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Implementation of food safety management systems in the UK
Lena Dzifa Mensah
*
, Denyse Julien
Manufacturing Department, Cranfield University, Bldg 50, College Road, Cranfield, Bedordshire MK43 OAL, UK
article info
Article history:
Received 5 July 2010
Received in revised form
19 January 2011
Accepted 29 January 2011
Keywords:
Regulation
Food safety
Implementation factors
Food and drinks manufacturing sector
UK
abstract
This paper reports the first stage of work being undertaken to understand the factors that have impacted
on the current state of food safety in the UK food manufacturing sector. The paper first explores
developments in international food safety regulation in general and in particular, the UK. Using a survey
and case study methodology, the paper examines the response of food manufacturing enterprises to food
safety regulation, and uses statistical techniques to investigate the effects of enterprise size on the drivers
for, benefits of, and challenges to compliance. Further, the factors that influence the successful imple-
mentation of an integrated food safety management system are also examined. The results show a great
deal of both statutory and private regulation that has incentivised enterprises. In response, enterprises
have implemented integrated food safety management systems to proactively deal with the risks
associated with food safety, however, enterprises claim that statutory regulations are biased towards
consumers, without adequate impact assessments on all stakeholders within the chain, and hence
causing industry to incur significant costs that could otherwise be avoided. Even though compliance with
food safety regulation is burdensome, the cost of non-compliance will also be significant to enterprises.
The findings also show that there is no significant effect of size of enterprise on the drivers, benefits and
challenges to compliance with food safety regulation.
Ó2011 Elsevier Ltd. All rights reserved.
1. Introduction
The competitive landscape for international trade in food is
continuously evolving. Most developed and developing countries
are removing tariffs and quotas as trade barriers, and implementing
more stringent measures to ensure the safety of food. Food safety is
the concept that food will not be injurious to the consumer at the
point of consumption, when it is prepared and/or eaten according
to its intended use (BS EN ISO 22000, 2005). Regulators of the food
sector have justifiable reasons for these changes in competitive
landscape. Some have attributed it to the increased awareness of
consumers about food safety, which is causing them to put pressure
on regulators. Others have attributed it to the outbreak of Salmo-
nella and Bovine Spongiform Encephalopathy (BSE) in the UK (Loader
& Hobbs, 1999) and E. coli 0157:H7 in some developed countries in
Europe and America. Developing countries have also had their fair
share of food contamination issues, even though the scale of impact
is difficult to estimate, due to inadequate surveillance systems and
reporting structures (WHO/FAO, 2005). These occurrences in the
past awakened concerns of major stakeholders; they believed that
prevailing mechanisms of controls and management of food safety
were inefficient and ineffective (Henson & Jaffee, 2006). The
economically more advanced nations have been the driving force
for most of these changes (Hanak, Boutrif, & Pineiro, 2000), with
their governments striving consistently to increase traceability and
transparency through integrated approaches to food safety
management. As a result of these developments, there has been
a general reform of existing frameworks for the governance of food
safety globally. These forms of control executed at the global level,
however, have implications at the domestic level, in terms of what
practices can be undertaken at the different functional nodes of the
global food value chain. Governments have incorporated the
reforms at the global level into their national reforms, through
various forms of incentives which put additional responsibility on
enterprises, and in the case of small and medium enterprises
(SMEs), more pressure on their already scarce resources, making
survival uncertain. Mandating the implementation of integrated
food safety management systems has been seen by many as one of
the most certain ways of assuring food safety, given the nature of
food, the difficulty associated with determining its safety before
consumption and the potentially devastating effects of food safety
failure on human life. However, for some of the stakeholders who
bear direct responsibility for operationalising the requirements of
integrated food safety regulation, the process requirements are
onerous, and yet the expected benefits that drive compliance are
*Corresponding author. Tel.: þ44 1234750111x5654; fax: þ4 4 1234754605.
E-mail addresses: l.d.mensah@cranfield.ac.uk (L.D. Mensah), d.m.julien@
cranfield.ac.uk (D. Julien).
Contents lists available at ScienceDirect
Food Control
journal homepage: www.elsevier.com/locate/foodcont
0956-7135/$ esee front matter Ó2011 Elsevier Ltd. All rights reserved.
doi:10.1016/j.foodcont.2011.01.021
Food Control 22 (2011) 1216e1225
not actually realised upon implementation. Further, the process is
fraught with a lot of both internal and external challenges.
A number of literature exist on the impact of food safety regu-
lation on enterprises, the drivers for, benefits of, and challenges to
an integrated approach to operationalising the requirements of food
safety regulation in a variety of countries and sectors; these studies
have provided guidance on how to effectively implement regulatory
requirements on the shop floor, particularly in Hazard Analysis
Critical Control Point (HACCP) regulation, and the compliance
process model. Even though SMEs are said to contribute signifi-
cantly to the economies of most countries, they are the least likely
to comply with regulatory requirements because of resource
constraints. Most studies have focused on large enterprise, inde-
pendent of SMEs, arguing that it is difficult to get responses from
smaller enterprise, and hence there is a paucity of work in this area.
Further, the authors are not as yet aware of any study that has
particularly studied the drivers, benefits, challenges and success
factors in the context of the UK food manufacturing sector.
Exceptions occur in Fairman and Yapp (2004) and Yapp and
Fairman (2006), who studied some of the variables in the context
of SMEs in the catering sector and Taylor (2001) who did not make
explicit the sector of focus. The uniqueness of this paper lies in the
use of an empirical approach to study food manufacturing enter-
prises in the UK, a statistical examination of the significance of the
difference between both SMEs and large enterprises in relation to
an integrated approach to food safety management, and a contri-
bution to the insights relevant to challenges enterprises face, to
inform future policy revisions and decisions. Section 2looks at the
developments in food safety regulations and Section 3discuses
public and private regulation of food safety in the UK. Section 4
outlines the methodology, and results are presented in Section 5.
