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Food Safety Standards Compared (2022)

 

Image credit: Robert Anasch

 

Different food safety standards have different food fraud requirements. For example:

  • Some standards require food businesses to include counterfeiting in their vulnerability assessments, while others don’t.
  • Some standards specify that vulnerability assessments must be performed on ingredients, while others state they should be done on finished products.

Confused? We are here to help.  Read on to find out which standards have what requirements, and get recommendations for creating a great food fraud prevention (VACCP) program.

Background

Food safety standards are standards that describe requirements for food and related businesses.  The requirements aim to ensure that food and food-related goods are safe for consumers and customers.  The correct term for such standards is food safety management systems standards (FSMS).

There are food safety standards for all types of operations within the food supply chain, including:

  • growing and packing fresh produce,
  • manufacture of food and food ingredients,
  • buying and selling food (“brokers”),
  • storage and transport of food,
  • manufacture or converting of packaging materials
  • manufacture of animal feed or pet food,
  • services such as cleaning, laundry, or pest control for food businesses.

While the over-arching aim of all food safety standards is to keep consumers safe, many standards also serve secondary purposes. Some of the most popular food safety standards were developed by food retailers, with the aim of protecting their brands as well as keeping consumers safe. Other standards were developed to help food businesses understand best practices and gain a way to demonstrate their excellence through independent certifications.  Some standards include quality parameters, while others only address food safety issues.

There are dozens of internationally accepted food safety management system standards, each with slightly different requirements.  This can make it difficult to know which standards are ‘better’ or more suitable for your food company.

To solve this problem, a standard for food safety standards was created by the GFSI (Global Food Safety Initiative).  The GFSI assesses and approves food safety standards using a process called benchmarking. The aim of GFSI benchmarking is to define best practice in food safety standards and provide a way to compare and align different food safety standards.

Among the dozens of food safety standards, some are benchmarked by the GFSI (Global Food Safety Initiative), while others are not.  Benchmarked standards usually have more requirements and more rigorous expectations than non-benchmarked standards.  The auditing and certification processes for benchmarked standards are typically more expensive than for non-benchmarked standards.

Food Fraud in Food Safety Standards

Food fraud prevention activities are an important part of all food safety management systems because food fraud can pose a risk to food safety.  Some food safety standards have separate, stand alone requirements for food fraud prevention activities, while others do not.  Standards that are GFSI-benchmarked all include explicit, separate food-fraud-related requirements. Other standards rely on the hazard analysis elements of the food safety system to identify and control hazards from food fraud.

The GFSI benchmarking requirements specify that all benchmarked standards include a vulnerability assessment for food fraud and a mitigation plan for food fraud prevention.  Most GFSI-benchmarked standards also include details about which materials should be assessed and which types of food fraud need to be managed.

Non-GFSI standards vary in how they require a food company to approach food fraud.  Some specify or recommend a VACCP program, which is based on food fraud vulnerability assessment activities. Others, like AIB, require that food fraud risks be considered in the supplier approvals processes.  The regulations of the USA Food Safety Modernization Act (FSMA) require that food businesses identify hazards from economically motivated adulteration type food fraud and implement preventive controls to minimise the risks.

Among the most well-known standards there are some notable differences. For example, the SQF Food Safety Code requires food businesses to assess and manage risks from counterfeit-type food fraud, while the BRC Food Safety Standard only requires businesses to assess the risks from adulteration or substitution activities. BRC also requires horizon scanning activities, while the SQF and IFS standards explicitly mention food fraud training.

Below you will find a table that compares the current food fraud requirements of each of the major food safety standards.

Table 1.  Food fraud requirements of major food safety standards, 2022.  Click here for a pdf version. 

