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FSMA and Food Fraud required in BRC and SQF?

sqf brc fsma food fraud mitgation vulnerability assessment audit

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#1 MBrown042

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Posted 22 July 2019 - 04:59 PM

Hi all..

 

Looking for some quick responses please...

 

 

Is FSMA (PCQI and HARPC etc.) required for both BRC and SQF?

 

Is Food Fraud ( Vulnerability Assessment etc. ) required for both BRC and SQF?

 

I know SQF can be exempt from some clauses, but BRC is different. Can someone explain?

 

Thank you,

 

MBrown



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#2 Charles.C

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Posted 22 July 2019 - 05:06 PM

Hi all..

 

Looking for some quick responses please...

As per usual.

 

Is FSMA (PCQI and HARPC etc.) required for both BRC and SQF?

No idea what this means.

 

Is Food Fraud ( Vulnerability Assessment etc. ) required for both BRC and SQF?

Yes.

 

I know SQF can be exempt from some clauses, but BRC is different. Can someone explain?

Which Clauses do you refer?

 

Thank you,

 

MBrown

 

Hi MBrown

 

The response time may vary with the clarity of the OP.


Kind Regards,

 

Charles.C


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#3 MBrown042

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Posted 22 July 2019 - 05:14 PM

Hi Charles,

 

I am going to be conducting some assessments on some of our vendors as a viable source.  I will be inspecting their facility and conducting an document review as well as an observation assessment.   We are using an audit developed by my company, and we have added some elements to the audit.  The issue is, some of our vendors are SQF certified and some of our vendors are BRC certified. 

 

We have added a HARPC requirement and Food Fraud requirements.  We require that all of our vendors are GSFI certified.



#4 MBrown042

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Posted 22 July 2019 - 05:19 PM

Hi Charles,

 

Below is where it says Food Fraud is not mandatory for SQF.

 

I just want to know if food fraud is required by BRC

FSMA (HARPC) is that required for both BRC and SQF?

 

Thanks in advance...

 

 

 

 

2.7.2 Implementation Guidance
What does it mean?
In July 2014, GFSI published a discussion paper “GFSI position on Mitigating the public health risk of food fraud,” in
which it states “The GFSI Board recognizes that the driver of a food fraud incident might be economic gain, but if a
public health threat arises from the effects of an adulterated product, this will lead to a food safety incident.”
Food fraud is often described as EMA, economically motivated adulteration. However, it is more than that. As well as
adulteration, food fraud includes substitution, dilution, addition, misrepresentation or tampering of food ingredients or
food products. It is in fact illegal deception for economic gain.
The economic risks of food fraud to the industry are apparent. It is estimated that fraud costs the global food industry
between $US40bn -$US50bn every year (Australian Food News, 11th July 2017). However, the public health impacts
are less so. In many cases, the health impact of food fraud is not known until after the fact, when consumers become
sick and the adulterant is detected.
GFSI now requires that a food fraud vulnerability assessment and mitigation plan to be incorporated into the food
safety management systems in all GFSI benchmarked schemes. SQF in edition 8 now requires food fraud to be
considered for the site (2.7.2), and for incoming materials and ingredients (2.4.4.5, 2.4.4.6).
What do I have to do?
Although this element is not mandatory, it is a key GFSI requirement and can only be exempted on receipt by the
Certification Body (CB) of a written request from the site justifying exemption. If the justification is accepted by the

CB, the element can be exempted. If not, and the site has not completed a vulnerability assessment and mitigation
plan, then the CB is required to raise a major non-conformance against 2.7.2.



#5 Charles.C

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Posted 22 July 2019 - 05:37 PM

Hi Marvis,

 

Regret I'm not in USA so unable to comment much on FSMA. Maybe someone else can help.

 

afaik, BRC does not use a "mandatory" system like SQF. A Food Fraud Vulnerability Requirement is included in the Code BRC8.