A discussion of results is done in Section 6and conclusion made in
Section 7.
2. Developments in food safety regulation
The governance of food safety has evolved significantly in the
past two decades. The evolution has affected the way in which food
safety is assured globally. Notable trends include:
2.1. A move towards more stringent approaches to food safety
Food safety control presently combines both performance-
based approaches (e.g end-product testing, inspection and sample
testing) and integrated process-based approaches (e.g. regular
audits, assessment by third party auditors, accreditation) to food
safety management. Voluntary inspections have almost given way
to mandatory legal frameworks in the form of Acts and Directives.
Retailers are now using recognised certification frameworks
(hands-off), which set out the basic minimum requirements of food
safety acceptable in the global food industry, and require supplying
enterprises to be certified by third party auditors, before qualifying
to supply food. Such certifications may be voluntarily or manda-
torily sought by suppliers.
2.2. A requirement to justify food safety regulations
Through the World Trade Organisation (WTO), trade barriers
related to tariffs and quotas have been lowered considerably. This
has fostered growing interdependencies through the exchange of
food products, across national borders. However, emphasis is being
placed on non-tariff barriers, and the wider recognition of their
impact on trade (Henson & Caswell, 1999). The established view
among some researchers is that, standards in developed countries
present trade barriers to less developed countries (Henson & Jaffee,
2006). Therefore, the Sanitary and Phytosanitary Agreement (SPS)
was formulated by the WTO, to ensure that no country is unduly
restricted from participating in global value chains. The SPS agree-
ment endorses the use of international standards, based on CAC’s
recommendations as a control measure for food safety, and requests
that importing countries with regulatory standards more stringent
than international standards, justify both scientifically, through risk-
based assessments (SPS Agreement, Article 5, paragraph 1), and/or
economically (SPS Agreement, Article 5, paragraph 6), through
systematic quantified assessment of the costs and benefits of
proposed food safety regulations (Henson & Caswell, 1999).
2.3. A proliferation of standards
There has also been an increase in the number of standards that
seek to promote food safety. These include the British Retail
Consortium’s global food safety standard (BRC), the International
Food Standard (IFS), the Dutch Hazard Analysis and Critical Control
Point (HACCP), the Safe Quality Food (SQF) 2000 Level 2, and the
ISO 22000:2005.
The BRC standard was developed in 1998, to respond to the
needs of UK retailers and brand manufacturers, however, the
standard has gained popularity globally (e.g. in Europe and
North America).
The IFS on the other hand was drawn up by the German and
French retailer and wholesaler associations, and their Italian
counterparts. IFS aims to create a consistent evaluation system
for all enterprises supplying retailer branded food products.
The SQF Program is owned by the Food Marketing Institute
(FMI). The standard combines both food safety and quality
management certification for all chain participants involved in
the production and processing of food.
The Dutch HACCP was designed by the Dutch National Board of
Experts, to specify the requirements for HACCP-based food
safety systems. The standard specifies the codes of practice
within a management system framework, and is particularly
suitable for suppliers to the Dutch market.
ISO 22000 is a global standard developed to harmonise on
a global level, the requirements for food safety management, for
businesses in food businesses (BS EN ISO 22000, 2005), apart from
food manufacturers.). The standard combines interactive commu-
nication, system requirements, prerequisite programmes, and
HACCP principles to assure food safety. The ISO 22000:2005 is
complemented with the PAS 220 Prerequisite Programmes (PRPs)
on food safety for food manufacturing to form the new Food Safety
System Certification (FSSC) 22000 for food manufacturers.
2.4. Similarities and differences amongst standards
Most of the standards discussed above are similar in the sense
that they all have one main objective: to protect consumer health
through an integrated process-based food safety management,
achieved through specifying the basic minimum requirements
acceptable for food safety, and third party audits. They provide
a framework for uniformity in requirements, audit procedures and
mutual acceptance of audits, and reassure retailers and branded
manufacturers of the capability and competence of suppliers,
All the standards have the Codex Alimentarius Commission’s
(CAC) HACCP principles as their foundation and some integrate
quality management system requirements (Table 1) into the food
safety standards (e.g. BRC, IFS, SQF). The major difference amongst
the standards is that they are owned by different stakeholders in
different geographical regions, and while some seek to specify
L.D. Mensah, D. Julien / Food Control 22 (2011) 1216e1225 1217
generic requirements that could be adapted to chainparticipants at
different functional nodes in value chains, some are specificto
either primary food producers or food processors.
2.5. Attempts at harmonising food safety regulations
There are significant variations in food safety regulations across
countries and among value chains. These variations increase the
burden of auditing costs and certifications on food manufacturers,
as retailers require different certification frameworks to qualify
suppliers. The impacts of these variations on relevant actors
present practical reasons for the need for harmonising food safety
regulations (Motarjemi, vanSchothorst, & Käferstein, 2001). There
are, however, justifiable reasons to explain these variations
(Henson & Jaffee, 2006). Some are attributed to the distinct tastes,
diets, income levels and perceptions that influence the tolerance of
populations, towards the risk associated with food. The different
private standards introduced by brand manufacturers and retailers
further introduce more variations into food safety regulations and
the modes of conformity assessments (Henson & Mitullah, 2004). A
common reference point was therefore required, from where the
process of harmonisation of standards could be started, to reduce
multiple certifications on food enterprises. The SPS Agreement,
introduced by the WTO, facilitates a move towards this much
needed common reference point, by providing a basis to establish
equivalence and harmony in food safety regulations. According to
Article 4, paragraph 1 of the SPS Agreement, Member States are to
accept the measures of control employed by others as equivalent if
the exporting country demonstrates to the importing country that
its’measure meets the importing country’s appropriate level of
health protection. As mentioned in earlier sections, harmony is
further encouraged by the WTO, through the endorsement of
international standards as a measure of control for food safety. The
WTO Agreement on Technical Barriers to Trade (TBT) which is
binding on Member States, also includes as principles to foster
harmonisation, the ‘one-one-one’principle, which implies, one
standard, one test accepted everywhere, one conformity assess-
ment mark where relevant (IEC, 2008).
