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#60958 Micro. Guidelines for Food Contact Surfaces

Posted by Charles.C on 30 April 2013 - 03:03 PM

Dear All,

I previously posted a table of various micro. guidelines for food contact surfaces which were mostly issued pre-2000 at this link –


To update the earlier info., the attached excel file presents guideline data I have accumulated for 12 countries issued in the period 2000 – 2012. The compilation demonstrates that for a range of food-related scenarios, some “average” opinions for various (just) cleaned surfaces are –

(a) For Aerobic Plate Count (APC) - the majority of data suggests that, for routine cleaning/sanitising, surfaces typically have maximum APC counts in the range 10-100cfu/cm2 .
(b) For factors like Coliform, (generic) E.coli, Enterobacteriaceae, S.aureus, the expected maxima are, predictably, low, eg 1-10 cfu/cm2, or undetected. The latter requirement also invariably applies for “zero-tolerance” pathogenic microbial species.

Hopefully of some interest. Further input / comments welcome as usual.

Attached File  Compilation of International Micro. Guidelines for food contact surfaces, 2000 onwards.xls   993KB   6486 downloads

Rgds / Charles.C

#87813 Are you happy with your job?

Posted by Nancy@Masser's on 14 April 2015 - 12:23 PM

I have been actively job searching for several months.  While I believe in our products and love my co-workers; the top management in my company does not support food safety.  A food safety culture has to come from the top.  And if a vice-president of the company won't take the gum out of his mouth when he walks through the facility how am I supposed to tell the workers they can't chew gum??  And that's just one tiny example of how what I try to do gets sabotaged.  I could go on and on.  It's laughable. 



#158542 The Coronavirus (COVID-19) is a hoax thread - the ONLY topic for discussing a...

Posted by GMO on 14 April 2020 - 11:46 AM

I never expected to see a thread like this on here.


There are interesting questions.  One, for example is in 2015 the flu vaccine, at least in the UK was only about 30% effective and there were over 20,000 additional deaths that year, not all, but most due to flu.  We didn't see that in the same way.  Why?


Well there are good reasons not to.  COVID 19 is more contagious, partly because some people are asymptomatic, partly because people who do go on to severe symptoms are initially asymptomatic.  This means it spreads hard and fast.  20,000 may be where we get to in the UK but only because of the controls we've put in place.


I sensed a flippancy in my peer group team around it to start with.  Estimates vary and will only ever be accurate once everybody is tested but initial reports had it at around 1-2% mortality.  We have 1000 people on my site.  I said to my team, are you ready for 10-20 of our team to die?  You see, that's the problem.  Low death rates are one thing in theory but when the 1-2% are people you care about, it's very different.  When one of my team got it and was in hospital, I can tell you my fear and my tears were very real.


I get that this kind of lock down cannot continue forever and there is a difficult balancing act to be had.  The economic impact of this close down is catastrophic and will kill people.  Cancer operations and chemotherapy has been stopped.  That will kill people.  The isolation will drive up mental health disorders.  That will kill people.  It's not simple.  It's really not simple at all.


In the meantime, I'm doing what I do, working as a key worker, making food for the nation and helping support people like my sister who works for the NHS.  Let us not succumb, as sadly so many others have, to irrationality.  We're scientists.

#158116 The Coronavirus (COVID-19) is a hoax thread - the ONLY topic for discussing a...

Posted by wtheriot on 02 April 2020 - 09:22 PM

Refer to New England Journal of Medicine.


A peer publication.


Dr. Fauci is pretty much telling the truth to his fellow doctors who are for the most part the reader of the NEJ.


Unfortunately, Dr. Fauci will then get on TV a number of times and tell people virtually the exact opposite of what he said in the well regarded NEJ.


He is afterall a government shrill.


I absolutely love listening to Richie from Boston, someone who I've listened to for quite a while now - way before this hoax pandemic thing started.


You'll find the NEJ article entry and the date of publication in one of this most recent videos.


Some folks are offended by what I write, and like Richie, I really don't care how people feel about what I have written here - I love my country, always have, I love the people and that is all I really care about.


https://www.youtube....hie from boston

I again have to state that this is the most unprofessional statement I have read on this forum. It gets even worse form someone who has continuously cited his experience as an "auditor" and now sells his consulting services.

