Even the best-run food service or retail businesses can be blindsided until they have a food safety incident. This post explains why ticking boxes isn’t enough—and how the Swiss Cheese Model reveals hidden weaknesses before they add up to disaster.
It will help you visualise and understand:
Why food safety incidents happen despite good intentions
How small food safety compliance gaps — holes in your food safety defences — can add up to a catastrophe
And, most importantly, practical steps to find and fix those holes (the hidden risks) in your food safety operations.
Table of Contents
The Cost of Poor Food Safety Compliance
Despite decades of innovation and stricter rules, food safety compliance remains a real challenge for UK food businesses. Each year, approximately 2.4 million people in the UK are affected by foodborne illness (such as E.coli infection), with the cost to the NHS and the wider economy estimated at £10.4 billion per year (Food Standards Agency, 2024). These aren’t just numbers — they reflect real harm to people, lost business, and pressure on public health services.
Understanding what food safety is — and why it matters — is the first step to making real improvements. We’ve written about that here: What is Food Safety?
Why Incidents Happen Even In Compliant Businesses
The reality is, most food safety incidents don’t happen because of one major mistake or a single reckless act. They’re usually the result of several small weaknesses in different parts of your operation — the sorts of gaps that are easy to overlook until the damage is done. This is why even “compliant” businesses sometimes get caught out with a poor inspection or a customer complaint.
The Swiss Cheese Model is a powerful way to understand this. Each layer of defence in your food safety plan (or HACCP Plan) has its own gaps. From supplier checks and cleaning routines to temperature control and staff training. When those gaps in different layers line up, hazards can slip through, leading to disastrous consequences for your business and your customers.
Finding The Root Cause Of Food Safety Non-Compliance
It’s easy to blame individuals — usually the food handler on the front line — but this approach misses the bigger picture. Many of the root causes are actually higher up the chain: management decisions, inadequate equipment, poorly designed workflows, or gaps in training and leadership. Building a strong food safety culture, with good leadership, regular training, and a willingness to learn from mistakes, is what really makes the difference.
Blame Culture vs Just Culture in Food Safety Compliance
In food businesses, “blame culture” and “just culture” are two ends of a continuum. At one extreme, a blame culture means mistakes are met with finger-pointing and punishment. Staff become afraid to report problems, and learning is replaced with fear. At the other end, a just culture creates trust, open communication, and shared responsibility. Staff are encouraged to speak up about risks, near-misses, and errors — so that everyone can learn and improve the system.
Most businesses fall somewhere in between, and it takes time and consistent effort to shift towards a just culture. It won’t happen overnight. But every step you take — from listening to staff feedback, to learning from mistakes instead of hiding them — helps build a safer, more resilient food safety compliance system.
Swiss Cheese Model To Understand Food Safety Compliance
The Swiss Cheese Model is a way to explain how food safety incidents occur. Imagine your defences as slices of Swiss cheese, each with holes in different places. Each slice is a barrier — like staff training, cleaning routines, supplier checks, or temperature controls. On their own, each barrier has weaknesses (the holes). But it’s only when the holes in several slices line up that a hazard can get all the way through and cause an incident. The more layers you have, and the fewer holes, the safer your business will be.
Every food business relies on these layers of defence to keep food safe. No single layer is perfect; but when you line up enough slices, the weaknesses are less likely to all align, and hazards are much less likely to reach your customer.
HACCP & The Swiss Cheese Model
There is a similar logic behind HACCP (Hazard Analysis and Critical Control Points) and food safety management. HACCP requires that you to break your process into discrete steps, identify where things can go wrong, and set up controls and monitoring at key stages. Think of each stage of your HACCP as another slice in your food safety cheese — if you keep enough layers strong, you block most risks before they become a real problem. Even a HACCP review is a safety defence – yet small most businesses are unaware of when a HACCP should be checked.
Food safety gets compromised by ignorance, mistakes, and staff simply not following processes. These are unintentional outcomes — but they’re often predictable and preventable if you know where to look.
Subtle, regular self-checks—like seeing your business through an EHO’s eyes—can help you spot compliance gaps early. This is where using an EHO inspection checklist can help.
