At an international webinar for food industry professionals, presented by the authors of this article, a key question arose: How can the competency of production and food handlers be assessed after they complete training? This question led to an exchange of ideas and perspectives on how food businesses can move from basic training to a more robust, workplace-based competency assessment approach. By examining global standards such as hazard analysis and critical control points (HACCP), the Global Food Safety Initiative (GFSI), and the Safe Quality Food (SQF) program, this article will explore the gaps in current competency assessments and the risks posed by these gaps, as well as provide actionable strategies to empower frontline leaders and quality assurance (QA) teams to improve where necessary.

Defining Competency in Food Safety

Competency in food safety is the ability to consistently perform tasks that meet or exceed established food safety standards. It goes beyond theoretical knowledge, requiring employees to apply principles like hazard identification, temperature control, and allergen management in real-world settings. Competency is multifaceted, involving knowledge, skills, behavior, experience, and attitude. This ongoing process of learning, applying, and refining leads to optimal food safety and quality outcomes.

Competency Requirements Across Global Food Safety Standards

Global food safety standards require varying assessments of competency, from training and documented observations to ongoing competency checks. While frameworks like SQF, Brand Reputation through Compliance Global Standards (BRCGS), FSSC 22000 (Food Safety System Certification), and Food Standards Australia New Zealand (FSANZ) (Table 1) emphasize the importance of continuous skill verification, the gap often lies in practical, on-the-job assessments and consistent application. High-performing organizations go beyond compliance to ensure continuous skill development and a leadership-driven food safety culture.

U.S. and Canada Competency-Based Assessment

In the U.S., the Food Safety Modernization Act (FSMA) emphasizes the need for workers to be properly trained, with training records required to demonstrate competency. However, the emphasis is often on documentation rather than the demonstration of competency in the workplace. The same challenges arise: training completion may be equated with competency, but this may not equate to practical, observable behavior on the job.

In Canada, the Safe Food for Canadians Regulations (SFCR) require that food handlers demonstrate competency aligned with the tasks they perform, but again, much of the assessment focuses on documented training rather than observed performance in real-world settings. Much like FSMA, SFCR emphasises preventive controls, but translating these standards into observable, practical competency on the production floor appears to remain a challenge for many businesses.

The Need for Competency Assessment

While both countries have regulatory frameworks that promote food safety training, the same pitfalls persist: the tendency to focus on training records and theoretical knowledge, rather than practical, on-the-job competency. An alternative approach is the Vocational Education and Training (VET) model in Australia, where assessments should be observable, repeatable, and relevant to workplace tasks.

Adapting this VET-inspired thinking in U.S. and Canadian food businesses could improve food safety outcomes. Competency needs to be verified through consistent, on-the-job performance assessments—not just with training certificates or compliance audits.

“Traditional food safety assessments often rely on knowledge testing, signoffs, and completion records, which can fail to assess real-world application.”

Integrating VET Principles into Food Safety Assessment

In Australia's VET sector, competency-based training and assessment rely on the Principles of Assessment¹ (validity, reliability, flexibility, fairness) and the Rules of Evidence² (validity, sufficiency, authenticity, currency). These principles ensure that competency is demonstrated through consistent, on-the-job performance and is not assumed.

However, many food businesses lack the rigor seen in formal VET assessments. Often, competence is signed off without observing tasks in context, or training attendance is equated with capability. This can result in systems that look robust on paper but fail in practice.

Adopting the intent of VET-style assessment on the production or service floor—focusing on observable, repeatable competency—can help bridge the gap and drive better food safety outcomes.

From Testing to Learning: A Strategy for Competency-Based Success

Traditional food safety assessments often rely on knowledge testing, signoffs, and completion records, which can fail to assess real-world application. True competency must be demonstrated through practical tasks, such as managing allergens during busy service or ensuring proper cleaning under time pressure. QA and frontline leaders must foster a culture of active learning, where employees receive on-the-job feedback and coaching to reinforce food safety practices.

Key Insights: Bridging Knowledge with Application

• Flexibility vs. consistency: While food safety standards offer flexibility in how competency is assessed, this flexibility can lead to inconsistencies in how performance is evaluated. Some frameworks focus on theory, while others include observation and hands-on assessments, but the frequency and structure of these assessments are often undefined, resulting in gaps in the evaluation process.
• Practical assessments: The real test of competency lies in performing tasks in the correct context. Knowledge retention from quizzes or written tests does not prepare employees for the realities of the job. It is in the moments of action—managing allergens during service or addressing safety concerns under pressure—where competency truly counts. These moments define food safety success.
• Ongoing, holistic assessment: Standards like FSSC 22000 take a more holistic approach, acknowledging that competency involves education, training, and experience. However, the challenge lies in ensuring the consistent application of these assessments across industry. To ensure safety, businesses must integrate continuous evaluation through practical assessments, feedback, and leadership support to promote sustained improvements in food safety practices.

