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#1 CLN

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Posted 19 July 2017 - 07:46 PM

Hello  

 

After performing an assessment on Food Fraud under the Food Safety Warehouse and Distribution Edition 8, I am about to request an exemption from SQF 2.7.2 Food Fraud, but before I do - can someone within this Forum convince me that 3PL warehouse that provides just storage, and doesn’t own ingredients, or doesn't control incoming and outgoing of packaged ingredients can prevent deliberate fraudulent acts, or detect fraud without the customer assistance?

 

Your input into the Economically-motivated adulteration (EMA) well be appreciated.

 

David


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#2 SQFconsultant

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Posted 20 July 2017 - 12:58 AM

We presently have three clients for development of their Edition 8.0 for storage and distribution and all are 3PL - all of them essentially passing through palleted food products and ingredients for their customers.
 
While the food and ingredients are in their chain of custody/or one might say chain of supply responsibility they have full control and responsibility for these items while in their care.  You can't say your facility does not have control of the product/ingredients - they are under your roof, they are your responsibility to protect your customers products and you are responsible to create the Food Fraud plan under 2.7.2 just like all of our 3PL clients must do.
 
You can attempt to get an exemption from this clause, however I seriously doubt the CB will waive it.

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Glenn Oster

 

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#3 CLN

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Posted 20 July 2017 - 02:32 PM

Perhaps I’d used the word “control” too loosely. We do understand that we have ownership at the storage level between our four walls and transport to our customer manufacturing sites. However, what you are suggesting “below” sounds more like Food Defense Planning rather than Food Fraud planning. Otherwise, I have to assume these other 3pl warehouses are ordering the customers product/Ingredients and approving their supply vendors for their customers, therefore requiring a Food Fraud Plan.

Our customer’s control the supply chain process from Vendor Approval, Purchasing, Incoming Appointments, Storage Requirements, Product Sampling Plan, and shipping, and we provide sanitary food grade warehousing and transportation.
With all this said, as part of our customer’s approved supply chain vendor process, they should develop a food fraud assessment plan that would notify the 3pl warehouse if active fraudulent event is occurring for their supply chain.

Meanwhile, I am going to contact our customer “who are SQF level 3” if they have us as a contact for their EMA plans.

Thanks for your input, I am learning something new every time I use this site for information, and guidance.

David


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#4 SQFconsultant

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Posted 20 July 2017 - 05:37 PM

No David, not food defense, food fraud - every single one of our 3PL do one thing - they are simply acting as a pass thru storage facility, but each one must develop a food fraud program.


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Warm regards,

 

Glenn Oster

 

SQF Registered Consultant - Certified for 29 FSC's

Serving clients in: USA, Costa Rica, Panama & Caribbean Islands

International Toll-Free: 800-546-1452

 

http://www.linkedin.com/in/getgoc

 

www.GlennOsterConsulting.com


#5 Madam A. D-tor

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Posted 20 July 2017 - 06:24 PM

No David, not food defense, food fraud - every single one of our 3PL do one thing - they are simply acting as a pass thru storage facility, but each one must develop a food fraud program.

 

This is an interesting case.

 

First let me say that I do not know no have experience with the standard you are discussing.

However SQFconsultant, like David, I believe you are talking about food defense instead of food fraud.

Food fraud is intentional substitution, addition, tampering, or misrepresentation of food, food ingredients, or food packaging; or false or misleading statements made about a product for economic gain. To have economic gain large numbers ( a whole batch or production) should be involved.

If these logistic service suppliers only handles fully enclosed packs in order of the customer/owner of the products and are not involved in sourcing or selecting suppliers, how can they have a role in food fraude control?

I am sure you can make a documented program for it, but what is in it?

Is it perhaps the role of the 3PL to notice any deviations at reception? This is IMO always a responsibility of the 3PL and is not specifically involved in food fraud. Please note that food fraud is not to be seen at the packaging. The packaging is not damaged. The packaging is containing something that is not on the label: Organic while it is not, too less meat, no 100% olive oil but mixed with sunflower oil, not yellow fin sole but rock sole, not Irisch lamb but Canadian, goat cheese made of mixed goat and cow milk, etc. A logistic service supplier that is only moving pallets with products has little involvement in controlling this.

 

@ David,

I do agree with SQFconsultant that CBs are not happy to gain exemptions. This should be motivated in your manual. Mostly this motivation is also a risk assessment.