  AIB* BRC* FSSC* GlobalGAP* IFS* SQF*
Food types to include in food fraud prevention activities Ingredients (implied)

 

 

 Raw materials

 

 

 Products and processes

 

 

 Unclear

 

 

 Raw materials,

ingredients,

packaging,

outsourced processes

 Raw materials,

Ingredients,

finished products

 
Food fraud types

 

 

 

 Economically motivated adulteration (only)

 

 

 Adulteration,

substitution

(only)

 

 

 Any type where consumer health is at risk (in definition, Appendix A)

 

 Unclear, however counterfeit or non-foodgrade packaging or propagation materials are included as examples

 

 Substitution, mislabelling, adulteration, counterfeiting

 

 

 Substitution, mislabelling, dilution, counterfeiting

 

 
Vulnerability assessments explicitly required? Risk assessment (implied, Appendix A) Yes Yes Risk assessment Yes Implied (Edition 9)
Mitigation plan required?

 

 

 – Mitigation activities are to be included in the vulnerability assessment Yes Yes Yes Yes
Does packaging need to be included in the vulnerability assessment? Yes

(implied)

 

 Yes

(see 3.5.1.1)

 

 Yes

(as per food fraud definition, Appendix A)

 Yes

 

 

 Yes

 

 

 Implied

(primary packaging is a ‘raw material’)
Is a separate food fraud procedure explicitly required? – – Yes – Implied

(“responsibilities shall be defined”)

 Implied

(“methods and responsibilities shall be documented”)
Is training in food fraud explicitly mentioned? – – – – Yes

(Clause 3.3.4)

 Yes
Is an annual review explicitly required? – Yes – – Yes Yes
Other

 

 

 – Horizon scanning for developing threats must be done (Clause 5.4.1) – – Criteria for vulnerability assessments must be defined

(4.20.2)

 Food safety risks from food fraud must be specified (2.7.2.2)

*  The full names of the standards are as follows:

AIB International Consolidated Standards for Inspection Prerequisite and Food Safety Programs, 2017

BRCGS Food Safety, Issue 8

FSSC 22000, Version 5.1

GlobalG.A.P. Integrated Farm Assurance (IFA), Version 5.4-1

IFS Food, Version 7

SQF Food Safety Code, Edition 9

To get this table in a downloadable format, click here.

Takeaways

Among the major food safety management system standards, there are small but significant variations between food fraud prevention requirements.  Key differences include whether finished products or ingredients are to be assessed, which types of food fraud must be included and the presence/absence of requirements related to horizon scanning and training.

If that all seems confusing, don’t despair!

Recommendations for a robust and compliant food fraud prevention program (VACCP)

At Food Fraud Advisors we have been working at the intersection of food fraud and food safety since the very beginning!  Creating a robust and compliant food fraud program can take time and effort but it isn’t complicated.  Follow the steps below to get started:

  1. Carefully read the food fraud clauses of the standard you are/will be certified to.  This download has a complete list of clauses for food fraud requirements of all major standards.
  2. Pay attention to the food types and the food fraud types that are mentioned in your standard.
  3. Create a robust vulnerability assessment (here’s how) and a mitigation plan for identified vulnerabilities.
  4. Whether or not it is explicitly required in your standard, we recommend you create a food fraud prevention procedure that defines the methods, responsibilities and criteria for food fraud prevention.
  5. You should also conduct training for all relevant staff and ensure that the food fraud system is reviewed at least annually.

Get a complete guide to the food fraud requirements of all the major food safety standards from us, the food fraud experts, here.  Our join the waiting list for our 2022 workshops here.

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Investigating Susceptibility to Food Fraud

Some foods are more susceptible than others to economically motivated adulteration, substitution and dilution.  Understanding the susceptibility of an ingredient or raw material type is an important part of every vulnerability assessment process.

A TWO PART PROCESS

Susceptibility is investigated in two parts.

(1) General Susceptibility (is this type of food often affected by food fraud or not?)

You can estimate a foods general susceptibility using publicly available information.

(2) Specific Susceptibility (is the food we purchase likely to be affected by food fraud?)

The specific food fraud attributes depend on your supply chain, management of the supply chain and testing and auditing activities.

STEP 1. GENERAL SUSCEPTIBILITY

To investigate the general susceptibility of a food or ingredient to food fraud, use publicly available information about incidences of fraud that have occurred in the past and that might occur in the future.

