMS as
The organization should sustain the continual part of its root cause analysis and related corrective
improvement of its food safety culture by ongoing: action plan.
a) top management commitment and consistency
(see 5.1); The organization should document any food safety
b) communication and nudging (see 8.4); interventions that are implemented and communicate
them to interested parties.
c) employee engagement, empowerment and
ownership (see 5.4.1 and 8.2);
NOTE BS ISO 10018 provides guidance on 11.4 Recognizing people and
engagement. celebrating gains
d) data-based actions to improve the performance The guiding coalition team should establish, implement
of the organization’s food safety culture and maintain an effective and valued targeted reward
(see Clause 10); and recognition programme.
e) reporting of near misses (see 11.2); NOTE Recognition and appreciation of those that have
f) application of interventions (see 11.3) and embraced food safety and achieved the expectations
commitment to holding employees accountable are fundamental elements of a mature food safety
with consequences for non-compliant food safety culture and can support employee engagement.
behaviors; Rewards can be part of the recognition programme, but
g) recognition of people and celebration of gains they are not the most important part of it: sometimes
(see 11.4); a simple “Thank you” (recognizing and appreciating)
can have more effect than a reward. Nominations
h) management of changes (see 9.1) and of disruption
for recognition can be top-down, bottom-up, cross-
and crises (see 9.2); and
functional or a combination of them all.
i) assessment (see 10.2.2) and update (see 11.5) of
the food safety culture. The organization should verify that the recognition
programme is:
11.2 Reporting near misses a) aligned with the organization’s vision, mission and
values (see 5.2);
The guiding coalition team should encourage and
empower all employees at all organizational levels and b) integrated with the food safety culture strategy
functions to report near misses using an open two-way (see Clause 7);
communication [see 5.4.26) and 8.4.2]. c) connected with the achievement of expectations
(see 7.4);
Where near misses are reported, the organization d) communicated to relevant interested parties
should identify the root cause of detected near misses (see 8.4.1); and
and implement an effective correction action plan to
e) transparent, fair and consistent.
avoid reocurrance. The guiding coalition team should
verify that the employee or team that reported the
The organization should connect recognition for
near miss has been informed of the actions taken in
competencies associated with an employee’s role with
response to the near miss.
their career plan [see 5.4.1b)].

11.3 Applying interventions 11.5 Updating

The organization should intervene when food safety
The organization should continually update its FSMS to
expectations are not met (correction and corrective
reflect the desired food safety culture.
action), and/or when a potential risk to food safety is
identified (preventive action), and/or when norms are
not aligned with the organization’s mission and vision.

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PAS 320:2023

Annex A (informative)
Summary of actions from the main clauses in PAS 320

This annex provides a summary of the actions from the

main clauses in PAS 320. The clauses are aligned with
the framework shown in Figure A.1 and the actions
from each clause are grouped under Plan, Do, Check
and Act.

Figure A.1 shows the relationship of the clauses.

Figure A.1 – Overview of the relationship of the clauses in PAS 320

The actions can be summarized as follows. iv) Establish and manage organizational
a) Plan. structure, responsibilities, accountabilities
and authorities.
1) Understand the fundamentals of a food safety
culture and the context of the organization • Establish a guiding coalition team.
(Clause 4). • Identify and engage interested parties.
i) Define the concept of food safety culture. • Establish and manage change champions.
ii) Establish the relationship between food • Identify and manage social influencers.
safety culture and organizational culture. 3) Understand the organization’s food safety
iii) Understand the organization’s internal and culture (Clause 6).
external issues. i) Determine the desired food safety culture.
2) Establish the governance for a food safety ii) Collect data for maturity assessment.
culture (Clause 5).
iii) Assess and measure the current maturity level
i) Demonstrate commitment, accountability of the organization’s food safety culture.
and consistency from top management.
ii) Define the organization’s vision, mission
and values.
iii) Establish the policy for a food safety culture

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 PAS 320:2023

4) Design a strategic change plan to achieve the

desired food safety culture (Clause 7).
i) Identify the drivers of change.
ii) Establish the organization’s readiness to
drive changes to achieve the desired food
safety culture.
iii) Map the needs, behaviours, expectations
and changes to the existing FSMS against the
culture maturity gaps.
iv) Determine food safety risks and
opportunities.
v) Plan the changes of organization’s food
safety culture into the existing FSMS.
5) Prepare the key functions towards the desired
food safety culture (Clause 8).
i) Identify and provide resources.
ii) Develop competence and awareness.
iii) Communicate and nudge.
iv) Establish and maintain documentation.
b) Do (Clause 9).
Embed the change plan of the organization’s food
safety culture into the existing FSMS.
1) Manage and embed change.
2) Manage disruptions and crises.
c) Check (Clause 10).
Evaluate the performance of the organization’s
food safety culture.
1) Monitor and measure.
2) Verify.
3) Perform management review.
d) Act (Clause 11).
Sustain the continual improvement of the
organization’s food safety culture.
1) Continually improve the organization’s food
safety culture.
2) Report near misses.
3) Apply interventions.
4) Recognize people and celebrate gains.
5) Update the FSMS to reflect the desired food
safety culture.

