The food industry is changing rapidly. Proposed certification scheme updates, such as SQF Edition 10 and ISO 9001:2026, are shifting the focus from compliance to proactive, integrated food safety management. For quality assurance (QA) teams, this represents both a challenge and an opportunity: ensuring safe, compliant operations while influencing broader operational performance and workforce capability. 

Too often, QA is perceived as a necessary cost to be minimized where possible and a function that can be entirely focused on audits, certifications, and "ticking boxes." While these activities may satisfy regulatory requirements, they seldom drive meaningful improvement in food safety culture, operational performance, or employee capability. The draft SQF Edition 10¹ highlights a clear shift in expectations, with greater emphasis on food safety culture, change management, and environmental monitoring. Similarly, the proposed ISO 9001:2026² updates strengthen the focus on digitalization, sustainability, ethical leadership, proactive risk management, and interested party engagement. Together, these changes signal that food safety (and quality) is no longer just about compliance—it is a strategic, business-wide responsibility that empowers employees to protect consumers and their brand. 

QA's Evolving Role

QA teams can no longer operate in isolation. Modern food safety management requires alignment among employee capability, operational performance, and business strategy. QA professionals who embrace this integrated role position themselves as strategic business partners, enhancing performance, developing workforce capability, and reducing risk.

Achieving this requires leadership engagement and a clear business case for skills development.³ The authors teach at the University of Adelaide and emphasize these principles in postgraduate QA course work. Students show strong interest in these practical, system-focused approaches. Many have provided positive feedback, noting the value of structured guidance in understanding how capability, culture, and continuous improvement align.

Shaping the next generation of food industry leaders, several students are now taking this classroom learning and applying it on the job with a small-scale startup food business under the guidance of author Andrew Thomson. This industry-based learning is giving students a clear view of how competency development, process design, and leadership accountability integrate within a functioning food business that will strengthen food safety outcomes.

W. Edwards Deming's philosophy of systemic thinking, leadership accountability, and continuous improvement remains foundational. His "Plan–Do–Check–Act" (PDCA) cycle continues to provide a structured, evidence-based framework for assessing and improving processes while strengthening competency across teams. It also provides a useful lens for the modern-day QA professional:

• Plan: Identify critical food safety and quality risks and performance gaps
• Do: Implement targeted interventions and hands-on learning
• Check: Monitor outcomes through observation, audit data, and metrics
• Act: Adjust programs based on evidence and feedback.

Leadership Buy-In: The Challenge

Securing meaningful engagement from CEOs and boards remains one of the most persistent challenges for QA teams. While senior leaders may support compliance in principle, translating this into resource allocation, strategic prioritization, and ongoing reinforcement is often difficult.

By rethinking food safety as a continuous improvement initiative rather than a checklist exercise, QA teams can demonstrate the value of investing in performance improvement initiatives. Leaders who understand that well-trained, competent employees are empowered to protect consumers, reduce risk, protect their brand, and improve operational efficiency are more likely to invest in sustainable learning programs.

Key points from Deming's "14 Points for Management"⁴ offer further guidance:

• Point 1: Create constancy of purpose toward improvement of product and service, with the aim to become competitive and to stay in business, and to provide jobs.
• Point 6: Institute training on the job.
• Point 8: Drive out fear, so that everyone may work effectively for the company.
• Point 14: Put everyone in the company to work to accomplish the transformation.

Boards and senior leaders should ask questions such as:

1. How does our business ensure that employees and leaders are competent in their food safety responsibilities?
2. How is performance monitored and benchmarked against comparable food businesses?
3. How does leadership understand and address the gaps between compliance and actual on-floor competency?

QA teams that present competency and performance data in business terms, linking training outcomes to safe food through reduced incidents, improved audits, operational efficiency, and employee retention, demonstrate strategic value. Leadership is more likely to invest in sustainable programs when the business case is framed around risk reduction and operational performance, rather than just regulatory compliance.

“Competency in food safety is demonstrated through behavior and performance, as evidenced by how well employees recognize food safety hazards, apply control measures, and respond to unexpected conditions or situations in the workplace.”

