Food safety compliance is supposed to keep your business—and your customers—safe. But even with robust policies and detailed checklists, unsafe practices can still happen. Decades of behavioural science research—and recent evidence from the Food Standards Agency—show that education and training alone rarely deliver lasting change. Closing these gaps means tackling the many behavioural factors at play: people’s beliefs, habits, motivations and work environment.
In this post, we’ll explore why food safety compliance can fail—and how behavioural science can make the difference. Let’s start by looking at why gaps persist—before moving onto a more effective, longer-lasting approach to changing behaviour.
Table of Contents
Why Gaps Persist In Food Safety Compliance
Many businesses think that if the paperwork is in order, everything is covered. But it is never that simple.
🔹 Human error and shortcuts: People get busy, distracted, or slip into bad habits—especially when safe cues are missing.
🔹 Workarounds: If a system isn’t practical or doesn’t feel relevant, staff will find their own way. These shortcuts get shared and normalised.
🔹 Pressure and incentives: When the focus is on speed or output, standards slip—especially if leaders put production ahead of food safety.
🔹 Culture and communication: If staff don’t feel safe to raise concerns, problems go unsaid—often out of fear or because feedback leads nowhere. Who delivers safety messages matters too.
🔹 Role models and reinforcement: Poor role models, especially among senior staff, set the wrong tone. But when leaders champion good habits (like handwashing) and back this up with regular reminders and feedback, it helps reset safe practice.
🔹 Environment and resources: If staff can’t access the right knife or chopping board, they’ll improvise. When the basics aren’t in place, even good systems break down.
🔹 Beliefs, biases and emotions: People trust what they can see—cleaning only when there’s visible dirt, or reacting to disgust rather than following procedure. Invisible risks, like germs, often get missed or underestimated.
Even with the best intentions, the same risks can appear time and again—noncompliance can slip through the cracks.
The Swiss Cheese Model: Why Food Safety Compliance Leaves Holes
The Swiss Cheese Model by James Reason helps us visualise how food safety incidents and near misses happen when gaps in defences line up. Each slice of cheese represents a layer of control measures. These include food safety policies, food hygiene training, cleaning schedules, and supervision.
But every slice has holes that represent non-compliance. These holes or gaps in practice are constantly opening and closing. When the holes align, hazards can slip through, causing harm.
In other words: Even the best-written policies have blind spots. Training only works if it actually changes behaviour—yet sometimes the real barriers aren’t about knowledge at all.
Want a deeper understanding? Read our post on the Swiss Cheese Model for more on exposing gaps in your food safety system.
As an example, these holes can line up even more easily in high-pressure environments—like dark kitchens—where space, time, and staffing are often stretched thin. In these fast-turnover, delivery-only settings, behavioural change is essential to stop hazards slipping through.
Want to see how this plays out in practice? Read our post on The Regulation of Dark Kitchen Food Safety for practical insights on closing gaps in this unique sector.
Closing food safety compliance gaps is vital. But before we can close these gaps we need to understand why and how they develop in the first place.
Introducing Behavioural Science in Food Safety
Behavioural science gives us the tools to understand why people act the way they do at work—and, crucially, what needs to change for safer habits to stick. One of the most respected models in this field is Michie’s Framework (also known as the COM-B framework), developed by Professor Susan Michie and colleagues. COM-B stands for Capability, Opportunity, and Motivation—the three key ingredients that drive behaviour.
When it comes to food safety, this means asking questions:
🔹Do people have the right skills and knowledge? (Capability)
🔹Do they have the chance to do things safely? (Opportunity)
🔹Are they motivated to make safety a priority, even under pressure—and, crucially, when no one is watching? (Motivation)
By diagnosing these factors, you can target your efforts to behaviours that matter most—and start to close persistent compliance gaps.
With this framework in mind, here’s a practical set of questions to help you identify holes in your food safety defences.
Behavioural Science in Practice: The Diagnostic
How behavioural science closes food safety gaps: ask these practical questions about staff capability, motivation, and opportunity to make safe practice stick every day.
Use this diagnostic:
- Capability:
- Do staff have the right food safety skills for each task?
- Is training bite-sized, hands-on and practical, ongoing?
