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SQF 2.7.2 Food Fraud, site-specific issues?


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#1 tezza07

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Posted 13 August 2019 - 12:51 PM

Good morning,
 
We had our SQF audit and when I presented our Food Fraud Vulnerability Assessment the auditor said it did not focus on site-specific issues (only raw material vulnerabilities on incoming material). Can someone clarify what the code is looking for? Is it internal intentional fraud (like we deliberately sub a lower grade material without knowledge or consent of customer?)
 
If anyone has an example of a packaging manufacturer vulnerability assessment as a guide it would be greatly appreciated. (bonus points if it's for a paper manufacturer).
 
Code states:
 
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 and counterfeiting which may adversely impact the food safety of
packaging product.
 
Thanks in advance :)


#2 The Food Scientist

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Posted 13 August 2019 - 01:14 PM

An example would be, do you use only approved suppliers? Do you have any checking of COAs to match received products, lot #s, checking labels, some sampling to make sure that material is in-fact what they are sending you is really it? Like what are you doing to insure your material received is safe from fraud? Also training of employees, making sure they are aware of any suspected frauds, like incoming trucks...etc. When you're auditor said that, did you not ask them to clarify for you what exactly they are looking for? Remember they are working FOR YOU, YOU pay THEM. You should ask and ask everything in the closing meeting and make sure you understand all your NCs. Hope that helps :)


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


#3 Charles.C

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Posted 13 August 2019 - 03:04 PM

 

Good morning,
 
We had our SQF audit and when I presented our Food Fraud Vulnerability Assessment the auditor said it did not focus on site-specific issues (only raw material vulnerabilities on incoming material). Can someone clarify what the code is looking for? Is it internal intentional fraud (like we deliberately sub a lower grade material without knowledge or consent of customer?)
 
If anyone has an example of a packaging manufacturer vulnerability assessment as a guide it would be greatly appreciated. (bonus points if it's for a paper manufacturer).
 
Code states:
 
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 and counterfeiting which may adversely impact the food safety of
packaging product.
 
Thanks in advance :)

 

 

Hi tezza,

 

As partially  illustrated in previous post, basic answer to ^^^^red is - Yes you are correct.except maybe the fraud is targetted on you.

 

This is one irritant of SQF, IIRC other Standards tend to stop at receipt of raw materials.

 

Offhand, I don't remember any "worked"  SQF Packaging Fraud Vulnerability Examples being posted here so far.

 

I think the PwC tool developed for food includes this aspect within its question menu but it's significant  work to implement the whole package.

 

also see the SQF Packaging Guidance, eg -
 

 

The vulnerability assessment shall include an evaluation of the site vulnerabilities including from staff, contractors, and other associates.

 


Kind Regards,

 

Charles.C


#4 SQFconsultant

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Posted 13 August 2019 - 03:53 PM

It is not "internal" - the intent is "external" suppliers/supply chain. Normally a,food fraud issue comes from things such as - economic gain, intent to cause harm to the customer/hurt their business, etc. Prime example of food fraud several years ago was a major supplier of Maryland blue lump crabmeat in cans where the supplier ran into a financial situation and decided to buy a low grade crabmeat from China and mix it in and then since none of the customers were noticing they fully replaced the good stuff with the bad stuff. That is food fraud.


Warm regards,

 

 

Glenn Oster

Glenn Oster Consulting, LLC

 

SQF On-Site System Development & Implementation Consultant

You Can DIY or Bring in the Professionals / We specialize in Small-to-Mid-Size 

Food, Food Contact Packaging & Food Logistic/Storage & Distribution

 

Pre-Development SQF GAP Analysis of Operational & Capital Needs

On & Off-Site SQF System Development & Implementation Consulting

Internal Auditor Training Program / eConsultant 

772.646.4115 USA // glenn@glennosterconsulting.com

Yorktown, VA / Charlotte, NC / Miami, FL / Boquete, Panama

www.GlennOsterConsulting.com

 

 

SQF Pre-Development GAP Analysis -

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https://bit.ly/2UeemhP

 

 

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#5 SQFconsultant

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Posted 13 August 2019 - 04:07 PM

Asan aside - for packaging... fraud could be carried out by a supplier by using a sub grade material, coloring agents, different resins etc.