In light of discussions above, international standards clearly form
a fundamental part of food safety harmonisation. The proliferation
of global food safety standards necessitated a system to ensure that
a global standard developed for one region and retailer was valid for
other regions and retailers. It is as a result of these issues that the
Global Food Safety Initiative (GFSI) was introduced in 2000, to
benchmark existing certification frameworks for food safety, to
ensure convergence amongst food safety standards, andto maintain
a benchmarking process for food safety management schemes. So
far, thirteen GFSI benchmarked international standards for
manufacturing, primary production and one for both primary and
manufacturing have been accepted by major retailers (e.g. Carrefour,
Tesco, Metro, Migros, Ahold, Wal-Mart and Delhaize) (CIES, 2007).
The international standards recognised by the GFSI have success-
fully been aligned with the common criteria defined by food safety
experts from the Food Business. This implies those retailers will
accept any of the recognised GFSI certification schemes as proof of
‘due diligence’in food safety procedures (CIES, 2007).
2.6. Tougher requirements for laboratory analysis and third party
auditing bodies
The changing landscape of food safety has put increased pres-
sure on laboratories used for analysing products for food safety
and third party auditing bodies. There has been a trend toward
‘accreditation’of laboratories and third party auditing bodies ea
process by which conformity assessment bodies are examined for
independence, competence and skill, among other things (IEC,
2008). The ‘accreditors’, who usually receive their authority from
government, use this process to assure confidence and mutual
recognition of accreditations in the food value chains.
2.7. An increased role and responsibility for consumers
An effective and efficient control and management of food safety
requires the concerted efforts of industry, government regulators,
academia and consumers. Previously, a lot of emphasis was placed
on what governments had to do to assure food safety. Recent
developments recognise the role of consumers (Hanak et al., 2000)
and the private sector as essential. The consumer’s role in food
safety is three-fold: handling and using food in the appropriate
manner, being at the receiving end of potential health risks in value
chains, and playing an advocacy and watchdog role in the regulatory
process. Through the third role, consumers provide information to
regulators on food safety. Consumer representation on decision
making and policy is particularly significant in the UK. There are
specialist consumer organisations which focus exclusively on both
general consumer and sectoral interest, which may be formed by
government, with specific statutory status (Simmonds, 2002); and
others are established by non-governmental organisations. Con-
sumer bodies are involved in meetings of national or international
technical committees, during the standards development process, to
ensure that the regulations developed conform to standards that
address issues of concern to consumers.
3. Public and private regulation of food safety in the UK
The control and management of food safety in the UK has been
realised through partnerships of both the public and private sector
(Fig. 1). Major stakeholders include national government, non-
governmental sector bodies, special interest groups andvalue chain
actors. Food safety assurance is achieved through two main routes:
private regulation and statutory regulation of the food industry.
Statutory regulation controlling food is primarily to protect the
health of consumers and prevent fraud (Tansey & Worsley, 1995).
These goals are achieved by a combination of the Food Safety Act
1990 as amended (similar versions available for Scotland, Northern
Ireland and Wales), which is the primary regulation for food safety,
and secondary regulations and Directives, issued by the European
Union.
The Act, regulations and Directives are used to constrain the
behaviour of actors in the food value chain, and implement policies
that serve consumer interests. These statutory regulations also
spell out behaviours, mechanisms for enforcing them, and sanc-
tions to be applied. According to the Food Safety Act 1990, retailers
have an obligation to exercise ‘due diligence’to assure food safety.
This ‘due diligence’defence protects consumers, and shields traders
from being convicted, in the event of crisis, if they have taken all
reasonable precaution and exercised all due dilligence to avoid
committing the offence.
Table 1
Key common requirement for food safety standards.
FSMS Elements BRC HACCP ISO
22000
SQF Dutch
HACCP
IFS
Management system UU U UU U
Prerequisite programmes UU U UU U
HACCP UU U UU U
Validation & verification UU U UU U
Emergency preparedness/
crisis management
UU
Quality management UUUU
L.D. Mensah, D. Julien / Food Control 22 (2011) 1216e12251218
Private regulation of food safety is linked to the trend of major
retailer development of own-brand range of food products
(Lawrence, Simmonds, & Vass, 2002). To ensure that suppliers of
retailers are not exposed to product liability, a system was required
to ensure ‘due diligence’in safety procedures. This was necessary so
that in the event of criminal or civil prosecution against the retailer,
there will be proof that ‘due diligence’has either been followed or
not. Retailers developed in-house food technology departments in
the 1980s to monitor their own-brand food supply lines and visited
their suppliers, giving technical advice. In the 1990s, retailers
advised suppliers to use third party auditors, approved by them to
audit their safety systems. As a result of concerns raised about the
variations characterising the different requirements and the
approaches to third party auditing, consensus was reached by
British retailers, on a common minimum standard for food safety.
This was to provide third party auditors with a common basis with
which to provide ‘due diligence’defence for retailers. Coming along
these developments was the introduction of the BRC standard in
1998, to specify the basic minimum requirement for food safety.
Presently, other standards are being adopted for use by British
retailers, which also specify the minimum basic requirements for
food safety acceptable by relevant stakeholder, at the different
functional nodes in value chains.