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Madam A. D-tor

#6 CLN

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Posted 20 July 2017 - 07:35 PM

A. D-tor

 

Regards to your statement, “If these logistic service suppliers only handle fully enclosed packs in order of the customer/owner of the products and are not involved in sourcing or selecting suppliers, how can they have a role in food fraud control?  I am sure you can make a documented program for it, but what is in it?”

The underlined words. you hit on it on the head!  

 

I have a Food Safety meeting with our HACCP team tomorrow evening, and I am sure this will be hot-topic where I must defend SQF clause, but don't have enough science base evidence out there support especially that we don’t store the top ten known fraudulent foods.

 

Thanks, everyone for contributing to this topic, and I hope this starts lots of backdoor conversations about Food Fraud.

 

David

 


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#7 Madam A. D-tor

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Posted 20 July 2017 - 08:10 PM

[....]

I have a Food Safety meeting with our HACCP team tomorrow evening, and I am sure this will be hot-topic where I must defend SQF clause, but don't have enough science base evidence out there support especially that we don’t store the top ten known fraudulent foods.

[...]

 

Well, if you know that you do not store the top ten known fraudulent foods, that you probably did some kind of risk assessment. It is a start.

How do you know, you do not store this? How will you be kept informed about this top ten? it will surely change. Do you select the products/customers that are stored? If some customer wants to store a product that is known to be fraudulent, will you refuse it? On which base?  I think you already have thought about it. Maybe even discussed it? If you document these thoughts, you already have a food fraud policy.

 

How will you recognize fraudulent businesses?

Slightly off topic: I once audited third party transport and storage provider and the director told me the following story. When the company has just started and was not as big, there was a new customer that really wanted to hire a few pallet places. This new potential customer would not say, who recommended the service supplier. This new customer was willing to pay a high price for the storage of the pallets. The director at that time agreed with it. When the pallets arrived, he saw that the product (fresh pine apples) were not the best quality, but he also noted that the pallet was not stacked very well. When he took a closer inspection he saw some bags in the middle of the cartons (only cartons on the outside of the pallet, leaving space in the middle of the pallets). He did not know what to do and was very afraid for his family who lives next to the company. He did not do anything. When the customer loaded the products he did not say anything. After that, he refuses this customer, even though the customer was again offering high prices. After this he also learned to be suspicious if a customer offers to pay high prices. "If the price is too good to be true, it is probably too good to be true." Would you have recognize this situation on forehand?


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Madam A. D-tor

#8 CLN

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Posted 20 July 2017 - 08:31 PM

.

A.D-Tor

 

In reference to "Do you select the products/customers that are stored? If some customer wants to store a product that is known to be fraudulent, will you refuse it? On which base?  I think you already have thought about it. Maybe even discussed it? If you document these thoughts, you already have a food fraud policy."

 

We had address this issue and performed background checks on potential customers, and will refuse any dealings with suspicious company as part our food defense Plans.

 

Thanks you gave me something to bring to the table tomorrow that is useful.

 

David

 


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#9 Charles.C

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Posted 20 July 2017 - 09:28 PM

This is an interesting case.

 

First let me say that I do not know no have experience with the standard you are discussing.

However SQFconsultant, like David, I believe you are talking about food defense instead of food fraud.

Food fraud is intentional substitution, addition, tampering, or misrepresentation of food, food ingredients, or food packaging; or false or misleading statements made about a product for economic gain. To have economic gain large numbers ( a whole batch or production) should be involved.

If these logistic service suppliers only handles fully enclosed packs in order of the customer/owner of the products and are not involved in sourcing or selecting suppliers, how can they have a role in food fraude control?

I am sure you can make a documented program for it, but what is in it?

Is it perhaps the role of the 3PL to notice any deviations at reception? This is IMO always a responsibility of the 3PL and is not specifically involved in food fraud. Please note that food fraud is not to be seen at the packaging. The packaging is not damaged. The packaging is containing something that is not on the label: Organic while it is not, too less meat, no 100% olive oil but mixed with sunflower oil, not yellow fin sole but rock sole, not Irisch lamb but Canadian, goat cheese made of mixed goat and cow milk, etc. A logistic service supplier that is only moving pallets with products has little involvement in controlling this.

 

@ David,

I do agree with SQFconsultant that CBs are not happy to gain exemptions. This should be motivated in your manual. Mostly this motivation is also a risk assessment.