Regardless of your personal opinion, the world has initiated a "pandemic" response, requiring all of us under a GFSI to work our programs to the max and help each other. This help may be to ensure employee safety (for those that feel this is a serious health risk) OR to pass the next audit following this situation. I assure you, audiotrs WILL BE REVIEWING CRISIS MANAGEMENT procedures.


Absolutely nothing helpful about the above comment or other posts concerning COVID-19.


Today our city ordinances increased  and now required us as an essential business to remain open, we must do health screening in the form of respiratory test or temperature test. We have been assessing our document needs as well as testing our protocols once someone is sent home with a high temperature. Again, we have our local and state government requiring us to do this and now are being inspected by any one of several city departments to ensure we are compliant. we aren't real interested in tin hat theories about hoaxes, we are seeking solid risk based assessments and documentation.

#158091 The Coronavirus (COVID-19) is a hoax thread - the ONLY topic for discussing a...

Posted by majoy on 02 April 2020 - 05:22 PM

Glen, you have the exact same idea as some people i know all citing the Event 201 as justification of what was happening in the world.


At this point, it is not up to what WE (or as an individual person) believe anymore.


If you are working in a food manufacturing facility and under government oversight (USDA, CFIA etc.) and they are telling you that you should put a procedure in place for the "outbreak", are you going to tell them NO and that this is a hoax? this is a planned event and argue that more people die from seasonal flu?

You cannot just choose to ignore the GOVERNMENT as an employee or even as business owners - our hands are tied.


I respect other people's opinion on this "pandemic", but to operate a business in this time, you have to comply with the government regulations - you simply cannot impose what you PERSONALLY believe anymore.


Now, if this is really staged event and there is a group or people who made up all this pandemic -- good for them, they are so good to put all the countries to its knees. Its done, no turning back on this.


Let's just share our professional advice here on what we are doing to address the requirements of the government to be able to operate our businesses and make safe food available for the public.

#150301 SQF Audit Time -- ASK QUESTIONS, Don't Just Sit There!

Posted by SQFconsultant on 25 October 2019 - 02:57 PM



As an SQF Consultant I've sat in on several first time (and second, third, etc etc) certification audits.


Not as an active participant, but as an observer.


Some of the audits I've sat in on were ones that we had no prior engagement, but most we either had developed their entire SQF system for them/working in conjuncton with them or had contributed heavy consulting time to the company to develop or recover (or what we call getting Humpty Dumpty back on the wall again consulting.)


Now to the meat of things...


As Consultants we can not jump in during an audit to run block for the client - we can observe and discuss things with our clients at breaks, lunch, etc.


The idea is to prepare clients for audits - well before the audit occurs.


To have them become quite knowledgable about the code, standards, everything and to bring sets of the code to the audit for everyone as well.


You want to be prepared and not look at the Consultant for help, becuase if you do there is a possibility you will be gig'd for lack of knowledge by the Auditor.


This posting however is about lack of knowledge by Auditors and how you as the auditee should behave during the audit -- at the conference table, etc.


As an SQF Consultant there is nothing more sinking (feeling) than watching an SQF Auditor repeatitly miss-call items, make gigantic errors and then watch the facility personnel sit there and take it without saying anything.




If you are fully up to speed as the SQF Practitioner and know the code you have no reason whatsoever to not challenge a finding that is wrong.


Some folks feel that challenging an Auditor is a bad thing - I find that not challenging an Auditor that is 100% wrong is the really, really, really BAD thing.


Look, I was one of the first SQF Auditors in the US and I will admit having made a couple of errors, all of which I corrected - but I was never, ever challenged.


And I think the reason why people don't challenge Auditors is due to fear of the unknown.


It's not always an easy thing to challenge an Auditor, for all concerned included the Auditor, but if the Auditor is wrong the question is - Are you willing to take the gig because you are afraid to say something?


On the last Audit that I sat in on the SQF Auditor miss-called 10 (yes, ten) items and gave a major where it should have been a minor - the company personnel froze up and would not challenge - they were willing to take a failure because they were afraid of the Auditor and what he (as they said ) might do to them the next time around if they challenged him.


In this case I challenged him - technically speaking it was not my place to do so. But I knew there was no way there was going to be a failure on  my watch.


So, I challenged him on each point.


We got back all 10 and the major was made a minor.