There are a few different ways to access information about previous incidences and emerging issues with a raw material type, as shown below.

how to investigate info graphic

1. Online databases – access to historical data:

  • Decernis has an extremely comprehensive database of food fraud incidents which can be searched by food type and by adulterant type.  This database was developed and formerly operated by the US Pharmacopeial Convention (UPS). It also contains information about analytical methods.   https://decernis.com/solutions/food-fraud-database/.
  • Food Fraud Advisors’ Food Fraud Risk Information Database is a free and open-access online database of food fraud incidences and emerging threats, organised by food type.  No log-in required.
  • HorizonScan contains historical data about both commodities and suppliers.  Users can set up email alerts for issues relevant to them.
  • FoodSHIELD was created by The Food Protection and Defense Institute, which is part of the University of Minnesota and partially funded by the USA Department of Homeland Security.  FoodSHIELD resources, including a database of economically motivated adulteration incidences are available to members.  Unfortunately membership is limited to representatives from local, state, and federal governments, the military and laboratories that perform analyses.  Members must first pass a membership checking process to ensure they are eligible to access the information. https://www.foodshield.org and https://www.foodshield.org/index.cfm/discover-tools-links/what-is-foodshield/foodshield-brochure/
  • The Food Protection and Defense Institute also operates a Food Adulteration Incidents Registry.
  • EMAlert is software that helps USA businesses with commodity scanning and assessing vulnerabilities for USA regulatory compliance.  Subscriptions start at US$2,500 per year.
  • Safety HUD byMerieux NutriSciences provides access to regulatory and media reports on food fraud and food recalls.  It includes customizable alerts and dashboard http://resources.mxns.com/safetyHUD_SQF
  • The Rapid Alert System for Food and Feed (RASFF) is managed by a group of European national food safety authorities and alerts its member states to incidences of food and feed safety and integrity.  RASFF publishes a searchable database for investigating incidences of food fraud.  To learn more about RASFF click here.  For direct access to the database, open the RASFF Portal.
  • The US FDA has a searchable list of food recalls and food safety alerts, including those related to food fraud.  http://www.fda.gov/Safety/Recalls/

2. Email alerts via subscription service:

  • Food Forensics, a laboratory located in United Kingdom, offer a monthly horizon scanning risk newsletter to members.
  • FoodChainID Horizon Scan is a paid subscription service that provides alerts on adulteration and fraud, as well as food safety contamination events.
  • Some trade associations provide email services to members.
  • The Rotten Apple, by Karen Constable (of Food Fraud Advisors), is a weekly newsletter that includes trends and analysis as well as a summary of updates made to the Trello Food Fraud database each week.
  • Government-run food safety and food regulatory bodies in some jurisdictions send emails to interested parties.  Contact your local authority for more information.

3.  Direct intelligence:

  • Information can be obtained by asking law enforcement officials and government departments.
  • Suppliers can provide information about their material types.
  • Trade associations can be approached for information on food fraud and emerging issues.
  • Conferences and webinars about food fraud and food defence are held regularly and these can be a good source of information.

STEP 2. SPECIFIC SUSCEPTIBILITY

Next, consider all the characteristics of your specific material as it is purchased by your food business.

Characteristics that should be considered include those associated with the supply chain, purchasing policies and the format of the material.

Each characteristic should be considered with regards to how it could affect the degree to which a person may be motivated to fraudulently adulterate the material and how it could allow a person to:

a) gain access to the material,

b) commit fraud by adulterating, substituting or diluting the material or

c) avoid detection.

To ensure that all relevant characteristics are considered it is best to use a checklist.

Create your own checklist or use a checklist prepared by experts such as those found in a proprietary Vulnerability Assessment Tool.

There are a number of fraud assessment tools available on-line, with differing degrees of usefulness (some are really annoying to use!).  The most comprehensive checklist for food fraud vulnerability assessments can be found in Food Fraud Advisors’ Vulnerability Assessment Tools.

Need more help?  Get easy-to-use, comprehensive downloadable templates in our online training course.

