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?
This is a (quite useful) official fssc22000 guidance (seemingly for both food/packaging) -
fssc22000 food fraud guidance final (April 2018).pdf 465.91KB
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 -
(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 -
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).