SQF 2.7.2 - Food fraud mitigation organic vs. conventional
Hello,
I need your help again. I got a Non Conformance on my SQF desk audit because we didn't include protecting Organic products from fraud in the vulnerability assessment. We buy fresh produce to make juice and we make conventional and organic juices. We have internal procedures to prevent food fraud internally but my question is how do I verify that my supplier is not selling me conventional produce as organic. Would a pesticide testing of the incoming fruit be enough? or the fact that there are no residues doesn't mean necessarily that is organic?
As always thank you for all your help!
svelasan
How are you monitoring incoming organic produce? Just like SQF consultant mentioned, are you not doing any tests to confirm? Are you relying on organic certifications, COAs? Perhaps go and audit that supplier, or maybe ask for a copy of their organic audit cert?
My question is if doing only pesticide testing on organic produce would be enough?
I think SQFconsultants point is the critical one.
If you do not need pesticide testing on your conventional produce then you shouldn't need it on your organic.
Trading a safe product (conventional) for a safe product (organic) from a safe supplier is not a food safety risk (aka public health concern).
Organic principles include much more than just no pesticides - and actually some pesticides are allowed. It would be an indicator but best addressed within your organic audit.
It is a problem for your organic certification, your customers, raises supplier trust issues and deceptive but shouldn't be a problem for SQF based on the code.
If your conventional supplier controls are adequate and also applied to organic you should be fine for food safety but you will likely run into trouble on your organic audit.
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 or counterfeiting which may adversely impact food safety.
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.
My question is if doing only pesticide testing on organic produce would be enough?
Hello,
I need your help again. I got a Non Conformance on my SQF desk audit because we didn't include protecting Organic products from fraud in the vulnerability assessment. We buy fresh produce to make juice and we make conventional and organic juices. We have internal procedures to prevent food fraud internally but my question is how do I verify that my supplier is not selling me conventional produce as organic. Would a pesticide testing of the incoming fruit be enough? or the fact that there are no residues doesn't mean necessarily that is organic?
As always thank you for all your help!
svelasan
I have to respectfully disagree..........the issue is the vulnerability assessment regardless of organic or traditional. An entire range of products was omitted from the assessment.
In order to verify that your organic product actually is organic, and not fraudulent, you need to include them in your assessment.
Now, correct me if i'm wrong (i've managed organic) but there is very little or no overlap between allowable traditional pesticides and the ones allowed under the organic certification. You could test for the non-permissible pesticides only (a really good lab can help you sort this out) OR you can simply rely on the paperwork trail etc that you've already got from your organic vendors (you've done that part well!) The other thing you can do to beef up your organic requirements is have the vendors sign a legally binding attestation that product coming to you as organic, is only organic-----then spot check
And also, ask for the list of pesticides they ARE using......send random samples to a lab to test for those and the traditional ones. Organic can get quite tricky and you've got to have a good understanding of what the farmers can and cannot do whilst following USDA organic standards
So re-do the assessment and include the organic products and how you CURRENTLY mitigate fraud............this issue isn't your organic verification, it's your omission of an entire product line.