Visit our training academy today

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Pesticide Residues Found in ‘Organic’ Fruit and Veg

The most recent survey of pesticides in foods (USA) found that more than 98 percent of the tested foods had no or acceptable (safe) levels of pesticide residue. These figures are great overall.  But the results for organic foods are not so good.  Organic fraud is one of the most common types of food fraud.  Karen Constable of Food Fraud Advisors took a deep dive into the results of the survey to see how organic foods performed.

About the Pesticide Data Program

The United States Department of Agriculture (USDA) surveys the nation’s food supplies every year, checking for residues of pesticides, pesticide by-products and environmental contaminants, which are chemicals no longer used as pesticides, but known to persist in the environment.

The 2019 survey tested almost 10,000 samples of 21 types of fresh, frozen and canned fruit and vegetables, plus tomato paste, dried garbanzo beans, rice and oats.  The foods were sampled throughout the year, across the country from wholesale markets, retail outlets and distribution centres.  Both domestic and imported foods were sampled.  Each commodity was tested using sensitive analytical tests to check for residues of approximately 500 pesticides and around 20 environmental contaminants.

The official report (find it here ) contains excellent and detailed information about the sampling systems.  The report also provides a broad overview of results for commodities and discusses the differences between domestic and imported products.  But it does not specifically discuss the results for organic foods.

Results for Organic Foods

In 2019 and 2020 the USDA acknowledged widespread problems with compliance in US organic certification programs.  In the USA, organic certification is regulated by the USDA and their organic program is the only organic certification scheme that may be used.

Among the 9,697 samples that were tested in 2019 by the USDA in their pesticide data program, 845 (8.7%) of them were labeled as ‘organic’.   The pesticide survey is not designed to sample specifically for organic foods and the official report does not report results for organic foods as a category.

However, the raw data from the survey is publicly available and can be analysed to find out which foods were labeled as ‘organic’ but contained residues of non-organic-approved pesticides.

For the 2019 survey there were 845 samples labeled ‘organic’ and two that were labeled ‘pesticide free’.  Both of the products labeled ‘pesticide free’ contained detectable levels of pesticide, but at safe* levels.  Around one quarter of organic-labeled foods contained residue(s) of at least one pesticide and just under half of those had unsafe** levels.  There was a small number of notable samples (1%) that contained either very many residues or unsafe levels of multiple pesticides.

Summary

  • 26% of ‘organic’ samples had detectable levels of pesticide(s)
  • 9% of ‘organic’ samples had unsafe** levels of at least one pesticide
  • 1% of ‘organic’ samples contained four or more pesticides at unsafe** levels
  • 1% of ‘organic’ samples contained traces of more than 10 pesticides

26 percent of ‘organic’ samples had detectable levels of pesticide(s)

Every sample in the USDA survey was tested for approximately 500 pesticides and environmental contaminants.  Of the 845 samples that were labeled as ‘organic’, 220 (26%) contained detectable levels of at least one pesticide.

Note that not all organic-approved pesticides are included in the tests.  The main organic-approved pesticides that were included in 2019 were Spinosad and Spinosad A.

9 percent of ‘organic’ samples had unsafe* levels of at least one pesticide

Of the 845 organic products that were tested, 72 (9%) were found to contain at least one pesticide at levels that exceed or were presumed to exceed the EPA ‘tolerances’ for that pesticide.  The tolerances are ‘the maximum amount of a pesticide allowed to remain in or on a food’.

7 ‘organic’ products contained four or more pesticides at unsafe* levels

There were 7 products (<1%) that were found to contain unsafe levels of four or more pesticides.  Five of those seven products were fresh basil (4 grown in USA, 1 imported from Mexico).  The other products were fresh cilantro (grown in USA) and white basmati rice imported from India.

Only one of those seven products contained detectable levels of the organic-approved pesticides Spinosad or Spinosad A.

5 ‘organic’ samples contained residues of more than 10 pesticides

Of the 845 samples that were labeled ‘organic’, 5 (<1%) contained detectable levels of more than 10 different pesticides.  These five products were locally grown fresh basil, fresh mustard greens, imported basmati rice and imported frozen strawberries.