It disturbed me greatly that there are a number of incompetent SQF Auditors out there - it disturbed me that our client froze up even though going into the Audit they were in good form.


And I am not tooting my horn here, beleive me I really thought about not saying anything, but I just could not sit there and let the situation happen.


All of this comes down to this ----


Know the SQF Code

Know your facility

Be Prepared


Let the Auditor know that you and your team know the code

Let the Auditor know that you will challenge him/her on any items that you feel are miss-placed, wrong, etc.


It's OK to put them on guard, they will certainly be a lot more careful in application.


Stay on task - don't volunteer information to an Auditor unless asked.


Don't let the Audtor nor you get into banter about family, about how this other company did badly or well on their SQF Audit, etc.


Get a good nights sleep and have food and coffee service brought in - everybody appreciates that and it is not seen as a bribe.


Be SQF at your Audit.


Ask questions - don't be a sitting duck waiting for the bullets.


Thank you for your time.

#145926 How many Non-conformances did you get at your last audit?

Posted by The Food Scientist on 24 July 2019 - 07:21 PM

SQF in April, score: 95 


Was my first sqf audit. Next year is unannounced! Is it bad that I'm nervous already? 


My very first audit was unannounced. I was even only 2 months in the position, alone with no guidance or help, got a C,  how about that?  :roflmao:

#47832 Please share an example of a mock recall report

Posted by George @ Safefood 360° on 09 August 2011 - 04:00 PM

Hello Carine,

I've attached a PDF of a product recall record/report that would comply with the global food standards. I hope you find it helpful...


Attached File  Product Recall Report.pdf   65.08KB   5525 downloads

#220 Example HACCP Manual and Procedures for Packaging Company

Posted by Simon on 06 June 2003 - 09:32 AM

The zip file below (approx. 228 kb) contains:

- Hygiene management procedures (with index and list of supporting documents)
- Supporting Documents
- Example HACCP study manual
- BRC/IoP Gap Analysis Checklist

This documentary system has achieved certification to the BRC/IoP Packaging Standard - category B. Obviously all of the procedures were in place and fully implemented.

zipped hygiene documents

Please note:

1. Although in the procedures microbiological auditing (swabbing etc.) is not a requirement of the standard but was always carried out by this company as a customer requirement.

2. You are welcome to do what you want with these documents (apart from sell them). They are provided free, 'as is' and with no warranty. They are provided solely as examples to give you ideas. They must be reviewed and amended as appropriate to your own organisation, product and process etc.

If documents are missing or anybody wants a specific document just ask in here. Also if you want to talk about documents again we can do it in here.

#179408 Competition: Close Encounters of the Food Safety Kind

Posted by Simon on 11 October 2021 - 02:50 PM

Hi all, after spending the day reading through all the stories and comments I've come to realise I cannot select the top three let alone rank the positions.  You are all awesome and have unique and varied stories so I'm proposing in the spirit of the forum we share the prizes between all those who interacted with this competition.  I'll only do this if there is a majority that agree.  So this would mean that the 17 members mentioned below would receive.


$25 amazon voucher and you all get a t/shirt.
Please send an email to team@ifsqn.com with your name and address and email.


If you are really against this proposal please say below or send me a message.


Rey Sierra

#178543 SQF Edition 9 Code Amendments

Posted by Scampi on 16 September 2021 - 07:51 PM

I object to the amendments wholeheartedly (and already cover all of them--we can't have emergency suppliers in my commodity)


Then allegedly spend months and months nitpicking the code prior to release.............only to turn around and amend


As soon as retailers got involved in food safety it's been a rapidly downword spiral, and no appreciable reduction in recalls see link http://blog.globalfo...mber-of-recalls


If these "schemes" worked, there would be a direct reduction............instead they revise the code in ridiculous ways, and the bad actors still pass and still infect consumers 


End rant

#178536 SQF Edition 9 Code Amendments

Posted by TylerJones on 16 September 2021 - 07:01 PM

SQF is turning into BRC.... I guess I can write up my policy to have ALL visitors submit a negative COVID test 72 hrs prior to being at the plant, thus negating a unannounced audit. 

