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Food Safety Standards Compared (2022)

 

food vulnerability assessment

 

When it comes to food fraud, each food safety standard has slightly 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.

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 protecting the retailers’ 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 time-consuming and often 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 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, 2022. 

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 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? – Implied

(Clause 5.4.1)

 – – 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 of Prerequisite and Food Safety Programs, 2023 (NEW!)

BRCGS Food Safety, Issue 9 (NEW!)

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

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 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.
  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. 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.

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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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Top 5 Food Frauds of 2022 (so far)

Food Fraud Advisors’ Principal, Karen Constable, shares her top five food frauds for 2022.

At the time of writing, we’re almost halfway through 2022.  This year we have discovered some interesting frauds, and unfortunately also plenty of food frauds that occur over and over. Due to the criminal nature of food fraud, each of the examples shared here represents just a tiny proportion of the food fraud that is being perpetrated on a daily basis across the globe.

The incidents and fraud types in this list have been chosen because they pose food safety risks to consumers or are likely to be affecting large numbers of products.

Traditional Guatemalan candies on street stall during Lent in Antigua, Guatemala

 

  1. Counterfeit Wonka chocolate bars in the United Kingdom

Counterfeiting is a type of food fraud where a well-known brand of food or drink is produced by an unauthorised manufacturer and passed off as the real thing.  In the case of Wonka bars, the brand owner is Nestle.

A man was caught in March 2022 for supplying counterfeit Wonka bars to retail outlets in the United Kingdom.

To make the counterfeit chocolate bars, the fraudster would have had to use heavy industrial food manufacturing machinery, which is expensive, and order custom-printed packaging, which is also expensive and can usually only be purchased in large quantities.  That’s a significant financial investment.

Because of the high costs to manufacture the fake products, we can infer that the fraudster must have expected to make significant profits.  We know that the risk of getting caught did not deter him because he was prosecuted for doing the same thing in 2016.  In April 2022 he pleaded guilty to doing it again.

One source says that Nestle, the legitimate brand-owner, no longer makes Wonka bars.  However, at least three online candy stores in my home country (Australia) are selling them today, which makes me think that there are counterfeit Wonka bars in many countries.  This could be quite a big operation.

The British authorities said that some of the counterfeit bars found in the United Kingdom contained undeclared hazelnuts, which makes them seriously dangerous to allergic consumers.

  1. Secret tank in milk tanker fraud in Italy

This fraud is unusual.  Or perhaps it happens a lot but is rarely exposed.

In this fraud, a truck used for transporting milk had been modified so that the milk could be diluted with water just prior to unloading.  This allowed for milk to pass quality tests, and then to be diluted after passing the tests but before being pumped into the purchasers holding tanks.

Like the counterfeit chocolate bars, this type of fraud requires significant financial investment; it is expensive to make major modifications to stainless steel tanks.  Only two shipments of milk were confirmed to have been affected, but it is likely that the fraud was intended to be done on a much larger scale.

This fraud poses risks to food safety because the water used to dilute the milk could be contaminated, and the tanker might not be able to be properly cleaned because of the extra hardware inside the holding tanks.

Listen to the whole (fascinating) story of how the fraud was discovered here:

  1. Seafood smuggling

Seafood smuggling is a ubiquitous food fraud.  It happens a large scale, all the time.  It is happening now, in 2022.

Seafood smuggling results in traceability problems that go right through the supply chain.  It’s estimated that at least 10% of seafood in any retail outlet has been affected by food fraud at some point between harvest and store.

Governments lose money from seafood smuggling because taxes, tariffs and duties are avoided when seafood is smuggled.

Smuggled seafood is significantly more likely to have originated in illegal catch areas, or caught in excess of fishing quotas, so it puts a strain on the environment as well as having an economic cost.  Smuggled seafood can also be affected by species fraud, where the fish is mislabelled.

When frozen seafood is smuggled it may also be affected by expiry date fraud too.  Expiry date fraud is when old frozen seafood is relabelled so it looks ‘younger’ than it actually is.

A large seafood smuggling ring was discovered by authorities in China in February of 2022, and this is probably the tip of the iceberg when it comes to seafood smuggling.

Seafood fraud is more common than you might think

 

  1. Organic fraud with grains and cereals from Eastern Europe

False claims about the organic (or ‘bio’) status of grains and cereals is a type of food fraud we call misrepresentation.  Organic fraud in bulk commodities is probably happening frequently in 2022, exacerbated by supply chain issues from the Ukraine war.

With this type of fraud, the grains or cereals are conventionally-grown, but their documentation is forged to make it look like they are organic.

Example: a shipment of oats was seized by authorities in Italy in January 2022 because they were alleged to have been falsely labelled as organic.

  1. Country of origin fraud

This type of fraud occurs commonly and affects packaged retail products across many food product categories.

In Europe in 2022, there have been quite a few incidences of country-of-origin fraud and protected designated origin (PDO) fraud, including:

  • A market operator in Italy was accused of country-of-origin fraud in relation to dried fish, legumes and spices which were claimed to be from Africa and Japan but which were instead from countries deemed ‘at risk’, meaning they require official clearances before being sold.
  • Products including fresh fruit, vegetables, mushrooms and honey in France displayed rates of up to 30% “anomalies” in the way the origin of the food was declared.  The survey focussed on food from outside of France being incorrectly declared as being French.
  • Significant quantities of bulk wine and bottled wine was seized by Italian authorities who allege the wine was labelled or was going to be labelled with false claims regarding its geographical provenance.

***

Want the inside scoop on frauds like this?

Become a paying subscriber of The Rotten Apple for weekly food fraud updates.

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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

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Frequently Asked Questions

Vulnerability Assessment Tool (BRC Method) – Frequently asked questions (FAQ)

Is this assessment tool suitable for businesses operating to food safety management system standards other than BRC?