Where Are The Holes in Your Cheese?
Not all food safety compliance gaps are obvious. Some holes in your defences are active failures— errors that happen in the moment, such as staff forgetting a check or skipping a step. Others are latent conditions — hidden system-level issues, like outdated equipment, unclear procedures, incomplete training, or poor layout, that might go unnoticed until they combine with an active failure.
When each hole aligns in multiple slices, it allows hazards to pass through the defences and cause harm.(Adapted from NHS Wales Swiss Cheese Model Toolkit).
Understanding both types of gaps helps you spot weaknesses before they combine to cause an incident (See Figure 1 below).
Seven Layers of Food Safety Compliance Defences
A recent study* adapted the Swiss Cheese Model for food safety and identified seven key layers of defence (See Figure 1):
Facilities (layout, equipment, storage)
Training (regular, role-specific, practical)
Suppliers (ingredient and water checks)
Environmental cleaning (schedules and verification)
Personal & food hygiene (handwashing, PPE, cross-contamination control)
Temperature control (cooking, chilling, hot-holding, records)
Systems & records (audits, management review, HACCP plans)
No single layer will catch everything, but together they form a much stronger defence. This model helps shift the conversation away from blaming individuals, and towards strengthening your food system as a whole.
*Source: da Cunha. et al. (2022) – Swiss Cheese Model apple to food safety in food services.
Figure 1: Seven Layers of Defence in a Food Business
How Defences Fail: Simple, Real-World Example
A real-world note:
It’s not unusual to walk into a commercial kitchen and see staff working around proper handwashing or using the wrong chemical to disinfect food-contact surfaces—even after formal training. These aren’t “bad apples,” but symptoms of compliance gaps in the food system management system. It’s the root cause that needs attention.
No single failure causes most food-safety incidents. It’s usually a chain of small gaps. And this is where mentoring can help. It gives you the ongoing support to tackle weak spots before they turn into failures. Find out about food safety compliance mentoring.
Examples of Food Safety Compliance Gaps
In food safety, examples of compliance gaps can include:
- Facilities: The only hand-wash basin is blocked by boxes, so staff skip handwashing when it’s busy.
- Training: A new member of staff doesn’t know the correct cleaning routine and uses the wrong chemical on food-contact surfaces.
- Suppliers: A delivery of chilled chicken arrives above 8°C, but nobody checks or rejects it — the meat goes straight into the fridge.
- Environmental cleaning: The cleaning schedule is out of date, and no one has checked behind the fridge for weeks — allowing a pest issue to develop.
- Personal & food hygiene: Staff use the same gloves to handle raw meat and ready-to-eat food, thinking the gloves themselves are “clean.”
- Temperature control: Cooked rice is left to cool in a deep pan, staying at a dangerous temperature for hours — giving bacteria time to multiply.
- Systems & records: Temperature checks are only written down once a week, from memory, rather than being checked in real time.
Latent conditions can include:
🔷 Poor equipment maintenance or lack of equipment
🔷 Inadequate staff training and induction
🔷 Unclear or outdated procedures
🔷 Understaffing and high workload
🔷 Weak leadership or lack of accountability
🔷 Staff failing to speak up about their concerns or report issues
When two or three of these conditions happen together, they can easily line up and cause a serious incident — which is exactly what the Swiss Cheese Model helps us to visualise.
Creating a Positive Food Safety Culture
Spotting gaps is the first step. But real improvement comes from closing them before they turn into something serious. Most food businesses already have some layers in place — but it’s often the small gaps, or the layers that are assumed to be “fine,” where problems start.
A positive food safety culture means staff feel able to speak up about risks without fear of blame or punishment. Encourage staff to report near-misses, suggest improvements, and raise concerns early. This “just culture” is a strong defence in itself — and helps you find and fix holes before they become incidents.
What To Do Next?
If you want help finding the weak spots in your business, or just want a fresh pair of eyes on your current food safety system, book a Clear Path to Compliance call.
We’ll discuss your current defences objectively, map out where your risks really are (not where you think they are) and develop an action plan to put things right.
Don’t let small holes turn into a giant headache.
Get in touch by email: [email protected] Or call: 02920 026 566
