Food Fraud Advisors

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Acronym Decoder

BRC and BRCGS: British Retail Consortium (superseded) and British Retail Consortium Global Standards.  The British Retail Consortium (BRC) is a group of British companies that published guidance and standards for food manufacturers, including a food safety standard that was also commonly referred to as BRC.  The standards owner is now known as BRCGS.

CoOL or COOL: Country of Origin Labelling.

EMA: Economically motivated adulteration or substitution. EMA is a subset of food fraud and is defined as the fraudulent, intentional substitution or addition of a substance, or dilution of a substance for the purposes of economic gain.  Non-EMA food fraud includes black market importation and trading of food and alcoholic beverages for the purposes of avoiding duty and taxes.

DEFRA: The Department for Environment, Food and Rural Affairs, a United Kingdom government department responsible for food production and standards as well as environmental and agricultural responsibilities.

FDA:  Food and Drugs Administration.  The FDA is the name of a regulatory body in a number of countries, including USA, Philippines and India.

FSA: Food Standards Agency, a United Kingdom government regulatory body.

FSMA: Sometimes pronounced ‘Fizzmah’.  Stands for Food Safety Modernisation Act (United States of America).

FSSC 22000: A food safety management system standard similar to ISO 22000 but with extra requirements incorporated to meet the requirements of a GFSI standard.

FSVP:  Standards for Foreign Supplier Verification Program.  It is part of the requirements of the US Food Safety Modernisation Act and applies to US importers of food and their suppliers.

GFSI: Global Food Safety Initiative.  The GFSI is a group of food companies whose mission is to harmonize, strengthen, and improve food safety management systems around the globe.  The GFSI provides direction and approval to organizations that create food safety management systems, so a GFSI-approved food safety standard is one that represents international best practice.  Well known GFSI standards include BRC, FSSC 22000 and SQF.

GMO: Genetically Modified Organism.

HACCP:  HACCP is a set of principles designed to control and prevent food safety risks during food production.  The principles of HACCP are codified (written down) by the Food and Agriculture Organization of the United Nations (FAO).  Download the 2020 revision of the HACCP Code here.

HARCP: Hazard Analysis Risk-based Preventive Control.  HARCP = food safety as legislated by the United States.  This acronymn being used by some in the USA when talking about the requirements of the recently enacted Food Safety Modernisation Act (FSMA) in that country.  HARCP is claimed to differ from HACCP by including requirements for preventive controls.  Read more about HARCP here.

IA: Intentional Adulteration.  Within the US Food Safety Modernisation Act (FSMA), Intentional Adulteration specifically refers to malicious adulteration that is intended to cause widescale harm.  Learn more about intentional adulteration here.

ISO 22000:  ISO is the International Organization for Standardization.  They have thousands of standards across many different businesses, products and systems.  ISO 22000 is the ISO standard for food safety management systems.  Like other major food safety management systems it is based on the principles of HACCP.

NSF:  a pseudo-government organization head-quartered in the United States that is active in the area of food safety and sanitation.

PCQI:  Preventive Controls Qualified Individual.  The name of the role held by an expert food safety professional who meets certain requirements under the (US) Food Safety Modernisation Act.

SQF:  Safe Quality Food Institute.  The Safe Quality Food Institute owns and publishes a group of food safety standards also known as SQF that is a GFSI – approved standard.

USP: United States Pharmacopeial Convention.  USP is a non-profit organization that creates identity and purity standards for food ingredients and food chemicals, as well as for medical drugs.

TACCP: Threat Assessment Critical Control Point.  TACCP = prevention of malicious threats to food.

VACCP: Vulnerability Assessment Critical Control Point.  VACCP = food fraud prevention.  Learn more about TACCP and VACCP here.

Learn about Vulnerability Assessments, what they are and how to do them, here.

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FSSC 22000 and IFS Food Standards (Updated)

FSSC 22000 and IFS Food Standard have been updated recently, with FSSC 22000 Version 6 to be enforced from April 2024, and IFS Food Version 8 enforced from October 2023.

You can get (free) copies of the newly updated standards from the standards owners:

FSSC 22000 Version 6

IFS Food Version 8

Changes to Food Fraud Requirements in the Standards

FSSC 22000

There have been minor changes to the food fraud requirements in FSSC 22000 for Version 6.  The clause numbers remain the same: 2.5.4.1 and 2.5.4.2.

