PAS 320:2023

Developing and sustaining a mature

food safety culture – Guide
Publishing and copyright information
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last issued.
© The British Standards Institution 2023.
Published by BSI Standards Limited 2023.
ISBN 978 0 539 26345 9
ICS 67.040; 67.230

No copying without BSI permission except as permitted by copyright law.

Publication history
First published April 2023
 PAS 320:2023

Contents
Foreword........................................................................................................... ii
Introduction ...................................................................................................... iv

1 Scope............................................................................................................ 1
2 Normative references.................................................................................. 2
3 Terms, definitions and abbreviated terms................................................. 3
4 Understanding the fundamentals of a food safety culture and the
context of the organization........................................................................ 6
5 Establishing the governance for a food safety culture............................ 8
6 Understanding the organization’s food safety culture............................ 12
7 Designing a strategic change plan to achieve the desired food safety
culture.......................................................................................................... 14
8 Preparing the key functions towards a food safety culture.................... 17
9 Embedding the change plan of the organization’s food safety culture
into the existing FSMS ............................................................................... 20
10 Evaluating the performance of the organization’s food safety
culture ......................................................................................................... 21
11 Sustaining the continual improvement of the organization’s food
safety culture............................................................................................... 23

Annexes
Annex A (informative)
Summary of actions from the main clauses in PAS 320.................................. 24
Annex B (informative)
Information to be communicated internally within the organization.......... 26

Bibliography...................................................................................................... 27

List of figures
Figure 1 – Framework for a process to mature and sustain the continual
improvement of the organization’s food safety culture................................ 7
Figure 2 – Structured example of the progressive nature of the maturity
levels of the organization’s food safety culture.............................................. 13
Figure A.1 – Overview of the relationship of the clauses in PAS 320............. 24

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PAS 320:2023

Foreword
The development of this PAS was facilitated by BSI Standards Limited and it was
published under licence from The British Standards Institution. It came into effect
on 30 April 2023.
Acknowledgement is given to the following • Maple Leaf Foods
organizations that funded this PAS: • McDonald’s
• Campden BRI • Musgraves
• Dairy Food Safety Victoria • Neogen®
• Dairy Farmers America • One Harvest
• Eagle Certification • OSI Group
• Food Design Consultants Group • PepsiCo
• Intertek Alchemy • SSAFE
• Jiangxi Institute of Standardization • Sunny Queen Australia
• Kerry Group • UKAS
• Musgraves • University of Lincoln
• Neogen® • Walmart
• One Harvest • Zhejiang Institute of Standardization
• SSAFE • Zhejiang ShouXianGu Botanical Drug Institute Co., Ltd
• Walmart
• Zhejiang Institute of Standardization Acknowledgement is also given to the members of
a wider review panel who were consulted in the
• Zhejiang Shouxiangu Pharmaceutical Co., Ltd.
development of this PAS.
Acknowledgement is given to Ana Cicolin, as the
The British Standards Institution retains ownership and
Technical Author of this PAS. Further acknowledgement
copyright of this PAS. BSI Standards Limited, as the
is given to Dr Lone Jespersen as the Technical Author
publisher of the PAS, reserves the right to withdraw or
of the initial draft document produced during the
amend this PAS on receipt of authoritative advice that
development of this PAS. The following organizations
it is appropriate to do so. This PAS will be reviewed at
were involved in the development of this PAS as
intervals not exceeding two years.
members of the Steering Group:
• BRCGS This PAS is not to be regarded as a British Standard.
• BSI Food & Retail Sector It will be withdrawn in the event it is superseded by
• Campden BRI a British Standard.

• Compass Group
The PAS process enables a standard to be rapidly
• Dairy Farmers of America developed in order to fulfil an immediate stakeholder
• Dairy Food Safety Victoria need. A PAS can be considered for further development
• Danone as a British Standard, or constitute part of the UK
input into the development of a European or
• Eagle Certification
international standard.
• Hello Fresh
• Institute of Food Science and Technology (IFST)
• Intertek Alchemy
• Kerry Group
• KFC UK and Ireland

ii © The British Standards Institution 2023

 PAS 320:2023

Information about this document Compliance with a PAS cannot confer immunity from
legal obligations.
This publication can be withdrawn, revised, partially
superseded or superseded. Information regarding the In particular, attention is drawn to the following
status of this publication can be found in the Standards specific Act and regulations:
Catalogue on the BSI website at bsigroup.com/
• EC Regulation No. 852/2004 of the European
standards, or by contacting the Customer Services team.
Parliament and of the Council of 29 April 2004 on the
hygiene of foodstuffs [1];
Where websites and webpages have been cited, they
are provided for ease of reference and are correct at • FDA Food Safety Modernization Act (FSMA) [2]; and
the time of publication. The location of a webpage or • Codex Alimentarius, CXC 1‑1969 [3].
website, or its contents, cannot be guaranteed.

