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Food Fraud plan for my facility as per requirements of FSSC 22000

food fraud vulnerability mitigation assessment tool

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#1 Anwer Khattak

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Posted 11 December 2020 - 05:03 AM

Hello everyone, I want to make a Food Fraud plan for my facility as per requirements of FSSC22000. Can somebody share any template to work up on in a powdered milk industry or can anybody suggest some free tools to make a functional Food Fraud plan? I had gone through USP Food Fraud mitigation guidance, but i can't actually understand the Vulnerability assessment, Potential impact assessment and the Vulnerability characterization process mentioned. Can somebody help me in understanding this part? Regards


Edited by Jacob Timperley, 11 December 2020 - 04:00 PM.


#2 MDaleDDF

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Posted 11 December 2020 - 03:52 PM

https://www.ssafe-food.org/

This is a good tool, accepted by my auditor for a dry mix manufacturer, similar to what you do.



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#3 chris@crepecuisine

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Posted 11 December 2020 - 03:54 PM

Hi Anwar,

 

Please find attached my assessments on skimmed milk powder which you may find useful.

 

Please note I work to BRC standards and not FSSC 22000 so I don't know how they word the requirements, you may have to align the template to FSSC requirements 

 

All the best,

 

Chris

Attached Files



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#4 Charles.C

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Posted 12 December 2020 - 12:49 AM

Hello everyone, I want to make a Food Fraud plan for my facility as per requirements of FSSC22000. Can somebody share any template to work up on in a powdered milk industry or can anybody suggest some free tools to make a functional Food Fraud plan? I had gone through USP Food Fraud mitigation guidance, but i can't actually understand the Vulnerability assessment, Potential impact assessment and the Vulnerability characterization process mentioned. Can somebody help me in understanding this part? Regards

 

You might usefully try a little searching through the forum. There are literally a legion of threads on this topic (Food Fraud) for every GFSI-recognized Standard. IIRC, FSSC  do offer a specific recommended list of expectations to address within their intepretation of Food Fraud. The latter are probably covered within most methodologies developed for other GFSI-recognised Standard (although, IIRC, FSSC's intended VA scope is somewhat different to both of SQF's Manufacturing Standard and BRC8,  eg compare FSSC22000's requirements to this (mainly) BRC content oriented thread [albeit nominally FSSC22000])-

 

https://www.ifsqn.co...ed/#entry121797

 

Sadly, based on various threads on this forum over the last few years, the methodology mentioned in Post 2 has seemingly generated a lot of bad experiences mixed with a few good ones. It is true that if the software can be persuaded to co-operate, many auditors seem to accept it's process/output, probably due that they are suitably impressed  by the volume of mandatory data inputs and the ultimate collection of auto-generated charts and graphic displays.

 

PS - I get the impression from yr post in other thread that you have already completed this OP ?? i e -

 

https://www.ifsqn.co...ol/#entry168267


Edited by Charles.C, 13 December 2020 - 11:40 PM.
edited

Kind Regards,

 

Charles.C


#5 Anwer Khattak

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Posted 13 December 2020 - 07:33 AM

Hi Anwar,

 

Please find attached my assessments on skimmed milk powder which you may find useful.

 

Please note I work to BRC standards and not FSSC 22000 so I don't know how they word the requirements, you may have to align the template to FSSC requirements 

 

All the best,

 

Chris

Dear Chris,

As per my understanding you have followed the USP food fraud mitigation guidance document. Can you please elaborate if we are supposed to carry out impact assessment (the second step mentioned in the guide) for each ingredient?

And how we do the overall vulnerability characterization (step 3 mentioned in the guide), it would help a lot if you can explain in detail.

 

Thanks.


Edited by Anwer Khattak, 13 December 2020 - 07:37 AM.


#6 Anwer Khattak

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Posted 13 December 2020 - 07:37 AM

You might usefully try a little searching through the forum. There are literally a legion of threads on this topic for every GFSI-recognized Standard. IIRC, FSSC  do offer a specific recommended list of expectations to address within this issue. The latter are probably covered within most methodologies developed for other GFSI-recognised Standard (BRC probably exceeds FSSC's requirements)  eg -

 

https://www.ifsqn.co...ed/#entry121797

 

Sadly, based on various threads on this forum over the last few years, the methodology mentioned in Post 2 has seemingly generated a lot of bad experiences mixed with a few good ones. It is true that if the software can be persuaded to co-operate, many auditors seem to accept it's process/output, probably due that they are suitably impressed  by the volume of mandatory data inputs and the ultimate collection of auto-generated charts and graphic displays.

 

PS - I get the impression from yr post in other thread that you have already completed this OP ?? i e -

 

https://www.ifsqn.co...ol/#entry168267

Hi Chris,

I have already gone through the thread you have mentioned and it proved to be of much help, but I have some confusions mentioned earlier.

 

I am still working on the SSAFE tool. I had just solved the issue of report generation.



#7 chris@crepecuisine

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Posted 14 December 2020 - 09:23 AM

Hi Anwer,

 

I would expect the assessments to be carried out for each ingredient, but it depends on FSSC requirements which I have no knowledge of.

 

Vulnerability characterization boils down to the overall score you give each ingredient, but you also need to back up what score you are giving with evidence of research, here is a good starting point:

 

https://trello.com/b...isk-information

 

Hope this helps!