  • The biggest change is that this standard now explicitly requires that the methodology for the vulnerability assessment process be defined.
  • Version 6 does not make any mention of the “documented procedure” for vulnerability assessments that was part of the previous version (Version 5.1).
  • The definition for food fraud in FSSC 22000 (Appendix 1) has had “feed” added to its scope.
  • For businesses within the FSSC category FII (food brokering, trading and e-commerce), they must also ensure that their suppliers have a food fraud mitigation plan.

 

Food Fraud Requirements of FSSC 22000, Version 6 (with new wording in blue)

2.5.4 Food Fraud Mitigation

2.5.4.1 Vulnerability Assessment

The organization shall:

    • Conduct a food fraud vulnerability assessment based on a defined methodology, to identify and assess potential vulnerabilities; and
    • Develop and implement appropriate mitigation measures for significant vulnerabilities.

The assessment shall cover the processes and products within the scope of the Organization.

2.5.4.2 Plan

    1. a) The organization shall have a documented food fraud mitigation plan, based on the output
      of the vulnerability assessment      , specifying the mitigation measures and verification procedures. 

      b) The food fraud mitigation plan shall be implemented and supported by the organization’s
      FSMS.
      c) The plan shall comply with the applicable legislation, cover the processes and products
      within the scope of the organization and be kept up to date.
      d) For food chain category FII*, in addition to the above, the organization shall ensure that
      their suppliers have a food fraud mitigation plan in place.

*FII = Food brokering, trading, and E-commerce activities

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IFS Food

The new version of IFS Food, Version 8, has had its requirements significantly re-worded.  The clause numbers remain the same: 4.20.1 to 4.20.4.

The new wording is easier to understand and makes the requirements more easily enforced for auditing.  But does not change what a food business must do to comply.  For example, while the previous version required that food fraud vulnerability assessments be reviewed “at least annually and/or in the event of increased risks”, the new version says they should be reviewed “at least once within a 12-month period or whenever significant changes occur.”

The only notable change to meaning is that the phrase “full commitment from the senior management” has been removed from clause 4.20.1, presumably because it is not easily auditable.

Food Fraud Requirements of IFS Food, Version 8 (with new wording in blue)

4.20 Food Fraud

4.20.1 The responsibilities for a food fraud vulnerability assessment and mitigation plan shall be clearly defined. The responsible person(s) shall have the appropriate specific knowledge and full commitment from the senior management.

4.20.2 A documented food fraud vulnerability assessment, including assessment criteria, shall be documented, implemented and maintained.  The scope of the assessment shall cover all shall be undertaken on all raw materials, ingredients, packaging materials and outsourced processes, to determine the risks of fraudulent activity in relation to substitution, mislabelling, adulteration or counterfeiting. The criteria considered within the vulnerability assessment shall be defined.

4.20.3 A documented food fraud mitigation plan shall be documented, implemented and maintained developed, with reference to the vulnerability assessment, and shall include the testing and monitoring methods.  and implemented to control any identified risks. The methods of control and monitoring shall be defined and implemented.

4.20.4 The food fraud vulnerability assessment shall be reviewed, at least once within a 12-month period or whenever significant changes occur. regularly reviewed, at least annually, and/or in the event of increased risks. If necessary, the food fraud mitigation plan shall be revised/updated accordingly.

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Takeaways

There are no big surprises in these two updates, but it pays to read all clauses carefully.

The good news is that if you have to stay up to date with multiple standards we’ve got you covered – at least when it comes to staying on top of food fraud requirements 😊

We’ve just released Edition 3 of our authoritative guide to current food fraud requirements in all major food safety standards, for auditors, consultants and food fraud specialists, with updates for the amended FSSC and IFS requirements.

Get all the food fraud requirements of all the major standards in one convenient e-book (updated)

Download it instantly, print or save it and keep it as a handy reference.

It costs USD27, which includes all future updates.  Learn more about it here.

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Honey Fraud – Much Worse Than We Thought?

From the desk of Karen Constable, principal consultant at Food Fraud Advisors.

My daughter loves honey and eats a lot of it. She spent a few months in Europe last year – mostly in Spain –  and told me the honey there had no flavour.  She said it tasted like sugar water.