Limitations of Technology 

Learning management systems and compliance platforms provide value in organizing and tracking training activities. These tools improve efficiency, but they cannot confirm competency. The Australian Skills and Quality Authority defines competency as "The consistent application of knowledge and skill to the standard of performance required in the workplace. It embodies the ability to transfer and apply skills and knowledge to new situations and environments."⁵

Competency in food safety is demonstrated through behavior and performance, as evidenced by how well employees recognize food safety hazards, apply control measures, and respond to unexpected conditions or situations in the workplace. 

When leadership equates training completion with genuine capability, the business develops an artificial sense of security. A certificate on file or a green dashboard suggests everything is fine—even when unsafe shortcuts, gaps in understanding, or inconsistent behaviors persist on the production floor. This creates a dangerous disconnect between what the system reports and what is actually happening. In many cases, "nothing went wrong this time" is misinterpreted as evidence of competency when it may simply be luck, limited visibility, or untested conditions.

This illusion of assurance weakens food safety culture and increases operational, certification, regulatory, and reputational risk. Digital platforms can efficiently record who completed a module, but they cannot confirm whether a worker can identify a food safety hazard, follow a control procedure under daily working conditions, or escalate a deviation appropriately.

Protecting consumers requires demonstrated capability, not administrative completion data. Capability must be evidenced through observation, practical assessment, coaching, and ongoing feedback embedded in daily operations. Dashboards can support compliance, but they cannot guarantee performance.

QA and frontline leaders, therefore, play a critical role in turning administrative data into genuine insight—clarifying actual capability, revealing blind spots, and verifying that knowledge gained online or in the classroom is consistently translated into safe practice on the floor. Their leadership closes the gap between what the system records and the behaviors that truly reduce risk, ensuring that training results in measurable, operational improvement.

Assessing Food Safety Skills: Standards and Expectations

Global standards emphasize the need for evidence of competency, not just documentation. For example, Hazard Analysis and Critical Control Points (HACCP) requires employees to demonstrate an understanding of hazards and manage CCPs. GFSI-benchmarked programs^6,7 emphasize that safe food handling is evidenced in practice, not just written procedures. SQF Edition 10 highlights food safety culture, leadership accountability, and competency assessment as core elements.

Global food safety certification schemes benchmarked to GFSI—including SQF, BRCGS, and FSSC 22000—require that all employees, including temporary workers and subcontractors, be trained and retrained as necessary to have an understanding of food safety that is commensurate with on-the-job tasks performed. While this ensures knowledge, food businesses must go further to demonstrate competency through the practice of skills, observation, feedback, and evidence that employees can consistently apply safe practices in their work environments.

Skills assessment should cover essential tasks such as:

• Temperature control and monitoring
• Allergen management
• Cleaning processes
• Risk assessments
• Handling nonconformances
• Root cause analysis
• Reporting.

These assessments ensure that employees not only know what to do but can consistently apply it under operational conditions.

Risks of Inadequate Competency Assessment

Failing to assess skills appropriately carries a significant risk:

• Operational risks: cross-contamination, allergen incidents, product spoilage, and recalls
• Regulatory risks: nonconformance, penalties, and potential loss of certification
• Reputational risks: eroded customer trust and brand damage
• False assurance: dashboards and certificates may mislead leadership about actual competency, creating a disconnect between what is recorded and what happens on the floor.

These risks emphasize the importance of a strong, evidence-based approach to competency for both consumer protection and organizational performance.

“Accountability is the backbone of any skills development or training program, yet it is often overlooked in food manufacturing and processing environments, as responsibility for capability is unclear; no one explicitly owns the performance expectations.”

Assessing Competency in Practice

A structured approach to competency assessment includes the following steps:

• Define required skills: Link each task to risk and desired outcome
• Observe performance: Frontline leaders or QA staff watch employees perform tasks
• Ask reflective questions: Employees explain why they perform tasks in a certain way
• Provide meaningful feedback: Reinforce correct practices and address gaps
• Employees show a willingness to understand suggestions from QA or frontline leaders
• Record and review: Feed results into continuous improvement cycles
• Adopt the principles of assessment for gathering evidence of competency: fairness, flexibility, validity, and reliability to ensure credibility, consistency, and alignment with standards.

