4 replies to this topic

[JPA]

Hi everyone.

 

We just got audited for FSSC and we were given a non-conformance on Food Fraud Mitigation. Mass Balance testing was declared as a control in the assessment of likelihood of detection. But we were not able to provide evidence of its implementation. The person who created our vulnerability assessment left  

Can someone please help me? How do I conduct Mass balance?

 

Thanks.

[Charles.C]

Hi everyone.

 

We just got audited for FSSC and we were given a non-conformance on Food Fraud Mitigation. Mass Balance testing was declared as a control in the assessment of likelihood of detection. But we were not able to provide evidence of its implementation. The person who created our vulnerability assessment left

Can someone please help me? How do I conduct Mass balance?

 

Thanks.

 

Hi JPA,

 

You may need to post more details regarding yr Procedure for VA, eg - .

 

Please supply some context, eg (a) Product, (b) what specific safety-related fraud characteristic is "Mass Balance" controlling ?

 

Are you aware that FSSC have issued a Guidelines Manual on Food Fraud ?

[pHruit]

Hi everyone.

 

We just got audited for FSSC and we were given a non-conformance on Food Fraud Mitigation. Mass Balance testing was declared as a control in the assessment of likelihood of detection. But we were not able to provide evidence of its implementation. The person who created our vulnerability assessment left

Can someone please help me? How do I conduct Mass balance?

 

Thanks.

Mass balance is about making sure that the quantity coming out is equal to the quantity coming in, less any expected/explainable/understood losses due to e.g. production yields, wastage etc., over a specified period - could be a batch, a day, a period of weeks/months.

For example, if I start with zero balance of organic 100% beef burgers on January 1st, and in the period January 1st - March 31st I buy 300kg of organic beef burgers, but find that I have sold 350kg of organic beef burgers, one would potentially infer that I've fraudulently (or accidentally - but that isn't great either...) sold 50kg of organic beef burgers that are either not organic, or not beef, or possibly neither organic nor beef.

It's a fairly standard traceability approach used by e.g. some of the organic certification bodies in the UK.

 

It might be the case that your products/raw materials/supply chain are such that this type of verification activity has some specific benefit, but equally it might be worth reviewing the guidance mentioned by Charles and deciding whether there is a different approach that you prefer and that would work as well as, or better than, the mass balance approach if it's one with which you're not particularly comfortable.

 

 

@Charles - I've seen this used quite widely and had to do many such exercises in audits, with no direct/tangible food safety implications as such. It's always been entirely about demonstrating control of organic status, or similar "identity" claims, i.e. "fraud" in the basic misrepresentation sense of things.

[Charles.C]

Mass balance is about making sure that the quantity coming out is equal to the quantity coming in, less any expected/explainable/understood losses due to e.g. production yields, wastage etc., over a specified period - could be a batch, a day, a period of weeks/months.

For example, if I start with zero balance of organic 100% beef burgers on January 1st, and in the period January 1st - March 31st I buy 300kg of organic beef burgers, but find that I have sold 350kg of organic beef burgers, one would potentially infer that I've fraudulently (or accidentally - but that isn't great either...) sold 50kg of organic beef burgers that are either not organic, or not beef, or possibly neither organic nor beef.

It's a fairly standard traceability approach used by e.g. some of the organic certification bodies in the UK.

 

It might be the case that your products/raw materials/supply chain are such that this type of verification activity has some specific benefit, but equally it might be worth reviewing the guidance mentioned by Charles and deciding whether there is a different approach that you prefer and that would work as well as, or better than, the mass balance approach if it's one with which you're not particularly comfortable.

 

 

@Charles - I've seen this used quite widely and had to do many such exercises in audits, with no direct/tangible food safety implications as such. It's always been entirely about demonstrating control of organic status, or similar "identity" claims, i.e. "fraud" in the basic misrepresentation sense of things.

 

Hi pHruit,

 

Thks the comment. I agree not unreasonable from a purely Economic gain POV.

 

Indeed interpretations of the scope of Food Fraud could make a publication on their own. In fact GFSI themselves offered a short monograph/definition which was later revised to include a health related aspect. FSSC were smart enough to simply reference GFSI's interpretation of Food Fraud as being the pertinent one (their Guidance content is predictably "ambiguous").

 

Whether "health"  includes psychological trauma as might perhaps occur due your mentioned misrepresentation would be an interesting auditorial argument. I suppose (= BRC interpretation FF ?) that one can postulate that any suspicious discrepancy like weight loss be automatically equated to a worst case FS situation since such an approach might have prevented the melamine disaster but IMO it's a distinctly slippery FS slope.

 

The Post below (and its sub-link) delve/speculate further into the FF minefield. FSSC afaik have essentially reiterated their ver4 text for FSSC22000 ver5. Inclusion (or not) of onsite fraud (à la SQF) is another nicety.

 

https://www.ifsqn.co...00/#entry168422

Edited by Charles.C, 10 June 2021 - 04:57 PM.
edited

[pHruit]

I find it quite an interesting area in general - one of those parts of food safety (ish ) systems where we're all nominally trying to achieve the same thing, but actually we're perhaps not...

Those of us who, like me, have become indoctrinated into the BRC mindset may have become so accustomed to the idea that it is far broader than food safety that of course everyone sees it that way. That is clearly not the case though!

 

BRC's interpretation is perhaps skewed by the UK retail landscape - veering slightly towards cynicism, one rather wonders if it has as much to do with certain retailers being terrified of bad press as it does with food safety. Obviously some types of fraud will, or may, present a safety risk - the melamine example being a classic and particularly disturbing case - but the audit experience for BRC is IMEX far more general than that.

I note their page https://www.brcgs.co...ety/food-fraud/ makes specific reference to "all product descriptions and claims are legal", rather than "all products are safe", and this rather marries up with my experiences in the UK industry since the great Horsegate fiasco.

Customers also seem to approach much of it this way - whether the Italian tomato in that jar of pasta sauce is actually from Italy, rather than generic European, is treated to the same level of scrutiny (and indeed sometimes more ) than whether the HACCP plan under which it is produced is robust and properly validated.

 

Psychological trauma probably is a factor, but it is perhaps the trauma suffered by brand/retailer PR departments and boards of directors, rather than consumers