21 replies to this topic

[Omega Lim]

Hi,

 

How to do the Food Fraud Prevention procedure which is the FSSC 22000 Version4.1 additional requirement?

I have try to setting up a FFVA using SSAFE tool.

However, I have no idea what to do besides the food fraud assessment.

Any reference procedure for food fraud prevention plan?

 

Thank you.

[Ryan H.]

Hi Omega: There are a ton of threads on this forum about food fraud. I would simply search on the search bar and i'm sure you will find a lot of materials. 

[Ryan H.]

http://www.ifsqn.com...272-food-fraud/

 

Here is one for example. I grant you that it is not FSSC 22000, but i'm sure it could help..

 

Best of Luck..

[Charles.C]

Hi,

 

How to do the Food Fraud Prevention procedure which is the FSSC 22000 Version4.1 additional requirement?

I have try to setting up a FFVA using SSAFE tool.

However, I have no idea what to do besides the food fraud assessment.

Any reference procedure for food fraud prevention plan?

 

Thank you.

 

Hi Omega,

 

This is a (quite useful) official fssc22000 guidance (seemingly for both food/packaging) -

 

 fssc22000 food fraud guidance final (April 2018).pdf   465.91KB   798 downloads

 

The included definition for Food Fraud  is -

 

The definition that FSSC uses is based on the GFSI Position paper issued in 2014 2 : Food Fraud is the collective term encompassing the intentional substitution, addition, tampering or misrepresentation of food/feed, food/feed ingredients or food/feed packaging, labelling, product information or false or misleading statements made about a product for economic gain that could impact consumer health (GFSI BRv7:2017).

(final bracket above seems inaccurate, see * below)

 

Above definition is similar* to that in  BRC7/SQF8 Manufacturing, Food Glossaries. [However it is dissimilar to (text) in SQF Code (Food) Manufacturing.]

*BRC glossary has no specific mention of "consumer health" or food safety (=EMA?). Guidance specifically excludes the site vulnerability, focuses on supply chain.

SQF refers to food safety and includes site's "susceptibility" .Guidance implicity includes Process, ie -

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?”

FSSC (4.1) includes supply chain, Process (?), health so perhaps nearer SQF than BRC. But, based on Posts 7 et seq,  inclusion of Process is questionable, more info required to clarify.

 

As i read it, 7 specific potential "vulnerabilities" are minimally, "implicitly" expected to be addressed -

 

(1)     Economic vulnerability (how economically attractive is fraud)
(2)     Historical data (has it happened)
(3)     Detectability (e.g. how easy to detect, routine screening present)
(4)     Access to raw materials, packaging materials and finished products in the supply chain  
(5)     Relationship with supplier (e.g. long relationship or spot-buying)
(6)     Certification through an independent sector specific control system for fraud and authenticity
(7)     Complexity of the supply chain (e.g. length, origins and where the product is substantially changed/processed)

 

I am unsure as to what number (6) references, -  3rd Party Food Fraud Audit ? However the rest are "covered" /"partially" covered in various templates here for BRC / SQF although sometimes with differing SOPs.  One current, relatively simple, fairly close match and probably adaptable (although note the surrounding  sheets) is here  - 

 

http://www.ifsqn.com...ed/#entry121799

(or Post 13/same thread for an expanded version)

(a possible criticism could be regarding validation for the decision criterion numbers but this aspect is common to most other SOPs also, and haccp itself)

 

Another, semi-matched  (BRC-"validated")  template which uses a matrix decision procedure (arguably more transparent/realistic) is here -

 

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

 

The Guidance also contains discussion of various other requirements, eg Mitigation Plan, FS System.

 

I interpret the Guidance (see sec 6./Pg4) as implying that FSSC auditors will currently assume that this topic is a sort of "Work in Progress"

 

The above linked template clearly has (many) less queries than ssafe/pwc tool but it still likely involves use of validatory databases for history etc. ( Unless "intuition" may suffice).

Edited by Charles.C, 15 December 2020 - 01:34 PM.
aded * segment - "BRC .... required"

[Omega Lim]

Hi,

 

For VACCP, is it do the assessment for our raw material is enough?

Do we need to do vulnerability assessment on our process step?

