A Model of Compliance for the Self-Regulation of an Industry: The Case of a New International Food-Packaging Hygiene Model

By Dr. Liz Wilks

Ensuring proper hygiene has always been at the forefront of the food-packaging industry that includes manufacturers and retailers.

In a comprehensive abstract, Dr. Liz Wilks shares timeless insights from the results of revolutionary research that not only reviews how the UK food-packaging industry introduced a voluntary code of practice for packaging hygiene, but also developed guiding principles for companies to adopt. Dr. Wilks examines a multitude of topics that include a literature review of the food and packaging industry and practitioner insights that include survey data findings, the perceived benefit of implementing a global packaging standard, and the potential drivers and/or barriers to adoption. While providing a glimpse into how a group of key stakeholders came together in order to develop and implement a common UK food hygiene standard, she tracks one hundred companies over a five-year period to help guide other industries or companies to create their own guidelines and establish key principles for models of compliance.

A Model of Compliance for the Self-Regulation of an Industry combines careful research with case studies and other valuable information to assist sectors or companies in the development and implementation of a new industry standard.

• Language: English
• Publisher: AuthorHouse UK
• Release date: Sep 14, 2022
• ISBN: 9781665596190

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© 2022 Dr. Liz Wilks. All rights reserved.

No part of this book may be reproduced, stored in a retrieval system, or

transmitted by any means without the written permission of the author.

Published by AuthorHouse  09/13/2022

ISBN: 978-1-6655-9620-6 (sc)

ISBN: 978-1-6655-9618-3 (hc)

ISBN: 978-1-6655-9619-0 (e)

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Abstract

This research is the first of its kind in not only reviewing how the UK food-packaging industry introduced a voluntary code of practice for packaging hygiene but also in developing a set of guiding principles for companies to adopt. The insights gained from this research remain valid still today for an industry and companies in developing and implementing any new standard.

The first universal global food-packaging hygiene standard was launched together with the Institute of Packaging (the UK Packaging Association) in 2001 (BRC/IOP, 2001).

This research covers a summary of the related literature as well as the development of the standard itself. Moreover, primary research through surveys and interviews was carried out alongside the key principles for a model of compliance for companies seeking to adopt this standard. This was achieved based on two specific models—Cameron & Quinn (2006) and Kotter (2005)—to determine the readiness and evolution of the culture of selected paper and board companies in implementing this standard.

This research brings together the food and packaging industry in demonstrating how collaboration throughout the supply chain can provide an effective system for self-regulation, as well as

• provide guidelines for other sectors/industries developing self-regulatory standards. These will aid other sectors also having to develop voluntary standards to comply with government regulations.

• establish key principles for a model of compliance for packaging companies based on the BRC/IOP Global Packaging Standard. These principles will support the required growth of the global packaging standard worldwide.

Acknowledgements

I would like to express my appreciation to all of those companies that have participated in this research for their valuable contributions and their open and constructive comments, which remain valid still today for other sectors implementing new standards within their businesses.

Special thanks are due to the following companies and individuals for providing particular information relevant to this research:

• My original tutor, Prof. Gary Coleman from the Cardiff School of Health Sciences, University of Wales Institute Cardiff

• Dr Christopher Suter, the Royal Society for Public Health (RSPH)

• Alan Campbell, Campden and Chorleywood Food Research Association

• John Swift, chair of the CITPA product safety committee

• Jori Ringman, Confederation of the European Paper Industry

• Dr Gordon Stewart, the Institute of Packaging (IOP;later IOM3)

• Terry Robins, Robins Packaging Consultants

• Kevin Swoffer, Safeways & the British Retail Consortium

• David Brackston, the British Retail Consortium

• Henry Emblem, Environmental Packaging Solution

Finally, I cannot forget my friends and family, especially my partner, for the patience and support they have given me during this time—and now my children.

Contents

List of Figures

List of Tables

List of Abbreviations Used

1.     Literature Review of the Food and Packaging Industry

• The Food-Packaging Industry

– The UK Retail Industry

• Due Diligence

• Food Safety Legislation and Codes of Practice

– Food Safety Legislation

– Food Safety Codes of Practice

– The Consumer Goods Forum (CGF) and the Global Food Safety Initiative (GFSI)

• Food Packaging

– European Food-Contact Regulation

– Good Manufacturing Practice

– UK Food and UK Food-Packaging Safety

• Paper and Board Packaging Industry Guidance

• The Development of a Common Food-Packaging Hygiene Standard

• Overview of the Requirements of the Global Standard for Packaging and Packaging Materials, Version 1