Accountability: The Missing Link 

Accountability is the backbone of any skills development or training program, yet it is often overlooked in food manufacturing and processing environments, as responsibility for capability is unclear; no one explicitly owns the performance expectations. When training is delivered without genuine engagement, follow-through, or shared responsibility, it becomes an administrative task rather than a driver of safe behavior. The results are predictable: weakened food safety culture, inconsistent performance, and increased operational risk.

Effective capability-building requires mutual agreement across all key parties—QA teams, frontline leaders, and production employees. All three parties must understand and agree that training or skills development is required, why it is necessary, and what specific food safety risks it addresses. Without this shared understanding, training is perceived as an administrative task rather than a meaningful operational safety measure.

Once this alignment is established, accountability must run through the entire PDCA cycle:

• Plan: Clearly define the required competency, the risk it reduces, and the performance expectations
• Do: Deliver training supported by hands-on coaching and operational reinforcement
• Check: Verify competency through observation, questioning, and performance checks—not just completion records
• Act: Address gaps, strengthen behaviors, and embed routines that sustain capability.

When QA teams, frontline leaders, and employees share responsibility for building competency—and agree on the need, the purpose, and the expected behaviors to be enacted—training becomes a strategic tool that supports safe operations, rather than a "box-ticking" activity.

From Check to Act: Turning Competency Data Into Improvement

Collecting evidence of food safety competency is only the first step. To realize its full value, food businesses must translate data into actionable insights that drive performance, inform leadership decisions, and strengthen food safety culture, as outlined below.

1. Analyze and Benchmark. Cumulative data across teams, shifts, and sites needs to be collected. Compare the results against internal standards and industry benchmarks to identify trends, recurring skill gaps, and areas of strength. For example, repeated errors in allergen handling may indicate a training deficiency, while consistent excellence in cold chain management can highlight best practice behaviors to share across the business.

2. Corporate Reporting and Communication. Data becomes far more powerful when presented to senior leaders and boards, rather than just showing completion rates or certificates. Reports should focus on:

• Percentage of employees demonstrating competency in critical tasks
• Observed safe behaviors vs. incidents
• Trends over time, highlighting improvements or emerging risks.

By linking evidence of competency to operational performance and risk reduction, QA transforms from a compliance function to a strategic business partner. Visual dashboards and summaries help leadership quickly grasp the impact of training initiatives and workforce capability.

3. Identify Gaps and Improvement Opportunities. Competency data highlights both strengths and vulnerabilities within the food safety system. QA teams can use this information to identify:

• Tasks or processes where employees consistently fall short of required standards
• Specific teams, shifts, or sites that need targeted support
• Gaps between training completion and actual on-the-floor performance.

Prioritizing these gaps based on risk severity ensures that interventions are focused where they will have the greatest impact—protecting consumers, strengthening culture, and reducing operational and compliance risk.

4. Inform New Training Strategies. Evidence-driven insights allow a food business to design targeted, hands-on interventions:

• Short, focused microlearning sessions for high-risk tasks
• On-floor coaching and mentoring for real-time skill reinforcement
• Refresher programs tailored to teams or shifts identified as underperforming.

Integrating these strategies into PDCA cycles ensures continuous improvement—plan interventions, implement them, check outcomes, and adjust based on performance. This approach ensures that training is no longer generic but precise, practical, and measurable.

5. Feedback into Food Safety Culture. Sharing competency results with employees fosters engagement and accountability. Constructive, transparent feedback highlights strong performers, identifies development needs without blame, and encourages peer coaching and reflection. Over time, this strengthens a culture where food safety is internalized as a shared responsibility rather than treated as a compliance obligation.

This is also the point where tailored learning solutions become essential. Rather than repeating the same generic training for everyone, competency data enables targeted support—hands-on coaching for specific tasks, microlearning refreshers for high-risk steps, or scenario-based practice for roles that must respond under operational demands. Tailoring learning to actual performance gaps ensures efficiency, builds confidence, and accelerates real capability development across the workforce.

6. Close the Loop with Leadership. Finally, QA teams must present evidence and improvement strategies to senior leaders and boards, connecting competency assessment to measurable outcomes:

• Reduced incidents, near-misses, or nonconformances
• Improved audit performance and regulatory compliance
• Operational efficiencies, reduced waste, and cost savings
• Enhanced employee engagement and capability.