 

Chris



#8 Anwer Khattak

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Posted 15 December 2020 - 03:28 AM

Would accessing each ingredient for Food Fraud be necessary or just making up a Food Fraud plan with the SSAFE tool be enough?



#9 chris@crepecuisine

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Posted 15 December 2020 - 10:47 AM

Hi Anwer,

 

What does FSSC 22000 ask you to do?

 

If you post the clause, I may be able to help you further...



#10 Charles.C

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Posted 15 December 2020 - 11:23 AM

Hi Anwer,

 

What does FSSC 22000 ask you to do?

 

If you post the clause, I may be able to help you further...

 

See -

 

https://www.ifsqn.co...41/#entry130505

 

(Note this is ver. 4.1, haven't yet compared to latest version)

 

PS - there is a degree of confusion in respect to different GFSI-recognised Standards implementing somewhat different interpretations of food fraud/vulnerability assessment. (GFSI's own definition also changed from 2014 to 2017).

 

For example (2019) -

 

Attached File  vulnerability assessment.jpg   147.66KB   20 downloads

 

And as for GFSI -

 

Attached File  GFSI - food fraud2.PNG   75.97KB   11 downloads

 

IMO, definitely a distinction with a difference !


Edited by Charles.C, 15 December 2020 - 03:30 PM.
added PS

Kind Regards,

 

Charles.C


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#11 Anwer Khattak

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Posted 17 December 2020 - 04:00 AM

See -

 

https://www.ifsqn.co...41/#entry130505

 

(Note this is ver. 4.1, haven't yet compared to latest version)

 

PS - there is a degree of confusion in respect to different GFSI-recognised Standards implementing somewhat different interpretations of food fraud/vulnerability assessment. (GFSI's own definition also changed from 2014 to 2017).

 

For example (2019) -

 

attachicon.gif vulnerability assessment.jpg

 

And as for GFSI -

 

attachicon.gif GFSI - food fraud2.PNG

 

IMO, definitely a distinction with a difference !

 

Hi Charles,

FSSC has a complete guidance document on Food fraud (attached).

As I am preparing a FF plan for first time, so I am having difficulties.

Attached Files



#12 Charles.C

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Posted 17 December 2020 - 06:31 AM

Hi Charles,

FSSC has a complete guidance document on Food fraud (attached).

As I am preparing a FF plan for first time, so I am having difficulties.

 

Thks for feedback.

 

From a quick look, the 2019 (ver 5) Guidance requirements/text look almost identical to my (2018-ver. 4.1) attachment.


Kind Regards,

 

Charles.C


#13 PowderQM

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Posted 17 December 2020 - 04:27 PM

Hi Anwer,

 

we are a FSSC 22.000 certified skimmed milk powder producer. We used the SSAFE document for the assesment for each product category (thankfully only two) separately. Sometimes it is also neccesary to asses for each supplier separately. If you have many raw materials with very different supply chains, it makes sense to group the raw materials (and supply chains) in advance.

Where the tool reveals weaknesses, it is necessary to introduce additional controls (analyzes, etc.) or, if these are not necessary (e.g. if the end product is examined), to justify this in writing.

 

For all who need more training or information regarding Food Fraud, I found this website with free trainings:

https://www.foodfrau...ention-academy/



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#14 Charles.C

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Posted 17 December 2020 - 09:17 PM

Hi Anwer,

 

we are a FSSC 22.000 certified skimmed milk powder producer. We used the SSAFE document for the assesment for each product category (thankfully only two) separately. Sometimes it is also neccesary to asses for each supplier separately. If you have many raw materials with very different supply chains, it makes sense to group the raw materials (and supply chains) in advance.

Where the tool reveals weaknesses, it is necessary to introduce additional controls (analyzes, etc.) or, if these are not necessary (e.g. if the end product is examined), to justify this in writing.

 

For all who need more training or information regarding Food Fraud, I found this website with free trainings:

https://www.foodfrau...ention-academy/

 

Hi Powder,

 

Thks for info.

 

IIRC this link is one of the "old chestnuts"  here. Somewhere usually connected to the (reputable) Michigan U. Food Fraud "Plan"

 

$100 for recognition is not exactly free although the MU courses, from memory, are indeed claimed to be free.

 

@ anwer khattak,

 

You are maybe over-thinking the FSSC requirements a little. I suggest for starters -

 

(a) Chris's example (post3) is IMO already, mainly, well-aligned to stated FSSC/VA requirements (ie Ad1/2)  except  (seemingly) for the additional requirements as discussed in link in post 10, eg vulnerabilities within site

(b) For the latter item in (a), I suggest you study one of Chris's earlier attachments here -

https://www.ifsqn.co...ed/#entry121857

(c) For the mitigation plan (also specified by SQF etc), will need to focus on results from (a,b) respectively.

 

Anyone who has already navigated FSSCs rather tortuous expectations for this food fraud topic is only too welcome to  post their experiences with respect to (a,b,c) above.

 

PS - You might also consider looking at the impressively detailed examples presented in IFS's Food Fraud Publication which include VA  and Mitigation plan but, afaik, not including within site process except for IFS Packaging Standard. See attached below.

 

Attached File  IFS Food Fraud-Guide,2018.pdf   3.18MB   48 downloads


Kind Regards,

 

Charles.C


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