Edited by Charles.C, 04 September 2018 - 02:22 PM.
post moved

[chris@crepecuisine]

Hi Omega,

 

Conduct an assessment on your raw materials and supply base, mapping each supply chain and assessing where in the chain the material is vulnerable.  For example once a spice is ground into a powder it is more vulnerable to economically motivated adulteration.

 

From a TACCP perspective, you need to assess each process step of your process and assess at which points your process is vulnerable to malicious contamination, economically motivated adulteration, misappropriation, etc.  For example a lone worker has the ability to perform malicious contamination with less risk of getting caught. 

 

Hope that helps

Edited by Charles.C, 04 September 2018 - 02:22 PM.
post moved

[Mbalentle]

I also have the same enquiry. On our FSSC V 4-1 audit a month ago, we received a finding for not including the process steps.

Is there anyone with an example of how they assessed their process steps against food fraud. we are a food packaging manufacturing company and I find it so difficult to develop a process assessment. 

[Charles.C]

I also have the same enquiry. On our FSSC V 4-1 audit a month ago, we received a finding for not including the process steps.

Is there anyone with an example of how they assessed their process steps against food fraud. we are a food packaging manufacturing company and I find it so difficult to develop a process assessment. 

 

Hi Mbalentie,

 

You are possibly confusing VACCP with TACCP.

 

Note: address all types of Food Fraud [ie VACCP] as defined by GFSI (i.e. substitution, unapproved enhancements, misbranding, counterfeiting, stolen goods or others); address all products from incoming goods (e.g. raw materials, packaging materials) to outgoing goods (e.g. (semi) finished product). See Appendix 1 for more information

 

 

 

# (added later) Possibly my error, FSSC does appear to require inclusion of Process for VA. But also see following  posts.. Very confusing !.

Edited by Charles.C, 15 December 2020 - 01:27 PM.
added #

[sangle]

We to are a packaging manufacturing company and had our audit in Feb.  I had done a vulnerability assessment on our incoming raw materials (paper, glue, steel ect.) as well as a mitigation but was not asked for documentation on our process steps.  Perhaps this is something that will show up during our next audit and I will be doing some investigating to see what needs to be done and how to accomplish it.  When I find out something I will post it.

Shanna

[Charles.C]

We to are a packaging manufacturing company and had our audit in Feb.  I had done a vulnerability assessment on our incoming raw materials (paper, glue, steel ect.) as well as a mitigation but was not asked for documentation on our process steps.  Perhaps this is something that will show up during our next audit and I will be doing some investigating to see what needs to be done and how to accomplish it.  When I find out something I will post it.

Shanna

 

Hi Shanna,

 

I assume you are referrring to FSSC22000.

 

The (negative) answer is in the previous Post.

 

PS - However for SQF it could be required.

[sangle]

_{Yes Charles, FSSC22000.}

[Omega Lim]

We to are a packaging manufacturing company and had our audit in Feb.  I had done a vulnerability assessment on our incoming raw materials (paper, glue, steel ect.) as well as a mitigation but was not asked for documentation on our process steps.  Perhaps this is something that will show up during our next audit and I will be doing some investigating to see what needs to be done and how to accomplish it.  When I find out something I will post it.

Shanna

Hi Sangle,

 

Can you share the example of vulnerability assessment and mitigation that you done?

Thank you.

[Mbalentle]

Hi Mbalentie,

 

You are possibly confusing VACCP with TACCP.
.

I meant the VACCP which is for food fraud.

 

Below was the finding we got on our VACCP. Our VACCP included raw material evaluation and supplier evaluation.

 

Statement of nonconformity:

Food fraud plan did not include production steps.

[Charles.C]

 

I meant the VACCP which is for food fraud.

 

Below was the finding we got on our VACCP. Our VACCP included raw material evaluation and supplier evaluation.

 

Statement of nonconformity:

Food fraud plan did not include production steps.

 

 

Hi Mbalentle,

 

As i read the Guidelines, Clause 2.1.4.4 is ambiguous as to the scope of the VA.

However IMO Clause 4 is not ambiguous, only mentions raw materials and finished goods, and implies no reason to include process steps.

 

I suggest you should have challenged the auditor to justify his comment/NC with regard to the official Guidelines.

 

TACCP would be a different matter of course.

[sangle]

I would be happy to share with you.  Hope it helps.

 

Shanna

 

 

Fraud Category

Susceptibility

Mitigation Strategy

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

• Paper
• Liner
• Steel
• Boxes

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)

Glue

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.

