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Food Safety- An ISO 22000 Auditor’s Perspective on HACCP, Leadership, Regulation and the Global Responsibility for Safe Food

Food safety is unlike many other management-system disciplines. A quality defect may result in rework, rejection or financial loss. A service failure may result in an unhappy customer. But a food-safety failure can affect human health within hours, create long-term consequences after repeated exposure, and in extreme cases cost lives.

That is why food safety cannot be reduced to an FSSAI license, a HACCP certificate, an ISO 22000 certificate or an inspection report.

Food safety is first a duty of care.

And perhaps our mothers understood that principle long before management systems gave it a formal name.

There was no ISO 22000 in our kitchens. There was no HACCP plan, no FDA or FSSAI inspector, and no Critical Control Point monitoring sheet beside the stove. Yet our mothers smelled the milk before serving it, rejected doubtful vegetables, protected cooked food, worried about contamination, and often threw something away simply because they were not convinced it was safe.

They did this because the people who would eat the food mattered to them. They cooked with their heart, care, and love. That, to me, represents management commitment in its purest form.

Modern commercial food businesses obviously cannot operate on affection. A restaurant serving 500 guests or a manufacturer producing five million packages needs science, documented controls, competent people, and verification. But the underlying philosophy should remain exactly the same: “I am responsible for the person who will eat this food.”

ISO 22000 converts that commitment into a systematic discipline. The current ISO 22000:2018 integrates food-safety management with HACCP principles, prerequisite programmes, communication and systematic control of hazards throughout the food chain.

HACCP asks us to understand what can go wrong, identify significant hazards and establish controls before somebody is harmed. Prerequisite programmes create the hygienic environment within which food is produced. Identification and traceability allow us to know what material came from where, what happened to it and where the finished product went.

Traceability is therefore not paperwork.

When a slaughterhouse mark identifies meat, when a batch number identifies a processed product, when an expiry date communicates validated shelf life or when a restaurant retains supplier information, each represents part of a chain of accountability.

Recent events demonstrate why this matters.

In September 2026, authorities in Navi Mumbai uncovered an alleged operation in which expired or near-expiry branded food products were reportedly being relabelled with altered expiry dates and nutritional information for export. Products carrying major international brands were found, although the manufacturers themselves were not accused of participating in the operation. The issue quickly crossed India's borders, with Canadian authorities examining whether affected products could have entered their market.

For an FSMS auditor, the lesson is profound.

Food safety does not end at the factory gate.

Warehousing, transportation, labelling, distributors, intermediaries, exporters and retailers are all part of the food chain. A breakdown in identification or traceability can become not merely a company problem but a national reputation problem.

The same principle appeared dramatically in Indonesia in September 2026, when more than 1,700 students and teachers became ill within only three days in incidents linked with the country's large free-school-meal programme. In one outbreak, improperly stored food and delays between cooking and serving were among the reported concerns.

The programme itself had a valuable social objective.

But good intention cannot compensate for failed operational control.

Time, temperature, storage, transportation, hygiene, competence and verification are not bureaucratic requirements. They protect people.

What Kuwait Taught Me About Governance

Having lived and worked in Kuwait for many years, I have seen another important side of food-safety management: credible regulatory deterrence.

In Kuwait, even the small neighborhood grocery shop—the familiar bakala—operates within a regulatory environment where food validity, hygiene, licensing, and consumer requirements matter. My own experience over the years was that businesses understood that violations could have serious operational consequences, including closure.

Food handlers are expected to meet health requirements. Kuwait's Public Authority for Food and Nutrition, PAFN, continues to take enforcement action where people handle food without required health certificates. In April 2026, PAFN reported closing an establishment where violations included food being handled by workers without the required health certification.

PAFN inspections in 2026 also resulted in closures for spoiled food, adulterated food, hygiene violations, and even thawing frozen meat for sale as fresh.

During my years there, I also saw how meat inspection, storage, and official markings contributed to consumer confidence. A regulatory stamp on meat is not simply ink.

It represents identity, inspection status, traceability and accountability.

I also remember a small bakala that, as I recall, remained closed for an extended period after expired yoghurt and other expired products were discovered. What struck me was that this appeared less like an attempt deliberately to harm someone and more like a serious failure of stock control. Nevertheless, the business paid a very high price.

That experience created an important distinction in my mind.

Every food-safety violation matters, but every violation is not morally the same.

A small operator who fails because of inadequate knowledge, poor FEFO stock rotation, weak training or ineffective supervision remains accountable. Corrective action is required, and regulatory action may be justified.

But knowingly changing an expiry date, hiding contamination, falsifying records or deliberately releasing unsafe food because destroying it would reduce profit represents something fundamentally different.

One is failure of the management system.

