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Exemption from food Fraud SQF8


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#1 Hoosiersmoker

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Posted 28 December 2017 - 08:34 PM

I am also in the middle of trying to determine if we can request exemption from the food fraud portion of SQF edition 8 as a food packaging manufacturer. We are a food contact packaging manufacturer but our process is conversion from raw paper rolls through finished product. The initial risk assessment shows no step in the process that fraud could occur. I will be polling our carton group members first of the year to see if any of them have additional input on this but as for now it looks like another section we need at the very most to reference in our program but not actually have to do anything with. If anyone has specific facts regarding this please let me know.


Edited by Charles.C, 05 January 2018 - 10:00 PM.
split off from fssc22000 thread


#2 namorris

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Posted 05 January 2018 - 05:36 PM

hoosiersmoke - Have you had any resolution to your comment? I am facing a similar issue using FSSC22000 v4.1 upgrade (ISO22000 standard)



#3 Charles.C

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Posted 05 January 2018 - 10:01 PM

hoosiersmoke - Have you had any resolution to your comment? I am facing a similar issue using FSSC22000 v4.1 upgrade (ISO22000 standard)

 

JFI, Note that FS standards are not same.


Kind Regards,

 

Charles.C


#4 FurFarmandFork

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Posted 05 January 2018 - 10:04 PM

I doubt you would be exempt. If you currently purchase an ingredient that is supposed to be "food grade" like resin, and they could reasonably sell you "non-food grade" material that would be cheaper for them, that's an obvious incentive for fraud.

 

Now, whether you determine that to be significant or not in your vulnerability assessment is totally up to you, and you can chalk it up to your supplier approval program to keep it in check (reputable suppliers). But that's different from requesting an exemption.


Austin Bouck
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#5 SQFconsultant

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Posted 06 January 2018 - 12:25 PM

No exemption that I know of would apply for a mandatory requirement.


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#6 Hoosiersmoker

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Posted 19 April 2018 - 05:47 PM

SQF consultant. Food Defense is but Food Fraud is not a mandatory element according to the guidance documents I have (Ed 8 Sec 2.7.2). The ED for Food Packaging also does not list it as Mandatory



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#7 Quality Is the Goal

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Posted 23 April 2018 - 08:19 PM

2.7.2 is not mandatory, but 2.4.4 Approved Supplier Program is mandatory.

 

2.4.4.5 The site's food fraud vulnerability assessment (refer to 2.7.2.1) shall include the site's susceptibility to raw material substitution, mislabeling, and counterfeiting which may adversely impact food packaging safety.
2.4.4.6 The food fraud mitigation plan (refer to 2.7.2.2) shall include methods by which the identified food packaging safety vulnerabilities from materials shall be controlled.

 

My company producing food contact packaging material such us wax paper and in April we just had an SQF pre-assessment audit and Auditor was asking for mitigation plan and food fraud procedures, so im pretty sure there is no exception, or You will have to have a good justifications. 



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#8 romanfj

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Posted 14 May 2018 - 03:32 PM

Can you prove that there is no possible way for any of your suppliers to potentially substitute one or more components in the materials or products they sell you?

 

If so, you may be the most fortunate person ever to be in QA/QC  :smile:

 

If not, this is the reason one qualifies one suppliers.  Through the qualification process, you can evaluate whether they are likely (or not) to potentially defraud you.



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#9 jdominguez

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Posted 09 July 2018 - 08:46 PM

I am in the same boat and stumped. our customers are our suppliers, we perforate food contact packaging materials. :headhurts:



#10 Hoosiersmoker

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Posted 07 September 2018 - 12:51 PM

I will be requesting an exemption from the Food Fraud requirements as we purchase all raw materials form the manufacturers direct, most of them use their own equipment (In continuous control pre-delivery, no opportunity for substitution) the rest are direct ship also. The risk is determined to be as low as it could be. I will complete the assessment and use it as the reason for the exemption. I will let you know how it all goes. Hopefully, it will help other packaging manufacturers if they grant the exemption.



#11 Hoosiersmoker

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Posted 07 September 2018 - 02:20 PM

I think I will add that to my list of reasons to gain exemption - BRC doesn't recognize it as even necessary to include in their Food Packaging Manufacturing module. that being the case and knowing they have a recognized GFSI standard, how can they be different. It's either required or it isn't, right?



#12 Hoosiersmoker

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Posted 07 September 2018 - 02:26 PM

I still maintain that is why SQF doesn't list it as a required element in Module 2 - It doesn't apply to all food sector categories, i.e Food Packaging Manufacturers. My list of reasons for an exemption is growing! Thanks everyone! Wish me luck.



