Management Responsibility in Food Safety
- M. DuBose
- 3 days ago
- 5 min read
Why It Still Matters and How to Fix It.
For more than two decades, we have emphasized the truth that the food industry continues to relearn the hard way: food safety begins and ends with management responsibility. In our book Food Safety Management Programs and my 2002 Food Quality article “Take It from the Top,” I emphasized that no amount of documentation, testing, or auditing can compensate for weak leadership commitment. That message has only grown more urgent as regulatory expectations evolve, and supply chains become more complex. (I use the term “our” book because this text is a collection of inputs (“quotes”) from folks that I had worked with over many years. As you read these comments, they aren’t all from me, but from professionals throughout many industries that I have and still have the pleasure of working with.
Today, with FSMA fully implemented, the FDA’s New Era of Smarter Food Safety underway, and the 2026 enforcement cycle for the Traceability Rule approaching, the industry is seeing renewed pressure to demonstrate not just compliance, but culture. And culture always starts at the top.
As we explore management responsibility and why it remains a persistent challenge, we review what was identified as the root causes, and how modern companies can finally close the gap.
Why is Management Responsibility in Food Safety Still an Ongoing Issue:
Leadership Often Underestimates Its Role - Overall, our many years in the industry, we have long observed that executives frequently assume food safety and quality are “handled” by QA or operations. Early ISO management systems stressed top management involvement; but many continued to choose a different interpretation. In reality, only leadership can allocate resources, set priorities, and model behaviors that make food safety and quality non‑negotiable.
When leaders treat food safety and quality as a cost center or a regulatory burden, the entire organization follows suit.
Competing Priorities Dilute Focus - Production targets, customer demands, labor shortages, and cost pressures often overshadow food safety and quality. These texts highlight that when management sends mixed messages “safety first, but don’t slow down production” employees’ default to what they believe leadership truly values.
Lack of Understanding of Regulatory Accountability - Since FSMA, the legal responsibility for food safety, has shifted squarely onto senior leadership. Preventive Controls, supply‑chain programs, and the Foreign Supplier Verification Program all require documented oversight by “qualified individuals” and responsible management.
Yet many executives still don’t realize that:
They are accountable for the adequacy of the food safety plan.
They must ensure resources for training, verification, and corrective actions.
They can and will be held liable for systemic failures.
Food Safety Culture Is Still Misunderstood - The ISO standards and the food safety
standards have been stressing that by describing food safety and quality culture as the “behavioral backbone” of our management systems. Today, GFSI benchmarked food safety system and ISO quality management systems emphasize the requirements for measurable food safety/quality culture and measurable objectives. However, there are still many operations that continue to treat culture as a slogan rather than management practice.
FSMA and the Preventive Controls Rule: What has changed recently in Management Responsibility? A lot and all of it reinforces our original messages from early teachings.
FSMA made management responsibility explicit. Leadership must:
Approving the food safety plan
Ensure the Preventive Controls Qualified Individual (PCQI) has authority.
Provide resources for monitoring, verification, and corrective actions.
Oversee supplier verification and recall readiness.
This is no longer optional, it’s enforceable.
FDA’s New Era of Smarter Food Safety now expects technology‑enabled traceability, stronger organizational accountability, data‑driven decision‑making, and demonstrated food safety culture.
This aligns directly with the emphasis on transparency, communication, and leadership modeling.
FSMA 204 (Traceability Rule) requires executive‑level support for system upgrades, cross‑functional coordination, investment in digital recordkeeping, and clear assignment of responsibility for Key Data Elements (KDEs) and Critical Tracking Events (CTEs)
Companies that lack strong management engagement will struggle to comply.
GFSI’s Strengthened Food Safety Culture Requirements. Benchmarked approved Food Safety Management Schemes like SQF, FSSC 22000, and BRCGS now require leadership communication, employee engagement, performance measurement, and accountability structures.
Key Areas of Management Responsibility That Still Need Improvement
Resource Allocation - Food safety cannot be done “on the side.” Companies must invest in training, equipment maintenance, environmental monitoring, digital traceability, and qualified personnel.
We often stated that: “If you think training is expensive, try ignorance.” We still all these years later still emphasize that the true term is “education.” We must explain the “why” we do something rather than “just do it this way.”
Clear, Consistent Communication - Leaders must reinforce food safety expectations daily, participate in audits and walk‑throughs, celebrate food safety successes, and communicate the “why,” not just the “what”.
Silence from leadership is interpreted as indifference.
Empowerment and Accountability - employees need authority to stop production, clear escalation pathways, non‑punitive reporting systems, and recognition for proactive behavior. Management must model accountability, but not to just demand it.
Integration of Food Safety into Business Strategy - Food safety/Quality objectives should be part of budget planning, risk assessments, capital projects, supplier selection, and performance reviews.
If food safety and quality goals are not in the KPIs, it isn’t truly a priority.
Continuous Improvement- We would like to emphasize that both the food safety and quality programs are a living system. Management must support trend analysis, risk assessments, root cause investigations, internal audits, management reviews, and corrective and preventive actions (CAPA).
Continuous improvement is impossible without leadership engagement.
Here are some of the ways companies can fix the problem starting today:
Conduct a Management Responsibility Gap Assessment
Evaluate:
Leadership knowledge
Communication practices
Resource allocation
Cultural indicators
Regulatory awareness
This creates a roadmap for improvement.
Train Executives and Not Just Operators
Executives should be trained (educated) at a minimum on:
FSMA requirements
Food safety culture
Risk‑based decision‑making.
Crisis management
Traceability and supply‑chain risks
Actually, executives should be trained (educated) in the entire management system requirements. Our workshops often reveal that leadership teams simply don’t know what they don’t know.
Establish a Formal Food Safety Culture and Quality Programs
Include:
Leadership messaging
Employee surveys
Behavioral observations
Culture metrics
Annual culture goals
Interviews with associates stressing their roles in food safety and quality culture.
This turns culture into a measurable management responsibility.
Strengthen Management Review Processes
Reviews should include:
KPI trends (status in meeting measurable objectives)
Audit results
Corrective actions
Environmental monitoring data
Supplier performance
Training effectiveness
Continuous Improvement opportunities
Management review is where leadership demonstrates ownership.
Make Food Safety a Shared Value
An effective core message: Food safety is everyone’s job, but leadership sets the tone.
Companies that succeed in embedding food safety and quality into:
Onboarding
Daily meetings
Recognition programs
Performance evaluations
Strategic planning
When employees see leaders walk the talk, culture follows. Years ago, I worked with a fantastic plant manager who would walk the floor almost daily asking individuals about their role in quality and food safety. He would recognize those that provided a valid description of the individuals and company’s culture. Associates later told me that when they saw how important it was to the Plant Manager to do this, they realized how truly important this was to the overall operation. To this day, I remember that operation as one of the very best.
My measure from 2002 remains as relevant as ever: food safety (and quality) must be led from the top. Regulations have evolved, expectations have increased, and technology has advanced, but the root cause of most failures is still the same: insufficient management engagement.
The good news is that companies can fix this. With intentional leadership, structured programs, and a commitment to culture, management responsibility becomes not a weakness, but a competitive strength.
References:
Take It from the Top! Excepted from Food Quality magazine, Nov/Dec 2002 issue.
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