 

Although requirement does seem rather bizarre for "storage", probably is "food Fraud" as per thread title and equivalent to BRC (=GFSI) -
 

 

2.7.2      Food Fraud
2.7.2.1      The  methods,  responsibility  and  criteria  for  identifying  the  site's  vulnerability  to  food  fraud  shall  be
documented,  implemented  and  maintained.    The  food  fraud  vulnerability  assessment  shall  include  the  site's
susceptibility  to  product  substitution,  mislabeling,  dilution  and  counterfeiting  which  may  adversely  impact  food
safety.
2.7.2.2   A food fraud mitigation plan shall be developed and implemented which specifies the methods by which the
identified food fraud vulnerabilities shall be controlled.
2.7.2.4    Records of reviews of the food fraud vulnerability assessment and mitigation plan shall be maintained.

 

(SQF8 Storage and Distribution)

 

Food defence is 2.7.1

 

For some (unknown to me) reason 2.7.2 appears not to be mandatory whereas 2.7.1 is

 

@CLN - I don't quite see how yr customers control the storage if it's (apparently) your responsibility to provide "sanitary food grade warehousing " ?

 

Perhaps it refers to things like changing the labels ?


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Charles.C


#10 CLN

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Posted 21 July 2017 - 03:23 PM

Good Morning Charles,

 

In regard to Customer Controls storage. The customer has the capability to control their product systemically through Electronic Data Interface (EDI) with very little interaction for the warehouse staff.  Which the Customer can do the following, Place orders, specify how product/ Ingredient is received, storage condition (ambient or cold storage), Quarantined, Sampled, Release, and how the product/ Ingredient is distributed.   And like you said, we provide the “Food Grade Warehousing” with the Sanitary Transportation to their manufacturing site or any other option they choose to make.

 

I was confused when I read the clause 2.7.2, with words in the sentence like “Shall” like the other people who mistook this as mandatory.   Now that we know this not mandatory, does this mean if we choose to not perform an assessment we won’t be dinged by the SQF auditor?  


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#11 Charles.C

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Posted 22 July 2017 - 04:53 AM

Good Morning Charles,

 

In regard to Customer Controls storage. The customer has the capability to control their product systemically through Electronic Data Interface (EDI) with very little interaction for the warehouse staff.  Which the Customer can do the following, Place orders, specify how product/ Ingredient is received, storage condition (ambient or cold storage), Quarantined, Sampled, Release, and how the product/ Ingredient is distributed.   And like you said, we provide the “Food Grade Warehousing” with the Sanitary Transportation to their manufacturing site or any other option they choose to make.

 

I was confused when I read the clause 2.7.2, with words in the sentence like “Shall” like the other people who mistook this as mandatory.   Now that we know this not mandatory, does this mean if we choose to not perform an assessment we won’t be dinged by the SQF auditor?  

 

Hi CLN,

 

IMEX 'mandatory" usually means something like "must"

 

IMEX all the FS Standards sometimes have flexibility at places in the use of  English language. Regrettably the flexibility is not always consistent.

 

IIRC (somewhere) SQF do offer their intentions behind terms like "should, shall" etc and probably "mandatory" also (a rather more significant term IMO).

 

(Perhaps somewhat redundantly[?]) SQF8 Manufac. Code has -

All mandatory and applicable elements of the SQF Food Safety Code shall be audited at each site irrespective of the findings of the corporate audit.

 

 

I deduce SQF's "mandatory" is "stronger" than  SQF's "shall". :smile:

 

Since the clause discussed is as yet non-functional, the answer may be in the new SQF FAQ on their website (somewhere). If not i have no idea (not a SQF user). Sorry.


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Charles.C


#12 CLN

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Posted 22 July 2017 - 02:18 PM

Charles

Thanks for the clarification 👍


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#13 Karenconstable

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Posted 30 July 2017 - 02:39 AM

Interesting comments above.  I have one thing to add...

 

Food fraud can take the form of genuine products being 'diverted' and replaced with  'fake' or inauthentic foods.  For example, a pallet of genuine (expensive) whisky could be swapped with a pallet of counterfeit whisky while in storage.*  This type of food fraud is very much within the control of the storage facility.  A famous case of food fraud was the theft of huge amounts of maple syrup from a warehouse in Canada; people had gone into the warehouse, poured syrup out of the drums and left the drums behind.  No one noticed that the drums were empty for a long time.   Google 'maple syrup heist Canada' if you are interested to read more.

 

So your food fraud prevention program should most certainly address your facility's vulnerabilities to food fraud of the 'substitution', 'theft' and 'diversion' types, as well as the scenarios described in the other posts above.