USDA Pesticide Survey (PDP), 2019; results for foods labeled ‘organic’

How does this compare with previous data?

Click here to view the results for 2014

  2014   2019
Proportion of ‘organic’ samples that contained detectable levels of at least one pesticide   22%   26%
Proportion of ‘organic’ samples that contained at least one pesticide at ‘unsafe’ levels   2%   9%
Worst performing commodities***   Frozen cherries

Tomatoes

   Fresh basil

*** Note that none of these commodities were sampled in both 2014 and 2019

Is this food fraud?

Organic foods should not contain residues of non-organic-approved pesticides.  But the presence of such residues is not necessarily the result of food fraud.

Analytical tests can detect extremely low levels of pesticides.  Low levels of pesticides can be present on samples due to accidental contamination, such as by blowing from another field during application, or by being transferred from other produce during transport or storage.

Where residues are present at higher or unsafe** levels, there is a greater likelihood that the pesticide(s) were applied to the food deliberately.  Interestingly, of the seven ‘organic’ foods that contained four or more pesticides at unsafe levels, all contained multiple other residues at lower levels, but only one contained any residue of the organic-approved pesticide Spinosad/SpinosadA.

A properly controlled organic supply chain should not result in produce that contains non-approved pesticides at unsafe levels.  It is reasonable to assert that such produce has been deliberately treated with the pesticide(s), such as would occur during conventional growing or post-harvest processes.  It would be reasonable to conclude that the products were therefore conventionally grown rather than being authentically organic.

In this survey between 1 and 9 percent of the organic samples appear to have been grown using conventional methods but were marketed as ‘organic’.  This mislabeling represents food fraud.

*safe levels:  For the purposes of this report, ‘safe’ = any analytical result that was reported as being detected but not annotated as being (i) Residue at with presumptive violation – No Tolerance, (ii) Residue with a presumptive violation – No Tolerance (iii), Residue with a presumptive violation – Exceeds Tolerance.  The tolerance is a limit set by the EPA that is ‘the maximum amount of a pesticide allowed to remain in or on a food’.

**unsafe levels:  For the purposes of this report, ‘unsafe’ = any analytical result that was reported as being detected and annotated with either (i) Residue at with presumptive violation – No Tolerance, (ii) Residue with a presumptive violation – No Tolerance (iii), Residue with a presumptive violation – Exceeds Tolerance.  The tolerance is a limit set by the EPA that is ‘the maximum amount of a pesticide allowed to remain in or on a food’.

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Vulnerability Assessments

What is a vulnerability assessment?

 

A vulnerability assessment is a risk-assessment-style evaluation of a food’s vulnerability to food fraud.

A food fraud vulnerability assessment is a documented assessment that identifies vulnerabilities to food fraud and explains how those vulnerabilities were identified.

Vulnerability assessments are also done to assess the threat of a malicious attack on food.  Malicious attacks include attacks conducted for extortion, ideological reasons or terrorism. We call these issues of food defense. To learn more about vulnerability assessments for food defense (intentional adulteration), click here.

Why ‘vulnerability’ and not ‘risk’? 

 

  • A risk is something that has occurred before and will occur again. A risk can be quantified using existing data.
  • A vulnerability is a weakness that can be exploited.  A vulnerability can lead to a risk.

Food fraud is difficult to estimate and quantify, so we use the word vulnerability rather than risk.

Why do a vulnerability assessment?

 

  1. To protect consumers: Food that is vulnerable to food fraud presents significant risks to consumers.  Food that is adulterated or diluted   [Read more…]

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Future and emerging threats of food fraud

Food fraud: you don’t want it.

  • If you are manufacturing, wholesaling or retailing food or beverages, fraudulent activities within your supply chain pose risks to your brand and to your customers.
  • Different food types vary in their susceptibility to food fraud.
  • The risks change over time.
  • Purchasers of food and food ingredients must remain vigilant about new and emerging risks.
  • The requirement to monitor emerging and predicted food fraud issues is a part of all major (GFSI) food safety standards.

Learn how to monitor food fraud threats here.