– Requirements of the Global Packaging Standard

– The BRC/IOP Food Packaging Hygiene Standard—Review of Version 1 to Version 4

– Global Reach

– Extension to Include Non-Food Packaging

– Clauses Amendments—the Global Packaging Standard Version 4

– Fundamental Clauses and Audit Grading—Global Packaging Standard Version 4

– The Global Standard for Packaging and Packaging Materials: Versions 1 through 4—Hygiene Risk Assessment

– Implementation

– Self-Regulation of the UK Food-Packaging Industry

– Competing Standards

– Existing Packaging Standards and Training in the UK 2002

• Organisational Culture and the Adoption of External Standards

– Organisational Culture

– The Competing Values Framework

– Reliability and Validity of the OCAI Tool

• Does a Company’s Success Depend on Its Organisational Culture?

– The Competing Values Framework and TQM

• Change Management

– Change Models

– Kotter’s Model of Change

– Kotter in Practice

• Conclusions

• Recommendations

2.     Methodology

• Research Timeline and Limitations

• Survey

– Final Survey 2009—Aims and Objectives

– Survey Design and Covering Email

– Survey Sample Size

– Survey 2009—Limitations

• Audit Reports

– Audit Report—Aims and Objectives

– Profile of Packaging Companies Reviewed against the RSH Audit Reports 2009 and 2010

• Case Studies

– Case Study Objectives

– Profile of the Case Studies

– Case Study Approach

– How Important Is the Cultural Profile of a Company in Implementing the Global Packaging Standard?

– What Is the Process Taken for an Organisation to Implement the Global Packaging Standard?

– Case Study Limitations

3.     Guidance for Developing and Implementing an Industry Standard

• Creation of the Principles

• Content and Mechanism

• Implementation

4.     Survey 2009

• Survey Data Findings

• Respondents’ Packaging Product Type

– Sectors Supplied

– Management Systems

– Companies without the BRC/IOP Packaging Standard

– Companies with the BRC/IOP Standard

• The Global BRC/IOP Packaging Standard Version 2 vs. Version 3

– Emphasis on Quality

– Extension to Cover Non-Food Packaging

– Reduction of Audit Frequency

– More Detailed Guidance Notes

• Areas of Perceived Benefit in Implementing the Global Packaging Standard

– Market Benefit

– Internal Working Practices

– Hygiene and Quality Assurance

– Internal Costs and Resources

– Due Diligence

– Training

• Drivers and Barriers to Adoption

– Drivers

– Barriers

5.     RSH Global Packaging Audit Reports 2009/2010

• Comparison of Companies Audited in Both 2009 and 2010

• Detailed Overview of RSH Audit Reports in 2009 and 2010

– Senior Management Commitment

– Hazard and Risk-Management System

– Technical Management Policy

– Site Standards

– Product and Process Control

– Personnel

6.     Overview of Case Study Companies, Including Initial Survey Results

• Additional Discussion Findings

• Case Studies—Summary of Findings on Organisational Culture

• Overview of the OCAI Model for the Case Studies Combined

– Overview of OCAI Model for Each Case Study

– Overview of Findings: Cultural Congruence

• Case Studies—Summary of Findings in the Process of Implementing the Global Packaging Standard

– Summary of Practical Tools Observed

– Case Study Quotes

– Interviews – Additional Themes Arising

7.     Model of Compliance for Packaging Companies to Adopt the Global Packaging Standard

• Areas 1, 2, and 3: Food-Packaging Hygiene and the Principles of the Global Packaging Standard, Including Its Current and Future Status

• Area 4: Gap Analysis Against the Standard

• Area 5: Where Are We Now and Where Do We Want to Be?

• Area 6: Getting Ready

• Areas 7 and 8: Practical Tools and Training

8.     Overall Conclusions

• The Food and Food-Packaging Industry

• The Development of a Common Food-Packaging Hygiene Standard

• Organisational Culture and the Adoption of External Standards

• UK Market Perception of the Global Food-Packaging Standard

• RSH Audit Report 2009 and 2010

• Case Studies

9.     Recommendations

• The Food and Food-Packaging Industry

• The Development of a Common Food-Packaging Hygiene Standard

– Direct Contribution to the Global Standard Version 1 through 3

– The Effectiveness and Evolution of the Global Packaging Standard Version 3

– Direct Contribution to the Global Standard Version 4

– Guidance for Developing and Implementing an Industry Standard

• RSH Audit Reports 2009 and 2010

• Organisational Culture and the Adoption of External Standards

Glossary

References

List of Figures

Figure 1.1 Overview of EU regulations for food packaging (European Commission, 2009)

