Food Fraud Advisors

You are here: Home / Archives for food fraud consultant

by

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.

by

Raw Material Specifications

Raw material specifications are an important defence against food fraud for all food businesses.  Whether you are a restaurant, a specialty grocer, delicatessen, central kitchen, hotel or manufacturer, you are susceptible to food fraud.  Robust specifications can help to protect your food business from inadvertently purchasing, using or serving fraudulent ingredients and raw materials.  They can also help to protect your business from the financial fall-out if things go wrong.

Fraudulent materials include:

Modern Dairy food-processing industry Worker On A Milk Factory

Specifications for raw materials and ingredients should contain the following information:

  1. Name of the material
  2. A description of the material, including biological, chemical and physical characteristics
  3. Composition of the material, including additives and processing aids
  4. Country of origin
  5. Method of production
  6. Packaging format/s or unit of measure
  7. Delivery method/s
  8. A description of the labelling, lot ID and coding for traceability
  9. Storage conditions and shelf life
  10. Preparation and/or handling before use
  11. Acceptance and rejection criteria
  12. Requirements for certificates of analysis for high risk materials or vulnerable materials
  13. Special requirements such as allergen information, organic status, GMO status, fair-trade and ethical sourcing policies
  14. Information about compliance with statutory and regulatory requirements, where relevant
  15. A requirement for suppliers to notify of any authenticity issues with the product
  16. A requirement for suppliers to notify of any changes to the product
  17. Formal agreement between the supplier and purchaser
  18. Document control features, such as author, date and page numbers.

Download our excellent template today

How to develop a raw material specification:

  • Create a template that suits the needs of your business.  A tabular format is easy to work with.  Include all of the sections above, even if you don’t think you will use them now, or if they are not relevant to some of your materials.  You can always leave them blank.
  • You should create a separate specification for every unique material, do not create category-level specifications.
  • Obtain product specifications from your suppliers and use them to add key criteria to your specifications.
  • Add any extra criteria that will help you to control the quality, safety and authenticity of your products.  It is useful to imagine that you are receiving the material at your door or loading dock; what would you like to know about the material before you accept it? For example: Is it at the correct temperature?  Is it properly labelled?  Is the packaging undamaged with no evidence of tampering?  Is the material free of undeclared allergens?  Does it have the fat content you expect?  Has it been aged (meat) for as long as you expect?  Is it free from salmonella?  Use these questions to check that you have included all important criteria in your specification.
  • Don’t forget to include requirements for suppliers to have a food safety certificate, licence, approval or registration, where relevant.
  • If you are purchasing materials under fixed supplier contracts (as would be the case for  food manufacturers), the draft specifications will need to be approved by your purchasing department and by the suppliers themselves before they can be formally issued and implemented.
  • Review each specification at least annually and update the issue/review date.

Need help?

Contact Us Today

Our food safety and authenticity experts can develop your purchasing specifications. Click here for a free introductory consultation.

by

Letter from Thailand – food fraud, food safety, food excellence

The World of Food Safety Conference was held in Bangkok in conjunction with THAIFEX in early June 2017.  Delegates represented large and medium sized food businesses in South East Asia as well as government and trade organisations.  Thai, Singaporean, Malaysian and Myanmar delegates dominated the group.  The attendees were hungry for knowledge about food fraud and food fraud prevention; almost 50% of the topics across the two-day conference were related to food fraud, traceability, supply chain management and crisis management.

As well as speaking about recent trends and developments in food fraud, I enjoyed learning from the other speakers, sampling the wonders of THAIFEX and enjoying Thai food which was truly excellent.

Karen Constable spoke about Food Fraud at World of Food Safety Conference

 

Background checks as an aid to fraud mitigation

I was lucky to gain some fantastic insights into the intricacies and challenges of performing background checks on business people in Asia from Jingyi Li Blank,  Mintz Group.  Background checks on business owners are a great way to understand vulnerabilities to food fraud when seeking new suppliers or investigating sources of new raw materials.  South East Asia and China present some challenges for companies performing background checks, including the way that people in the area often have multiple spellings and versions of their names, as well as issues related to cross-border jurisdictions.

Prevalence of food fraud prevention systems

Julia Leong from PricewaterhouseCoopers shared some statistics on current levels of compliance among food companies who have interracted with the PwC SSAFE tool: 41% of companies have no systems to detect or monitor fraud, 36% have no whistle-blowing systems and 38% do not perform background checks on employees. Food businesses that neglect these areas are exposing themselves to serious financial risks from food fraud.

Support for food businesses in developing countries from GFSI

It was heartening to hear about the new program being launched by the Global Food Safety Initiative (GFSI) in developing countries.  The Global Markets Program is designed to bridge the gap between food operations with no formal food safety systems and those who have GFSI-endorsed certification by helping companies to develop food safety management systems through a process of continuous improvement.  Within the program, manufacturing support systems related to hygiene and other basic principles of food safety are implemented progressively over a defined time period as the companies work to attain either a basic or intermediate level of compliance.  The results are not accredited but become the foundation for further improvements so that the business can work towards implementing a complete food safety program.