 

* Note, some food safety standards would consider theft or diversion type frauds to be within the scope of their food fraud requirements, some would not.  My interpretation is that the BRC standard does not require controls for this type of food fraud, it only mentions adulteration or substitution of food raw materials.  SQF Edition 8 specifically mentions counterfeiting, product substitution and mislabelling.


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#14 CLN

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Posted 31 July 2017 - 01:01 PM

Thanks for your input into this topic. I had reviewed several periodicals and expert opinions over the last several days.  And from what I had gathered, I will give more consideration to people guidance that only pertains to 3pl warehousing with our type of customer base. In other words, not all 3pls operate in the same matter.

 

In Addition, I will be addressing most of these issues that were brought up in this forum that equates to site security, and a separate section for addressing Intentional Economical Adulteration (IEA) that warehouse is potentially susceptible to.

 

Again, thanks for your advise.

 

David


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#15 Madam A. D-tor

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Posted 01 August 2017 - 05:33 AM

[....]

Food fraud can take the form of genuine products being 'diverted' and replaced with  'fake' or inauthentic foods.  For example, a pallet of genuine (expensive) whisky could be swapped with a pallet of counterfeit whisky while in storage.*  This type of food fraud is very much within the control of the storage facility.  A famous case of food fraud was the theft of huge amounts of maple syrup from a warehouse in Canada; people had gone into the warehouse, poured syrup out of the drums and left the drums behind.  No one noticed that the drums were empty for a long time.   Google 'maple syrup heist Canada' if you are interested to read more.

 

So your food fraud prevention program should most certainly address your facility's vulnerabilities to food fraud of the 'substitution', 'theft' and 'diversion' types, as well as the scenarios described in the other posts above.

[...]

In my opinion theft etc  is not related to food fraud, but to food defense.

This is included in Food Security in the BRC Food standard.

 

4.2: Security systems shall ensure that products are protected from theft or malicious contamination while under the control of the site.

4.2.1: The company shall undertake a documented assessment of the security arrangements and potential risks to the products from any deliberate attempt to inflict contamination or damage. Areas shall be assessed according to risk; sensitive or restricted areas shall be defined, clearly marked, monitored and controlled. Identified security arrangements to reduce risks shall be implemented and reviewed at least annually.


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Madam A. D-tor

#16 jalex1940

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Posted 18 August 2017 - 01:30 PM

Hello, we are a CO-OP manufacturer and all of our supplies and ingredients are sent to us by the company we produce for. My question is, how can 2.7.2 Food Fraud pertain to our establishment?


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#17 CLN

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Posted 21 August 2017 - 03:21 PM

In reference to Manufacture Co-op:

 

This is a dulling task to perform an assessment for Food Fraud, but after performing some brain storming activities using our Food Safety Plan “Product Flow Process” as a guide, our Food Safety Team (FST) were able to determine that Food Fraud is a human element.

 

With this bit of information, we had reviewed each job responsibly and we were able to uncover some situations where Opportunities, Motivation, and Lack of Control Measure could lead to potential food fraud incidents – Therefore, mitigation is required to develop preventive control measures.

 

There are web sites on the internet that can help you develop your Food Fraud strategies for three categories, Opportunities, Motivation, and Lack of Control Measures, at least able to explain it better than I can.

 

I hope this helps, Good Luck!

David


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#18 agasr

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Posted 21 August 2017 - 11:03 PM

David, 

We fit into the same category of 3PL as you. Planning to apply for exemption for Food Fraud alone (not food defense) with CB as well for the same reasons you quoted in your original post. The Guidance document on Module 12 should come out soon. Once that is published we plan to apply for exemption by the way. 

 

Thanks for posting this on this forum. 

 

Regards, 

agasr.


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#19 CLN

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Posted 22 August 2017 - 04:09 PM

Agasr,

 

Does your 3PL destroy obsolete materials for your customers?  If so, we had learned there is an opportunity in our dispositional process for Finished Goods (Retail Products) that are susceptible to food fraud. Someone could easily swap these loads to the landfill or farm centers if there is no control measure in place to prevent this actionable item.

Regards,

David


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#20 agasr

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Posted 24 August 2017 - 10:14 PM

CLN, 

No we dont dispose off customer products. We facilitate to ship out to landfills, again, per customer requirements. When such requests come through we request them to supervise it and take care of. 

Hence, our current thinking that we can apply for an exemption. Let us see, I will know more when the SQF S&D 8.0 guidance come out. 

 

Thanks and Regards, 

agasr. 


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