‘Honey’ that doesn’t taste like honey may have been diluted with water and adulterated with non-bee sugar syrups: food fraud.  Honey is one of the most fraud-affected foods on the planet, so perhaps it shouldn’t be surprising to hear that “honey in Europe just doesn’t taste like honey”.

But I was surprised. Europe takes its honey seriously.  And it takes food fraud seriously, too.  I wouldn’t have been surprised to hear about flavourless probable-fraud-affected ‘honey’ in other parts of the world, but I was surprised to hear my daughter say it was “everywhere” in Europe.

Listen to this post on YouTube by clicking the preview below.

 

The last time I saw Europe-wide honey fraud results they were quite good.  For example, a honey-checking operation that was part of the famous Europol/Interpol anti-food-fraud activity, Operation Opson X, in 2021, found that of the  495 honey samples tested, 93% were compliant.  Separately, a European honey fraud survey in 2015 – 2017 reported only 14% ‘suspicious’ samples.Seven percent, fourteen percent, as non-compliance rates, they are hardly fantastic but they don’t match my daughter’s claim that all the honey she tasted in Europe was affected.

But new results have just been published for a multi-year European anti-honey-fraud operation and they are pretty bad.  Of the 320 samples tested in the operation, almost half were suspected of being non-compliant with the provisions of the European honey standard (the Honey Directive).

What is going on here? Why are these results so much worse than past surveys?

Firstly the samples that were tested do not represent the European-wide honey market.  The sampling focussed only on imported honey and only on adulteration with sugar syrups.

Secondly, the methods used in this most recent round of testing are almost certainly different from previous European surveys.  The test methods are only suitable to identify “suspicions of fraud” by looking for chemical markers of extraneous sugars (presence/absence only) and they are different from the officially-approved honey test methods.

The European Joint Research Council (JRC) says these methods are “the most sophisticated methods” currently available but they have not been validated and they are not part of the regulatory framework.

For this enforcement activity, the analytical results were used only as a tool to decide whether further investigations were needed to uncover fraud in the honey supply chain.  Further investigations included on-site inspections, examination of documents, computers and phone records.

Investigators reported that fraudsters appear to be deliberately adjusting the levels of adulterants so that they can evade border control checks.  The European Union’s Food Safety Commission says that officially-approved honey authenticity test methods are not keeping up with the fraudsters, claiming that analytical methods used for border control checks “lack sufficient sensitivity to detect low and intermediate levels of sugar adulterations”.

Something is just not right with honey in Europe

The investigations began more than eighteen months ago, but it appears likely that there are still high levels of fraud-affected honeys in the European market now. More than sixty percent of importers were found to have imported at least one suspicious consignment.

In fact, the European Food Safety Commission, last week reported that “there is a strong suspicion that a large part of the honey imported from non-EU countries and found suspicious by the JRC of being adulterated remains present and undetected on the EU market” (source).

Takeaways

Honey fraud is difficult to detect and expensive for government agencies to investigate.  Fraud perpetrators have been shown to use sophisticated systems to evade detection, and these investigations appear to show that importers and exporters are working together to defraud customers and governments.

If your business purchases honey, food fraud mitigation activities must go beyond checking documents or relying on letters of guarantee.

As a consumer, it is impossible to tell whether honey is fraud-affected or not, but if you suspect honey of being fraudulent, contact the brand owner as a first step and share your concerns.

…. Or you could seek out incense honey, a premium mono-floral honey from the incense flower in Portugal, for which all samples in a recent analytical test were found to be authentic 😊.

🍏 Source: https://food.ec.europa.eu/safety/eu-agri-food-fraud-network/eu-coordinated-actions/honey-2021-2022_en 🍏

 

*** This post originally appeared in Issue #81 of The Rotten Apple Newsletter.  Subscribe to The Rotten Apple to get unique, helpful food safety and food fraud information direct to your inbox every Monday  ***

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5 Food Fraud Trends to Look Out For in 2023

Our Principal Karen Constable has been following food fraud news since 2015.  Every week she personally reads, watches and listens to hundreds of articles, posts and journals about food fraud.

