FSSC 22000 First-Time Certification: The 6 Most Common Failures

The Six Most Common Failures

1. Food safety culture not demonstrably embedded. FSSC 22000 Version 6 Additional Requirement 2.5.9 and BRCGS Issue 9 Section 1.1 both require food safety culture programmes — not policies, but demonstrated culture. Auditors assess through staff interviews, observation of food safety behaviours, and review of culture measurement activities. An organisation with a policy but no measurement, training or leadership communication programme will not pass.
2. HACCP plan not based on full hazard analysis. Auditors review the hazard analysis methodology — not just the resulting HACCP plan. A plan that identifies the same critical control points as the previous certification cycle without evidence that hazard analysis was conducted from first principles for the current site, products and process configuration is a finding. All potential biological, chemical and physical hazards must be considered from scratch.
3. Food fraud vulnerability assessment not current. Both standards require food fraud vulnerability assessments covering all incoming materials. Many first-time applicants have assessments that are several years old and do not reflect current supply chain configurations, ingredient sourcing changes or emerging food fraud threats. The assessment must be current and cover all incoming materials.
4. Supplier approval programme not risk-based. Supplier approval for food safety must be risk-based — higher-risk suppliers (those providing high-risk ingredients with food safety implications) require more intensive approval than lower-risk suppliers. An approved supplier list applying the same criteria to all suppliers regardless of risk level does not meet the requirement.
5. Allergen cleaning validation not completed. Allergen cleaning validation — demonstrating cleaning procedures effectively remove allergens — is required by both standards. Many first-time applicants have cleaning procedures for allergen removal but have not validated them using allergen-specific test methods under worst-case conditions.
6. Traceability exercise not completed at required speed. Both standards require traceability exercises demonstrating end-to-end traceability within a defined time. The exercise must be completed and documented before the certification audit — and must demonstrate required speed under actual operating conditions, not laboratory conditions.

The Food Safety Culture Gap — Why It Is Different

Food safety culture is qualitatively different from the other five failures because it cannot be fixed through a procedure revision or a documentation update. Culture is demonstrated through observable behaviours, consistent management messaging, and measurement that shows awareness and commitment across the workforce — including seasonal, agency and contractor staff.

The minimum food safety culture programme that satisfies FSSC V6 and BRCGS Issue 9 includes: a food safety culture assessment or baseline measurement, a communication programme that reaches all site personnel in accessible language, leadership actions that visibly prioritise food safety, and a measurement mechanism that tracks culture over time. An annual food safety awareness session is not sufficient on its own.