The Food Industry: A Sector Under Close Scrutiny

The food industry is one of the most heavily regulated sectors in the world. And for good reason: food safety is a public health concern that tolerates no approximation. For a QHSE manager in the food industry, the obligations are numerous and the penalties severe.

Here are the 5 regulatory pillars that every professional in the sector must master.

Requirement 1: The HACCP Plan and Food Safety

What the Regulations Say

EU Regulation (EC) No 852/2004 on the hygiene of foodstuffs requires every food business operator to implement a food safety management plan based on HACCP principles.

What You Need to Do

The Food Safety Management Plan (PMS in French: Plan de Maitrise Sanitaire) includes:

Prerequisite Programs (PRPs): Basic hygiene good practices
- Cleaning and disinfection schedule
- Pest control program
- Cold chain management
- Personnel hygiene
- Water management
- Waste management
The HACCP Study: Hazard analysis specific to your products
- Hazard analysis (biological, chemical, physical)
- Determination of CCPs (Critical Control Points)
- Critical limits, monitoring, corrective actions
- Verification and documentation
Traceability: The ability to track every product at every stage

Inspections

Regulatory authorities (in France: the DDPP, veterinary and food safety services) regularly inspect facilities. Penalties range from warnings to administrative closure, including fines of up to 300,000 euros and 2 years of imprisonment for endangering consumer health.

Best Practices

Review your HACCP plan whenever there is a change in product, process, or supplier
Regularly train your staff on good hygiene practices
Conduct internal HACCP audits at least twice a year
Retain all CCP monitoring records
Test your recall/withdrawal procedure at least once a year

Requirement 2: Full Traceability

What the Regulations Say

EU Regulation (EC) No 178/2002 (General Food Law) mandates “one step forward, one step back” traceability for all operators in the food chain.

What You Need to Do

Upstream traceability:

Identification of all raw material and ingredient suppliers
Recording of received batches (batch number, date of receipt, quantity)
Certificates of analysis and conformity for raw materials
Transport conditions upon receipt

Internal traceability:

Link between raw material batches and finished product batches
Recording of manufacturing conditions (temperature, duration, parameters)
Batch identification at every step of the process

Downstream traceability:

Identification of all customers who received each batch
Quantities delivered per batch and per customer
Delivery dates and transport conditions

The Mock Recall Exercise

The regulation does not explicitly require it, but BRC and IFS standards do. It involves simulating a product recall to verify that your traceability system works:

Select a finished product batch at random
Within 4 hours, identify all raw materials used AND all customers supplied
The target: 100% traceability in under 4 hours

Requirement 3: Allergen Management

What the Regulations Say

EU Regulation (EU) No 1169/2011 (INCO) requires the declaration of 14 major allergens on the labeling of all foodstuffs.

The 14 Allergens to Declare

Cereals containing gluten
Crustaceans
Eggs
Fish
Peanuts
Soybeans
Milk (lactose)
Tree nuts
Celery
Mustard
Sesame seeds
Sulphur dioxide and sulphites
Lupin
Molluscs

What You Need to Do

Allergen mapping: For each product, identify the allergens present in the ingredients
Cross-contamination risk analysis: Shared lines, common storage, cleaning between production runs
Operational control: Flow separation, production scheduling, validated cleaning
Compliant labeling: Clear mention of allergens (in bold in the ingredient list)
Staff training: Awareness of allergen-related risks

Common Mistakes

Forgetting hidden allergens in additives and processing aids
Underestimating cross-contamination risks through shared equipment
Systematically using “may contain…” instead of genuinely controlling the risk
Not updating the allergen mapping after a supplier change

Requirement 4: Workplace Safety Specific to the Food Industry

Sector-Specific Risks

The food industry combines a number of specific occupational hazards:

Cold-related risks:

Working in cold rooms (0 to -30 C)
Musculoskeletal disorders amplified by cold
Slip hazards on wet or icy floors

Chemical risks:

Concentrated cleaning and disinfection products
Ammonia (refrigeration systems)
CO2 (fermentation, modified atmosphere packaging)

Biological risks:

Exposure to allergens
Zoonoses (in the meat supply chain)
Legionellosis (cooling towers)

Ergonomic risks:

Repetitive movements on packaging lines
Manual handling (raw materials, finished products)
Awkward postures (working at height on tanks)

Machine-related risks:

High-speed production lines
Cutting, grinding, mixing equipment
Maintenance interventions on running machinery

What You Need to Do

A specific risk assessment document (in France: Document Unique / DUERP) incorporating all of the above risks
A musculoskeletal disorder prevention plan (the leading cause of occupational illness in the sector)
Specific certifications (forklift operation, electrical work, working at height, confined space entry)
Enhanced medical monitoring for positions exposed to cold, noise, and chemical agents

Requirement 5: Retail Standards

Why Are They Essential?

If you supply large-scale retailers, BRC (British Retail Consortium) and IFS (International Featured Standards) are de facto mandatory. They are not regulations, but contractual requirements imposed by distributors.

BRC Global Standard for Food Safety (Version 9)

Key points:

Certification grades: AA, A, B, C, D (below C, no certification)
Annual audit (or every 6 months for the lowest grades)
Strengthened requirements for food safety culture
Food fraud and food defense are mandatory
GFSI certification (international recognition)

IFS Food (Version 8)

Key points:

Percentage-based scoring (minimum 75% for basic certification)
Higher level starting at 95%
10 KO (Knock Out) criteria: non-conformities that automatically result in audit failure
Focus on management responsibility and resource management
GFSI-recognized certification

The 10 IFS Food KO Criteria

These points are eliminatory: a single major non-conformity on any of them means audit failure:

Management commitment
CCP monitoring system
Personnel hygiene
Raw material specifications
Finished product specifications
Foreign body management
Traceability
Internal audits
Withdrawal/recall procedure
Corrective actions

How to Structure Your Food Industry QHSE System

The Integrated Approach

Do not manage food safety, occupational health and safety, and environment in separate systems. Build an integrated system:

A single process map that incorporates HACCP, OHS, and environmental requirements
A common document management system with procedures covering all aspects
An integrated audit program that checks all dimensions
A QHSE dashboard that consolidates indicators across all 3 domains
A single management review that addresses all topics

Key Sector Indicators

Number of product recalls/withdrawals
Microbiological analysis results (% compliant)
Customer complaints related to food safety
BRC/IFS score
Internal HACCP audit completion rate
Mock recall results (response time)
Lost-time injury frequency rate
Reported musculoskeletal disorders

Conclusion

The food industry is a sector where QHSE is not an option but a condition for survival. The obligations are numerous, but they share a common goal: producing safe food, under secure working conditions, while respecting the environment.

The key to success? An integrated system, trained teams, and tools that simplify daily operations rather than adding complexity.

Betterfly supports numerous food industry companies in managing their QHSE system, from HACCP compliance to BRC and IFS standard monitoring. Request a demo to see how our platform adapts to the specificities of your sector.