- Are staff confident to ask for help or raise concerns?
- Motivation:
- Are safe habits (ways of working) recognised and rewarded?
- Do staff believe food safety matters with what they do?
- What drives people to cut corners—or do things right?
- Opportunity:
- Is there time and the right tools for safe food practice?
- Does the environment make safe behaviour easy or hard?
- Is it normal for staff to ask questions about food safety?
Once you know where the gaps are, behavioural science offers practical ways to close them.
How Behavioural Science Closes Food Safety Gaps
Behavioural science gives us the tools to understand and influence the determinants of behaviour.
Here’s how you can use behavioural science to close food safety compliance gaps:
- Habits and cues: Use visible prompts (nudges) and simple reminders so that safe practice becomes second nature—not just a rule to remember. So for example, use posters and colour coding to make cross-contamination risks visible. (For more on that, read our article about breaking the chain of infection).
- Positive reinforcement: Use reminders and feedback, recognition and rewards to encourage safe behaviour. Don’t just tell staff what they have done wrong. Explain why and use anecdotes and stories to bring relevance to life.
- Immediate feedback: Use real-time coaching and constructive feedback to help staff understand why something is wrong. Correct non-compliance quickly and repeatedly, so that desired behaviours replace undesired habits.
- Address workarounds: Find out where short cuts exist. Instead of punishing workarounds so they become hidden, ask why they happen. Get staff talking about invisible practices to make them visible. Then redesign systems to make it easier for staff to do the right thing. Don’t expect compliance if managers and supervisors are not walking the talk.
- Culture and psychological safety: When people feel seen, heard, and safe to speak up, they give more effort and pull together to keep standards high. Encourage a sense of belonging and positive role models. Use emotions such as appreciation, acceptance and pride to get staff pulling together to elevate business performance.
The result? Fewer gaps, fewer surprises, and a food safety culture to help you achieve your business goals.
So, how do you put this into practice? Here’s where to start:
Practical Steps to Make Compliance Stick
Using Michie’s Framework to close food safety compliance gaps
- Map your food safety processes using the Swiss cheese model: Find out where your HACCP defences (your cheese slices) may be thin, weak, or worked around. These are the holes in your defences. Think about where these holes have already aligned. Look at customer complaints and food safety incidences. Analyse problems identified in third party audits and your EHO report. Look for repeating patterns of non-compliance and outstanding corrective actions in your monitoring checks. Your monthly Management Review is an opportunity for you to identify compliance gaps.
- Observe daily routines: Be a fly on the wall and find out what really happens – look at repeating failures in your HACCP monitoring checklists (where corrective actions are documented). Look for discrepancies between what staff say they do and what they actually do. Talk to staff to uncover what is really going on to make the invisible visible. If you feel lost on where to start – read our post about using an EHO inspection checklist.
- Talk to your team about shortcuts and workarounds: Ask why they exist, rather than who’s to blame. Keep asking why to find the root cause of deviations from safe practice and procedures. Perhaps they don’t see some procedures are relevant? Perhaps the system is setting them up to fail. Get staff onboard and working together to close safety gaps.
- Use behavioural science techniques: Prompts, nudges, feedback, recognition, and peer learning—to create new habits that stick. Make the changes fun – get staff thinking about food safety together.
- Keep improving: Monitor, adapt, and celebrate small steps that indicate quick progress wins, not just pass or fail.
Dr Julie Rasmussen
❓Frequently Asked Questions (FAQs)
Still have questions? Here are some of the things businesses often ask.
What is the Swiss cheese model in food safety?
It’s a way to show how and where gaps (weaknesses or failures) in multiple layers of safety controls can line up to let hazards through. Closing those gaps takes more than paperwork, a compliant structure, or food safety training—it needs a food safety culture where safe habits are embedded and corrected as the norm.
How can behavioural science improve food safety compliance?
Behavioural science helps us diagnose why gaps develop. We can use it to build safe habits, reinforce good practice, and make food safety normal—not just a set of rules to be applied.
Is behavioural science just for big food businesses?
No—these principles work in any food business, from small cafés, restaurants, hotels, care homes, and schools to supermarket chains.
Your Next Move?
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Learn more about our Food Safety Compliance Mentoring service.
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