#177888 A few pointers from our SQF Ed. 9.0 unannounced audit

Posted by TylerJones on 26 August 2021 - 02:53 PM

Hi all, just passed a SQF Food Manufacturing 9.0 unannounced audit with a 99. A few pointers from this audit for anybody interested: Food Safety Culture results need to be given out to all employees. Best way I did that in my operation was to post in the breakroom. Auditor was specifically calling out posting of results over what was specifically in the culture plan. Did check that the company policy stated food safety culture was implemented. EMP cannot just be risked away. Seems like there will be no way in the future to have a low risk product over a 4.0 pH level without testing for a pathogen unless you have scientific data such as an industry standard. Really seemed to like having cyber attack as part of CM. Ingredients imported from developing countries- have plenty of supporting documents to back up your RA for Food Fraud. Other than those few areas nothing stood out. Best of luck!



#165000 What does your visitors policy look like during Covid-19?

Posted by Simon on 02 September 2020 - 06:01 PM

I try hard to bite my tongue, but I find it insulting to hear lucky covid-19 naysayers spouting their hoax rubbish.
Two people I knew very well, both in their 50’s, died of covid-19. 

#157352 During COVID-19 should we be cancelling visits and rescheduling them as a way...

Posted by Simon on 16 March 2020 - 08:47 PM

I am aware that Coronoavirus is a very emotive topic, but can we please stay 'on topic'. wherever possible. 


The original question was.


During COVID-19 should we be cancelling visits and rescheduling them as a way to protect our staff from potential exposure?


We have to remember that discussions are not just for those posting in the topic, but probably more so for those who come here looking for answers to their questions.


If we want to have a "What is the root cause of Coronavirus (facts and conspiracy theories)?" then no problem, but start it in the "Community General Chat" sub-forum.


Thank you.


#157342 During COVID-19 should we be cancelling visits and rescheduling them as a way...

Posted by wtheriot on 16 March 2020 - 07:08 PM

So now, FSSC is in the BS as well by requiring an impact statement for CV.  

I dont think this is a very professional response. Since all of our jobs are in the "risk managmeent" area, calling a virus "BS" is about as unprofessional as you can get.


If nothing else, business contingency plans must be worked in case of supplier shortages that cause disruption.

#91342 2.5.1 Responsibility, Frequency, and Methods

Posted by ChocoTiger on 14 July 2015 - 08:37 PM



Here are generic examples of what is needed for,,, and  The programs I included in this are the prerequisite programs required by SQF.


Let me know if you need any additional help.



#50651 Yoghurt Risk Assessment (ISO 22000, 7.3 - 7.4.4)

Posted by Charles.C on 22 December 2011 - 03:15 AM

Dear All,

I attach 1st version of an ISO/fssc 22000 yoghurt hazard analysis / CCPs etc with some explanatory information on additional sheets as indicated. I hope the content is intelligible.

If you hv any comments/criticisms on the text, please do not hesitate to communicate.

Attached File  ISO 22000 Hazard Analysis for Yoghurt, yha 1.0a.xls   451KB   3852 downloads

Rgds / Charles.C

PS - Happy Xmas and New Year to Everybody !


#143928 Audit Template for FSSC 22000 (2018)

Posted by Charles.C on 14 June 2019 - 07:39 PM

Noticed this basic template while browsing.


Includes "Checklists" for  iso22000(2018), iso2002-1(2009), Additional Requirements 2.5.1.to 2.5.9


Note that the layout does not  detail individual sub-clauses [eg covers 5.1 but not 5.1 (a)] but may be useful for overall layout.


Attached File  Audit Report Template FSSC-22000 - 2018.pdf   455.01KB   1946 downloads


PS - just noticed this is same document as linked in a parallel thread -


#122778 Meeting the requirements of 2.7.2 Food Fraud

Posted by FurFarmandFork on 12 March 2018 - 04:46 PM

Figured I'd provide an example that got me through my audit in February and provide a reference thread since this question just keeps coming up.


The requirements in the SQF code 8.0 module 2: The site's food fraud vulnerability assessment (refer to shall include the site's susceptibility to raw material or ingredient substitution, mislabeling, dilution and counterfeiting which may adversely impact food safety. The food fraud mitigation plan (refer to shall include methods by which the identified food safety vulnerabilities from ingredients and materials shall be controlled. 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, counterfeiting or stolen goods which may adversely impact food safety. A food fraud mitigation plan shall be developed and implemented which specifies the methods by which the identified food fraud vulnerabilities shall be controlled. The food fraud vulnerability assessment and mitigation plan shall be reviewed and verified at least annually. Records of reviews of the food fraud vulnerability assessment and mitigation plan shall be maintained.



