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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BRC and BRCGS: British Retail Consortium (superseded) and British Retail Consortium Global Standards.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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Food Safety Standards Compared (2023)

 

food vulnerability assessment

There are many different food safety management system standards (FSMS), and they all have different requirements.  So how do you know which standard is the best one for your food company?

When it comes to food fraud, the food safety standards have minor differences in their 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.  Some explicitly require training in food fraud awareness, while others do not.

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.

The over-arching aim of all food safety standards is to keep consumers safe, but most standards also have secondary aims. Some of the most popular food safety standards were developed by food retailing groups, and these standards were written to protect the retailers’ brands as well as keep 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 practices for 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 time-consuming and 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 requires all benchmarked standards to require food companies to do a vulnerability assessment for food fraud and create 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 (EMA) 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 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, 2023. 

Click here to open or download a pdf version of this table

 AIB*BRC*FSSC*GlobalGAP*IFS*SQF*
Food types to include in food fraud prevention activitiesIngredients (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)YesYesRisk assessmentYesImplied (Edition 9)
Mitigation plan required?

 

 

–Mitigation activities are to be included in the vulnerability assessmentYesYesYesYes
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?––Implied (“method shall be defined”)–Implied

(“responsibilities shall be defined”)

Implied

(“methods and responsibilities shall be documented”)

Is training in food fraud explicitly mentioned?–Implied

(Clause 5.4.1)

––Yes

(Clause 3.3.4)

Yes
Is an annual review explicitly required?–Yes––YesYes
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 of Prerequisite and Food Safety Programs, 2023

BRCGS Food Safety, Issue 9

FSSC 22000, Version 6 (NEW!)

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

IFS Food, Version 8 (NEW!)

SQF Food Safety Code, Edition 9

Takeaways

Among the major food safety management system standards, there are small but significant differences 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 first days of food fraud requirements in food safety standards… and we’ve been helping businesses since day one.

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. Pay attention to the food types and the food fraud types that are mentioned in your standard.  HINT: you may need to check the definitions or glossary. Carefully read the food fraud clauses of the standard you are/will be certified to.
  2. Pay attention to the food types and the food fraud types that are mentioned in your standard. HINT: you may need to check the definitions or glossary.
  3. Create a robust vulnerability assessment (here’s how) and a mitigation plan for identified vulnerabilities.
  4. 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.

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Investigating Susceptibility to Food Fraud

Updated 26th June 2022

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 food fraud 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.

1. Online databases – access to historical data:

A food fraud database provides a way to access historical information about food fraud.

A food fraud database is a collection of information about food fraud incidents and food fraud risks. There are a number of free and paid databases operated by governments, not-for-profits and private companies available worldwide.  The type of data varies from database to database, as does the cost and the features.  For a current list of food fraud databases, check out our post Food Fraud Databases Compared.

2. Email alerts via subscription service:

Email services provide near-to-real-time information about food fraud incidents as they occur. This can be a good way to keep on top of developing food fraud risks.   Below is a list of email subscriptions that can provide information about food fraud.

  • 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:

Direct intelligence is another means of gathering information about the occurrence of food fraud for a given food or ingredient.

  • 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

In step one you considered the general likelihood of food fraud occurring for the food or ingredient you are assessing.

In step two you must consider the characteristics of your specific material as it is purchased by your food business.

Characteristics that should be considered include those associated with your supply chain, purchasing policies and the format of the material, for example whether it is a powder or liquid or solid.

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

Checklists help to ensure that all relevant information has been considered.

You can 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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Saffron Fraud (Everything You Ever Wanted to Know)

What is Saffron?

Saffron is a spice made from the dried stigma (part of the flower) of the saffron plant (Crocus sativus). You can see the red stigmas in the pictures.

Saffron flowers showing the red coloured stigmas. Image credit: Lorenzo Lamonica

 

Why is Saffron Vulnerable to Food Fraud?

Genuine saffron is harvested by hand, highly prized for its colour and flavour and very expensive.  In fact, it is the most expensive spice and costs between USD $1,100 to $11,000 per kg.  The international saffron market was worth US $430 million in 2018.

Saffron trade is complicated.  Saffron’s most important growing areas are in Iran, Greece, Morocco and India. Afghanistan and Spain are also important sources of saffron.  Saffron labelled Spanish is mostly grown in other countries but packed in Spain. Iran accounts for most global production at 90% – 93% but only accounts for 40% of direct global exports, according to the report (confusing!), apparently because the Iranian saffron is resold by other countries.

With so much of its production in one country, and with a short harvesting season, saffron supply is extremely vulnerable to weather events.  For example, there was a tripling of prices from 2006 to 2009 because of heavy frost in Iran in 2007.  Climate change is a threat, with increased moisture in some areas leading to more fungal plant diseases, and drought in other areas limiting yields.

Saffron Fraud

Saffron is one of the most frequently adulterated foods.  Powdered saffron is more at risk than whole saffron.

