Review of GFSI Food Fraud Technical Document, May 2018

Last week on May 9, 2018, the Global Food Safety Initiative (GFSI) published a Food Fraud Technical Document titled “Tackling Food Fraud Through Food Safety Management Systems,” which outlines the new compliance requirements. Some requirements may be surprising or lead to audit non-conformances but the basic principles are not new. In addition to this new document, there are many training and education resources, including a few listed below. This new document is a key for confirming the definition, scope, starting point, and the expectation for these first compliance requirements.

Excerpt from our FFI Report:

Title: Review of GFSI Food Fraud Technical Document: Tackling Food Fraud through Food Safety Management Systems

Date: May 16, 2018

Author: John Spink, PhD

Link to full FFI Report:

Review of GFSI Food Fraud Technical Document, May 2018
GFSI series of documents that address Food Fraud: Position Paper 2014, Benchmarking Document 2017, and Technical Report 2018


The Global Food Safety Initiative (GFSI) published the GFSI Food Fraud Technical Document titled “Tackling Food Fraud through Food Safety Management Systems.” This publication supports the previous reports on the GFSI food fraud position paper (2014) and GFSI Benchmarking Document (2017). This new document reinforces the previous GFSI statements and supports the efforts to “just get started.” This new document is a key for confirming the definition, scope, starting point, and the expectation for the first compliance requirements. While HACCP is 20+ years in development, the GFSI food fraud requirements have only been in effect for 20 weeks. The new food fraud requirements help move the risk assessors from “point A” to just “point B” and not all the way to a full HACCP-type plan which would be “point Z.” While “Point Z” is the ultimate goal, we must get to “Point B” before moving to “Point C,” “Point D” and on.  This new technical document reviews the previous statements and clarifies the near path forward.


The key conclusion points include:

  1. Holistic scope – all fraud and all products: The scope is all types of fraud (from adulterant-substances to counterfeits and stolen goods) and all products (from incoming goods through to product in the marketplace including counterfeits.) All types of fraud and all products can cause health hazards and lead to economic harm.
  2. Just get started: There is continued emphasis on starting the process that will be supported by continuous improvement and sharing of best practices.
  3. Auditors are to confirm the process, not judge the plans: To begin the compliance, the scope is to confirm the process is started.

Several key points were emphasized by GFSI, and our FF Insight is included here:

  • ‘(2) “While a Food Fraud Manager is “accountable” for the full compliance, they may not be “responsible” for each of the individual tasks. For example, managing and monitoring stolen goods may already be conducted by a supply chain logistics or corporate security staff.”
  • FF Insight: The GFSI document provides more detailed insight into compliance through explaining some details of the implementation. A concern by industry has been that a new food fraud task force would require many new staff members. This GFSI statement emphasizes that all the topics must be covered, but they can be implemented by other current staff.
  • FF Insight: It is significant that GFSI uses a non-traditional food safety example such as stolen goods that are not usually under the accountability of a food quality assurance team.
  • ‘(3) “The requirements refer to “The Organization”: While the traditional HACCP-type food safety approach is applied at manufacturing facilities, these operate within the overall organization. The food fraud vulnerabilities are company-wide, and thus the food fraud scope is company-wide.”
  • FF Insight: GFSI is clear that the food fraud vulnerability assessment and prevention strategy is to cover the entire organization, not just the facility that may be the location of an audit. A traditional food safety audit focuses on HACCP so would focus on the operations of a facility or manufacturing location. For food fraud, the overall vulnerability and control plans may be completely and competently addressed at the enterprise-wide level. Thus, a manufacturing site audit could rely on a company-wide assessment. Unless there is a unique operational activity, each manufacturing facility would usually not be required to conduct a separate review.
  • ‘(8) “(B) Understand the difference between hazard (a potential source of harm), risk (the probability of loss or injury from a hazard) and vulnerability (susceptibility to a risk): many hazards will have a low or very low likelihood and therefore not represent a risk; likewise, the susceptibility of a company or system to a risk is not only linked to the severity of this risk but more to the company’s awareness of their weakness and how they manage it.” … While an “all hazards” assessment approach is important, all vulnerabilities are not risks, all risks are NOT hazards, and all hazards are NOT hazards that require a preventive control. The final mitigation plan must focus on those vulnerabilities that require a preventive control as identified through a carefully and documented analysis of the risks, likelihood and fraud opportunities.”
  • FF Insight: GFSI calms an industry concern that each and every identified vulnerability would require a control plan. Thus, this all-hazards approach allows for a broad lens to monitor possible root causes while including a clear method to narrow the focus to only the worst problems. The GFSI requirements are for “a” method to conduct this assessment with no prescribed or required approaches.
  • ‘(12) “With this in mind, there is an awareness that addressing food fraud is new and different for those being audited as well as for the auditors: “The auditor is not expected to detect fraud or affirm that an anti-fraud program is capable of “preventing fraud.” This approach is very much in line with the verification of a HACCP plan during the food safety audit.”
  • FF Insight: GFSI includes a practical and pragmatic approach that emphasizes the auditors be “not expected to detect fraud or affirm the anti-fraud program.” The audit is intended to confirm that a food fraud vulnerability assessment is in place and that there is a food fraud prevention strategy, and that it covers the relevant GFSI scope. Industry-wide compliance with these first efforts will be a key advancement from “point A” to “point B.” As time goes on, there will be more advanced programs that will provide insight for more advanced audit requirements.
  • FF Insight: To reinforce this point, the key and optimal first role of the auditor – especially now only 20 weeks into the food fraud requirements – not 20 months or 20 years – is to confirm the requirements are being addressed, documented, and cover the relevant GFSI scope.

The new GFSI Food Fraud Technical Document reinforces the previous statements and supports the efforts to “just get started.” Next will be “how to start,” then “how much is enough.” The new GFSI Food Fraud Technical Document is very important since we now have a firm and clear starting point to address food fraud prevention. Use this as a spark for you to start or refine your food fraud prevention strategies. See the link to the GFSI document, our review, or the resources below. JWS.

Note: Our resources for capacity- and capability-building:

  • Food Fraud Overview and History [includes the history of the GFSI Food Fraud Think Tank, Position Paper, and inclusion in the GFSI Benchmarking Document], Presented by John Spink, Food Fraud Session, GMA Annual Conference, Tokyo, 2018, URL (5-minutes):
  • Food Fraud Update and Terminology Survey, Presented by John Spink, GMA Science Forum 2018, URL (21-minutes):
  • Food Fraud Prevention Strategy Development [SQF] – Intro to Vulnerability Assessment”: A presentation at the 2018 SQF Conference. This covers the basic audit requirements then the “how to start” and how to conduct the first stage of a Food Fraud Vulnerability Assessment (35-minutes):
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