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PAS 320:2023

Annex B (informative)
Information to be communicated internally within
the organization
The following information can be communicated
internally within the organization (see 8.4.2):
a) the organization’s mission, vision and values;
b) the organization’s policy of food safety culture and
related measurement system outcomes;
c) responsibilities, accountabilities and authorities;
d) the organization’s food safety culture maturity level;
e) current and emerging food safety hazard and risk
awareness information as listed in 8.3.3;
f) the change plan (see 7.7) and its related elements;
g) positive changes;
h) failures and concerns;
i) near misses (see 11.2);
j) disruptions and crises (see 9.2);
k) performance of food safety culture (see Clause 10);
l) gains and recognition (see 11.4);
m) latest industry knowledge and learnings, trends
and food safety events related to the organization’s
business;
n) outcomes of the assessment of food safety culture
(see 10.2.2); and
o) any other parameters related to food safety that
might impact the organization’s culture.
NOTE This is a non-exhaustive list.

26 © The British Standards Institution 2023

 PAS 320:2023

Bibliography

Standards publications PAS 99, Integrated management systems

For dated references, only the edition cited applies. PD ISO/TR 14639-2:2014, Health informatics –
For undated references, the latest edition of the referenced Capacity-based eHealth architecture roadmap – Part 2:
document (including any amendments) applies. Architectural components and maturity model

BS 13500:2013, Code of practice for delivering effective

governance of organizations Other publications
[1] EUROPEAN UNION. EC Regulation 852/2004 of the
BS 65000, Organizational resilience – Code of practice European Parliament and of the Council of 29 April
2004 on the hygiene of foodstuffs. Luxembourg:
BS EN 31010, Risk management – Risk assessment Office for Official Publications of the European
techniques Communities, 2004.1)

BS EN ISO 9000:2015, Quality management systems – [2] US FOOD AND DRUG ADMINISTRATION (FDA).
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BS EN ISO 22000:2018, Food safety management ORGANIZATION (WHO). General principles of food
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food chain WHO: Adopted in 1969 and last reviewed in 2020.3)

BS EN ISO/IEC 17000:2020, Conformity assessment – [4] WORLD HEALTH ORGANIZATION (WHO). Food
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BS ISO 10010:2022, Quality management – Guidance [5] GLOBAL FOOD SAFETY INITIATIVE (GFSI). A culture
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BS ISO 10018, Quality management – Guidance for [6] OXFORD UNIVERSITY PRESS. Shorter Oxford English
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Vocabulary

1)
Available at: https://eur-lex.europa.eu/eli/reg/2004/852/oj.
2)
Available at: https://www.fda.gov/food/food-safety-modernization-act-fsma/full-text-food-safety-modernization-act-fsma.
3)
Available at: https://www.fao.org/fao-who-codexalimentarius/sh-proxy/en/?lnk=1&url=https%253A%252F%252Fworkspace.fao.
org%252Fsites%252Fcodex%252FStandards%252FCXC%2B1-1969%252FCXC_001e.pdf.
4)
Available at: https://www.who.int/news-room/fact-sheets/detail/food-safety.
5)
Available at: https://mygfsi.com/wp-content/uploads/2019/09/GFSI-Food-Safety-Culture-Full.pdf.
6)
Available at: https://www.oed.com.
7)
Available at: https://www.bsigroup.com/LocalFiles/EN-HK/ISO%20Revision_FDIS/Importance%20of%20Leadership%20
whitepaper%20-%20FINAL%20-%20July%202015.pdf.

© The British Standards Institution 2023 27

PAS 320:2023

Further reading
JESPERSEN, L., GRIFFITHS, M., MACLAURIN, T.,
CHAPMAN, B. & WALLACE, C.A. Measurement of food
safety culture using survey and maturity profiling tools.
In: Food Control, Volume 66, 174-182.
Elsevier: 2016.8)

YIANNAS, F. Food safety culture. Creating a

behavior-based food safety management system.
Springer: 2008.9)

YIANNAS, F. Food safety = behavior – 30 proven

techniques to enhance employee compliance. 2016.
Author: Frank Yiannas.10)

US FOOD AND DRUG ADMINISTRATION (FDA). New era

of smarter food safety – FDA’s blue print for the future.
FDA: 2020.11)

THALER, R. and SUNSTEIN, C. Nudge: Improving

Decisions about Health, Wealth and Happiness.
London: Yale University Press, 2008.

Useful websites
Food and Agriculture Organization of the United
Nations (FAO)/World Health Organization (WHO) Codex
Alimentarius
https://www.fao.org/fao-who-codexalimentarius/en/

Global Food Safety Initiative (GFSI)

https://mygfsi.com/

World Health Organization (WHO) – Food safety

https://www.who.int/health-topics/food-safety

US Food and Drug Administration (FAO)

https://www.fda.gov/food

8)
Available at: https://www.resolve.ngo/docs/measurement-of-food-safety-culture-using-survey-and-maturity-profiling-tools-
jespersen-et-al.pdf
9)
Available at: https://link.springer.com/book/10.1007/978-0-387-72867-4
10)
Available at: https://link.springer.com/book/10.1007/978-1-4939-2489-9
11)
Available at: https://www.fda.gov/media/139868/download

28 © The British Standards Institution 2023

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