Figure 1.2 Alert notifications by hazard category (The European Union, 2010)

Figure 1.3 Example of a non-conformance in pest control (http://www.bbc.co.uk/news/uk-england-oxfordshire-11419498)

Figure 1.4 Paper and board for food contact (CEPI, 2010)

Figure 1.5 Fields of audit for packaging and packaging materials (BRC/IOP, 2008)

Figure 1.6 The number of sites holding the Global Standard for Packaging and Packaging Materials standard in April 2010 (British Retail Consortium, 2010)

Figure 1.7 Organisational cultural assessment instrument (Cameron & Quinn, 2006)

Figure 1.8 Average cultural plot for more than one thousand companies (Cameron & Quinn, 2006)

Figure 1.9 Average cultural profile for manufacturing (Cameron & Quinn, 2006)

Figure 1.10 Average profile for each item on the OCAI (Cameron & Quinn, 2006)

Figure 1.11 The competing values of TQM (Cameron & Quinn, 2006)

Figure 1.12 The eight stages of major change (adapted from Kotter, 1996)

Figure 1.13 Errors common to organisational change efforts and their consequences (Kotter, 1996)

Figure 2.1 No. of sites certified to the global packaging standard (BRC website, January 2009) https://www.brcgs.com/

Figure 2.2 Global packaging standard—product split of companies (BRC website, end of 2009)

Figure 2.3 Risk levels for each Kotter section

Figure 3.1 Guidance model to implementing the global packaging industry standard

Figure 4.1 Respondents’ packaging product type

Figure 4.2 Level of packaging contact with food

Figure 4.3 Industry sector supplied with packaging

Figure 4.4 Percentage of turnover relating to food and drink packaging

Figure 4.5 Percentage of customer audits

Figure 4.6 Timeframe for standard adoption

Figure 4.7 Reasons to adopt the BRC standard

Figure 4.8 Comparison between version 2 and version 3

Figure 4.9 Areas of perceived benefit in implementing the global packaging standard

Figure 4.10 Internal working practices affected

Figure 4.11 Quality and hygiene assurance

Figure 4.12 Perceived benefit of due diligence

Figure 4.13 Advice received

Figure 4.14 Training insight

Figure 4.15 Drivers for adoption

Figure 4.16 Barriers for adoption

Figure 5.1 Major non-conformances identified in 40 audits undertaken in 2009 and 2010 (RSH Global Packaging Audits)

Figure 5.2 Comparison of non-conformances identified in 40 companies in the RSH Global Packaging Audit Reports of 2009 & 2010

Figure 5.3 Section 1 non-conformances by risk level, RSH Audit Reports 2009, Global Packaging Standard V3

Figure 5.4 Section 1 non-conformances by risk level, RSH Audit Reports 2010, Global Packaging Standard V3

Figure 5.5 Section 2 non-conformances by risk level, RSH Audit Reports 2009, Global Packaging Standard V3

Figure 5.6 Section 2 non-conformances by risk level, RSH Audit Reports 2010, Global Packaging Standard V3

Figure 5.7 Section 3 non-conformances by risk level, RSH Audit Reports 2009, Global Packaging Standard V3

Figure 5.8 Section 3 non-conformances by risk level, RSH Audit Reports 2010, Global Packaging Standard V3

Figure 5.9 Section 4 non-conformances by risk level, RSH Audit Reports 2009, Global Packaging Standard V3

Figure 5.10 Section 4 non-conformances by risk level, RSH Audit Reports 2010, Global Packaging Standard V3

Figure 5.11 Section 5 non-conformances by risk level, RSH Audit Reports 2009, Global Packaging Standard V3

Figure 5.12 Section 5 non-conformances by risk level, RSH Audit Reports 2010, Global Packaging Standard V3

Figure 5.13 Section 6 non-conformances by risk level, RSH Audit Reports 2009, Global Packaging Standard V3

Figure 5.14 Section 6 non-conformances by risk level, RSH Audit Reports 2010, Global Packaging Standard V3

Figure 6.1 Average cultural plot for manufacturing

Figure 6.2 OCAI organisational culture overview of six case studies

Figure 6.3 Quality and hygiene competing values

Figure 6.4 Overview of OCAI model for each case study

Figure 6.5 Overview of case studies by OCAI dimension

Figure 6.6 Case studies overview—dominant characteristics

Figure 6.7 Case studies overview—organisational leadership

Figure 6.8 Case studies overview – management of employees

Figure 6.9 Case studies overview—organisational glue

Figure 6.10 Case studies overview—strategic emphasis

Figure 6.11 Case studies overview—criteria for success

Figure 7.1 The principles for a model of compliance for companies adopting the global packaging standard