Kind Regards,

 

Charles.C


#6 The Food Scientist

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Posted 22 July 2019 - 06:15 PM

FSMA, regardless of BRC or SQF, is required by law. Not a BRC user but this is what SQF says regarding that:

 

2.4.3.17 Where food safety regulations in the country of production and destination (if known) prescribe a food
safety control methodology other than the Codex Alimentarius Commission HACCP guidelines, the food safety team
shall implement food safety plans that meet both Codex and food regulatory requirements.
 
Food Fraud is not "mandatory"  like Food Defense under the clause.  However it is under "Approved Supplier program" as well and that one is mandatory. So yes, it is "required". 

Everything in food is science. The only subjective part is when you eat it. - Alton Brown.


#7 SQFconsultant

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Posted 22 July 2019 - 06:15 PM

Considering that you require your vendors to be GFSI certified, why not ask each for a copy of their most recent SQF, BRC, etc cert and audit and then run a standard 1st/2nd party food safety audit, then you won't need to worry about all the ins and outs of hte various certifications.  This is what we do... keeps us sane!


Warm regards,

 

 

Glenn Oster

Glenn Oster Consulting, LLC

 

SQF On-Site System Development & Implementation Consultant

You can DIY or Bring in the Professionals 

 

Small to Mid-Size Food, Food Packaging & Food Logistic/Storage 

SQF GAP Analysis of Operational & Capital Needs

Internal Auditor Training Program / United States of America, Canada & Centro America

772.646.4115 USA // glenn@glennosterconsulting.com

Boquete, Panama & Yorktown, Virginia USA

www.GlennOsterConsulting.com

 

 

SQF Pre-Development GAP Analysis -

Operational & Capital Compliance

https://bit.ly/2UeemhP

 

 

 

 

 

 

 

 

 

 

 

 

 

 


#8 Charles.C

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Posted 22 July 2019 - 07:02 PM

Just to nit-pick Posts 3,7, the terminology "GFSI-certified"  has no meaning as such.

 

I'm slightly unclear as to whether the thread is focused on food fraud or not ? :smile:


Kind Regards,

 

Charles.C


#9 pHruit

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Posted 23 July 2019 - 09:00 AM

To the OP:

It may be worth downloading copies of the relevant standards (BRC available here and SQF here, both free) if you are hoping that they can be used to fulfil some specific function beyond being GFSI-benchmarked.

I'm not overly familiar with SQF, but BRC does include food fraud as a mandatory requirement in section 5.4.

 

Its not clear from your posts whether you are only considering suppliers in the US?
In a general sense it's worth noting that the BRC standard itself has no inherent FSMA requirements - it does require compliance with local regulations and those of know intended markets, so it would be reasonable to expect a supplier physically located in the US to comply with this, but not necessarily the case for non-US facilities.  

There is an optional voluntary FSMA module (or at least there was under Issue 7 - not entirely sure what they're doing with Issue 8) so you could ask suppliers if this is something they have. I've no idea how significant the uptake for it was though.



#10 Hoosiersmoker

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Posted 25 July 2019 - 12:34 PM

My first question is what is your specific FSC? We are packaging and have an exemption from Food Fraud. Depending on the specifics of your suppliers you might also be able to gain exemption.



#11 Sweet'n'low

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Posted 31 July 2019 - 05:14 PM

My first question is what is your specific FSC? We are packaging and have an exemption from Food Fraud. Depending on the specifics of your suppliers you might also be able to gain exemption.

Don't forget the exemption to FSMA in general. FSMA does NOT apply to packaging manufacturers. I think that will change in the very near future. So to the OP, if you are in packaging, PCQI is not mandatory, but HACCP is. Might be just better to require PCQI and be a step ahead of the game. 

 

As for food fraud, all we did was show our auditor a FFVA (Food Fraud Vulnerability Assessment) from PWC that was free on their website. I didn't know that packaging was exempt from food fraud or else I would have brought that up in our audit. However, I think your citation of 2.7.2 may be outdated if it is from 2014. 

 

Also, as Glenn pointed out, if you are requiring your suppliers to attain and maintain a certification, then it should be minimal work on your end.







Also tagged with one or more of these keywords: sqf, brc, fsma, food fraud, mitgation, vulnerability, assessment, audit

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