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Implementation of food safety management systems

On September 16, 2022, the Official Journal of the European Union published the Commission Notice on the Implementation of food safety management systems covering Good Hygiene Practices and procedures based on the HACCP principles, including the facilitation/flexibility of the implementation in certain food businesses (2022/C d355/01).

Subject of the new guide

The new guide updates the previous guide from 2016 and takes into account the latest revisions of relevant legislation such as the introduction of allergen management and food safety culture as requirements in Regulation (EC) No. 852/2004, as well as in international standards such as the revision of ISO 22000, the General principles of Food Hygiene and the adoption of the Codex Alimentarius Code of Practice on Food Allergen Management for Food Business Operators. Since 2016, the European Food Safety Authority (EFSA) has also published scientific opinions such as the “Hazard analysis approaches for certain small retail establishments in view of the application of their food safety management systems and Hazard analysis approaches for certain small retail establishments and food donations”. The Commission Notice is not legally binding and provides guidance only.

What is a food safety management system (FSMS)?

According to the definition in the guidance, it is prerequisite programmes, supplemented with control measures at CCP, as appropriate, that when taken as a whole, ensure that food is safe and suitable for its intended use. The FSMS is also the combination of control measures and assurance activities. The latter aims at providing evidence that control measures are working properly such as validation and verification, documentation and record keeping. Appendix 1 of the guidance vividly presents an "overview of food safety management systems excluding primary production and related operations."


The guide provides an orientation for companies to make the somewhat fuzzy concept of "food safety culture" more tangible. A separate chapter has been devoted to food safety culture as a component of "Good Hygiene Practice" in Annex I, paragraph 3.14. Because the statutory components of food safety culture are based on subjective perceptions, the guidance in Appendix 3 lists tools for making the behavior-based approach to food safety culture measurable. For instance, an example of such a tool presented in Appendix 3 is a survey of different groups of employees, which leads to the identification of weaknesses in certain food safety culture principles and corrective actions that can be taken. In addition, a general assessment of the food safety culture can also be carried out by comparing the results, for example in different departments of a company or in different branches of the same group, for example supermarkets or butcher shops belonging to the same group. In addition, as a tool for evaluating food safety culture, the indicator examples also help food safety authorities. If they use the same questionnaire for audits in a given industry, the monitoring authorities can easily compare the standards in different companies in the same industry.

In Annex III of the Guide, the competent authorities are provided with a mirror image of guidance for auditing food safety culture management systems, including GHP and HACCP-based procedures. Thus, it is recommended to check, also with the help of questionnaires,

  • whether a food safety culture survey has been conducted,
  • what knowledge employees have about the importance of producing safe and appropriate food,
  • what attitude and behaviour employees have towards food hygiene,
  • what level of management commitment is in place and how communication with other departments is taking place,
  • how the leadership role is lived in involving all employees in food safety procedures, what resources are available to implement the food safety culture.

Table 1 then provides an example of a food safety culture checklist for agencies. Additional tools will be published as they become available.


With the publication of the new guide, it can now be expected that the management systems for food safety culture will also be increasingly monitored by the authorities. It is important that the verification of the food safety culture on the basis of objective data is not a one-time process, but a continuous process that should also be lived as a culture in the companies.

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