#13 Charles.C

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Posted 07 September 2018 - 02:28 PM

I think I will add that to my list of reasons to gain exemption - BRC doesn't recognize it as even necessary to include in their Food Packaging Manufacturing module. that being the case and knowing they have a recognized GFSI standard, how can they be different. It's either required or it isn't, right?

 

Hi Hoosiersmoker,

 

Apologies that actually my comment was (sort of wrong context) for BRC Food Manufacturing Standard. I haven't checked the BRC Packaging Standard.

 

 I deleted my Post until checked out for BRC Packaging Standard. :smile:

 

Nonetheless your comment is certainly correct re Food Standard.


Kind Regards,

 

Charles.C


#14 Charles.C

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Posted 07 September 2018 - 02:38 PM

addendum

 

The BRC5 Packaging Standard seems to have no mention of either fraud or vulnerability. Or defense for that matter.

 

Perhaps "Packaging" flies under the GFSI Fraud radar also ?


Kind Regards,

 

Charles.C


#15 Hoosiersmoker

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Posted 07 September 2018 - 03:11 PM

I agree that it seems suspicious food fraud being absent from BRC but any manufacturer of food, food related or food packaging has to at least comply with the 2002 Bio-terrorism act in the U.S. so food defense is federally mandated anyway. It is interesting that BRC doesn't address something that SQF deemed a huge addition to Edition 8. And given the amount of threads here why is it suspiciously absent from the BRC code? Or is it "Coming soon to a facility near you!"



#16 Hoosiersmoker

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Posted 07 September 2018 - 04:24 PM

It seemed a little too suspicious so after further digging I did find this from the BRC website: https://www.brcgloba...p-and-guidance/ Near the bottom of the page there are 3 "Position Statements" P552 appears to include Food Defense and Food Fraud as included in audits as of the issue date:

 

Food Fraud

Definition used in the BRC Global Standard for Food Safety

“Fraudulent and intentional substitution, dilution or addition to a product or raw material, or misrepresentation of the product or material, for the purpose of financial gain, by increasing the apparent value of the product or reducing the cost of its production.”

Definition used in GFSI benchmarking Issue 7

“A collective term encompassing the deliberate and intentional substitution, addition, tampering or misrepresentation of food, food ingredients or food packaging, labelling, product information or false or misleading statements made about a product for economic gain that could impact consumer health.”

Application in the packaging industry

Again, a risk assessment approach will help sites in determining if there is opportunity in their supply chain, raw materials management and processes for fraudulent activity to take place.

Potential sources of fraud for the packaging manufacturer include:

  • Fraudulent raw materials, e.g. non-FSC board/pulp sources in place of FSC board.
  • Downgrading or substituted product, e.g. selling recycled board as virgin.
  • Packaging which has been bought by non-genuine people, e.g. buyer purporting to be from a brand owner.

 

The potential hazards affecting brand owners that packaging manufacturers can help to mitigate include:

  • Genuine packaging which is misappropriated for fraudulent products, where excess printed packaging has been illegally obtained and is essentially indistinguishable from genuine products.
  • Fraudulent packaging which has been printed with genuine branding/artworks, where the brand logo has been obtained and is being used on fraudulent products.
  • Misrepresentation of the retailed product, i.e. fraudulent packaging and a fraudulent product retailed as a genuine product.

 

Two of these three points can be affected by the packaging manufacturer. For example, if the management of excess printed packaging materials is effective, ensuring that it is not possible for these types of materials to be used, then the risk of this scenario is reduced.

 

Similarly, where the site has proper control of logos and branding that has been given to them in order to print or decorate packaging materials, the likelihood that these can be obtained and mis-used by unauthorised parties.

Requirements in 4.10 – Waste and waste disposal, 5.2 – Graphic design and artwork control, 5.3 – Packaging print control, and 5.7 – Control of non-conforming product are all relevant as they contain requirements outlining the site’s responsibilities with regards to management of digital data, such as logos, control of printing plates and other decoration media, and management of excess materials and non-conforming (but useable) materials. This is not just with regards to physical items, digital security is crucial so sites should be investigating their systems vulnerabilities.

When auditing these clauses, BRC expectation is that the assessment shall result in a plan to manage the identified hazards associated with raw materials or groups of materials. This will include:

  • The identification of the measures to reduce the risk
  • Implementation of the identified processes to manage the risk
  • Testing and assurance processes (monitoring) where applicable is effectively applied
  • Corrective and preventative actions where testing or checks indicates failure
  • Annual review of the assessment (plan) for effectiveness.

