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Meeting the requirements of 2.7.2 Food Fraud

Food fraud VACCP SQF 8.0 Vulnerability Assessment

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#1 FurFarmandFork

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Posted 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:

 

 

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 or ingredient substitution, mislabeling, dilution and counterfeiting which may adversely impact food safety. 

2.4.4.6 The food fraud mitigation plan (refer to 2.7.2.2) shall include methods by which the identified food safety vulnerabilities from ingredients and materials shall be controlled.

 

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, counterfeiting or stolen goods 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.

2.7.2.3 The food fraud vulnerability assessment and mitigation plan shall be reviewed and verified at least annually.

2.7.2.4 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 (2.4.4.5, 2.4.4.6).

 

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

Susceptibility

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.

 


Austin Bouck
Owner/Consultant at Fur, Farm, and Fork.
Consulting for companies needing effective, lean food safety systems and solutions.

Subscribe to the blog at furfarmandfork.com for food safety research, insights, and analysis.

#2 maryd@allamericanseasoning

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Posted 12 March 2018 - 04:54 PM

Thank you for the information provided, but I am struggling to write an SOP on something I'm not too familiar with. Is it possible to share your SOP as an example?



#3 Charles.C

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Posted 12 March 2018 - 06:43 PM

Thank you for the information provided, but I am struggling to write an SOP on something I'm not too familiar with. Is it possible to share your SOP as an example?

 

Hi mary,

 

Perhaps you can try the free option recommended by SQF ?

 

@ 3F,

 

Appreciate yr monolog.

The practical problem looks identical to what BRC experienced a few years back.

Nobody yet understands exactly what Food Fraud means/SQF requires to be done to comply.

And can probably include the SQF auditors in that also.

It took BRC (and their auditors) over a year to remove some of the confusion during which almost any, preferably referenceable, Procedure could be regarded as a vulnerability assessment for "food Fraud". And may in fact still be so.


Edited by Charles.C, 12 March 2018 - 06:56 PM.
expanded

Kind Regards,

 

Charles.C


#4 FurFarmandFork

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Posted 12 March 2018 - 07:16 PM

Sorry, I didn't realize that the forum broke the table formatting (I wrote the post in word since it was so long). Here's an image of what I was talking about.

 

Attached File  food fraud vulnerability assessment and mitigation.PNG   55KB   29 downloads

 

@maryd, I spelled out the format and content of my sop in the post above and attached image, you can make one for your own process using the same template. If you need one made specifically for your company and ingredients there are many consultants on the forum (myself included) who would be happy to do so for a fee, however I wrote the post hoping that it provided enough information for others to make a similar SOP.

 

@Charles maybe it's because I have a relatively simple raw material list, but I really didn't find this new requirement/concept any more difficult than a HACCP hazard analysis, heck if something is a significant hazard as an ingredient for this reason it should already have been included there anyway? I felt like the SQF code and guidance was just as thorough at explaining what was required as they are for food defense.

 

 


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#5 Charles.C

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Posted 12 March 2018 - 07:25 PM

Hi 3F,

 

I deduce you consider hazard analyses are simple.

Hmmm. :smile:

 

I guess Food Fraud is not that complex in Principle until you try and "equate" it to Food Safety (eg via yr nice Table).

Maybe EMA is a better conceptual approach but "GFSI" liked the "could be FS-related" generic viewoint.  BRC had it textually "easier" (albeit equally FS debatable) than SQF since they were not obliged to separate FS and non-FS scenarios in their  FS Code.

 

Afaik there is general agreement that a minute proportion of Food Fraud events are safety related but also that where occurring they can be tragic in their consequences (eg melamine). Would that event have ever been scientifically FS predictable in an unweighted Vulnerability Assessment  for the Product(s) involved?


Edited by Charles.C, 13 March 2018 - 01:36 AM.
edited/expanded

Kind Regards,

 

Charles.C


#6 maryd@allamericanseasoning

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Posted 12 March 2018 - 09:15 PM

Thank you FurFarmandFork for the information. It was extremely helpful. I guess what I had in mind was more of a traditional SOP where you have a Purpose, Scope and Procedure on how to carry out a task.



