The number of foodborne disease outbreaks caused by the retail foodservice industry has not declined and has averaged about 50–60 percent of total foodborne disease outbreaks year to year. The most current data in the U.S. from the Centers for Disease Control and Prevention's (CDC's) Beam Dashboard¹ [using National Outbreak Reporting System (NORS) Data] shows that in 2023, there were 307 outbreaks resulting in 4,429 illnesses and 7 deaths caused by retail foodservice establishments. These figures represent 50 percent of the total number of 593 foodborne disease outbreaks from all settings in the U.S. When these data are compared with the data from 2009 (the first year that CDC began reporting outbreaks via NORS), there has been no significant change in the total number of foodborne disease outbreaks caused by the retail foodservice industry. Clearly, we must do more to continuously improve the governance of food safety risk in the retail foodservice industry to reduce foodborne disease outbreaks and illnesses.

The retail foodservice industry is principally made up of both independently owned restaurants and franchised/owner-operated restaurants associated with corporate brands, both contributing to the high numbers of foodborne disease outbreaks annually. Many of the foodborne disease outbreaks and illnesses caused by these restaurants have a root cause related to operational failures in basic food safety management requirements in restaurants. These contributing factors² are well known and cause the majority of the foodborne disease outbreaks in the U.S. Ultimately, the owner of the independent restaurant or the leadership/corporate governance of the brand's restaurants has failed in its duty to assure public health by failing to ensure that the business has a food safety culture (FSC) governing its food safety management (FSM) of the risk.

Interdependence Between Food Safety Management and Food Safety Culture

This failure in FSC governance of FSM at the restaurant level specifically affecting the food safety risk has recently been demonstrated by CDC.³ CDC's Environmental Health Specialist Network (EHS-Net) surveyed over 300 restaurants (both independent and franchised) across the U.S. and found that a weak FSC was a key risk factor of foodborne disease outbreaks. In their model, four domains—leadership, employee commitment, management commitment, and resource availability—were critical to shaping worker beliefs about the importance of food safety. Notably, the highest-rated factor was the availability of resources to maintain hand hygiene, followed by management and food handler peer commitment. CDC also emphasized leadership visibility and manager behavior as key levers of FSC. In their study, restaurant managers who showed a personal commitment to food safety and ensured availability of supplies—gloves, soap, thermometers—were more likely to foster a strong FSC. Clearly, when the business leadership and food safety managers and employees work within a management structure that includes commitment and resources for employees to do their jobs correctly, then execution gaps are closed, cultural expectation norms are strengthened, and FSM is improved.

Food safety management forms the operational backbone of food safety assurance in a business, whether it is an independent restaurant or one associated with a multi-unit brand. Food safety culture, while less tangible, is no less critical and shapes the "why" behind food safety management expectations. FSC is the invisible force that determines whether procedures are followed consistently and whether frontline employees feel ownership of food safety outcomes. The CDC study validates that both FSC and FSM matter, and alignment between management and culture at the operational level of the business is essential to operational success.

When I started my first job in the foodservice industry at a fast-growing foodservice corporation, I was overwhelmed with the responsibility of ensuring food safety across the supply chain, distribution, and restaurant operations. Coming from a background in scientific research in government and academia, where I controlled the variables and outcomes, I quickly realized that corporate food safety leadership required more than technical knowledge. At that time, I could only write food safety specifications, but I lacked influence over the systems and people responsible for executing them.

This is when I sought out Frank Yiannas, then working as the head of food safety at Disney. He was writing what would become a landmark food safety book, Food Safety Culture: Creating a Behavior-Based Food Safety Management System.⁴ Through this work, Frank introduced a powerful concept: that the values, behaviors, and attitudes of people executing food safety programs mattered just as much, if not more, than the procedures themselves. After reviewing his manuscript as a peer reviewer for the publisher, I recognized that robust FSM needed to be embedded within the culture of the organization to truly succeed. As I worked to build FSM into our corporate culture, I discovered that FSM was most effective at the restaurant level when it was driven by FSC.