The biggest food safety issue with saffron fraud is probably the use of synthetic dyes to boost the colour of fraudulent whole saffron and saffron powder. Sudan I-IV and Rhodamine B dyes have been found in saffron and are considered potentially genotoxic and carcinogenic.

Saffron threads. Photo by Syed F Hashemi

 

Adulterants in Whole Saffron

Here are some of the things that are added to saffron to fraudulently increase its value.

  • Parts of saffron flowers, including the yellow style and the white style.
  • Filaments from other plants, including corn fibres, safflower stigmas, calendula stigmas, pomegranate fruit fibres
  • Filaments from other sources including silk.  Adulterant filaments may be dyed with plant dyes including beetroot, pomegranate, fruit peel.
  • Liquids that are added to increase weight, including oils, glycerin and honey
  • Dyes and aroma compounds as listed below

Adulterants in Saffron Powder

Here are some of the things that are added to saffron powder to fraudulently increase its value.

  • Turmeric powder
  • Paprika powder
  • Ground seeds of sweet fennel, or annatto
  • Dried marigold flowers
  • Gardenia (Cape Jasmine) extract, for their crocetin esters which are also in saffron
  • Natural dyes from flowers and roots
  • Artificial dyes including erythrosine, ponceau 4R, tartrazine, Sudan dyes, magenta III and rhodamine B
  • Safranal, which is a synthetic aroma compound

Also, there are historical reports of fillers added for increasing the product’s weight, including chalk, gypsum and heavy spar (barium sulfate)

Other Types of Fraud (Non-Adulteration-Type Food Frauds)

  • Selling Philippine saffron or “saffron flowers” as if they are real saffron (C. sativus).  They are instead safflower or kasubha.
  • Exhausted saffron sold as whole saffron
  • Coloured paper shreds sold as saffron
  • Provenance fraud, in which the geographical origin of the saffron is misrepresented

Saffron testing

Testing is a challenge.  Microscopic inspections can be done on powdered as well as whole saffron, but they are time-consuming and expensive.  In addition, visual examinations won’t necessarily recognise adulteration with colourants or safranal.

Some DNA-based tests struggle to differentiate safflower from saffron, because they are closely related.  DNA tests also don’t find safranal or dyes.  Spectroscopic methods can be simple and quick but they are not very sensitive and won’t pick up all adulterants.   There are many other authenticity test methods, each with its own challenges.  It is recommended that a suite of complementary tests be used to cover all types of adulteration and fraud.  Provenance testing has been successfully done using stable isotope methods.

This piece was orginially published in The Rotten Apple, a weekly newsletter about food safety, food fraud and sustainable supply chains. 

Take a Look at The Rotten Apple Newsletter

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How to do a Vulnerability Assessment for Storage and Distribution

From the desk of Karen Constable, our Principal Consultant

The other day, a frustrated food safety manager wrote to me, wanting help to figure out how to do a food fraud vulnerability assessment for storage and distribution (BRCGS Issue 4).

It’s such a tricky one, because storage and distribution (S & D) facilities have so little direct control over product choices.  And the BRC standard is so wordy!

The good news is that when BRC first added product fraud to their storage and distribution standard in 2018 (Issue 3), they wrote a position paper that attempted to provide some guidance.

Even though Issue 4 is a bit different to Issue 3, the guidance in the position paper is still useful.

Here’s just a small portion of guidance from BRC Position Paper:

“The Standard does not define the exact process that the company must follow when completing the vulnerability assessment;however, it is likely to incorporate the following steps:

  • draw up a list of products and services and the controls that are already in operation (e.g. approval of suppliers by customers, pre-packaged products purchased)
  • consider any relevant information regarding potential fraud for each product and service
  • complete a risk assessment on the vulnerability of the products.

The output of the vulnerability assessment is usually a ranking or scoring of the materials to identify those which need additional controls. The ranking and actions required could, for example, be as follows:

  • Very high – a high-profile product with recent reports of adulteration or substitution published by regulatory authorities. Action or monitoring is required to ensure that only genuine materials are purchased.
  • High – a high-profile product that provides an attractive target for potential substitution or adulteration. Some action and/or monitoring is required to ensure that only genuine materials are purchased.
  • Low – this product is unlikely to be a target for substitution or adulteration. However, a re-assessment may be necessary if new information becomes available.
  • Negligible – no further action is required as the product is extremely unlikely to be a target for fraud.”

 

There’s more in the position paper, which you can read or download from the BRC Website: https://www.brcgs.com/media/1055426/sd308-position-statement-accommodating-the-requirements-of-gfsi-benchmark-72-into-issue-3-v2-12082019.pdf

If you are completely new to vulnerability assessments, we have step-by-step instructions on our website, which might help a little if you haven’t seen it yet.  Plus, our on-demand, online food fraud training might also help.  Although both of these resources were created primarily for food manufacturers the concepts of vulnerability assessments also apply to S & D facilities.

I can also assist with custom one-on-one consulting, guidance/feedback or custom templates if you need.   Just get in touch and we can hop on a phone call to discuss.

Regards,

Karen Constable

Food Fraud Advisors