#7 Charles.C

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Posted 13 March 2018 - 12:17 PM

Thank you for the information provided, but I am struggling to write an SOP on something I'm not too familiar with. Is it possible to share your SOP as an example?

 

Hi mary,

 

I haven't studied the SQF, VA requirements in detail  but JFI you might consider the procedures aready spelled out in 2-3 posts for VA as devised for BRC's food fraud demands.

These procedures are more explicit numerically than the layout in 3F's post and would need to be matched so as to include the specific items mentioned in SQF Code but I anticipate that the basic procedures presented should be perfectly acceptable for SQF-VA since afaik the chosen methodology is optional. (BRC do issue a specific, recommended, logic VA procedure for their Code [validation?] which has been utilised in links below.)

 

http://www.ifsqn.com...ate/#entry94061

 

http://www.ifsqn.com...542/#entry95464

http://www.ifsqn.com...542/#entry95690

 

 

http://www.ifsqn.com...ate/#entry94144

 

First and last links will need a little more thought as to selecting a criterion score for your situation. 2nd pair of links are self- integrated already.

 

Offhand, the last link  is probably the simplest format/procedure to adjust to match SQF but needs a little more thought to implement.

 

PS - note that this (BRC) post/excel contains some overlapping ideas/material to 3F's Table however the latter has been usefully customised for SQF.

 

http://www.ifsqn.com...542/#entry96114

 

PPS - IMO (as per BRC) the most likely result of using any of these various options will be an overkill in respect to what SQF are minimally needing. How much of an overkill will soon become obvious when audit feedback starts to be available.


Kind Regards,

 

Charles.C


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#8 MsMars

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Posted 13 March 2018 - 12:42 PM

Thanks for the info, FFF.  Our Food Fraud assessment and mitigation plan seemed to be enough to get us through the first Ed. 8 audit, but looking forward to simplifying and clarifying it to a point that it's actually useful to our establishment with the information that you've provided!



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#9 maryd@allamericanseasoning

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Posted 13 March 2018 - 12:50 PM

Thank you for the feedback. Greatly appreciated!!



#10 Scampi

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Posted 14 March 2018 - 02:51 PM

here are a couple of helpful links for fraud and food defense

 

https://www.pwc.com/...food-fraud.html

 

https://www.accessda.../fdplanbuilder/


Please stop referring to me as Sir/sirs


#11 Charles.C

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Posted 14 March 2018 - 10:20 PM

here are a couple of helpful links for fraud and food defense

 

https://www.pwc.com/...food-fraud.html

 

https://www.accessda.../fdplanbuilder/

 

Indeed the pwc tool has accumulated an envious number of mentions on this Forum. And also, from memory, a fair number of "Cons."

 

For some reason SQF seem to show preference for the Michigan MSU route to VA although there are few mentions here of its usage. Not totally free perhaps.


Kind Regards,

 

Charles.C


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#12 Mulan1010

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Posted 16 March 2018 - 03:15 PM

Thank you for sharing!



#13 Scampi

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Posted 19 March 2018 - 08:42 PM

This has been added to SQF to meet FSMA requirements. I was recently at a training session and the trainer suggested that we don't lose our heads over this and make it into something that it isn't. 

Do you lock doors YES

Do you inventory product YES

Do you verify labels YES

Do you spot check shipping/incoming/production YES

 

Then you've pretty much got it covered.

 

For me the biggest challenge was turmeric that we use.......has been laced with lead chormate.  Like PP mentioned, it was for economic gain, and it posed a PUBLIC safety risk, not necessarily a food safety risk


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#14 FurFarmandFork

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Posted 19 March 2018 - 10:16 PM

This has been added to SQF to meet FSMA requirements. I was recently at a training session and the trainer suggested that we don't lose our heads over this and make it into something that it isn't. 

 

No, I'm really interested to hear who your trainer was. Food Fraud is a GFSI requirement, so SWF had to add it to maintain the code's status as a GFSI approved auditing scheme.