Counterfeit company or private label brand goods sold

(Your company) does not label products with a high price point that would encourage counterfeiting.

Obsolete or unusable labels are discarded via shredding or sent back to owner for disposal, inventory of labels is kept that would identify theft.

Theft of Company goods

Fiber composite cans are not a likely candidate for theft and resale due to the space required for the product and low price point

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

 

[sangle]

Wow sorry the format did not carry through.  This is in columns. Let me see if I can fix it

 

Fraud Category                              Susceptibility                                     Mitigation Strategy

Product Substitution                       Paper                                                Our supplier approval program

or mislabeling (exchange               Liner                                                  and supplier preventive controls

for cheaper or inferior                    Steel                                                  verify that products are received

ingredient)                                      Boxes                                                within specification and that

                                                                                                                business relationships are

                                                                                                                maintained with responsible/

                                                                                                                reputable suppliers.

Product Dilution (added                 Glue                                                  Our supplier approval program

ingredients for weight that                                                                       and supplier preventive controls

are not the intended                                                                                verify that products are received

ingredient)                                                                                               within specification and that

                                                                                                                business relationships are

                                                                                                                maintained with responsible/

                                                                                                                reputable suppliers.

Counterfeit company or                 (Company) does not                         Obsolete or unusable labels

private label brand goods              label products with a high                 are discarded via shredding

sold                                               price point that would                         or sent back to owner for

                                                      encourage counterfeiting.                  disposal, inventory of labels

                                                                                                                 is kept that would identify theft.

Theft of Company Goods              Fiber composite cans are not            Outgoing freight is carried by

                                                      a likely candidate for theft                  licensed carriers and locks/

                                                      and resale due to the space              seals are used in all full

                                                      required for the product                     truckloads.

                                                      and low price point

 

 

I got this information from FurFarmandFork web site.

[Mbalentle]

Wow sorry the format did not carry through.  This is in columns. Let me see if I can fix it

 

Fraud Category                              Susceptibility                                     Mitigation Strategy

Product Substitution                       Paper                                                Our supplier approval program

or mislabeling (exchange               Liner                                                  and supplier preventive controls

for cheaper or inferior                    Steel                                                  verify that products are received

ingredient)                                      Boxes                                                within specification and that

                                                                                                                business relationships are

                                                                                                                maintained with responsible/

                                                                                                                reputable suppliers.

Product Dilution (added                 Glue                                                  Our supplier approval program

ingredients for weight that                                                                       and supplier preventive controls

are not the intended                                                                                verify that products are received

ingredient)                                                                                               within specification and that

                                                                                                                business relationships are

                                                                                                                maintained with responsible/

                                                                                                                reputable suppliers.

Counterfeit company or                 (Company) does not                         Obsolete or unusable labels

private label brand goods              label products with a high                 are discarded via shredding

sold                                               price point that would                         or sent back to owner for

                                                      encourage counterfeiting.                  disposal, inventory of labels

                                                                                                                 is kept that would identify theft.

Theft of Company Goods              Fiber composite cans are not            Outgoing freight is carried by

                                                      a likely candidate for theft                  licensed carriers and locks/

                                                      and resale due to the space              seals are used in all full

                                                      required for the product                     truckloads.

                                                      and low price point

 

 

I got this information from FurFarmandFork web site.

Hi Sangle. Thank you, I do hope this will help me and Hopefully Omega who initiated this topic. 

[sangle]

I don't know how to make a "thread" but the information came from a post on April 1, 2018 from FurFarmandFork titled Meeting New Requirements of SQF 8.0: 2.7.2 Food Fraud. Maybe that will help.

[Charles.C]

I don't know how to make a "thread" but the information came from a post on April 1, 2018 from FurFarmandFork titled Meeting New Requirements of SQF 8.0: 2.7.2 Food Fraud. Maybe that will help.

 

Hi sangle,

 

I congratulate yr initiative but note that FF procedures developed for Standard X are likely to encounter comments if borrowed for Standard Y.

[mahara25]

Please share updated FSSC 22000 Std.

[Charles.C]

Please share updated FSSC 22000 Std.

 

https://www.fssc2200...heme-documents/

[MYFANWY]

hi i have to do a food fraud and adulteration for salsa audit but im not BRC has anyone got anything they could share so i can get an idea what im doing