3.1. Drivers for, benefits of and challenges to compliance with food
safety regulations
Compliance with food safety regulation has become a ticket for
accessing the global food value chain. The past few decades have
seen significant new developments (section two above) that have
tightened controls in different countries. In response, the interest of
most researchers in this research community has shifted to
understanding the evolving competitive landscape as a result of
these new developments, and examining the response of enter-
prises to food safety regulation from different geographical posi-
tions, to improve policy decisions that will benefit both small and
medium enterprises (SMES) and larger enterprises. The environ-
mental and quality literature is fairly grounded in terms of the role
of regulation in assuring environmental sustainability (see Rugman
& Verbeke, 1998a, 1998b) and product quality, the drivers, benefits
and challenges to compliance, and the food safety literature is
increasingly drawing on these two perspectives to inform expla-
nations to the response of enterprises to food safety regulation, and
how it affects enterprises. However, Loader and Hobbs (1999)
suggest that enterprise response to food safety regulation may be
different to other forms of regulation because of the sensitive
nature of food safety issues and the immense perceived importance
of them. In spite of this, in all three types of regulations (environ-
mental, quality and food safety), enterprises are expected to take
action in order to protect the environment, public health and safety.
The wealth of literature available gives insights into the behaviour
of enterprises, which suggest that the response of enterprises is not
automatic; it reflects the interplay among different types of
incentives operating at the level of mandated government regula-
tion, pressure from the markets and liability laws (Henson &
Hooker, 2001; Jayasinghe-Mudalige & Henson, 2007; Khatri &
Collins, 2007). Whether enterprises respond in a positive or nega-
tive manner depends on a variety of factors e.g. sector, enterprise
size, financial situation and level of risk adversity (see Table 2).
Further, the impact of these incentives on the enterprise is
dependent on their perception of costs and benefits of compliance
or non-compliance. From existing studies, it is apparent that
regulation is a very important incentive for compliance in most
countries and the degree of enforcements could cause even the
smallest of enterprises to comply without question.
3.2. Successful implementation factors
A variety of studies have studied the impact of implementing an
integrated food safety management system in countries e.g. Canada
(Jayasinghe-Mudalige & Henson, 2007), Italy (Romano, Cavicchi,
Rocchi, & Gianluca, 2004)andAustralia(Khatri & Collins, 2007), in
different sectors e.g. catering, meat and poultry processing, without
necessarily examining what ensures successful implementation.
This is indicative of the fact that there is paucity of research on
relevant factors to consider for successful implementation. A myriad
of papers have focused particularly on how to implement the HACCP
component of international standards without considering relevant
factors to the whole system implementation. Trienekens and
Zuurbier (2008), however, draw on the quality literature to suggest
that adequate information should be available for planning, execu-
tion, and monitoring functions. In addition to this management
National Governments Departments and
Intergovernmental Organisations
E.g. World Trade Organisation (WTO)
Department of Environmental Food and Rural Affairs
(DEFRA)
Department of Health (DoH)
Food Standards Agency (FSA)
Food Safety Management System
(FSMS)
Non-governmental Private Sector Regulators
E.g. International Standards Organisation (ISO)
United Kingdom Accreditation Service (UKAS)
British Retail Consortium (BRC) )
Special Interest Groups
Consumer Pressure Groups e.g. National
Food Alliance , Organic , Fairtrade and Genetically Mod ified Food
Advocates and Non-advocates
Value Chain Actors
Retailers, Wholesalers, Manufacturers , Suppliers and Logistics
Providers
Public Pressure Value Chain Pressure
Voluntary Pressure
Mandatory Pressure
Intergovernmental Sector
Regulators
E.g. Cdex Alimentarius
Commission (CAC)
Fig. 1. Major stakeholders in the UK food safety management system.
L.D. Mensah, D. Julien / Food Control 22 (2011) 1216e1225 1219
support is also essential for successful implementation. As a result,
this paper draws on empirical evidence to investigate the underlying
constructs to influence successful implementation of integrated
FSMSs.
4. Methodology
A survey methodology was complemented with case studies
because the structure of the questionnaire did not allow for
a detailed investigation into compliance of enterprises, even
though it allowed for the use of a sample to estimate population
characteristics (Wright, 1997). The findings of the survey were
inadequate in themselves to provide detailed explanations of the
responses given and hence case study method was used to make up
for this limitation (Yin, 2009).
The study was interested in the institutional arrangements that
have impacted on the current state of food safety and the response
of food manufacturers to food safety regulation in the UK Food and
Drinks manufacturing sector. The study used certification to food
safety standards as a measure of compliance and as a shift from the
dependence on performance-based approaches to integrated
approach to food safety management.
4.1. Data collection
A review of relevant literature was conducted on developments
in food safety control and management in general and particularly,
in the UK. A postal survey-based questionnaire was then designed
and administered from MayeAugust, 2009. Postal surveys were
employed because the details for target respondents were not
readily available, however, general enterprise details were hosted
by various databases, and hence it was easier executing this phase
of the study using this technique. A section was included in the
survey-questionnaire to collect details of enterprises which were
willing to participate further. By including this section, which was
optional for respondent, the direct contact details of quality
managers was collected to allow for a detailed further investigation
using interviews. Three enterprises agreed to take part and hence
their quality and technical managers were interviewed to gain
insights and underlying reasons for their responses.
4.2. Research instrument
A structured survey-based questionnaire was developed,
drawing on existing literature that studied the drivers for, benefits
of, and challenges to, compliance with food safety regulation in
other countries, and the requirements of the ISO 22000 interna-
tional food safety standard. The purpose of the research instrument
was to explore the impacts of an integrated food safety manage-
ment system on enterprises, and investigate empirically, best
practices associated with implementation. The questionnaire was
divided into three main sections:
the first section dealt with the background of the enterprise in
relation to food safety management systems (food safety
standards certified to
1
, motivation
2
for compliance, benefits
2
of
compliance, and challenges
2
to compliance with food safety
regulation). An open-ended question was included in this
section to request for information on the mode of dealing with
the topmost challenge.