The associated guidance material:


What does it mean?


In July 2014, GFSI published a discussion paper “GFSI position on Mitigating the public health risk of food fraud,” in which it states “The GFSI Board recognizes that the driver of a food fraud incident might be economic gain, but if a public health threat arises from the effects of an adulterated product, this will lead to a food safety incident.”


Food fraud is often described as EMA, economically motivated adulteration. However, it is more than that. As well as adulteration, food fraud includes substitution, dilution, addition, misrepresentation or tampering of food ingredients or food products. It is in fact illegal deception for economic gain.


The economic risks of food fraud to the industry are apparent. It is estimated that fraud costs the global food industry between $US40bn -$US50bn every year (Australian Food News, 11th July 2017). However, the public health impacts are less so. In many cases, the health impact of food fraud is not known until after the fact, when consumers become sick and the adulterant is detected.


GFSI now requires that a food fraud vulnerability assessment and mitigation plan to be incorporated into the food safety management systems in all GFSI benchmarked schemes. SQF in edition 8 now requires food fraud to be considered for the site (2.7.2), and for incoming materials and ingredients (,


What do I have to do?


Although this element is not mandatory, it is a key GFSI requirement and can only be exempted on receipt by the Certification Body (CB) of a written request from the site justifying exemption. If the justification is accepted by the CB, the element can be exempted. If not, and the site has not completed a vulnerability assessment and mitigation plan, then the CB is required to raise a major non-conformance against 2.7.2.


For many sites, food fraud is a new consideration and the hardest part is getting started. What is a vulnerability assessment? What is a mitigation strategy?


The food fraud strategy is similar to the HACCP methodology sites are familiar with. In general terms, it is


: 1. Identify the risks (vulnerabilities)


2. Determine corrective and preventative actions (mitigation strategies)


3. Review and verify


4. Maintain records


The food fraud requirements talk about ‘vulnerabilities’ rather than ‘risk’. A risk (ISO 31000 Risk Management) is something that has occurred frequently before, will occur again, and there is enough data to conduct a statistical assessment. Vulnerability is more a condition that could lead to an incident (Dr John Spink, MSU). GFSI considers an “incident” to be a “consumer health risk if not addressed.”


‘Vulnerabilities’ need to be identified in incoming materials and ingredients, and within the site. Not all materials and ingredients are subject to risk, and the highest risks may be from minor or infrequent ingredients that originate from sensitive geopolitical areas, or suppliers with poor past histories. Ingredients can be prioritised based on perceived risk.


Within the site, vulnerabilities may include the potential for intentional or accidental substitution, dilution, or adulteration. The question that needs to be asked is “who benefits financially from internal food fraud?”


Mitigation strategies will be developed based on the identified vulnerabilities.


Although SQF requires that the food fraud vulnerability assessment and mitigation plan to be reviewed and verified at least annually, the site should be constantly aware of their supplier history and changes in the supply chain that could impact the vulnerabilities.


SQFI recommends that suppliers initiating their food fraud strategies seek assistance from one of the many resources that are available on-line. Although SQFI lists these resources, we take no responsibility for the information they provide or the outcomes of the assistance they offer


. SQFI partners with the Food Fraud Initiative at Michigan State University (MSU) http://foodfraud.msu.edu. This group offers free on -line training for sites and auditors on food fraud called Massive Open On-line Courses or MOOCs.


Other resources that could be considered include the PwC food fraud vulnerability assessment, and the USP Food Fraud Database.


Auditing Guidance


As with suppliers, food fraud is also relatively new to auditors, and SQFI recommends that all SQF auditors seek training in food fraud strategies through the resources outlined above, or through their internal CB training.


The auditor must avoid pre-determining site’s food fraud vulnerabilities or making a quick decision on 2.7.2 Food Fraud. Food fraud is a new and inexact science, and there is no prescribed methodology for determining vulnerabilities or their mitigating actions. It is based on the information that the site has available at the time.


The auditor will seek evidence of compliance to this requirement by review of documents and records, and interview. Evidence may include:


• There is awareness within senior management of the need for a food fraud vulnerability assessment and mitigation strategies.