Sustainability in the food supply chain; palm oil and coconut oil

Matthew Kovac of Food Industry Asia presented on behalf of Cargill, providing a fascinating introduction to the sustainability programs Cargill has introduced in their palm oil and coconut oil supply chains.  Cargill is a major grower, purchaser and refiner of palm oil and are aiming for a 100% sustainable target by 2020.   For Cargill, sustainability in palm oil means:

  • No deforestation of high value areas
  • No development on peat (burning beat causes air pollution and contributes to climate change)
  • No exploitation of indigenous peoples
  • Inclusion of small land holders

Coconut oil sustainability is being improved in conjunction with The Rainforest Alliance, by providing training and support for Filipino growers so that they can increase their yields, as well as providing them with access to wood fired dryers that allow the growers to produce copra that has better colour, less aflatoxins, less environmental contaminants and lower free fatty acids than traditionally sun-dried copra.

The many and varied hazards in HACCP for fish

It was both fascinating and scary to be reminded of the hazards to food safety from fresh fin fish by Preeya Ponbamrung, from Handy International: pathogenic bacteria, viruses, biotoxins such as ciguatera, biogenic amines (histamine being the most common), parasites and chemicals such as water pollutants and antibiotics used in aquaculture.  That’s quite a hazard list; it was heartening to hear Ms Ponbamrung describe the control methods employed by the fish processing industry to keep those hazards out of our food supply.

Crisis communications; winners and losers

We learnt about successful methods – and not-so-successful-methods – that food companies use to communicate food safety and food fraud risks to consumers.  Nestle was applauded for its fast, clear and practical response to reports of counterfeit versions of its popular MILO chocolate drink powder in Malaysia.  The brand owner promptly published instructions for consumers on social media and in the local press explaining how to tell the difference between the fake and the real product.

Image: MILO Malaysia Facebook, March 2015

 

Some other companies do not do so well with crisis communications.  Cesare Varallo of Inscatech, showed us that the public communications of Chipotle in the USA about its food safety problems were less than ideal.  The brand has suffered serious losses and it has been reported that 13% of its former customers say they will never return.  Time is of the essence in a food safety or food fraud crisis.  Does your company have a crisis plan?

Want to know more about any of these topics?  Get in touch with us, we love to help.

by

Food Fraud Survey

Have you ever been a victim of food fraud, either as a consumer or while working in the food industry?  It’s likely that at some point you have paid too much for a ‘premium’ product that was not exactly what it should have been.  Foods such as olive oil, organic products, fish and specialty beef products are commonly misrepresented to purchasers.  Take the food fraud survey to find out it you have been affected.

Take the survey

by

Vulnerability assessments are a waste of time according to this investigator

Vulnerability assessments are a hot topic in food safety at the moment, with Global Food Safety Initiative (GFSI) food safety standards set to include requirements for documented food fraud vulnerability assessments in the near future.  Most food safety and food integrity experts believe that vulnerability assessments are an important first step towards preventing fraudulent foods from reaching consumers.   However, in an interview with Food Safety News, Mitchell Weinberg, food fraud investigator and CEO of Inscatech describes food fraud vulnerability assessments as “frankly… a little bit of a waste of time.”  Mr Weinberg says that a food fraud vulnerability assessment is essentially about recording what you already know.  He explains that if a business is sourcing a food ingredient from a developing country, they should already know that it is more likely to be affected by fraud than if sourced locally.  Likewise, high value and high volume materials are more attractive to fraudsters.  Weinberg tells the interviewer:

“Just use common sense, figure out where the problem is, check it out… trust but verify.“

Weinberg is right; creating documented risk assessments of any kind is simply an exercise in writing down what we already know.  And common sense should be at the core of any risk assessment.  So is there any value in a documented vulnerability assessment?  

Absolutely!

  • A documented assessment is a record of who thought of what and when they thought of it.  It is evidence that fraud has been considered; it can be used to check that common sense was used in that consideration.  It can be audited, reviewed and updated.  It can be shared.
  • The process of creating a documented assessment can serve as a prompt to identify gaps in knowledge and provide an incentive to ‘fill in the gaps’.
  • A documented vulnerability assessment can be used to transfer knowledge.  Weinberg says creating a written assessment is making a record of what you already know; that is exactly what is needed when the person who made the assessment changes jobs or has to explain supply chain risks to a stubborn Purchasing Manager.
  • Most food businesses manufacture hundreds of food products and many more hundreds of ingredients; comparing the vulnerability assessments of different products and materials is an effective way to prioritise fraud prevention actions.  While the ultimate aim is for no product to be compromised ever, we all have to start somewhere.

Read more about Vulnerability Assessments here.

To view the interview with Mitchell Weinberg, click here.