The section also asked respondents to rate a range of factors
in relation to their contribution to successful design, imple-
mentation and continuous improvement of food safety manage-
ment systems, indicate their mode for developing food safety
management systems and equipping personnel with food safety
competences.
The second section explored food safety management system
design, implementation and continuous improvements
(management responsibility, resources management, planning
and realisation of safe products); however, the results of this
section are not presented here, because they are being used to
form the basis for further detailed investigations. The third
section concerned the characteristics of the company: owner-
ship structure, factory size in terms of number of employees
and respondent details. The survey-based questionnaire was
reviewed by three researchers in other disciplines of study and
piloted with a specialist in the field of food safety management.
A semi-structured interview script was used to gain further
insights into responses given in the survey. The questions were
standardised to increase interviewer consistency (Fowler, 2002).
4.3. Sample for survey
The target population was food manufacturing enterprises,
which was drawn from FAME, courtesy Cranfield University Library
Table 2
Key drivers, benefits, and challenges to FSMS implementation.
Variable Themes Authors Country Sector
Drivers Legislative requirement, insurance requirement,
customer requirement, employee requirement,
prospect of enhanced corporate image,
procedural and operational efficiency, good practice
Loader and Hobbs (1999),
Henson and Hooker (2001),
Romano et al. (2004),
Khatri and Collins (2007),
Jayasinghe-Mudalige and Henson (2007)
Italy, Canada,
Australia,
USA,
New Zealand
Meat and dairy sector, meat
and poultry processing, meat
Benefits Enhanced access to markets, cost effectiveness,
time savings, production efficiency, employee
development, improved information and
communication, enhanced compliance with
regulation organisational development, improved
product quality and safety
Taylor (2001),Romano et al. (2004),
Trienekens and Zuurbier (2008)
Europe, African
Caribbean
and Pacific,
Primary producers, processors
and distributors
Challenges Excessive cost of implementation, organisational
culture, excessive documentation,
lack of technical skills and knowledge relevant to
food safety regulation, development and
implementation, lack of time, difficulty in
vetting suppliers
Taylor (2001), Fairman and Yapp (2004),
Yapp and Fairman (2006),
Jayasinghe-Mudalige and Henson (2007),
Khatri and Collins (2007)
Australia,
Europe,
Meat sector, catering sector
1
Respondents could select more than one option.
2
Respondents were to select topmost five.
L.D. Mensah, D. Julien / Food Control 22 (2011) 1216e12251220
Resource. FAME is a database that contains information of enter-
prises (e.g. trading addresses, phone numbers, and websites) in the
UK and Ireland. The target population contains both animal feed
producers and human food manufacturers. Within this target
population, the sample frame of interest is the human food
manufacturers. Out of the 3.4 million enterprises hosted by the
database, search criteria were used to narrow down to relevant
enterprises in the sample frame. The criteria comprised: type of
industry, industry location and status. The search string used was
the UK Standard Industrial Classification of Economic Activity, SIC
(2003), all Category 15, which represents “manufacture of food
products and beverages”. A total of 6553 enterprises fitting these
criteria were exported to Excel. The filtering tool in Excel was used
to eliminate manufacturers of animal feed, dormant enterprises,
and enterprises that did not specify the description of their prod-
ucts. A total of 3124 enterprises fitting the set criteria remained.
This data was manually cleaned to remove duplications, retailers,
distributors and enterprises providing financial services to food
enterprises. Stratified sampling was used to select participant,
aiming to ensure that the final sample was a good representation of
the different sub-categories (e.g. dairy-based product manufac-
turers, manufacturers of fruits and vegetables, bakeries, poultry
processors) within the sample frame. A final random sample of 500
food manufacturing enterprises fitting the criteria set out was
selected for mailing. The decision to use 500 stemmed from
resource constrains. A total of 37 (7.4%) mailed questionnaires were
returned unopened, because enterprises had either moved
addresses or were no longer in operation. The total number of
responses received was 120, representing approximately 26% of the
final sample (463).
4.4. Case studies
The three cases used for further investigation were arrived at on
the basis of who was willing to participate, and were drawn from
the sample that was used for the survey. All three enterprises were
SMEs, certified to the BRC standard and privately owned. The
enterprises serviced international markets in addition to the UK
market and have been in business for at least 20 years. One was an
intermediary food processor and two were manufacturers of ready
to eat food products.
4.5. Analysis
The responses received were manually entered into a workbook
in Microsoft Excel and prepared for analysis. The prepared data was
then imported into SPSS 17.0. The descriptive characteristics of the
data were computed for various responses and interpreted based
on emerging trends from the analysis. The data of categorical
nature were analysed using the Chi-square statistical technique to
identify differences in the groups of respondents (SMEs and large
enterprises). Alpha (
a
) was set to 0.05 (Wright, 1997). Cramer’sV
was used to investigate the strength of the effects of size of
enterprise on the drivers, benefits and challenges to compliance.
Factor analysis was conducted on the variables that influence
the success of FSMS implementation, to identify underlying
constructs that are most important. Cronbach’s alpha was used to
assess the internal consistency reliability for the overall scale of
measurement and for individual elements within the scale.
Responses to the open-ended question were clustered to iden-
tify emerging themes. The responses received from the interviews
were transcribed and descriptively analysed (Miles & Huberman,
1994). Conclusions were then drawn based on the outcome of the
findings and analysis.
5. Results
This section presents the results of the empirical survey of the
UK Food and Drinks sector.