"Although this element is not mandatory, it is a key GFSI requirement and can only be exempted on receipt by the Certification Body (CB)"

 

 

 

For me the biggest challenge was turmeric that we use.......has been laced with lead chormate.  Like PP mentioned, it was for economic gain, and it posed a PUBLIC safety risk, not necessarily a food safety risk

 

 

I am genuinely curious as to what you define as a public safety risk vs. a food safety risk? I've never seen that terminology and can't fathom how eating the food could be dangerous to the public but not be considered a food safety issue?

For me the biggest challenge was turmeric that we use.......has been laced with lead chormate.  Like PP mentioned, it was for economic gain, and it posed a PUBLIC safety risk, not necessarily a food safety risk


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#15 Charles.C

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Posted 19 March 2018 - 11:03 PM

This has been added to SQF to meet FSMA requirements. I was recently at a training session and the trainer suggested that we don't lose our heads over this and make it into something that it isn't. 

Do you lock doors YES

Do you inventory product YES

Do you verify labels YES

Do you spot check shipping/incoming/production YES

 

Then you've pretty much got it covered.

 

For me the biggest challenge was turmeric that we use.......has been laced with lead chormate.  Like PP mentioned, it was for economic gain, and it posed a PUBLIC safety risk, not necessarily a food safety risk

 

Hi Scampi,

 

I would have thought lead chromate in food was a public health hazard. Seems to be toxic ?

 

PS - looks like 3F beat me to it !

 

PPS - but, IMO, SQF do  surely face a conceptual problem in differentiating quality and safety for this general topic. USP in their long monograph discuss this aspect in some detail. BRC, I think, simply assumed any food fraud categorised possibility could be included in a FS Standard. And thereby complying with GFSI ?


Kind Regards,

 

Charles.C


#16 Charles.C

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Posted 19 March 2018 - 11:24 PM

addendum

 

despite my opinion above, i noticed this database categorisation of turmeric's FF sensitivity via lead chromate contained no specific mention of health risk. Hmmm.

 

Attached File  turmeric.png   141.04KB   8 downloads

 

PS - maybe compare the above to this extract from the USP document -

 

Once potential adulterants have been identified, the user should determine if they could cause harm. For some specific foods there are readily identifiable adulterants, either due to historic use or inherent characteristics, which have an established potential for causing public health harm (e.g., lead chromate in turmeric). In this case, the potential severity and nature of the public health harm from the consumption of one or more of the identified, hazardous adulterants is the driving force behind prioritizing the potential impact and this can be assessed considering the toxicity of the adulterant and the potential adverse health outcomes resulting from consumption of the adulterant

Edited by Charles.C, 20 March 2018 - 02:55 AM.
expanded

Kind Regards,

 

Charles.C


#17 Scampi

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Posted 20 March 2018 - 05:30 PM

Ok folks, I was talking about Food Fraud specifically..........the risk assessment requires that you look at how easily (or not) your ingredients could be adulterated and how frequently that may occur. 

For me, food safety risks are issues that your HACCP plan should cover, even the best written plan in the universe cannot PREVENT your supplier from sending you adulterated items, particularly when they come from very far afield. You can have a beautifully run program but unless you are performing independent chem/micro analysis on each and every ingredient for each batch, you have to rely on the approved supplier program to do it's job.

 

We need to never forget, even a certificate of analysis from your supplier is only as valid as your follow up

 

The difference for me with ADULTERATED items, is that had that ingredient been wholesome, your process would have allowed whatever your finished good is to be safe, ergo no food safety risk. Manufacturing adulterated foods where they may not get noticed is a public safety issue............the melamine in infant formula was not a food safety risk, the product was not the issue, it was cutting corners to make a buck that was the risk

 

Or to use another example, I go to grocery store, I buy what i'm told is red snapper (i trust my store, i go there every week) but what I'm really getting is tilapia, now the tilapa will not make me sick, but it isn't what I thought I was getting.      

This is such an epidemic that the University of Guelph in Ontario Canada is entering the dna of EVERY THING WE EAT into a database in the hopes that within the next decade you will be able to run an instant test to verify that was you were told is correct

 

Food Fraud does not necessarily equal unsafe food

 

SQF 2.4.4.5.....vulnerability assessment shall include the sites susceptibility to raw material or ingredient substitution , mislabeling, dilution and counterfeiting that MAY adversely impact food safety


Please stop referring to me as Sir/sirs


#18 Charles.C

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Posted 21 March 2018 - 05:29 AM

Hi Scampi,

 

I previously noted here that due to their separation of Safety/non-Safety Food Codes SQF's handling of Food Fraud may have a (GFSI compliance) difficulty - 

 

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 or ingredient substitution, mislabeling, dilution and counterfeiting which may adversely impact food safety.