 

These changes should be included as part of audits from the date of issue of this document. However, it is not expected that non-conformities shall be raised until July 1st 2018.



#17 Hoosiersmoker

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Posted 02 October 2018 - 05:57 PM

OK so here's the update: After a thorough Vulnerability Assessment finding no way for substitution or diversion, I made a request for exemption from 2.7.2 Food Fraud from our Auditing body and in less than 30 minutes received AN EXEMPTION!!! I am to keep all of the information (Assessment, letter requesting the exemption and scoring matrix) including the email granting the exemption in case the auditor needs to review it, which I'm sure he will. 1 Month until audit... wish me luck on all of the other areas that we aren't exempt from!



#18 Charles.C

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Posted 03 October 2018 - 01:45 AM

Hi Hoosiersmoker,

 

I admire yr perseverance in ploughing through all the clauses/sub-clauses/original sources in order to request an exemption.

 

However i don't quite see how an action (ie VA)  specifically requested by a (non-exemptable) mandatory clause can separately be exempted ?


Kind Regards,

 

Charles.C


#19 Hoosiersmoker

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Posted 03 October 2018 - 01:43 PM

I have performed the VA and have it for the audit but all other aspects of 2.7.2 are exempt. I guess they figure it difficult to require action for no reason, being exempt basically means that section doesn't exist so why request documentation for something that doesn't exist?



#20 Scampi

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Posted 03 October 2018 - 02:03 PM

The SQF code has a lot of areas where one could apply for an exemption

 

For example......I will be applying for an exemption to the environmental swabbing based on my risk assessment...............SQF only made the risk assessment section mandatory thereby allowing companies to at least request an exemption

 

Even CFIA states that in our food category, environmental swabbing is not a good use of food safety time/effort as my products have been scientifically validated 1000 times over to not harbour pathogens OR spoilage organisms

 

2.4.8 Environmental Monitoring
2.4.8.1 A risk-based environmental monitoring program shall be in place for all food and pet food manufacturing
processes.
2.4.8.2 The responsibility and methods for the environmental monitoring program shall be documented and
implemented.
2.4.8.3 An environmental sampling and testing schedule shall be prepared, detailing the applicable pathogens or
indicator organisms to test for that industry, the number of samples to be taken and the frequency of sampling.
2.4.8.4 Environmental testing results shall be monitored and corrective actions (refer to 2.5.3.1) implemented
where unsatisfactory trends are observed.
 
And this section does not say (mandatory) beside it like all the others do
 
IMHO SQF has tried really hard to be everything to everyone without actually understanding any of the process' they are trying to write a code for.....

Because we always have is never an appropriate response!


#21 Hoosiersmoker

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Posted 03 October 2018 - 02:34 PM

In the past our auditor just marked these sections as N/A and moved on.



#22 Hoosiersmoker

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Posted 03 October 2018 - 02:39 PM

The one size fits all codes are becoming obsolete and will likely be replaced by code for each specific food sector category that include the requirements from module 2. At least then they can add as needed or split categories as needed.



#23 Scampi

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Posted 03 October 2018 - 03:20 PM

Here here...............easy on both ends

 

Now...........if we could just get some auditors with applicable work experience...............


Because we always have is never an appropriate response!


#24 Charles.C

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Posted 03 October 2018 - 10:29 PM

I have performed the VA and have it for the audit but all other aspects of 2.7.2 are exempt. I guess they figure it difficult to require action for no reason, being exempt basically means that section doesn't exist so why request documentation for something that doesn't exist?

 

Hi Hoosiersmoker,

 

I presume that as per 2.4.4.5 you will be obliged to repeat/update the VA for each audit.

 

Seems to me that this, albeit not in name, will still effectively involve parts of all of  2.7.2.(1, 3, 4).


Kind Regards,

 

Charles.C


#25 Hoosiersmoker

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Posted 04 October 2018 - 11:29 AM

I would think, generally speaking, throughout edition 8, changes in raw materials, new equipment or processes, new facilities etc. require you to immediately perform all assessments anyway so we would still have to do the assessments under those conditions but, as I said, if Food Fraud doesn't exist would an assessment for it exist? This is uncharted territory for me as well so I will ask those questions during the audit and get back to you.

 

I almost hope there's another Auditor assessment this year like we had last year because we were told that the person doing the auditor evaluation could be used as a consultant if we had any questions but she couldn't intervene with the actual audit so we asked her a TON of questions and she was very helpful.






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