Use of this document

As a guide, this PAS takes the form of guidance and
advisory recommendations. It is not to be quoted as if it
were a specification or a code of practice.

Presentational conventions
The guidance in this document is presented in roman
(i.e. upright) type. Any recommendations are expressed
in sentences in which the principal auxiliary verb
is “should”.

Additional commentary, explanation and general

informative material is presented in smaller italic type.

Where words have alternative spellings, the preferred

spelling of the Shorter Oxford English Dictionary is used
(e.g. “organization” rather than “organisation”).

Contractual and legal considerations

This publication has been prepared in good faith,
however no representation, warranty, assurance or
undertaking (express or implied) is or will be made, and
no responsibility or liability is or will be accepted by
BSI in relation to the adequacy, accuracy, completeness
or reasonableness of this publication. All and any such
responsibility and liability is expressly disclaimed to the
full extent permitted by the law.

This publication is provided as is, and is to be used at

the recipient’s own risk.

The recipient is advised to consider seeking professional

guidance with respect to its use of this publication.

This publication is not intended to constitute a contract.

Users are responsible for its correct application.

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PAS 320:2023

Introduction
According to the World Health Organization (WHO) [4], Following a structured and clear understanding
consuming contaminated food resulted in an estimated of the fundamentals of a food safety culture, the
600 million people – almost 1 in 10 people in the world establishment of governance plays a vital role in
– falling ill, and leads to 420 000 deaths every year, maturing it and sustaining its continual improvement.
resulting in the loss of 33 million healthy life years. PAS 320 includes recommendations related to
leadership; the organization’s vision, mission, values
These data confirm that organizations ought not to and policy; organizational structure; responsibilities,
operate in functional silos. Instead, organizations accountabilities and authorities; guiding coalition team;
need to have teams collaboratively working toward interested parties; change champions; influencers; and
shared values and goals to implement an effective food safety documentation.
food safety management system (FSMS) by adopting
a process approach to existing practices to drive With the governance in place, the guiding coalition
positive behaviours. team is able to understand the current state of their
organization’s food safety culture and plan to develop,
Management commitment is fundamental to build mature and sustain its continual improvement. To
the foundation for a food safety culture as a catalyst support this step, PAS 320 provides guidance on the
for business improvement, sustain the continual definition of the desired food safety culture and the
improvement of the organization’s food safety assessment and measurement of the current maturity
performance, and mature its food safety culture with level of organizations’ food safety culture.
the mindset that food safety is a whole food supply
chain responsibility regardless of the organization’s size Annex A provides an overview of the relationship of
or complexity. The WHO [4] stated that “food safety is the PAS 320 clauses and key actions from each clause.
a shared responsibility, and everyone has a role to play
including governments, industry, producers, business PAS 320 provides recommendations to enable the
operators and consumers”. design of a strategic change plan to achieve the desired
food safety culture.
PAS 320 provides a framework, using the plan-do-
check-act (PDCA) methodology and process approach, PAS 320 provides guidance on the establishment of a
to support organizations in developing, maturing and performance monitoring system to enable ongoing
sustaining the continual improvement of their food evaluation of organizations’ food safety culture.
safety culture. This approach can be used equally well PAS 320 includes recommendations on implementing an
by large and small organizations. The combination of ongoing improvement cycle approach which supports
the five dimensions of food safety culture (4.2) with the increased food safety performance and brings other
FSMS, management principles, and statutory, regulatory benefits to organizations including, but not limited
and customer requirements related to food safety is to, talent retention, investment return, business
fundamental to supporting organizations on performance improvement, reduction of the costs
this journey. associated with poor quality, and enhanced efficiency.

As a first step, PAS 320 provides guidance on

understanding the fundamentals of a food safety
culture, including its definition, integration between its
dimensions and the FSMS principles, its relationship to
the wider organizational culture, and related internal
and external issues.

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1 Scope

This PAS gives guidance on how to mature, sustain

and continually improve a food safety culture within
an organization.

The PAS provides a framework for:

a) understanding the fundamentals of a food
safety culture;
b) establishing the governance of a food
safety culture;
c) understanding the maturity level of the
organization’s food safety culture;
d) designing a strategic change plan to achieve the
desired food safety culture;
e) preparing key functions towards the desired food
safety culture;
f) embedding the food safety culture change plan
into the existing FSMS;
g) evaluating the performance of the organization’s
food safety culture; and
h) sustaining continual improvement of the
organization’s food safety culture.