5.1. Profile of respondents
The European Commission’sdefinition of enterprises, in terms
of number of employees (European Commission, 2003)was
adopted. Approximately 54% of enterprises that responded to the
survey belonged to the SME category (Table 3) and 46% were large
enterprises. Privately owned enterprises made up the largest of the
responses (Table 4).
5.2. Response to food safety regulation
Majority (97.5%) of enterprises that responded to the survey had
an integrated food safety management system (FSMS) in place.
Three enterprises (2.5%) did not have any FSMS in place; none-
theless, these enterprises had one of the ISO 9000 series imple-
mented. The first enterprise was a subsidiary of a multinational
enterprise, manufacturing beverages, had been in business for
many decades and hence had an established market. The last two
enterprises were corporations, manufacturing malt for brewers.
87% of enterprises had a third party certified FSMS implemented.
The BRC global food safety standard turned out to be the most
popular amongst the different standards implemented by UK food
enterprises (Fig. 2). Approximately 78% of enterprises had the BRC’s
global food safety standard in place. Approximately 6% of enter-
prises had two food safety standards implemented. 11% of enter-
prises had their own version of food safety management system in
place. Even though ISO 22000 has been introduced for approxi-
mately five years now, the standard and the IFS were less popular
with UK enterprises. Seven enterprises were certified to the ISO
22000 standard and three enterprises were certified to the IFS.
5.3. Motivations for compliance
Approximately 81% of enterprises claimed that they were driven
by the prospects of product safety improvement, 76% were driven
by customer requirements and 60% were driven by regulatory
requirements. The survey also revealed that 59%of enterprises were
driven by the expected marketing advantage that could be derived
from implementing the standard, others, 54% saw the potential for
Table 3
Size of enterprises.
Criterion Micro Small Medium Large
No. of employees (X)X<10 10 <X<50 50 <X<250 X>250
Total no. of responses 0 9 52 53
% of respondents 0 7.9 45.6 46.5
6 Enterprises did not indicate their enterprise size.
Table 4
Ownership structure of enterprises.
Ownership structure Total no. of
responses
%of
respondents
Private (Individually owned) 58 48
Subsidiary of a multinational enterprise 30 25
Corporation 19 16
Public-private partnership 8 8
Cooperatives 4 3
Publicly owned 1 1
Successful food safety management system implementation factors.
L.D. Mensah, D. Julien / Food Control 22 (2011) 1216e1225 1221
improved corporate image and 38% claimed that their certification
was motivated by the fact that their competitors were certified. Only
35% of enterprises complied because of potential liability claim. 30%
were driven by the prospect of operational cost reductions.
Approximately 18% of the enterprises claimed that they complied to
avoid potential export barriers from overseas customers, and
because it was an insurance requirement (see Fig. 3).
5.4. Benefits of compliance
This study also investigated the perceived benefits of complying
with food safety requirements in the UK Food and Drinks sector.
The findings are represented in Fig. 4. From the chart, 85% of the
respondents enjoyed the benefit of increased customer satisfaction.
83% of respondents claimed improved internal procedures and 82%
of the respondents also claimed improvements in product quality.
Approximately 72% also claimed that implementing a food
safety management system facilitated compliance with regulatory
requirements. Less than 30% of enterprises claimed benefits
relating to market access, reduced operating cost and lower
insurance charges. Only one enterprise claimed no benefits were
received from complying with food safety requirements.
5.5. Developer of food safety management system
Developing, implementing and continually improving food
safety management systems require the effort of all employees in an
enterprise to be effective and efficient. The various stages of the
process require particularly relevant competencies. Enterprises have
three options to adopt when developing and implementing a FSMS:
developing the system in-house;
inviting a consultant to develop the system, while providing
him with the necessary resources;
or jointly developing the system, while making use of both
in-house personnel and a consultant.
According to the survey, most enterprises (77%) developed their
systems in-house, 21% respondents claimed their system was
jointly developed with a consultant, and 2% respondent handed
over the whole process to a consultant. From these findings,
a higher need exists for employees involved in the development
and implementation of a FSMS to be technically competent as most
enterprises are tending to develop their food safety management
systems in-house.
5.6. Challenges to compliance
The challenges hindering compliance of enterprises to FSMSs
are three-fold (Fig. 5): financial, infrastructural and people related.
The study identified five topmost challenges as: lack of technical
knowledge and skill of employees (58%), employee resistance to
change (58%), lack of awareness of the requirement (40%), high cost
of development and implementation (26%), inappropriate infra-
structural capabilities for validating and verifying FSMS 30%.
5.7. Mode of overcoming topmost challenge
In response to the open question of how enterprises overcome
their topmost challenges hindering compliance with food safety
regulation, 40 enterprises (63%) out of the 64 that responded said
they implemented interventions that increased the knowledge and
competence of their workforce, by increasing their training budget,
implementing internal training and knowledge sharing schemes,
and implementing a training department (See Fig. 6). 10% of
enterprises said they implemented interventions that altered the
existing culture within their enterprises. Approximately 8% of
respondents said they improved communication in relation to
awareness of food safety requirements and how it affects each
employee’s job description. The remaining percentage (42%) was
accounted for by other respondents who suggested that they
invested in equipment and software packages for the management
of food safety, implemented standard operating procedures and
documented their plan of action to increase the consistency of
procedures, which will have a direct impact on food safety in the
enterprise.
Fig. 2. Certification of FSMS.
0 102030405060708090
Avoid potential export barriers
Insurance requirement
Prospect of operational cost reductions
Prevent liability claims
Competitors accredited
Improve corporate image
Enhance marketing advantage
Regulatory requirement
Customer Requirement
Product quality improvements
% of res
p
ondents
Motivation items
Fig. 3. Motivation for compliance.