Here’s what she is predicting for food fraud for 2023:

  1. Organic fraud in USA – (a little) less likely
  2. Waste disposal fraud
  3. Document fraud as a new area of concern
  4. Sustainability claims ‘fraud’ – more likely
  5. Authenticity testing – improving

1) Organic fraud

Awareness of organic fraud has been increasing rapidly everywhere in the world. In the USA, that increased awareness has been accompanied by growing recognition of problems with the National Organic Program (NOP). These problems are related to enforcement and coverage.  The NOP includes standards that define what can and cannot be labelled as ‘organic’, and it requires that products meet certain requirements in order to carry the USDA Organic seal.

There were a number of multi-year, very high volume frauds in the organic grain sector in the USA that have been discovered and prosecuted in recent years, including one perpetrated with corn grown in the mid-West and fraud in imported ‘organic’ soybeans. With some of those large operations exposed, the amount of fraudulent ‘organic’ bulk commodities should be reduced in the USA. The prosecutions may act as a deterrent to other would-be perpetrators.

The NOP rules have been strengthened so that they will apply to imported commodities and importing companies like brokers and traders.  They also require that the organic status of bulk food in non-retail containers is correctly identified with respect to its organic status. There have also been updates related to the qualifications of organic inspectors and the rigour of on-site inspections.

Although the new rules are at least one year away, the market for organic commodities has been ‘put on notice’ and this should reduce the amount of organic food fraud in the USA.

organic produce pesticide authentic fruit vegetable

2) Waste disposal fraud

Waste disposal fraud has (probably) been happening for decades, but we are becoming more aware of the risks.  Waste fraud takes many forms but a typical scenario is one in which a food company contracts a waste company to securely destroy and dispose of goods that do not meet quality or safety parameters so that they cannot be diverted back to consumers.  However when fraud occurs, the waste company sells the sub-standard food, or otherwise allows it to return to consumers.

In one recent example, damaged jars of food were diverted back to the legitimate marketplace by the company that had promised to destroy them (and issued a disposal certificate to the brand owner).

This type of fraud is not new, but awareness of potential fraud in the waste supply chain has increased.  At the same time, food companies’ supplier approvals programs are more likely to include waste contractors than previously.  This means that there could be less waste disposal fraud than before (hopefully!)

 

3) Food safety document fraud (a bigger worry than we first thought?)

Document fraud is nothing new. It is a key element in many types of food fraud.  Falsified laboratory reports, fake organic certificates and even fake disposal declarations are all examples of document fraud.

In the context of food fraud, document fraud is most likely to support a profitable fraud, such as passing off conventional soybeans as ‘organic’ so they can be sold for a much higher price.

In ‘normal’ food frauds, then, the document fraud is just part of the package, and the documents do not directly make the food vulnerable.

There is one class of food, however, that has a special – and perhaps easily missed – food fraud vulnerability.  These are foods that are not usually thought of as ‘high risk’ for food fraud, but that rely on authentic/true documents for critical food safety criteria.

An example is ready-to-eat cold, cooked chicken purchased by a sandwich manufacturer.  A faked expiry date or falsified microbiological result on the certificate of analysis would place the sandwich company and its consumers at risk of serious consequences.  Because the faked, forged or falsified documents in that scenario provide subtle economic advantages to the supplier, this type of scenario could be considered food fraud.

Such vulnerabilities could easily slip through the net of traditional food fraud assessments. For suppliers whose economic circumstances are getting tougher, the motivation to perpetrate ‘minor’ document frauds like falsifying microbiological tests could be getting stronger, potentially increasing the likelihood of such frauds occurring.

 

4) Problematic sustainability claims

Claims about the sustainability credentials of foods are on the rise, as consumers increasingly value such claims.  Unfortunately, many green claims made about consumer goods have the potential to be misleading.

A United Kingdom government survey found 40 percent of such claims were problematic because of either non-accredited, own-brand logos; non-disclosure of environmentally harmful practices or ingredients; vague language; or lack of evidence to support claims such as ‘eco’, ‘sustainable’ and ‘natural’.

Vague claims and own-brand logos do not necessarily constitute food fraud, however food businesses need to be careful about the integrity of the data they use to support claims they intend to make about their products or operations.

Claims about carbon neutrality, carbon net-zero and greenhouse gas emissions reductions need to be evidenced using data from the whole supply chain.  This is where food companies can be vulnerable.

