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.
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.