Figure 8.1 Guidance model to implementing the global packaging industry standard

List of Tables

Table 1.1 Summary of global food safety schemes 2010 (GFSI, 2010)

Table 1.2 Examples of food-packaging materials

Table 1.3 Turnover of the UK food-packaging market by product type (Mintel, 2010)

Table 1.5 Overview of the BRC/IOP food-packaging hygiene standard

Table 1.6 Summary of key changes to the overall format of the Global Standard for Packaging and Packaging Materials from version 1 to version 4

Table 1.7 Review of clauses by risk level and BRC/IOP packaging standards (BRC/IOP, 2001, 2004, 2008)

Table 1.8 Example of the risk assessment evolution of the global packaging standard (jewellery)

Table 1.9 Towards a global packaging standard—evolution of hygiene risk category determination

Table 1.10 Scope of the BRC standards 2010 (www.brcglobalstandards.com)

Table 1.11 Timeline of the evolution of the BRC suite of standards (www.brcglobalstandards.com)

Table 1.12 Type of BRC standard and scope by BRC membership (www.brcglobalstandards.com)

Table 1.13 An overview of existing global food-packaging hygiene standards

Table 1.14 Standards adopted by UK packaging companies in 2002 (DTI, 2002)

Table 1.15 Management—review of statements of intent—comparison of the global packaging standard versions 1–4

Table 1.16 Examples of dimensions of organisational culture criteria by theorist

Table 1.17 Summary of Cameron and Quinn core values with corresponding literature

Table 1.18 An introduction to the global packaging standard, versions 1–4

Table 1.19 Guidance in achieving Kotter’s eight stages (Kotter & Cohen, 2002)

Table 2.1 An overview of original and actual research—the global packaging standard

Table 2.2 Overlay of standard objectives against the survey 2009

Table 2.3 Survey rationale—2009

Table 2.4 Profile of the packaging companies reviewed in the RSH global packaging audit reports reviewed in 2009 and 2010

Table 2.5 Number of packaging companies audited, listed by risk level. (RSH audit reports, Global Packaging Standard Version 3)

Table 2.6 Overview of case studies—site relationships

Table 2.7 Overview of case studies conducted 2009

Table 2.8 Overview of case study objectives, methodology, and rationale

Table 2.9 Example of the organisational change questionnaire carried out in the global packaging case studies 2010

Table 2.10 Example of organisational process questionnaire used for global packaging standard case studies 2010, section 1 only (Kotter, 1996)

Table 3.1 Guidance on how to develop the principles for the creation of an industry standard

Table 3.2 Guidance on how to develop the content and mechanism of an industry standard

Table 3.3 Guidance on how to implement an industry standard

Table 4.1 Survey database target profile

Table 4.2 Survey response summary

Table 4.3 Survey 2009—sample of non-respondents

Table 4.4 Profile of management systems in place

Table 4.5 Awareness of standards in respondents without the BRC/IOP packaging standard

Table 6.1 Case studies—survey 2009 responses overview

Table 6.2 Useful changes to the standard between version 2 and 3

Table 6.3 Company benefits perceived from the global packaging standard (1-5: 5 most important, 1 not important at all)

Table 6.4 Rating the input of the standard in certain areas

Table 6.5 Case studies—head office strategies

Table 6.6 Summary of OCAI dimension by organisational culture over time

Table 6.7 Overview of Kotter results in implementing the global packaging standard

Table 6.8 Eight stages of adoption of the global packaging standard by case study

Table 6.9 Best practices determined from case study research

Table 6.10 Quotes gathered demonstrating the perceptions of the global packaging standard

Table 6.11 Training and experience of quality managers

Table 6.12 Perceived areas of investment to comply with the global packaging standard

Table 7.1 Draft contents of the principles of a model of compliance to the global packaging standard

Table 8.1 Overlay of the Global Packaging Standard Version 3 objectives and amendments to version 4, against the contribution area of this research

List of Abbreviations Used

1   Literature Review of the Food and Packaging Industry

In order to understand the drive towards self-regulation of the food-packaging industry, it is important to review the context of the supply chain within which the packaging manufacturers have been operating. With the food sector dominated by retailers representing a substantial market for packaging manufacturers, there has been an increasing pressure to meet the changing expectations of this sector. This required a shift in thinking from the quality of the packaging in isolation to the varied applications of packaging in a food environment.

The Food-Packaging Industry

The global packaging industry had an estimated turnover of $563 billion in 2009 (PIRA & WPO, 2009), and market statistics indicated