This PAS is intended for use by any organization of any

size or complexity across the food chain, from primary
production to final delivery to consumers.

This PAS might be of use to educational institutions,

trade associations, coalitions of action, professional
bodies, certification bodies and other services
providers, accreditation bodies, scheme owners and
regulatory bodies.

The recommendations in this document are generic.

The level of complexity of the food safety culture will
depend upon each organization’s context.

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PAS 320:2023

2 Normative references

There are no normative references in this document.

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 PAS 320:2023

3 Terms, definitions and abbreviated terms

3.1 Terms and definitions 3.1.6 food safety culture

shared values, beliefs and norms that affect mindset
For the purposes of this document, the following terms
and behaviour toward food safety in, across and
and definitions apply.
throughout an organization
3.1.1 antecedent NOTE Culture is defined separately; see 3.1.3.
situation or event that precedes or triggers behaviour
[SOURCE: GFSI, A culture of food safety – A position
3.1.2 continual improvement paper from the global food safety initiative [5],
recurring activity to enhance performance modified – note added]

[SOURCE: BS EN ISO 22000:2018, 3.7] 3.1.7 food safety hazard

biological, chemical or physical agent in food with the
3.1.3 culture potential to cause an adverse health effect
integrated shared values, beliefs, history, ethics, NOTE 1 The term “hazard” is not to be confused with
attitudes and observed behaviours the term “risk” which, in the context of food safety,
NOTE Food safety culture is defined separately, see 3.1.6. means a function of the probability of an adverse
health effect (e.g. becoming diseased) and the severity
[SOURCE: BS ISO 10010:2022, 3.1, modified – of that effect (e.g. death, hospitalization) when
note replaced] exposed to a specified hazard.
NOTE 2 Food safety hazards include allergens and
3.1.4 food chain
radiological substances.
sequence of stages in the production, processing,
NOTE 3 In the context of feed and feed ingredients,
distribution, storage, handling and retail of a food
relevant food safety hazards are those that can be
and its ingredients, from primary production to
present in and/or on feed and feed ingredients and that
consumption
can through animal consumption of feed be transferred
NOTE 1 The term “food” also includes ingredients, to food and can thus have the potential to cause an
beverages, feed and animal food. adverse health effect for the animal or the human
NOTE 2 The food chain also includes the production of consumer. In the context of operations other than
materials intended to come into contact with food or those directly handling feed and food (e.g. producers
raw materials. of packaging materials, disinfectants), relevant food
NOTE 3 The food chain also includes service providers. safety hazards are those hazards that can be directly or
indirectly transferred to food when used as intended.
[SOURCE: BS EN ISO 22000:2018, 3.20, modified – NOTE 4 In the context of animal food, relevant food
“retail” has been included, note 1 modified to include safety hazards are those that are hazardous to the
“ingredients” and “beverages”] animal species for which the food is intended.

3.1.5 food safety [SOURCE: BS EN ISO 22000:2018, 3.22]

assurance that food will not cause an adverse health
effect for the consumer when it is prepared and/or 3.1.8 food safety management system
consumed in accordance with its intended use set of interrelated or interacting elements of an
NOTE Food safety is related to the occurrence of organization to establish policies, objectives and
food safety hazards in end products and does not processes to achieve food safety management
include other health aspects related to, for example, system objectives
malnutrition.
[SOURCE: BS ISO 22003-1:2022, 3.1, modified –
[SOURCE: BS EN ISO 22000:2018, 3.21] note omitted]

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PAS 320:2023

3.1.9 governance 3.1.15 near miss

system by which the organization is directed, controlled incident where no injury and ill health occurs, but that
and held accountable to achieve its core purpose over has the potential to cause an adverse health effect for
the long term the consumer when food is prepared and/or consumed
in accordance with its intended use
[SOURCE: BS 13500:2013, 2.7, modified – note omitted]
3.1.16 nudge
3.1.10 guiding coalition team positive reinforcement and/or indirect suggestions that
diverse group of individuals (leaders), empowered alter people’s behaviours and direct them towards
by top management, that work together to secure positive behaviours without excluding choice
support for change from all interested parties and lead NOTE Examples include, but are not limited to:
the implementation of a change plan to achieve the
a) altering the behaviour of a group to maintain
desired food safety culture and sustain its continual
social distancing by adding floor markings;
improvement
b) discouraging team members from coming to
3.1.11 interested party work sick by sharing how others are put at risk
person or organization that can affect, be affected by, by their sickness;
or perceive itself to be affected by a decision or activity c) flies embossed into the urinals at Schiphol
airport, which have reduced spillage and bathroom
[SOURCE: BS EN ISO 22000:2018, 3.23 and cleaning costs.
BS EN ISO 9000:2015, 3.2.3]
3.1.17 organizational culture
3.1.12 leadership values, beliefs and practices that influence the conduct
establishing unity of purpose and direction and and behaviour of people and organizations
creating conditions in which people are engaged in
achieving the organizations’ objectives [SOURCE: BS ISO 30400:2022, 3.1.3]