The other may represent wilful disregard for consumer safety.

Where deliberate conduct satisfies the legal requirements of a criminal offence, it should be dealt with accordingly by the competent authorities. An auditor's job is not to pronounce somebody guilty of a crime. The auditor's responsibility is to identify objective evidence, recognise the seriousness of deliberate falsification or bypassing of controls, and ensure that it is not treated merely as another checkbox nonconformity.

Profit is essential for business.

Profit obtained by knowingly compromising food safety is not.

Compliance Must Become Conscience

This brings us to perhaps the most important question for top management.

What happens when food safety conflicts with profit?

Will management hold a shipment worth millions because laboratory results are uncertain?

Can a Quality Manager stop production without fear?

Will a restaurant discard expensive food when temperature control has been lost?

Will management initiate a recall voluntarily before a regulator orders it?

Those moments demonstrate leadership far more convincingly than a signed food-safety policy.

A Food Safety Management System therefore requires both compliance obligation and conscience.

Law provides the minimum boundary. Conscience determines what management does when nobody is looking.

And strategy determines whether the organisation recognises food safety not as a cost, but as an asset.

Safe food protects market access, export reputation, business continuity, brand value and customer confidence.

A regulatory fine may hurt once.

Loss of trust can damage a brand for years.

No Country Should Develop Food-Safety Systems in Isolation

Food is now global.

Ingredients may come from one country, be processed in another, packaged in a third and consumed thousands of kilometres away.

A food-safety weakness in Mumbai can become a concern in Canada within days. A contaminated ingredient produced in one country may trigger recalls across several continents.

Food-safety governance can therefore no longer develop within national silos.

Countries can learn from best practices in Middle East Asia, from Europe, and from the United States. Emerging economies can learn from one another.  And mature regulatory systems can equally learn from innovations elsewhere.

The objective should not be to declare one country's system superior. It should be to benchmark internationally, identify what works, and adapt good practices to local conditions.

ISO has already given the world a remarkable common platform.

ISO 22000 creates internationally understandable food-safety management principles applicable across the food chain. HACCP gives us a common hazard-control language. Related conformity-assessment standards provide frameworks for competent certification.

This common language is especially valuable in a globalized food economy.

Certification Bodies Must Play a Greater Role

Governments cannot inspect every restaurant, processor, warehouse and retailer continuously.

As far as I know , FSSAI's third-party food-safety auditing framework allows recognised independent auditing agencies to assess Food Business Operators, with satisfactory audits potentially reducing the frequency of routine regulatory inspections while government sampling and oversight continue.

This model should become stronger in a large country like India with her 140 Cr people.

Competent certification and auditing bodies can act as force multipliers for food safety, but only if their own credibility is beyond question. A certificate must never become a commodity.

Auditors must be technically competent, sector competent and impartial. Their performance should be reviewed. Witnessed audits, continuing professional development, complaints, audit-report quality and periodic competence reassessment should form part of the system.

And auditors themselves must know that their work may be independently checked.

The principle should be simple:

The food provider is accountable for safe food. The auditor is accountable for a competent audit. The certification or auditing body is accountable for its auditor. The regulator remains accountable for oversight and enforcement.

That creates checks and balances without expecting the regulator physically to be everywhere.

Trust on the Plate

This entire philosophy connects with a chapter in my book The Soulful Organization called “Trust on the Plate.”

In the book's role-model boutique hotel, the guest sitting at a restaurant table does something extraordinary without thinking about it.

The guest accepts the plate. The guest has not inspected the kitchen. The guest has not checked the chef's health status. The guest does not know the supplier. The guest has not examined refrigeration records. The guest does not know whether allergens were properly controlled. The guest has not checked the meat's traceability.

The guest simply takes the first bite. That means the plate carries much more than food.It carries trust.

ISO 22000 provides the management system. HACCP provides hazard control. Identification and traceability provide accountability. Law provides compliance obligations. Regulators provide governance. Certification bodies and auditors provide independent assurance.

But the organisation must demonstrate conscience and commitment.

Perhaps the future of food safety lies in combining two seemingly different worlds: the care of a mother's kitchen and the discipline of a world-class Food Safety Management System.

The mother's kitchen says: “I will protect you because I care about you.”

The management system adds: “And I will build controls so that your safety does not depend on one person's memory or goodwill.”

And good governance adds: “If that system is deliberately violated, accountability will follow.”

That is the food-safety culture we should aspire to create across borders. Because ultimately food safety is not merely about passing an audit. It is about being worthy of the extraordinary trust a consumer places in us every time they accept a plate of food.

Your health must never knowingly be traded for our profit.

That is duty of care. That is management commitment. That is food safety as strategy. And that is Trust on the Plate.

— Madhusudan Ray