This spreadsheet is designed for food fraud vulnerability assessments for businesses that manufacture food in accordance with the requirements of BRC’s (British Retail Consortium) GLOBAL STANDARD FOOD SAFETY, Issue 7 and Issue 8, which require that businesses assess their ingredients and raw materials for vulnerability to economically motivated adulteration, substitution or dilution.

The risk assessment methodology and matrix are based on the recommendations of the British Retail Consortium in their document Understanding Vulnerability Assessment (2015).  It is not suitable for vulnerability assessments on finished food products.  It is not recommended for businesses that need to meet the requirements of other food safety management system standards.  It is not suitable for food defense vulnerability assessments.  We recommend you purchase our other tools instead.

Is this assessment tool suitable for businesses that do not operate a food safety management system?

If your business is not operating to a food safety management standard and does not have supplier approval processes, purchasing specifications and robust systems for receiving materials then it is more vulnerable to accepting fraudulent material and this tool will underestimate the risk.

If your business is not operating to a GFSI standard, you should check out our other tools to help you prepare your vulnerability assessment.

What happens if I can’t complete all the questions?

If you have not answered all the questions the tool will calculate a high vulnerability rating. However it is possible to supplement the calculated rating with your own estimate if desired. This means that if you already think that a particular raw material has a very low risk of occurrence or detection you may choose to simply enter your best estimates of likelihood instead of completing all the data fields. This will allow you to prioritise your time and focus on the most important raw materials and ingredients first.  Note that if you do this the resulting assessment documents are unlikely to be acceptable to an auditor because they will not contain a complete explanation of how the risk assessment was performed.  To obtain a complete explanation, every question should be answered.

What if I disagree with the results?

The Vulnerability Assessment Tool calculates likelihood of occurrence and detection using information entered by the user.  Users are encouraged to also enter their own estimates.  The reported results are based on the user’s estimates if they have been entered; if not, calculated results are used.

Why are some of the questions repeated?

The tool was developed to be closely aligned with the recommendations of the British Retail Consortium in their document Understanding Vulnerability Assessment (2015).  That guidance document describes the elements that should be considered when assessing likelihood of occurrence and likelihood of detection and according to the British Retail Consortium’s methodology there are a number of elements that should be included in both occurrence and detection assessments.

Why is the Vulnerability Assessment Tool an Excel spreadsheet instead of specialised software?

The tool was created for Quality Assurance Mangers and Food Safety Managers to use. It was created with Microsoft Excel because most of its intended users are familiar with excel and so can begin entering data as soon as they open the spreadsheet, with no special training.   Data can be copied, pasted and searched just as you would in any spreadsheet and results can be easily extracted for use in other documents. Blank and completed spreadsheets can and should be incorporated into a company’s controlled documents and record-keeping system and Microsoft Excel files are usually suitable for this purpose.

The tabular format of the data entry pages allows users to have a ‘whole picture’ visual understanding of the data that has been entered and the gaps that need to be filled.  Other types of software such as questionnaire-style assessments do not provide a visual overview and require information to be entered in a defined series of steps which can be frustrating. Within the tables of the Vulnerability Assessment Tool, colour-coding functions provide instant feedback about whether an answer affects vulnerability in a positive or negative way, which can be a valuable learning tool.

Why are some of the cells password protected?

Password protection has been applied to many of the cells in the spreadsheet.  There are a number of reasons for this, the most important of which is so that users do not accidentally ‘break’ the formulas which would be very easy to do if it was unlocked.

This means that users are not able to make changes to the wording of the questions or the automatically generated answers.

Can I copy the results into my own spreadsheet or other document?

Yes. The data can be copied, pasted, sorted and manipulated as in any spreadsheet. When copying from the tool use the excel function ‘paste special – values’, which will prevent pasting formulas that might return error values in a different document.

Do I have to purchase a new spreadsheet for each material group?

No, you may make as many copies of this spreadsheet as you need for ONE food business in one manufacturing location.  You may not share it with other food businesses or take it when you change jobs.  For complete terms and conditions click here.

Is there a telephone number I can call for help and support with the tool?

For support, please email support@foodfraudadvisors.com with your query, including your preferred contact details and geographical location (for time zone purposes). We will contact you by telephone or Skype or email an answer to you.

January 2022: Why aren’t the formulas working?

Microsoft 365 recently switched its default Excel formula settings so that by default, formula calculations are turned off.

This means that none of the formulas in any spreadsheet will work until you switch the calculation function back on. To switch formula caluculations on, go to the ‘Formulas’ tab on the Excel ribbon and choose ‘Calculation Options’ on the far right. Set calculations to ‘Automatic’. This will fix the problem.

Can I have access to the formulas that generate the results?

If you disagree with the results the tool allows you to override them; the reported results are based on the user’s estimates if they have been entered; if not, calculated results are used.

If you think the methodology, including the risk calculations should be amended or you think there is an error in any formula please contact us. We want the Vulnerability Assessment Tool to be the best that it can and value your feedback.

Want to buy an unlocked version that is fully customisable?  Request a quote here.

My security settings will not allow me to run macros, is this a problem?

No problem; the Vulnerability Assessment Tool has been created without macros to keep things safe and secure and to prevent headaches with your internal IT systems.

I only have Microsoft Excel 1997 – 2003, will this be a problem?

No problem; the Vulnerability Assessment Tool is compatible with Microsoft Excel 2004 onwards (file extensions .xlsx) and Microsoft Excel for Mac 2011 onwards.  For more information about compatibility, click here.

Can I get a tax receipt?

Australian purchasers receive a tax invoice for GST purposes in their confirmation email.  Purchasers in other countries are not charged any tax but receive an itemised purchase receipt in their confirmation email.

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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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