33 replies to this topic

[Sarahb3339]

This information was helpful.  I am SQF and also recently have been audited by the FDA.  Correct me if I am wrong but SQF only requires the 5 categores of subsititution, mislabeling, ditlution, counterfeiting and stolen goods requiring the fruad assessment and mitigation strategy.  The FDA requires you to cover more categories. For sake of being in compliance with both should I combine all modulles into a food fraud assessment?  Or should I just stick to the 5 to keep it simple for my audit and auditor?

[Charles.C]

Sarah,

 

Can you clarify a little ?

 

This is SQF manufacturing (Post 1), ie 5 things -

 

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 (1)product substitution, (2) mislabeling, (3) dilution, (4) counterfeiting or (5) stolen goods which may adversely impact food safety

.

 

What do the FDA actually want you to cover ?

[Sarahb3339]

Hi Charles, 

 

I was told in addition to the "5" Ingredient fraud history, geographic origins, economic factors, Nature of material, cost of material, supply chain confidence, supplier relationship, supplier history, testing methods and a few others.  Is this mandatory or am I making this way to difficult?

[Sarahb3339]

Also, 

 

Does the category "food fraud" NEED to be added into my HACCP plan along with my biological, physical, chemical categories?

[Scampi]

A good fraud assessment should naturally cover all the bullets the FDA wants.  You can't really be confident about your supplier if you don't understand how many hands an item passes before it arrives to you

 

Seemingly simple everyday ingredients like black pepper, turmeric etc all come from far away lands where the food safety (and general safety of the country) are vastly different than ours

 

Monetary gain by supplying fraudulent ingredients depends solely on the material (think melamine in baby formula....ground black pepper) 

 

If  you're speaking about added fraud to your overall risk assessment...I wouldn't, it will make your RA massive and difficult to manage

[Charles.C]

Hi Charles, 

 

I was told in addition to the "5" Ingredient fraud history, geographic origins, economic factors, Nature of material, cost of material, supply chain confidence, supplier relationship, supplier history, testing methods and a few others.  Is this mandatory or am I making this way to difficult?

 

Hi Sarah,

 

You will find that PWC (a SQF Guidance recommendation) blend the above with the "5". That's why there are so many questions.

 

But the examples already referenced/posted here suggest that SQF auditors are actually accepting a lot  less.

 

I would anticipate that SQF as yet have no specific minimum/maximum.

 

FDA no idea at all. Where is their reference ?

 

Here is the PWC general philosophy which perhaps illustrates SQF's  way-of-thinking -

 

 food fraud vulnerability assessment and Mitigation.pdf   2.06MB   183 downloads

[Scampi]

I figure if the SSAFE tool is good enough for Nestle, it's good enough for me

 

https://www.nestle.c...-prevention.pdf

[DaBrads]

Thank you for this insight from all views on this topic. Our company is just getting started on GFSI certification and this really helped.

 

DaBrads

[Fili0502]

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!

Can you share how you made it?