What exactly does requirement 2.5.8 ask for in Version 7?
It asks senior management to run culture as an objective of the management system, with a plan, resources and evidence. Requirement 2.5.8 applies to all food chain categories and comes on top of clause 5.1 of ISO 22000:2018 on leadership. In the Version 7 scheme, it has three sub-clauses:
- a) senior management establishes, implements and maintains one or more food safety and quality culture objectives, and provides sufficient resources to maintain a positive culture; these objectives cover as a minimum communication, training, employee feedback and engagement, and performance measurement of defined activities in all sections of the organisation that affect food safety and quality;
- b) the objectives are supported by a documented plan, with targets and timelines, included in the management review and continuous improvement processes;
- c) a demonstrable commitment from all personnel to the production and safe handling of food shall be available.
Sub-clauses a) and b) already existed in Version 6. Two elements are new, as the official changes document shows: sufficient resources, and the whole of sub-clause c).
The definition changes too. Appendix 1 now uses the 2024 GFSI definition: shared values, beliefs and norms that affect mindset and behaviour towards food safety across an organisation. It adds that senior management has levers to shape that culture: communication about policies and responsibilities, training, employee feedback and performance measurement.
Element | Already required in Version 6 | New in Version 7 |
|---|---|---|
Objectives set by senior management | Yes | — |
Four minimum elements | Yes | — |
Documented plan with targets and timelines | Yes | — |
Inclusion in the management review | Yes | — |
Sufficient resources | No | Yes (2.5.8 a) |
Demonstrable commitment from all personnel | No | Yes (2.5.8 c) |
Detailed summary in the audit report | Partial | Resources and commitment added (Annex 2) |
What will the auditor check, and what must they write?
The auditor must write a precise summary, and that summary drives the collection of evidence. Annex 2 of Version 7, which sets the content of audit reports, asks for the following under requirement 2.5.8:
- an overview of how the objectives address communication, training, employee feedback and engagement, and performance measurement, across all relevant sections of the organisation;
- confirmation that sufficient resources have been provided;
- a reference to the culture plan, with its targets and timelines;
- confirmation that culture has been addressed in the management review;
- confirmation that evidence of the commitment of all personnel is available.
A nonconformity is raised against the most specific sub-clause, for example 2.5.8 a). Elsewhere in the report, the summary for clause 5 of ISO 22000:2018 must describe how the policy is made available to each worker, “linked to food safety culture”, and confirm that an interview was held with top management, naming who was interviewed.
On method, the Foundation FSSC guidance document on culture, published in July 2023 for Version 6, describes what the auditor looks at:
- Communication: can management explain its expectations and how they weigh on its decisions? Are messages in a language the operators understand?
- Training: programme, training matrix, written tests, assessment of operators at CCPs and OPRPs; the auditor may question any operator, not only team leaders.
- Employee feedback: when did an employee last report a problem, and what was done about it? Is there a confidential channel? Do operators take part in writing work instructions?
- Performance measurement: objectives by department, dashboard, periodic survey, complaint trends, near-miss management, more deviations at peak times.
As of 6 November 2026, the Foundation FSSC page on the Version 7 additional requirements points, for implementation guidance, to the guidance documents published for Version 6: this guide therefore remains the reference for method, to be read alongside requirement 2.5.8 of Version 7.
How do you measure culture on a Moroccan site?
By combining four sources, none of which is enough on its own: an anonymous survey, interviews, shop-floor observations and the indicators you already track. The scheme imposes no tool. The GFSI, in version 2.0 of its position paper published in 2026, describes five dimensions: values, vision and mission; people; hazard and risk awareness; consistency; adaptability and continuous improvement. It leaves the choice of methods to companies.
2.5.8 element | What you measure | Example indicators | Evidence to show |
|---|---|---|---|
Communication | Understanding of expectations, job by job | Share of operators who can explain the hazard at their workstation | Interview results, materials in Arabic and French |
Training | Real competence, not just attendance | Completion of the training plan, knowledge test results | Attendance sheets, marked tests, on-the-job assessments |
Feedback and engagement | Freedom to report, follow-up given | Number of reports, response time, suggestions adopted | Reporting log, meeting minutes |
Performance measurement | Food safety and quality results by department | Complaints, internal nonconformities, near misses, deviations at peak | Dashboard, trend analysis, management review |
Three precautions matter in a Moroccan plant, and in any site where managers and operators do not share a first language.
Language. A questionnaire in French only measures command of French, not culture. Provide an Arabic version, and an oral version for operators with limited reading skills.
Season. In a packhouse in the Souss, the farming region around Agadir, or in a cannery in full campaign, part of the workforce is seasonal. A survey run in low season describes a different site. Measure at peak as well, because the unannounced audit may fall then.
Anonymity. Without a guarantee of anonymity, an operator will not say that line speed comes before cleaning. Have the responses analysed by someone outside the direct line of management.
The FSSC guidance document also refers to BSI PAS 320:2023, a guide to developing a mature food safety culture, to place your maturity level and build a change plan.
How do you build the culture plan in six steps?
Start from the measurement, not from a list of posters. Each step leaves a trace the auditor can read.
Step | Content | Owner | Audit trail |
|---|---|---|---|
1. Measure | Survey, interviews, observations, indicators | Food safety team | Dated diagnostic report |
2. Set objectives | Two to four objectives linked to the four elements | Senior management | Signed objectives, built into the system objectives |
3. Plan | Actions, owners, numerical targets, timelines | Management and department heads | Documented culture plan |
4. Allocate resources | Budget, training time, people, tools | Senior management | Approved budget, scheduled time |
5. Implement | Actions, communication, collection of commitment | Department heads | Records, evidence of commitment |
6. Review | Results, gaps against targets, new actions | Senior management | Management review minutes |
Step 4 is the Version 7 change not to overlook. A plan without a budget or training time does not prove that “sufficient” resources have been provided. Put them in the annual budget and in the production schedule. To see where the plan fits in the overall upgrade, read our FSSC 22000 v6 to v7 upgrade plan.
How do you demonstrate the commitment of all personnel?
By combining a formal commitment with evidence of behaviour. The scheme requires a demonstrable commitment “from all personnel” to be available, without setting its form. A single document will not do, because the auditor will check on the shop floor what the paper claims.
A solid combination:
- a written commitment, explained and signed at the induction of every new employee, seasonal and temporary workers included, then repeated at refresher training;
- a short test showing that the person has understood what they are committing to at their workstation;
- regular observations of key behaviours: handwashing at entry, workwear, handling of a deviation;
- real reports, dealt with and followed up, which show that people do speak up.
An example: in a fish cannery in Safi, a commitment signed on hiring proves nothing if the seaming machine operator does not know what to do when a seam check is out of tolerance. That answer is what the auditor is looking for.
Which mistakes make requirement 2.5.8 fail at audit?
The same ones come up again and again: a plan written by the quality department alone, a measurement made once and then forgotten, targets without figures, no identified resources, a management review that says nothing about culture. Before the audit, check this list.
The other changes in the scheme are brought together in our guide to FSSC 22000 Version 7 changes. For an approach shared by BRCGS, IFS and FSSC 22000, see also our page on food safety programmes.