 

The "may" probably enables nominal compliance with GFSI's adoption of the "Spink" approach whereby certain potential Food Fraud activities (scope is in SQF Glossary) are initiated for economic gain (rather than for harm). These are seemingly  all regarded as being potentially capable of causing a FS-related event albeit in most cases being nominally quality-related. 

 

So, maintaining consistency with previous clause -


2.4.4.6  The food fraud mitigation plan (refer to 2.7.2.2) shall include methods by which the identified food safety vulnerabilities from ingredients and materials shall be controlled.

 

The "food safety vulnerabilities" presumably refers to the "may" expanded interpretation of clause 2.4.4.5.

 

Seems to me the VA for, say, the Manufacturing Code will be very similar to the VA for the Quality Code. Possibly identical.


Kind Regards,

 

Charles.C


#19 FurFarmandFork

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Posted 21 March 2018 - 03:48 PM

I agree with you Scampi that reasonably expcected food fraud events that pose a food safety hazard (such as your melamine example, which sickened/killed thousands of infants) should be included in the HACCP plan already, I included "food fraud" as a category in my hazard analysis to help ensure that I was indeed looking at it as a separate category for SQF, which I interpret is the basic intent of the inclusion in the code.

 

As I said above, the intent of the post is to demonstrate how I met the letter of the code and successfully included the new 8.0 requirements in my food safety manual, not that it is necessarily the best way or most holistic way to approach including food fraud as a food safety hazard.


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#20 GPER

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Posted 26 June 2018 - 05:44 PM

Where do I find the associated guidance material on the SQF website?  I am in a new position now and my previous experience is ISO.  In reviewing what is in place now I would like to improve the system.  This type of guidance would very much help.



#21 Quality Is the Goal

Quality Is the Goal

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Posted 26 June 2018 - 08:17 PM

Where do I find the associated guidance material on the SQF website?  I am in a new position now and my previous experience is ISO.  In reviewing what is in place now I would like to improve the system.  This type of guidance would very much help.

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#22 Quality Is the Goal

Quality Is the Goal

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Posted 26 June 2018 - 08:18 PM

 

Where do I find the associated guidance material on the SQF website?  I am in a new position now and my previous experience is ISO.  In reviewing what is in place now I would like to improve the system.  This type of guidance would very much help.

 

Hello GPER,

 

Please visit this link and You will be able to find SQF Code and SQF guidelines. Also please see attached file (SQF Food Fraud guidelines)

 

https://www.sqfi.com/documents/

 

Please see attachment above :)

 

 

Quality Is The Goal



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#23 GPER

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Posted 26 June 2018 - 08:31 PM

Hello  Quality is The Goal, 

 

Thank-you, I was able to find this link previously.  I noticed previously module 2 does have guidance documents.  I am wondering is there also a section for Packaging guidance documents?

 

  

Hello GPER,

 

Please visit this link and You will be able to find SQF Code and SQF guidelines. Also please see attached file (SQF Food Fraud guidelines)

 

https://www.sqfi.com/documents/

 

Please see attachment above :)

 

 

Quality Is The Goal



#24 Quality Is the Goal

Quality Is the Goal

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Posted 26 June 2018 - 08:38 PM

Hello  Quality is The Goal, 

 

Thank-you, I was able to find this link previously.  I noticed previously module 2 does have guidance documents.  I am wondering is there also a section for Packaging guidance documents?

No there is no guidance documents for packaging yet :( Im sorry ...  i called SQF and i was told that SQF supposed to post them in March, but they never been posted yet.



#25 GPER

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Posted 26 June 2018 - 08:56 PM

At least now I know I haven't lost my mind.  I have been searching and searching :).   

No there is no guidance documents for packaging yet :( Im sorry ...  i called SQF and i was told that SQF supposed to post them in March, but they never been posted yet.







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