While traditionally viewed as distinct, FSM and FSC are not mutually exclusive. Instead, they are complementary, and when aligned under effective leadership/corporate governance, they can form a resilient structure that reduces risk and drives continuous improvement. Food safety management⁵ is built on principles of hazard identification, specifications for control measures, monitoring, and corrective actions, and FSM provides the structured, science-based processes that ensure maximum risk reduction and process consistency. Core components typically include supplier food safety specifications, facility design, standard operating procedures (SOPs) for restaurant operations, employee training programs, sanitation protocols, food safety management systems (FSMSs)⁶ to actively control food safety risk factors, and now traceability of food sources. FSM is essential for defining what must be done to manage biological, chemical, and physical hazards in food sourcing, preparation, and service.

However, as discussed above, the mere existence of FSM does not guarantee consistent execution. This is where FSC becomes essential. Defined more specifically by the U.S. Food and Drug Administration (FDA) as part of an FDA-commissioned literature review in 2022,⁷ FSC refers to shared organizational values, leadership commitment, communication strategies, and behavioral expectations around food safety. For a foodservice chain, this means that board-level and executive oversight should ensure that food safety is not only codified through compliance but also embedded into the company's cultural identity and leadership practices.

Key applications of FSC in corporate business include visible leadership commitment, open and frequent communication about food safety risk and expectations, employee engagement, and systems of accountability that promote food-safe behaviors. FSC emphasizes "how people think and act" in support of food safety, regardless of whether they are being actively supervised. To focus the findings of this literature review on how FSC could be used in the corporate governance of FSM, I used ChatGPT to analyze the review. The results show that there are clear steps the industry can take to establish FSC within its business (Table 1). These steps show that while FSM can ensure compliance through structure, FSC determines the execution and consistency of that compliance.

Both FSM and FSC share several overlapping elements that enable synergy with a retail foodservice business—commitment (resources), communications/risk awareness, food safety specifications and expected behaviors (execution), training and education with employee accountability, and key performance indicators (KPIs) used for performance measurement. When these are used in FSM, they are related to requirements and performance; when used in FSC, these elements are about behavior, trust, buy-in, and organizational alignment to grow the business. FSM can be mandated and externally audited, but FSC must be nurtured from within as part of the business plan and led by the business leaders within the organization.

Food Safety Business Leadership is Key to Enabling FSC as the Corporate Governance of FSM

During 2024, FDA commissioned a study⁸ to compare the relationship between FSC and FSM via the perspectives of several food safety business leaders in large foodservice and sales businesses. Although a small sample size, it represents a very good business executive perspective on the synergy between FSM and FSC.

The synergies outlined include:

• FSC and FSM must be co-dependent to successfully mitigate food safety risks. FSC gives value to "why" food safety is important, and FSM includes the tangible systems and procedures that describe "how" food safety practices are executed.
• The advancement of FSC and FSM depends on continual improvement over time, as there is no "stopping point" to reach a strong FSC; it is a continual evolution.
• Keys to effective FSC and FSM include gaining leadership buy-in and leveraging the existing culture, norms, and infrastructure of the organization to support them, rather than trying to implement something novel or isolated on its own.
• Establishing clear, strong leadership alignment and buy-in allows for the maturity of FSC and FSM over time.
• Growth depends on an organization's willingness to critically reassess its FSC and FSM regularly, leveraging employee feedback and data to inform improvements.
• Listening and engagement at all levels support positive food safety behaviors.
• Mature organizations learn from others in the industry, especially given that food safety is not a competitive advantage.
• Leveraging innovative, modern technologies should be included in the financial investments in FSC and FSM.

To develop and sustain the important synergy between FSM and FSC and enable FSC to govern FSM in a business, a food safety business leader is needed to facilitate the interdependence of FSM and FSC. In the book Food Safety Leadership in the Business of Food Safety,⁹ I asked several corporate food safety business leaders to share their individual perspectives on how they lead FSM in their organization. The purpose of this book was to demonstrate to the retail foodservice industry, especially the leadership of these corporations, the importance of the food safety business leader to the success of the business. I also wanted to show how their work directly influences the improvement of food safety within the foodservice industry at large. More importantly, I wanted this book to provide knowledge for our industry on how food safety business leaders effectively work within their business to govern FSM.