Warm regards,

 

 

Glenn Oster

Glenn Oster Consulting, LLC

 

SQF On-Site System Development & Implementation Consultant

You Can DIY or Bring in the Professionals / We specialize in Small-to-Mid-Size 

Food, Food Contact Packaging & Food Logistic/Storage & Distribution

 

Pre-Development SQF GAP Analysis of Operational & Capital Needs

On & Off-Site SQF System Development & Implementation Consulting

Internal Auditor Training Program / eConsultant 

772.646.4115 USA // glenn@glennosterconsulting.com

Yorktown, VA / Charlotte, NC / Miami, FL / Boquete, Panama

www.GlennOsterConsulting.com

 

 

SQF Pre-Development GAP Analysis -

Operational & Capital Compliance

https://bit.ly/2UeemhP

 

 

Need help on FSVP?

We can help!

And if you are an eConsultant Client...

it won't even cost you anything -

www.GlennOsterConsulting.com

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 


#6 Charles.C

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Posted 13 August 2019 - 04:11 PM

It is not "internal" - the intent is "external" suppliers/supply chain. Normally a,food fraud issue comes from things such as - economic gain, intent to cause harm to the customer/hurt their business, etc. Prime example of food fraud several years ago was a major supplier of Maryland blue lump crabmeat in cans where the supplier ran into a financial situation and decided to buy a low grade crabmeat from China and mix it in and then since none of the customers were noticing they fully replaced the good stuff with the bad stuff. That is food fraud.

 

Hi Glenn,

 

Not a SQF user myself but the Guidance seems to disagree yr comment ?, eg -

 

‘Vulnerabilities’ need to be identified in incoming materials and ingredients, and within the site.  Not all materials and ingredients are subject to risk, and the highest risks may be from minor or infrequent ingredients that originate from sensitive geopolitical areas, or suppliers with poor past histories.  Ingredients can be prioritised based on

perceived risk.

 

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?

 

 


 


Kind Regards,

 

Charles.C


#7 SQFconsultant

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Posted 13 August 2019 - 10:52 PM

It is a bit of a sticky wicket in that all food fraud plans that get reviewed by auditors pass muster and they are based virtually 100% on external.


Warm regards,

 

 

Glenn Oster

Glenn Oster Consulting, LLC

 

SQF On-Site System Development & Implementation Consultant

You Can DIY or Bring in the Professionals / We specialize in Small-to-Mid-Size 

Food, Food Contact Packaging & Food Logistic/Storage & Distribution

 

Pre-Development SQF GAP Analysis of Operational & Capital Needs

On & Off-Site SQF System Development & Implementation Consulting

Internal Auditor Training Program / eConsultant 

772.646.4115 USA // glenn@glennosterconsulting.com

Yorktown, VA / Charlotte, NC / Miami, FL / Boquete, Panama

www.GlennOsterConsulting.com

 

 

SQF Pre-Development GAP Analysis -

Operational & Capital Compliance

https://bit.ly/2UeemhP

 

 

Need help on FSVP?

We can help!

And if you are an eConsultant Client...

it won't even cost you anything -

www.GlennOsterConsulting.com

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 


#8 Mulan1010

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Posted 28 August 2019 - 08:01 PM

In addition to doing a risk assessment on all raw material for possible food fraud we used the VACCP Hazard Analysis tool and listed each step in our process, like we did our HACCP Plan, but in the VACCP form we only considered if any possible food fraud hazards could occur at each step and if so then we would list what procedures we have in place to prevent that from happening.  The two different SQF Auditors we have had were good with that.






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