If a food company’s supplier provides incorrect data related to the carbon footprint of the material or service being purchased, the outcome of any emissions calculations done by the purchasing company will be incorrect.  The result?  The food company could be guilty of accidentally misrepresenting its sustainability status.

Other fraud pitfalls for food companies include fraudulent certification schemes and logos used by their suppliers, and errors in interpreting or complying with the varying green claim regulations in different markets.

Read more about the risks that come with carbon-neutral claims in Issue 61 of Karen’s newsletter The Rotten Apple and about consumers’ confusion with sustainable seafood claims in Issue 63.

 

5) Authenticity testing – more accessible, better expertise

Laboratories continue to improve their authenticity testing services to support medium-sized food businesses with food fraud detection. The level of food fraud knowledge and expertise in the food testing industry is getting better and more tests are becoming available.

The Food Authenticity Network’s (FAN) Centres of Expertise Program is making valuable contributions to the expertise and accessibility of food fraud tests.  A FAN centre of expertise is a laboratory or academic institution with expertise in one or more types of authenticity tests.

 

This article originally appeared in The Rotten Apple newsletter on 20th February 2023.

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Food Safety Hazards from Food Fraud (EMA)

Updated 28th June 2023

Are you confident in your FSMA preventive controls for hazards from food fraud?

This post is for you if your company manufactures food in the USA or exports food to the USA.

Food companies in the USA must comply with food safety regulations that require them to identify and address hazards from economically motivated adulteration (EMA), a type of food fraud.

In this post you can learn what EMA is and how to identify food safety hazards from EMA.  You can also discover what type of preventive controls are best for EMA hazards.

Definitions

EMA is short for economically motivated adulteration which is a type of food fraud.  Other types of food fraud include counterfeiting, making false claims (for example, fake ‘organic’ food) and species substitution (for example, selling cheap white fish labelled as snapper).

“Economically motivated adulteration (EMA) occurs when someone intentionally leaves out, takes out, or substitutes a valuable ingredient or part of a food. EMA also occurs when someone adds a substance to a food to make it appear better or of greater value.” (US FDA)

FSMA denotes the Food Safety Modernization Act (USA). is a set of rules for food manufacturers. Under the rules, food manufacturers must assess food safety hazards and implement preventive controls. The US Food and Drug Administration (FDA) is responsible for the enforcement of the rules.  If your company is outside the USA but exports to the USA, you must also comply with the FSMA rules.

Hazards are chemical, physical and biological agents that may be present in food and that are capable of causing harm to consumers of the food.  (Find the official FDA definition here)

Preventive controls are procedures and systems that are designed to ensure that food safety hazards are prevented or minimized to an acceptable level.

Rules for food fraud (USA)

FSMA requires that preventive controls are implemented by food manufacturers to prevent hazards to human health.  The relevant regulation is called the FSMA Final Rule for Preventive Controls for Human Food, and is commonly known as the Preventive Controls Rule.

The Preventive Controls Rule requires food manufacturers to identify and control hazards that could arise from:

  • natural occurrences (for example, some raw meat products naturally contain certain human pathogens);
  • unintentional contamination (for example food may be accidentally contaminated with a pesticide during a pest control treatment), and
  • economically motivated adulteration (EMA).

After food manufacturers have identified the hazards, they must minimize or prevent the hazards by creating and implementing preventive controls in their food manufacturing operations. These are procedures and systems that are documented and that include monitoring, corrective actions systems and verification activities.  The preventive controls form part of the food manufacturer’s food safety plan.

Learn more about the preventive controls rule on the FDA’s preventive controls guidance webpage.

A separate part of the FSMA rules also requires food manufacturers to create and implement systems to prevent intentional, malicious adulteration.  The FDA calls this type of adulteration Intentional Adulteration (IA). It is different from economically motivated adulteration.  Intentional adulteration prevention is also known as food defense.  Click here to learn more about food defense.

Hazards are chemical, physical and biological agents that may be present in food and that are capable of causing harm to consumers of the food

Examples of hazards from economically motivated adulteration (EMA)

Economically motivated adulteration (EMA) is a subset of food fraud.   Food fraud includes many types of deception carried out for the purposes of economic gain.  It includes activities such as mislabeling (for example, making false claims about the geographical origin of a food product) and other fraudulent activities that do not involve the adulteration of food.