• Interestingly, each business leader described their methods to build effective FSM in the context of influencing their business (FSC) to support and ensure food safety. The authors explain how they achieve effective synergy between FSM and FSC within their organizations. They also discussed important methods they use to influence the corporate governance of food safety outside of their FSM program/department.
• To correlate these individual perspectives into key recommendations for the corporate governance of FSM, I used ChatGPT to analyze each chapter of the book and harmonize the most common attributes into recommendations. The key takeaways from this analysis include making food safety leadership strategic, not operational; embedding food safety into cross-functional governance; making culture the execution engine, defining FSM and FSC as brand protection and a growth driver, and using mentorship and talent development as leadership imperatives to sustain the synergy between FSC and FSM (Table 2).

Takeaway

This article has explored the essential synergy between food safety management and food safety culture. This synergy, when fully realized, creates the conditions necessary to prevent foodborne disease risk factors in retail foodservice. Drawing on clear evidence from FDA and industry leaders and reinforced by CDC's recent findings at the restaurant level, the article illustrates that while FSM provides the operational structure and controls needed to manage hazards, it is FSC that ensures those systems are consistently executed through leadership, commitment, and daily behaviors. CDC's national study of restaurants highlights this point clearly: weak FSC correlates strongly with increased food safety failures, while strong leadership and resource support correlate with improved food safety outcomes.

Despite decades of food safety advancements, the rate of foodborne illness outbreaks in retail foodservice has remained largely unchanged. This stagnation signals a critical gap—not in knowledge of what must be done, but in ensuring that it is done reliably and with accountability. The path forward must now involve leveraging FSC as the mechanism of governance over FSM—embedding food safety into the values, decisions, and actions of restaurant leadership and teams. Only by treating culture as the governance framework through which FSM is enabled can we expect to see meaningful and sustained reductions in foodborne disease outbreaks. The evidence is clear: execution matters, and culture is the driver of execution.

References

1. Centers for Disease Control and Prevention (CDC), National Center for Emerging and Zoonotic Infectious Disease (NCEZID). "BEAM Dashboard." 2025. https://www.cdc.gov/ncezid/dfwed/BEAM-dashboard.html.
2. CDC. "Restaurant Food Safety: Contributing Factors." May 7, 2004. https://www.cdc.gov/restaurant-food-safety/php/investigations/factors.html.
3. Kramer, A., E.R. Hoover, N. Hedeen, et al. "Development of an Empirically Derived Measure of Food Safety Culture in Restaurants." Journal of Food Protection 86, no. 3 (March 2023): 100043. https://www.sciencedirect.com/science/article/pii/S0362028X23065018.
4. Yiannis, F. Food Safety Culture: Creating a Behavior-Based Food Safety Management System. Springer, 2009. https://link.springer.com/book/10.1007/978-0-387-72867-4.
5. King, H. Food Safety Management: Implementing a Food Safety Program in a Food Retail Business. Springer, 2013. https://link.springer.com/book/10.1007/978-1-4614-6205-7.
6. King, H. Food Safety Management Systems: Achieving Active Managerial Control of Foodborne Illness Risk Factors in a Retail Food Service Business. Springer, 2020. https://link.springer.com/book/10.1007/978-3-030-44735-9.
7. U.S. Food and Drug Administration (FDA). "FDA New Era of Smarter Food Safety: Food Safety Culture Systematic Literature Review." February 29, 2022. https://www.fda.gov/media/163588/download?attachment.
8. FDA. "Perspectives from Retail Food Organizations: Relationship Between Food Safety Culture and Food Safety Management Systems—Final Report: Interview Findings." November 12, 2024. https://www.fda.gov/media/184169/download?attachment.
9. King, H., Ed. Food Safety Leadership in the Business of Food Safety. BNP Media, October 2023. https://www.food-safety.com/ebook/food-safety-leadership.

Hal King, Ph.D. is Managing Partner of Active Food Safety LLC and a member of the Editorial Advisory Board of Food Safety Magazine. He can be reached at halking@activefoodsafety.com.