The Limits of Knowledge Testing: A Tragic Example

In 2016, the UK-based foodservice chain Pret A Manger was in the spotlight after the death of 15-year-old Natasha Ednan-Laperouse. Natasha, who was severely allergic to sesame, collapsed on a flight to France and later died after consuming a sandwich from Pret A Manger at Heathrow Airport. The sandwich contained sesame, a known allergen, but Natasha's allergy was not disclosed during the purchase.

Despite the company having allergen training in place for employees, this incident revealed a critical gap between theoretical food safety knowledge and its workplace application. Pret A Manger, although compliant with legislation, was criticized for failing to consistently communicate and manage allergen risks in practice. This failure was compounded by an inconsistent approach to allergen labelling across its outlets and the absence of allergen information on individual product packaging.

The company had not only overlooked essential food safety communication but also failed to address the issue of how employees could effectively assess and manage allergen risks in the workplace setting. This case study emphasizes how essential it is for employees to understand the importance of allergen cross-contamination and be able to demonstrate competency—not just in food safety knowledge, but also in applying that knowledge on the job every day.

In addition to Natasha's death in 2016, Pret A Manger was implicated in another fatal allergen-related incident in 2017. Celia Marsh, a 42-year-old customer, died after consuming a product that was incorrectly labeled as dairy-free but contained dairy protein. Following the coronial inquests into both deaths, Pret A Manger was criticized for being slow to implement necessary changes in its food safety practices. Reports also indicated that despite the company's compliance with food safety legislation, it had evaded the spirit of that legislation, as it had failed to ensure comprehensive allergen labeling across its entire product range.

The company's response to the crisis was widely denounced for being "too little, too late." After the coroner's findings were released, Pret A Manger introduced full allergen labeling on its products—a step it had previously resisted, arguing that it would increase the risk of "mislabeling." However, the damage to its reputation and customer trust had already been done.

In light of these tragedies, Pret A Manger's experience highlights a fundamental flaw in food safety training and assessment systems that rely too heavily on knowledge testing without sufficient emphasis on workplace application. These case studies highlight the critical need for businesses to extend knowledge-based training and create systems that allow food handlers to apply their training in the workplace. This is essential for preventing the fatal consequences that can result when competency is assumed based on theoretical knowledge.³

Reliance on knowledge testing is a global issue, not confined to one country. Training providers promote online (knowledge-based) food safety training to individuals and food businesses, often through social media platforms. It is viewed as a quick way to meet compliance requirements. These courses typically offer a certificate upon completion, which some businesses may consider sufficient for demonstrating competency. However, as highlighted by incidents like the Pret A Manger cases, this model of training—based primarily on knowledge testing—falls short of ensuring that food handlers are capable of applying food safety principles on the job under real-world conditions.

“On-the-job observation enables immediate feedback and corrective action, fostering continuous improvement and ensuring that food safety is a day-to-day responsibility, not a one-time training event.”

Moving Forward: Competency-Based Assessment and Empowerment

To shift the focus from compliance to true competency, food businesses must embrace competency-based assessments that assess both learning and performance through on-the-job application. This requires empowering employees with the time, tools, and continuous feedback necessary to build the confidence and skill to perform consistently at high standards.

Rather than relying solely on training completion certificates, this approach supports employees through hands-on experience, fostering a workplace culture where real-time learning and feedback loops are integral to daily practice. By equipping employees with the resources they need to thrive and holding them accountable for food safety practices, businesses can move beyond meeting regulatory minimums, driving continuous improvement in both safety and operational performance.

This shift from compliance-driven assessments to an empowerment-based framework is essential for protecting consumers; it is the key to building a culture of sustained food safety excellence, where employees take ownership of their roles and contribute to long-term improvements in safety, quality, and accountability.

The Importance of On-the-Job Observation Tools

On-the-job observation tools are crucial for ensuring that employees not only understand food safety protocols but also apply them effectively.

Practical Assessment
Traditional training often lacks real-world application. On-the-job observation tools evaluate key tasks like handwashing, preventing contamination, allergen management, and temperature control, ensuring that employees can perform food safety procedures on the job.

Continuous Monitoring
These tools support ongoing competency assessment, empowering supervisors and QA leaders to monitor and provide feedback throughout an employee's tenure. Continuous observation helps employees retain and apply their knowledge, reducing food safety risks over time.

Alignment with Global Standards
Global food safety standards (e.g., SQF, BRCGS, FSSC 22000) require continuous competency verification through observation, emphasizing that competency goes beyond knowledge to real-world application.

