Need to Know

• Unannounced audits can provide a more realistic picture of routine food safety practices by limiting facilities' opportunities to prepare specifically for an auditor's arrival.
• Unannounced internal audits can help identify gaps between documented procedures and actual practices that may be less apparent during scheduled audits.
• Audit readiness alone does not demonstrate a positive food safety culture; employees must understand and consistently practice food safety expectations whether or not they are being monitored.

Even companies with high scores from auditing and certification bodies may have a poor food safety culture. Audits may happen only a few times per year, allowing a facility to prepare by ensuring that the plant is exceptionally clean on the day of the audit and that all records are up to date. The more important question is how effectively the FSMS is implemented during routine operations, when no audit is taking place.

Food safety culture has been incorporated into Global Food Safety Initiative (GFSI)-recognized certification programs, including FSSC 22000, BRCGS, IFS, and SQF, and it is addressed in the Codex General Principles of Food Hygiene. Food safety culture is also a regulatory requirement for food business operators in the EU under Commission Regulation (EU) 2021/382. In the U.S., the Food and Drug Administration (FDA) has identified food safety culture as a core element of its New Era of Smarter Food Safety initiative and has emphasized the importance of influencing beliefs, attitudes, and behaviors to strengthen food safety.

However, an important question remains: How can we determine whether a positive food safety culture actually exists within a company? In other words, how can food safety culture be measured? Auditors normally visit a facility for a limited period and base their assessment on observations and sampling during that time. How can they determine whether the behaviors they observe reflect everyday operations? Food safety culture encompasses values, beliefs, attitudes, and behaviors, making some of its dimensions challenging to assess objectively.

Among the various factors that can contribute to building a positive food safety culture, one important tool is the unannounced audit, an approach already incorporated into many private food safety certification programs and used by regulatory authorities. Unannounced audits can provide a more realistic picture of everyday operations because facilities have less opportunity to make temporary preparations specifically for an auditor's arrival.

Based on my practical experience, the following are ways in which unannounced audits, whether conducted externally or internally, can help reinforce a positive food safety culture.

Consistent HACCP Team Oversight. The HACCP team must remain prepared at all times, knowing that an auditor could arrive at the facility without advance notice. This encourages the team to ensure that systems related to sanitation, hygiene, monitoring, and other food safety activities are functioning effectively during routine operations, not just in preparation for an audit.

Updated Records. The operational team develops the habit of keeping records current because there is no opportunity to complete or update them immediately before an audit. Records should be completed at the appropriate time as activities are performed. Records maintained contemporaneously are more likely to accurately reflect actual observations and activities.

Alignment Between Records and Actions. Documentation should accurately reflect what is happening on the production floor. Unannounced audits can help reveal gaps between documented procedures or records and actual practices, providing an opportunity to strengthen FSMS implementation.

Engaged Management. Company management must also remain involved and responsive, knowing that leaders may be questioned during an unannounced audit about their commitment to and reinforcement of food safety standards. When the audit date is unknown, management has an additional incentive to maintain ongoing oversight of the FSMS, including proactive measures and timely corrective actions. However, management engagement should ultimately be driven by a commitment to food safety rather than preparation for an auditor.

A Consistently Clean and Sanitary Plant. Audits typically involve a plant walkthrough to observe the implementation of good hygiene practices. With the possibility of an unannounced audit, the facility must maintain appropriate sanitation and housekeeping conditions as part of routine operations rather than preparing the plant only for a scheduled audit.

Unannounced Internal Audits. While many organizations rely primarily on external certification audits, companies can also use unannounced internal audits as a management tool. Internal audit teams can visit production areas, warehouses, processing units, or supporting facilities without prior notice. Such audits can provide a more realistic picture of daily operational practices, hygiene conditions, records maintenance, and employee behavior. They can also help identify gaps that may not be visible during scheduled internal audits for which departments have prepared in advance. Over time, unannounced internal audits can reinforce the expectation that food safety requirements apply every day, not only during formal audits.

Timely Management Review Meetings. Unannounced audits can also reinforce the importance of timely management review. Auditors may examine the outcomes of internal audits, corrective actions, performance trends, complaints, nonconformities, and improvement initiatives. Management review meetings provide an opportunity for senior leadership to evaluate the effectiveness of the FSMS, review performance indicators, and make timely decisions for improvement. Regular management review helps keep leadership actively engaged with food safety rather than treating it as a priority only before or during scheduled audits.

Changes in Mindset and Behavior. The possibility of an unannounced audit can reinforce the message that compliance with food safety practices is expected every day, not just on audit days. Workers, supervisors, and managers may become more consistent in hygiene practices, documentation, adherence to operational procedures, and individual responsibility for food safety. For these behaviors to become part of the organization's culture, however, employees must ultimately understand why the practices matter rather than follow them simply because an auditor might arrive.

Cultural Shift. When these practices are sustained over time, food safety can become embedded in an organization's values and daily routines rather than being viewed solely as a regulatory or certification obligation. Employees follow correct practices because they understand their importance, not merely because they are being monitored. At this stage, food safety begins to move beyond compliance and become part of the workplace culture.

Takeaway

Food safety culture cannot be developed through documentation or periodic certification audits alone. It emerges when food safety systems and expectations are consistently put into practice on the production floor. Unannounced audits, both internal and external, can help organizations determine whether procedures, records, and behaviors truly reflect their stated commitment to food safety during routine operations.

The ultimate objective, however, is not simply to keep employees prepared for an auditor's arrival. It is to reach a point at which the presence or absence of an auditor makes no difference. When employees share responsibility for food safety and consistently follow appropriate practices because they understand their importance, food safety has moved beyond audit readiness and become part of the organization's culture.