0 102030405060708090
No benefit
Lower insurance charges
Reduced operating cost
Enhanced prospect of trading in other countries
Improved employee morale
Improved corporate image
Compliance with regulatory requirements
Improved product quality
Improved internal procedures
Increased customer satisfaction
% of res
p
ondents
Benefit items
Fig. 4. Benefits of compliance.
L.D. Mensah, D. Julien / Food Control 22 (2011) 1216e12251222
5.8. Successful implementation factors
The variables underlying the factors that influenced successful
implementation of FSMS were ranked using a five point Likert
scale, where 1, represented ‘unimportant’and 5, represented ‘very
important’. The overall reliability of the scale of measurement was
0.835, and that for individual elements ranged between 0.81 and
0.83, which is sufficiently high (Nunnaly, 1978). The Kaiser-Meyer-
Olkin (KMO) statistic was 0.833, which indicates that factor analysis
is appropriate and hence should yield distinct and reliable factors
(Field, 2005). The correlation matrix yielded item-total correlations
from 0.101 to 0.649. Since none of the correlation coefficients were
0 or particularly high, all variables were included in the principle
component analysis (PCA). The results are shown in Table 5. The
PCA shows that the first four components explained approximately
64% of the total variance and had Eigen values of more than 1, and
hence were selected for further analysis (Field, 2005). The varimax
rotation suggested an optimum, interpretable four-factor solution,
suppressing factors with values <0.5. This loading show that there
are four factors and variables load very highly onto one factor,
factor 4 (Table 6).
6. Analysis and discussion
The study reveals a great deal of regulatory interventions by
government and the private sector, which were enacted to increase
transparency, traceability, consumer confidence in food safety, and
protect consumer health and safety. The statutory regulatory
approach was particularly deemed necessary because of the nature
of food, it being an experience good (Weimer & Vining, 1999) and
the inability of consumers to determine its safety before purchase
or consumption due to information asymmetry. Regulators, there-
fore, saw the need to step in to protect consumers. By so doing, it
was hoped that the potential devastating effects of food safety
failures could be avoided. These efforts have seen an increased
responsibility of major stakeholders in the food value chain (The
Strategy Unit, 2008). Enterprises have responded to stringent
regulations by complying with international food safety standards,
through process-based, integrated food safety management
approaches and getting audited by third party auditing institutions,
while still using performance-based approaches to verify specific
levels of certain food safety hazards.
6.1. Motivation for, and benefits of compliance
The push for regulation on an integrated food safety manage-
ment approach is primarily on the basis of the perceived degree of
assurance it gives, towards the protection of public health, and the
increased transparency it introduces into food value chains. How
enterprises respond is, however, dependent on their strategic
orientation, the nature of drivers, and the perceived industrial and
economic benefits. For enterprises that are domestic oriented,
compliance would normally be to domestic regulation only,
however, in the UK, domestic regulation has been aligned with
regional and international regulation, and the means of demon-
strating compliance to UK customers requires that food manu-
facturers get certified to an international food safety standard. It is
evident from the study that regulation is a significant driver for
enterprises complying, even though product safety improvements
turned out top of the list of drivers. This is reflected in the opinions
of food manufacturers on the role both statutory and private
regulation has played in enhancing food safety in the UK. Some
manufacturers believe that the current status of food safety could
still have been realised, even without statutory regulation.
According to these enterprises, regulations, especially statutory
regulations are unnecessary, bureaucratic, and add no more value
to assuring food safety. Because of the dynamic nature of the food
industry, regulations make it difficult to rapidly respond to these
changes. Furthermore, the regulations are biased towards the
consumer, without due assessments of the costs it imposes on
industry. On the other hand, other manufacturers believe that
because of the significant work and costs involved in complying
with food safety regulations, most enterprises would not have
complied to their current degree if there were no stringent
external incentives. There is a consensus, however, on the benefits
derived from compliance. This is reflected in the benefits enter-
prises gained, as compliance with food safety regulation put them
in good standing with both immediate customers and the statu-
tory regulations that govern both national and global value chains.
Enterprises claimed improvements in operating procedures, which
is reflected in their responsiveness to internal food safety issues;
a friendlier, trust worthy culture has been created and trans-
parency is increasingly being fostered, through the use of multi-
functional teams. Comparing the factors that motivated SMEs to
factors that motivated large enterprises revealed two top factors
common to both groups (product safety improvements, customer
requirement). The Chi-square analysis revealed that there is no
0 10203040506070
Lack of government support
Lack of access to adequate information
Rapid changes in regulation
Blame culture
High cost of education and training
Inappropriate infrastructural capabilities for
validating, verifying FSMS
High cost of development and implementation
Lack of awareness of requirements
Lack of technical knowledge and skill of employees
Employee resistance to change
% of res
p
ondents
Challenge items
Fig. 5. Challenges to food safety management system implementation.
Fig. 6. Intervention for addressing topmost challenge.
L.D. Mensah, D. Julien / Food Control 22 (2011) 1216e1225 1223
statistical significant effect of size of enterprise on the drivers of
compliance in the UK. Similar results were identified for the
benefits of compliance. However, one benefit item proved to be
statistically significant, improved product safety. This means that,
one can say with certainty that size of enterprises has an effect on
the benefit‘improved product safety’. Since Chi-square did not
indicate the strength of this effect, Cramer’sV(Morgan, Leech,
Gloeckner, & Barrett, 2007) was used to estimate the strength.
The value was 0.206, which was quite weak. This implies that there
is at least an observed difference, which is statistically significant;
however it may not be of any practical importance.
6.2. Challenges to compliance
The topmost challenge enterprises faced in their quest to
implement integrated food safety management systems was
people related. This is partly attributed to the low level of education
and training of employees related to food safety management
systems. This challenge is logical as most enterprises (73%) devel-
oped and implemented their food safety management systems
in-house, making use of their own employees. As the generic
knowledge and competence for manufacturing is inadequate in
itself to develop and implement FSMS, a competency gap is created.