When leadership sees competency data translated into business outcomes, investment in workforce development becomes a strategic imperative rather than a discretionary cost.

“Leaders set the tone for culture. Visible engagement, resource allocation, and consistent messaging are critical.”

Leadership's Role in Reinforcing Food Safety Culture

Leaders set the tone for culture. Visible engagement, resource allocation, and consistent messaging are critical. Key principles include:

• Modeling expected behaviors
• Empowering operational leaders to reinforce safe practices
• Fostering trust and transparency
• Aligning resources to enable meaningful engagement.

When leaders embed these principles, QA teams move from compliance enforcers to strategic partners, thereby influencing culture, performance, and consumer safety.

Integrating Microlearning and Continuous Improvement

Microlearning delivers short, focused sessions embedded in daily routines. Combined with the PDCA cycle, it ensures continuous improvement through iterative observation, feedback, and adjustment. Behavior reinforcement should be supported in on-the-job work practices through coaching, feedback, and reflection—not gamification. When microlearning is integrated with routine capability assessment, training becomes a mechanism to build real skill rather than just a delivery method.

AI-enabled training tools and courses offer potential efficiency gains in generating content and personalizing modules. However, in the context of food safety capability, such tools must be integrated with strong, validated on-floor assessment, observation, and feedback mechanisms. Without on-the-job application and behavioral reinforcement, AI-driven modules alone will not build competency.

Conclusion: From Assurance to Culture

GFSI's direction is clear—capability, not content, will define the future. As standards continue to evolve, food businesses that measure and build capability will outperform those that continue to rely on content-based compliance.

QA in the modern food industry must evolve beyond checklists and online modules. Leadership buy-in, competency-based training, and continuous improvement are essential for building a resilient and proactive food safety culture.

QA professionals have the opportunity to transition from gatekeepers within a silo to overarching strategic business partners who guide capability development, strengthen business resilience, and reduce operational risk. Their influence spans beyond compliance, connecting operational performance, workforce skills, and business strategy. Leadership engagement accelerates when executives see the direct link between competency, consumer protection, and overall business performance.

By embedding assessment into everyday operations, engaging employees, and providing credible evidence to leadership, QA teams can shift food safety from a "ticking-the-box" activity to a measurable strategic advantage. Competency, culture, and leadership alignment are not just regulatory and certification expectations—they are the foundation of a safe, profitable, and resilient food business.

Note

The findings and conclusions of this report are those of the authors and do not necessarily represent the official position of the Centers for Disease Control and Prevention (CDC).

References

1. Safe Quality Food Institute (SQFI). "Updating You on Edition 10: Release Timeline and Next Steps." September 26, 2025. https://www.sqfi.com/news/blog/view/sqfi-blog/2025/09/26/updating-you-on-edition-10--release-timeline-and-next-steps.
2. International Organization for Standardization (ISO). "ISO/DIS 9001: Edition 6, 2026." https://www.iso.org/standard/88464.html. 
3. Thomson, A. and M. Wilson. "The Business Case for Building Food Safety Skills." Food Safety Magazine. October 28, 2024. https://www.food-safety.com/articles/9861-the-business-case-for-building-food-safety-skills. 
4. The W. Edwards Deming Institute. "Dr. Deming's 14 Points for Management." https://deming.org/explore/fourteen-points/. 
5. Australian Skills Quality Authority. "Appendix 1: Definitions." https://www.asqa.gov.au/course-accreditation/users-guide-standards-vet-accredited-courses/accredited-courses-guide-appendices/appendix-1-definitions#:~:text=VET%20Accredited%202021.-,Competency,transfer%20and%20apply%20skills%20and%20knowledge%20to%20new%20situations%20and%20environments.,-Course%20document.
6. Global Food Safety Initiative (GFSI). "Capability Framework." https://mygfsi.com/.
7. Food Safety Magazine Editorial Team. "GFSI Releases Benchmarking Requirements Version 2024." Food Safety Magazine. December 20, 2024. https://www.food-safety.com/articles/10028-gfsi-releases-benchmarking-requirements-version-2024.