This blog post was created after several separate conversations with several senior industry leaders who are in charge of Food Fraud prevention for their Fortune 1000 Corporations. “Wait, what? What is required for GFSI compliance?” The answer was simple but a bit of a revelation. Also, by focusing on the specific requirements – and resources available – it is a bit more of a re-formatting rather than a big undertaking.
This is also an announcement of our new Food Fraud Audit Guide MOOC (see www.FoodFraudMOOC.com).
FSMA/ FDA Food Fraud Compliance Requirements
For Food Fraud prevention, FSMA refers to “economically motivated adulteration” with a broad focus covering all hazards that are “economically motivated.” FSMA does not require that companies do anything to pass an audit — but it does hold companies accountable for any and all hazards. We emphasize that after a Food Fraud incident, illness, or death, it would be logical for a government investigator to ask, “How did you determine this was NOT a ‘hazard that requires a preventive control?’”
- Question: Does your company have a documented process and method to determine what is NOT a FSMA-defined ‘hazard that requires a preventive control?’ (Are you confident in that process should you face an investigator after a Food Fraud incident that leads to a death?)
- Answer: If your company is GFSI compliant then you will have conducted a Food Fraud Vulnerability Assessment AND implemented a Food Fraud Prevention Plan. This appears to fulfill the legal requirements of FSMA with respect to Food Fraud prevention.
- Action: See GFSI below…
- Question: For your domestic or international suppliers, have you confirmed their compliance to FSMA (i.e. “supplier programs”) regarding “agents” that cause a “hazard that requires a preventive control” from actions that are “economically motivated”?
- Answer: If your suppliers are GFSI compliant then they will have conducted a Food Fraud Vulnerability Assessment AND implemented a Food Fraud Prevention Plan. This also appears to fulfill the legal requirements of FSMA with respect to Food Fraud prevention.
- Action: See GFSI below…
GFSI Food Fraud Prevention Compliance Requirements
GFSI clearly defines the scope of Food Fraud to include all types of fraud (e.g., not just adulterant-substances but also to include theft, tampering, counterfeiting, etc.) and all products (e.g., incoming goods such as raw materials and outgoing goods including finished products destined for retail shelves.) GSFI only requires that a Food Fraud Vulnerability Assessment be completed and documented and then that a Food Fraud Prevention Strategy be completed and documented. There are no further published requirements or guidance on the method, process, details, length, depth, etc.
- Question3: If you require GFSI compliance for your suppliers, do you have a process in place to review and confirm what they are doing to address Food Fraud by January 2018?
- Answer: If “no”, then you probably are not GFSI compliant.
- Action: Survey your suppliers. Provide an overview, definition and scope of Food Fraud, and point them to support resources.
- Question: If your customers require you to have GRSI compliance (e.g., manufactures’, retailers, etc.), do you have a process in place to review and confirm Food Fraud prevention compliance by January 2018?
- Answer: If “no”, then you probably will not be GFSI compliant.
- Action: See audit questions below and recommended steps.
GFSI Food Fraud Prevention Compliance Requirements
For yourself or your suppliers, review the basic Food Fraud Prevention Audit Questions:
GFSI Food Fraud Prevention Audit Requirements [1]:
- Have you conducted a food fraud vulnerability assessment (Y/N)
- Is this documented (written) (Y/N)
- Have you developed a food fraud prevention strategy (Y/N)
- Is this documented (written) and incorporated into the food safety management system (Y/N)
- Can you demonstrate and document effective implementation (Y/N)
- Do you have executive-level sign-off (Y/N)
- Have you minimally conducted an annual food fraud vulnerability update (Y/N)
- Do you have a method to review your incidents and general market incidents (Y/N)
- Do you address all types of food fraud (e.g., adulterant-substances, stolen goods, counterfeits, etc.) (Y/N)
- Do you address all products from incoming goods (e.g., raw materials and ingredients) to outgoing goods (e.g., finished goods) through to the consumer (Y/N)
If you answer “yes” to all ten questions – for both you and for your suppliers – then congratulations. You appear to be fully GSFI Compliant regarding Food Fraud. If not, then the first step is to review the requirements and begin a process that will achieve at least the minimum GFSI compliance requirements.
GFSI pre-filter/ initial screening Food Fraud Vulnerability Assessment
A method to begin assessing Food Fraud vulnerabilities is to start from the top-down (“macro level”) and conduct a “pre-filter” or initial screening. It is understandable if the first assessment has a low degree of certainty and robustness. This initial screening is based on COSO managerial accounting principles in Enterprise Risk Management (ERM). The pre-filter enables you to identify where a more detailed vulnerability assessment is needed — or not. The first assessment is often one matrix for all incoming goods and one matrix for all outgoing goods — each having no more than five types of market segments and five groups of products.
An initial screening is directional and leads to subsequent vulnerability assessments having high degrees of confidence and robustness. Without an initial screening, the other extreme would be conducting a full Food Fraud Vulnerability Assessment on every supplier-product combination (potentially at the ingredient level). For even a medium size company, they could have 1000 suppliers and each supplier providing an average of 10 product variations which would require 10,000 separate assessments. It was estimated the fully detailed vulnerabilities assessments could take years to complete.
One support resource is the Food Fraud Prevention Academy’s free, open, online educational opportunities. There are also in-person Executive Education courses available. These include the development of an effective and efficient Food Fraud Prevention Strategy and another on conducting Food Fraud Vulnerability Assessments. (An actual Food Fraud Initial Screening is completed in the latter course). It is most efficient to establish the parameters of your project before making decisions to move forward.
References
[1] Food Fraud Prevention Academy, Food Fraud Audit Guide MOOC (Massive Open Online Course), (see www.FoodFraudMOOC.com)