Encouraging Behavioral Change
On-the-job observation enables immediate feedback and corrective action, fostering continuous improvement and ensuring that food safety is a day-to-day responsibility, not a one-time training event.

Strengthening Food Safety Culture
Frequent observation helps embed food safety practices into the company culture. Frontline leaders are well placed to do so, as they best understand the specific operation and mentor employees, encouraging active participation in maintaining and improving food safety standards. This helps build accountability across teams.

Addressing Competency Gaps
Structured observation tools remove subjectivity in assessments, helping QA professionals and frontline leaders identify and address competency gaps with clear, actionable criteria. This ensures consistent performance aligned with required standards.

Supporting Competency Through a Modern Approach
To foster continuous skill development, businesses should integrate support resources like microlearning modules, checklists, and peer learning. Ongoing feedback, coaching, and recognition are essential for long-term competency and engagement.

Time for Mastery and Confidence
Food safety training should give employees time to practice tasks, enabling them to:

• Build confidence under pressure
• Understand the rationale behind protocols
• Achieve mastery through repetition.

This approach emphasizes continuous development over one-off assessments.

Providing Support Tools and Resources
Microlearning modules, visual guides, and checklists should be integrated into daily tasks, ensuring that employees stay updated and confident in applying food safety protocols.

Coaching and Continuous Feedback
QA leaders should offer ongoing feedback and personalized coaching to help employees grow and overcome challenges, ensuring continuous improvement.

Peer Learning and Collaboration
Experienced employees can mentor newer staff, fostering knowledge-sharing, teamwork, and shared accountability for food safety.

Promoting Human Skills Development
Encouraging critical thinking, communication, and problem-solving helps employees make proactive food safety decisions, improving overall safety.

Recognition and Reward for Competency
Recognition programs should celebrate employees who follow best practices, with incentives linked to food safety performance. Offering growth opportunities for top performers motivates employees to maintain high standards (Figure 1).

Why This Matters to CEOs

Shifting to competency-based food safety assessments challenges traditional training and performance methods, but for forward-thinking CEOs, this change is essential for long-term success. Here are just a few of the reasons why:

• Food safety failures are costly. Food safety failures can have a devastating impact on brand trust and reputation. One recall, allergen incident, or outbreak will outweigh the cost of investing in effective competency assessments.
• Compliance does not equal safety. Compliance with food laws and certification standards is not the same as ensuring safety. People, not paperwork (or digital systems), keep food safe. If your employees are not truly competent, then your business faces significant risks.
• Return on investment is tangible. Investing in competency results in less waste, fewer incidents, better audit outcomes, and a stronger business culture. These improvements are directly linked to key performance indicators like quality, efficiency, and customer satisfaction.
• Talent retention and engagement. Competency-based assessments empower employees, thereby reducing turnover, boosting morale, and attracting top talent. A strong learning culture fosters engagement and loyalty.
• Competency is a business imperative. Competency assessments are not just a training issue; they are also critical for reducing risks, improving performance, and building a future-ready workforce.

Conclusion: Why This Shift Matters and Who Must Lead It

Many businesses rely on online modules and training signoffs, but food safety failures often happen offline, under pressure, when judgment counts. It is time to shift from basic training to continuous competency development, where employees are supported in applying their learning with real-time coaching and observation.

Who Drives This Shift?

• Quality professionals must move beyond audits to mentoring and developing employees.
• Frontline supervisors need the right tools and support to shape behavior and culture, moving from compliance enforcement to capability building.
• CEOs and senior leaders must create the conditions for success by valuing practical competency, supporting frontline leaders, and fostering a food safety culture.

Why Change?

• Passing audits does not equal food safety competency.
• Online training and knowledge testing alone do not change behavior.
• Frontline execution under real pressure is your most critical risk control.

True competency must be demonstrated, supported, and reinforced. This is a leadership mindset shift, not just a training model. It is time to lead the charge from compliance to competency.

References

1. Australian Skills Quality Authority (ASQA). "Appendix 6: Principles of Assessment." Principles of Assessment Table 1.8-1 in the Standards for Registered Training Organisations (RTOs) 2015. https://www.asqa.gov.au/course-accreditation/users-guide-standards-vet-accredited-courses/accredited-courses-guide-appendices/appendix-6-principles-assessment.
2. ASQA. "Appendix 7: Rules of Evidence." Rules of Evidence Table 1.8-2 in the Standards for Registered Training Organisations (RTOs) 2015. https://www.asqa.gov.au/course-accreditation/users-guide-standards-vet-accredited-courses/accredited-courses-guide-appendices/appendix-7-rules-evidence.
3. Allergen Bureau. "Food allergen management guidance—for industry, by industry." 2025. https://allergenbureau.net/.