[SOURCE: BS EN ISO 9000:2015, 2.3.2.1, modified – 3.1.18 process approach

“leaders at all levels” and “quality” omitted] systematic definition and management of processes,
and their interactions, so as to achieve the intended
3.1.13 management results in accordance with the food safety policy and
coordinated activities to direct and control an strategic direction of the organization
organization
[SOURCE: BS EN ISO 22000:2018, 0.3.1]
[SOURCE: BS EN ISO 9000:2015, 3.3.3, modified –
note omitted] 3.1.19 scheme owner
person or organization responsible for the development
3.1.14 maturity model and maintenance of a conformity assessment system or
self-assessment tool for assessing and measuring the conformity assessment scheme
performance of an organization and the degree of
maturity of its management system, identifing areas [SOURCE: BS EN ISO/IEC 17000:2020, 4.13, modified –
for improvement and/or innovation and determining conformity assessment repeated for clarity]
priorities for subsequent actions
3.1.20 social norm
[SOURCE: BS EN ISO 9004:2018, A.1 and A.2, modified – common standards within a social group regarding
reworded from list items] socially acceptable or appropriate behaviour in
particular social situations, the breach of which has
social consequences

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3.1.21 succession plan

process for identifying and developing current
employees with the potential to fill key positions in
the organization

[SOURCE: BS ISO 30400:2022, 3.2.11]

3.1.22 top management

person or group of people who directs and controls an
organization at the highest level

[SOURCE: BS EN ISO 22000:2018, 3.41]

NOTE Top management positions may differ from one
organization to another and may include, but are not
limited to, organization owners, board members, chief
officers and the CEO.

3.1.23 walking the talk

showing that something is true by actions rather
than words

3.2 Abbreviated terms

For the purposes of this document, the following
abbreviated terms apply.
FSMS food safety management system
HACCP hazard analysis and critical control point
MS management system
PDCA plan-do-check-act

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4 Understanding the fundamentals of a food safety

culture and the context of the organization

4.1 Defining the concept of a food NOTE 2 FSMS principles include the following key
safety culture elements as described in BS EN ISO 22000:2018.
a) prerequisite programmes;
The organization should define, communicate (see
8.4) and document (see 8.5) across all areas of the b) hazard analysis and critical control point (HACCP)
organization its position on, and understanding of, principles;
food safety culture and what it means. c) system management; and
NOTE All organizations have a food safety culture at a d) interactive communication.
particular level of maturity. A common understanding NOTE 3 Management principles include the following
of what a food safety culture is supports organizations as described in BS EN ISO 22000:2018:
to assess, measure, mature and sustain the continual
a) customer focus;
improvement of its food safety culture.
b) leadership;
c) engagement of people;
4.2 Establishing the relationship
d) process approach;
between food safety culture and
organizational culture e) improvement;
f) evidence-based decision making; and
The organization should mature and sustain the
continual improvement of its food safety culture as an g) relationship management.
integral, constituent and inseparable part of its wider NOTE 4 Integration is critical to establish the
organizational culture. relationship between food safety culture and
organizational culture. PAS 99 provides a framework
The organization should fully integrate the five for integration with other management system
dimensions of a food safety culture, the organization’s standards to support a consistent and harmonious
FSMS and related management principles, and embed organizational structure
them into the organizational culture. The organization
should use food science and social science to support The organization should follow the framework
this integration and assess its impact over the for a process to mature and sustain the continual
organizational systems, processes and procedures. The improvement of its food safety culture given in
five dimensions of a food safety culture that should be Figure 1.
integrated within the organization are: NOTE 5 The wider organizational culture impacts the
a) vision and mission; way people think and feel (attitudes) which in turn
b) people; influences their actions (behaviours) and therefore
affects (positively and negatively) the food
c) consistency;
safety culture.
d) adaptability; and
e) hazard and risk awareness.
NOTE 1 These five dimensions are present in all
organizations and are expressed in accordance with the
maturity level of the organization’s food safety culture.

6 © The British Standards Institution 2023