This gap, if ignored could create resistant culture; morales would
drop and implementation would be in sabotaged. This is reflected
in the number of enterprises who said employee resistance to
change was one of their topmost challenges. In addition to the
regular short training courses to increase knowledge of workforce
on food safety, additional knowledge is required for professionals
that maintain and continually improve the system in the disciplines
of food microbiology and food chemistry. However, SMEs cannot
afford the services of such professionals with the skills to develop,
implement and maintain an integrated FSMS.
The financial related challenges arose from the costs involved in
developing, implementing and continually maintaining a food
safety management system. Some of these costs arise from the
regular refresher training for all staff members and occasional
specialised training for specific quality staff. Other costs arise from
the regular audits at planned intervals, to determine whether
a food safety system conforms to planned arrangements and is
effectively implemented and updated regularly.
According to enterprises, the most unnecessary of these costs
are those arising from the customers who turn up aside scheduled
visits, as enterprises have to pay huge sums per each day of visit.
A major challenge came from getting the right infrastructural
capacity to plan and implement the processes needed for validating
control measures, and verifying the effectiveness of the system
developed. Consequently, external agencies are contracted for vali-
dation and verifications. Here again, SMEs suffer the most because
they are not able to enjoy the economies of scale provided by bulk
rates from outsourced laboratory testing services (Loader & Hobbs,
199 9). These findings are consistent with the work of Fairman and
Yapp (2004), Taylor (2001) and Yapp and Fairman (2006) are valid
both in the case of large and small enterprises. However, they are
particularly true for SMEs because of their limited access to infor-
mation, knowledge and competency to interpret regulatory docu-
ments. As a result, enterprises with limited resources face significant
challenges. The survey found out that the challenges faced by larger
enterprises are not so different from the challenges to compliance
faced by SMEs, however, the limited capability and resources of
SMEs makes compliance a heavy burden. However, since compli-
ance to food safety regulation is increasingly becoming mandatory
in global value chains, and sustaining food safety in the value chain
is dependent on these SMEs (who are the weakest links), it is
essential that efforts be made to facilitate compliance of SMEs to
food safety regulation. Government cold step in to provide financial
related incentives to SMEs in particular. Public institutions could be
set up that provide services related to validation and verification of
food safety systems at costs that are affordable. Enterprises agree
that the training offered by Environmental Health Officers are more
affordable, however, they are biased towards microbiology, which is
sometimes not beneficial for all, and hence, an improved, more
targeted training, specific to sub-sectors would be more appropriate.
For enterprises that decide to develop and implement the system in-
house, management must ensure that employees involved in the
process have the requisite competences and skill sets, to enhance
morale, which will in turn increase the chances of success of
implementation. Testing the null hypothesis between SMEs and
large enterprises revealed that even though in practice there seems
to be a difference between these two groups, the responses indicate
that there is no statistical significance difference between the
challenges faced by SMEs and large enterprises in the UK.
6.3. Successful implementation factors
The factor structure suggested by factor analysis indicates that
the first success factor has 4 items (n¼4) and that relates to the
involvement and recognition of relevant stakeholders. The second
factor also has four items (N¼4) and that relates to continually
upgrading systems and people, and standardising procedures. The
third factor has two items (n¼2) which relate to equipping
employees with the competences to manage food safety both
Table 5
Total variance explained.
Component Initial eigen values Extraction sums of squared loadings Rotation sums of squared loadings
Total % of Variance Cumulative % Total % of Variance Cumulative % Total % of Variance Cumulative %
1 4.341 36.176 36.176 4.341 36.176 36.176 2.619 21.829 21.829
2 1.283 10.694 46.87 1.283 10.694 46.87 2.173 18.11 39.939
3 1.087 9.062 55.932 1.087 9.062 55.932 1.713 14.274 54.213
4 1.007 8.395 64.327 1.007 8.395 64.327 1.214 10.114 64.327
Table 6
Rotated component matrix.
Components
1234
Government intervention .782
Employee reward and recognition systems .764
External linkages with learning centers .722
Employee satisfaction measurement .641 .547
All employees awareness of the importance
of food safety to the organisation
.814
Use of standard operating procedures .662
Continual improvement .571
Employee involvement
Education and training .816
Supplier management .649
Culture within the organisation
Top management commitment .827
L.D. Mensah, D. Julien / Food Control 22 (2011) 1216e12251224
within the internal and external value chain. The final factor is top
management commitment. The fourth factor was the most highly
loaded and in theory, represents the first hurdle to overcome before
actual development and implementation begins. For some enter-
prises, it is management that pushes for food safety certifications or
compliance. Under this particular circumstance, the first hurdle of
getting top-level management involved would have been over-
come. However, forother advocates, other than top management, it
is essential to gain the commitment of top management, as the
requirements for most international food safety standards explic-
itly state the requirements for management (BS EN ISO 22000,
2005). Therefore, ignoring the role of top management would be
condemning the whole process to failure.
7. Conclusions
Food safety has become a sensitive and global issue; from recent
developments in the global food industry, there is no way around it
without suffering the consequences of non-compliance, regardless
of whether both industrial or economic benefits are realised by
enterprises or not. Even in the face of significant challenges to
enterprises and the reservations of some enterprises about the
regulatory process and the role of regulation in ensuring food
safety, statutory regulation enhances compliance of enterprises
with food safety requirements.
Consumer safety is paramount when it comes to food safety
regulation; however, regulators need to conduct due assessments
of food safety risks on consumers, and the cost implications of
enforcement strategies on industry, to mitigate costs incurred by
industry, without compromising consumer safety.
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