Economically motivated adulteration is a type of food fraud in which a person has added a substance to food to enhance its apparent value or profitability.  Often the added substance will boost the apparent quality or appearance of the food, other times the substance will be a diluent, which dilutes or replaces the genuine material with a cheaper material, thereby increasing the profitability of the resulting mix.

Food businesses are required by law to

  • understand food safety hazards that may be in their products;
  • create and implement systems that will prevent, minimize or eliminate those hazards;
  • systems for preventing, minizing and eliminating hazarsd  must be documented in a food safety plan.

Economically motivated food fraud (EMA) happens when food fraud perpetrators add materials to increase the apparent value of the food or to extend its shelf life in an undeclared or unlawful manner.  Materials that are added to make food or ingredients seem bigger, or heavier include water and other liquids, or fillers and bulking agents, such as starches, husks or sawdust.  Adulterants that are added to make food look better include unauthorised colorants, glosses and glazes.  Adulterants that extend shelf life include non-approved preservatives.

Food safety hazards can arise from EMA.

The food safety hazards from such adulterations include acute or chronic chemical poisoning, allergenic reactions, and microbial illnesses from pathogens introduced during the adulteration processes.

Example: Unauthorized color in turmeric

A significant proportion of powdered turmeric traded worldwide contains unsafe levels of lead.  Researchers in Bangladesh have confirmed that the lead is added to the spice in the form of toxic lead chromate which has an intense yellow-gold color, the color favoured by turmeric traders and buyers as an indicator of freshness and quality.  Curry powder, cumin and cinnamon have also been affected.  A survey of more than 1496 samples of 50 spices from 41 countries found that 50% of the spice samples had detectable lead, and more than 30% had lead concentrations greater than 2 ppm, a level that is 200 times higher than the recommended maximum lead content of candy in the USA.  Lead is a potent neurotoxin that damages organs including the brain.

Example: Undeclared peanuts in chopped hazelnuts

Peanuts are cheaper than most other nuts which makes them an attractive ‘filler’ or bulking agent in chopped nuts, powdered nuts and nut pastes.  When a food fraud perpetrator adds peanuts to a tree nut product, they gain more profit than if they sold a pure paste or powder.  In Germany in 2017, authorities found bulk quantities of chopped hazelnuts adulterated with 8% chopped peanuts.  The chopped hazelnuts were sold as ‘pure’ hazelnuts and did not declare any peanut ingredients on the label.  Because peanuts are a regulated human food allergen, their presence in the hazelnut product presented a serious food safety hazard.

 

How to identify hazards from economically motivated adulteration (EMA)

Follow the five steps below to identify hazards from EMA food fraud for your food manufacturing preventive controls plan.

  1. For each raw material that your company purchases to use in the food manufacturing process, investigate whether economically motivated adulteration is likely to occur within the supply chain.  Ask yourself: could adulterants be present in the raw material when it is purchased?  Learn how to investigate susceptibility to food fraud here.
  2. For each raw material and each finished product your company makes, also investigate whether economically motivated adulteration could occur inside your manufacturing facility or storage areas.  This is sometimes known as ‘insider activity’.
  3. After you have understood whether adulteration is likely to occur for each raw material, make a list of adulterants that could be added to each of the susceptible foods.   Historical records of past incidences of food fraud provide the best indication of the types of adulterants that can be expected in different foods and ingredients.  This page has a list of databases you can use to find historical records. .
  4. For each possible adulterant, make a note of whether it could be hazardous to human health if present in the food.  As an example, olive oil is commonly adulterated with (non-olive) vegetable oils.  That type of adulteration is unlikely to be hazardous and as such it would not require a preventive control under the FSMA rules*.   Document your decisions and justifications for such.
  5. Add the economically motivated hazards you have identified to your company’s food safety plan.  Implement preventive controls for each hazard.  Supplier approvals programs are commonly used for control of economically motivated hazards in incoming raw materials.

Need to learn more about food fraud prevention?  Visit our online training school.  Courses start at just US$59.

*Even if not strictly required under FSMA rules, it is always a good idea to prevent any type of food fraud from affecting your products.  This will protect your company and brand as well as your consumers’ health.