Food Fraud/Defense Requirements FSSC 22000 (4.1) ?
Hello everyone!
I'm a Quality Assurance in Fish Fillet Production Factory. We've got FSSC 22000 certificate in 2018 January and now we are updating new version. In this version, we have new titles (not even new but we focus on these) about Food Defense and Food Fraud Prevention. We have mitigation strategies, threat assessment and vulnerability assessment. But my question is
Do we need to provide procedures for Food Defense and Food Fraud, or only Board Mitigation Strategies is enough?
Thank you for your time.
Cheer!
Hello,
I recommend you to download the FDA's Food Defense Plan Builder https://www.accessda.../fdplanbuilder/
I consider that will help you with a gap analysis and guide you on the correct mitigation strategies and at the end it will be printable and pretty much will be an action plan + a written procedure for your facility.
Hello everyone!
I'm a Quality Assurance in Fish Fillet Production Factory. We've got FSSC 22000 certificate in 2018 January and now we are updating new version. In this version, we have new titles (not even new but we focus on these) about Food Defense and Food Fraud Prevention. We have mitigation strategies, threat assessment and vulnerability assessment. But my question is
Do we need to provide procedures for Food Defense and Food Fraud, or only Board Mitigation Strategies is enough?
Thank you for your time.
Cheer!
Hi Kaung San,
Yr red query - probably Yes and No.
See this thread (and several others if you search) -
Hello,
I recommend you to download the FDA's Food Defense Plan Builder https://www.accessda.../fdplanbuilder/
I consider that will help you with a gap analysis and guide you on the correct mitigation strategies and at the end it will be printable and pretty much will be an action plan + a written procedure for your facility.
Thanks a lot for your supporting. This tool is really helpful.
Hi Kuang San,
You mentioned that your company is FSSC 22000 certified, is it possible to help me with a list of documents required for this certification?
I would be very grateful.
Thanks,
Diane
Hi,
We have been recently audited for FSSC 22000 version 4.1, and we used this tool for our food fraud assessment.
This was also recommended during our food fraud training. During the audit, the auditor did not dwell much on the assessment from this site; she focused more on our food fraud mitigation plans (which were sufficient for her).
Hope this helps! :D
Hi,
We have been recently audited for FSSC 22000 version 4.1, and we used this tool for our food fraud assessment.
This was also recommended during our food fraud training. During the audit, the auditor did not dwell much on the assessment from this site; she focused more on our food fraud mitigation plans (which were sufficient for her).
Hope this helps! :D
Hi jeran,
Thank you very much for yr input.
May i ask a few questions ?
(1) What is yr finished product / it's perceived safety "risk status" ? For example meat, biscuits, RTE, NRTE ?
(2) The pwc tool requires the user to estimate a "probability" of H/M/L for each of approx 40 - 50 events/situations. (a) Did the auditor request you to validate any of yr probability decisions ? For example, could you have simply "guessed" the responses entered into the questionnaire without auditorial challenge ?, (b) did the auditor seem to appreciate the basic objectives driving the choice of questions, ie to cover the relative likelihood of one (or more) types of food fraud deriving from various potential causes, both site-external eg supply chain complexity and site-internal eg employee integrity ?
(3) How many answers from yr total 40+ responses were "H", ie requiring a "significant" mitigation folow-up ? Did the auditor appear to have any expected max/min result for "H" ?
(4) Afaik the pwc tool is not intended to provide mitigation strategies. Was the auditor aware of this fact ?
Thanks.
Hello everyone!
I'm a Quality Assurance in Fish Fillet Production Factory. We've got FSSC 22000 certificate in 2018 January and now we are updating new version. In this version, we have new titles (not even new but we focus on these) about Food Defense and Food Fraud Prevention. We have mitigation strategies, threat assessment and vulnerability assessment. But my question is
Thank you for your time.
Cheer!
Hi Kuang San,
I'm QA for my company too and we are only now taking up the challenge to move from GMP to FSSC 22000.
Do you have an index of documents for your food quality and safety manual? Or perhaps a checklist/list of documents required for the FSSC audit?
Thank you!!
Hi Diane,
Please don't repeat Posts.
Also see yr other thread -
As usual, the FDA has cocked things up. They have withdrawn their Food Defense Plan Builder, as well as their link to Carver + SHOCK, because they do not comply with the Intentional Adulteration rule in FSMA.
Food Defense is a larger issue than the specific IA rule in FSMA. If you are not subject to the IA rule, you may be able to get away with a more generic Food Defense Plan.
Honestly, I do not understand why FDA has specifically targeted four areas in the IA rule that you have to address. One would assume that a more generic approach to Food Defense, that their tool did a good job of addressing, would not be sufficient.
Well, let me edit that....I do understand why they chose these four areas.... but it just seems to me that concentrating on these four areas is not looking at other areas that could be vulnerable. FDA has basically said that liquid reception, liquid holding, mixing and secondary ingredient addition are the only places that need to be looked at.
I can think of a whole bunch of areas in my production lines where a bad actor could contaminate product.
Marshall
As usual, the FDA has cocked things up. They have withdrawn their Food Defense Plan Builder,
Where did you see this? It's still available to download here: https://www.accessda.../fdplanbuilder/
Marshal
Most facilities have more than one area where product could be contaminated, but bulk liquid would BY FAR be the easiest to contaminate. In house contamination has/should have always been a part of a robust HACCP plan......perhaps not from preventing a highly unlikely terrorists attack......but still from stupid people doing stupid things
Remember, the FDA budget was slashed astronomically............they can only do so much with what they have