As a result of the 2005 E.coli E0157 outbreak, the Pennington Inquiry identified serious and repeated breaches of Food Hygiene Regulations by the food business operator (FBO) as a contributing factor to these breaches was considered to be the nature of the FBO’s poor food safety culture. Relevant to this review, the FSA Board recognised that, ’the two main challenges presented by the Inquiry are to tackle businesses that share (the FBO) Tudors’ attitude and to engender a proactive, inquisitorial approach by those who inspect and audit those operators’ procedures – in other words a culture that is interested in achieving outcome rather than fulfilling a task.
The review itself was conducted according to the principles of a Rapid Evidence Assessment (REA) and covered a range of different types of evidence over a number of different regulatory contexts relevant to food safety.
The specific questions that this review set out to answer include:
• Who does/does not comply and why?
• What approaches/communications are more/less effective in securing regulatory compliance?
• What encourages long-term, sustained compliance?
• What deterrents and incentives have been shown to achieve and maintain compliant behaviour, and what more can business bodies and enforcement agencies do to increase compliance?
The review takes an approach from a dual perspective, examining both employers and enforcers, and communication between the two.
In line with the main aims of the review, the research questions are addressed principally in terms of the behaviours and cultures which drive compliance, ie factors primarily concerned with demographic, behavioural and psychosocial features of employers and organisations of interest.
Who does/doesn’t comply and why?
- Small and medium-sized enterprises (SMEs) tend to be less compliant than larger businesses, across enforcement areas including food safety though size alone is not always a useful prediction for compliance
- Particular types of SME food businesses were found to be less likely to comply, including, food takeaways, those with very low paid staff and food businesses located in areas where there is a rapid 'churn’ of businesses opening and closing.
- Potential barriers to compliance amongst smaller FBO’s were identified and include costs, time constraints and apathy.
- Non-compliance can still be an issue in large organisations
What approaches are most effective in ensuring regulatory compliance?
- There is still a lack of evidence on the impacts of different ways of working andorganisational cultures within enforcing bodies
- However, good communication with food safety teams can improve individual decision making and aid internal consistency of enforcement approach.
- Situational aspects of employment (e.g. open office layout) can encourage interaction and facilitate a team approach.
- There is no one size fits all strategy to ensuring compliance. Enforcement strategies must be tailored to the prevailing culture within a food business.
- Using typologies to classify FBO’s according to their culture, attitudes and behaviours therefore have potential to guide enforcement activities.
What encourages sustained compliance?
- Knowledge of how to comply (eg food safety training) is important, but does not guarantee sustained compliance. The duration of the impact of training is unknown, and regular updates are required to ensure compliance is sustained.
- The role that managers and supervisors have in encouraging and motivating employees to follow desired practice was found to be critical. ‘Role models’ can positively influence the behaviour of junior staff by demonstrating compliant behaviour.
Incentives and deterrents shown to achieve and maintain compliant behaviour
- Commercial concerns are of increasing importance as a means of incentivising compliance with food hygiene law. This can be the case in both small and large food businesses.
- Incentive schemes which award prizes for best levels of compliance can be effective within-company.