• There is a current, documented vulnerability assessment in place that identifies key ingredient vulnerabilities including justification for their inclusion. The methodology for selecting the key ingredient vulnerabilities shall be available.

• The vulnerability assessment shall include an evaluation of the site vulnerabilities including from staff, contractors, and other associates.

• There are documented mitigation (ie prevention) strategies in place for all identified vulnerabilities, which identify what is to be done and who is responsible.

• The mitigation strategies are active, and are being reviewed for effectiveness.

• The vulnerabilities and mitigation strategies are reviewed at least annually.

• There are records available of review of the food fraud program.




From the actual portions of the code, I identified the required mandatory items in this clause:

  1. A vulnerability assessment must be conducted that includes an assessment of our susceptibility to the following types of fraud which may affect food safety (or quality if you’re under the quality code)
    1. Substitution
    2. Mislabeling
    3. Dilution
    4. Counterfeiting
    5. Stolen goods
  2. A mitigation plan shall include methods we use to control the identified vulnerabilities we identified in the vulnerability assessment that apply to us.
  3. A policy/SOP needs to state that we will conduct this vulnerability assessment at some interval and support it.
  4. We need evidence that the mitigation plan was implemented
  5. The plan gets reviewed annually, and some sort of verification takes place
  6. There need to be records of some kind
  7. They specifically state that it is similar to the HACCP methodology, so I should basically incorporate it into my HACCP plan anyway


What I did

I created a new “top tier” SOP titled “Food Fraud Vulnerability Assessment”. This ensured that I had a record of management review annually (signatures), it was signed off by the CEO (knowledge), and outlined “methods and responsibilities”.


I then completed this table for my vulnerability assessment and mitigation strategy, note that YOUR COMPANY’S identified susceptibility and mitigation strategies will be different than the examples below, but the fraud categories are all those that were specifically identified in the SQF Code (note, susceptibility and mitigation strategies have been altered in this example to protect confidential information, however the information provided below is very similar to that which was audited by NSF):

Fraud Category


Mitigation Strategy

Product Substitution or mislabeling(exchange for cheaper or inferior ingredient)

Several raw materials are potential targets at our company:

  • Incoming spices may be substituted for inferior or fumigated materials.
  • Salts/minerals/vitamins could be produced from non FCC materials
  • Preservative blends could be mislabeled or produced at inferior purity
  • Acid blends could be mislabeled or produced at inferior purity

Our supplier approval program and supplier preventive controls verify that products are received within specification and that business relationships are maintained with responsible/reputable suppliers.

Product dilution (added ingredients for weight that are not the intended ingredient)

Several raw materials are potential targets at our company:

  • Spices may be bulked with other substances when received ground.
  • Salts/minerals/vitamins could contain cheaper materials.
  • Preservative blends could contain cheaper materials.
  • Acid blends could contain cheaper materials.

Company supplier approval program and supplier preventive controls verify that products are received within specification and that business relationships are maintained with responsible/reputable suppliers.

Counterfeit company or private label brand goods sold

 [our brand] is not a national premium brand with a high price point that would encourage counterfeiting.

Branded label proofs are maintained solely at the printer and in a secure digital filing system. Obsolete or unusable labels are discarded via shredding or incineration, inventory of labels is kept that would identify theft.

Theft of Company goods

Low cost beverages are not a likely candidate for theft and resale due to the weight and space required for the product and low price point.

Outgoing freight is carried by licensed carriers and locks/seals are used in all full truckloads.


This fulfilled my requirements to perform an assessment of vulnerabilities to the types of fraud identified in the SQF code, and identified mitigation strategies to control them as appropriate.

The procedure section of the SOP indicated that individual ingredient assements would be carried out through our food safety plan, supplier approval procedure, and ingredient specification maintenance. Label control was outlined in our labeling SOP, and loading/shipping controls were outlined in that SOP. Tieing all of the documentation/records/evidence together.

Finally, in addition to “physical, chemical, biological, radiological, allergen” hazard categories included in my hazard analysis, I included “food fraud” as a category anytime it was a “receipt of material” or a specific ingredient, and identified if any FOOD SAFETY hazard required additional controls beyond those included in the vulnerability assessment to ensure that no safety hazard was at an unacceptable level of control.


Note, all auditors are different, but this was considered solid evidence of compliance in our audit conducted 2/28-3/1/18. Hopefully this helps some other folks out who don’t know where to start.