Earlier tonight the Global Food Safety Initiative (GFSI) Board released their position paper on Food Fraud prevention. The GFSI Food Fraud Think Tank, created in 2012, was identified as a key contributor in the development of their position. The Think Tank included our MSU Food Fraud initiative, Danone, Royal Ahold, Eurofins, Walmart, and Inscatech. We are proud that our work was helpful, and they recognized us stating “…the Food Fraud Initiative at Michigan State University, leading the academic field of criminology with a special focus on food fraud.” Our MSU work is focused on a very rational approach to prevention.
For your information, we have several education programs that address Food Fraud prevention. Pencil in the dates:
Executive Education/ Short Courses
• September 22-23, Food Fraud Basics, Short Course, at MSU
• September 24-25, Quantifying Food Risk, Executive Education, at MSU – Invitation Only
MOOC — free, online, open to everyone, and includes two, 2-hour webinars:
• August 4 & 11, Food Fraud MOOC in Mandarin
• November 10 & 17 Food Fraud MOOC with Trends Update
Graduate Certificate in Food Fraud Prevention – four, 3-credit graduate classes
Quantifying Food Risk (VM825) Graduate Course – August 25- December 6, the first class in the series begins Fall Semester
The goal of our blog is to review and address some of the timely and important Food Fraud concepts. The clear GFSI position in the position paper is extremely important because it formally states the official position of the GFSI Board and GFSI. This is a statement of what the GFSI Board expects to find in a thorough and competent Food Safety Management System. We will review some of the key points below.
[Disclaimer: Although I was a member of the Food Fraud Think Tank these statements represent my own insight and opinions. These statements in no way represent the GFSI positon or analysis.]
GFSI Position on Mitigating the Public Health Risk of Food Fraud
Broad Definition of Food Fraud. GFSI formally defined their broad definition of Food Fraud to include adulteration, but also all fraud – explicitly including misbranding and stolen goods. Stolen goods present an especially complex challenge because authenticity testing would, of course, identify the product correctly as genuine. Stolen goods can present a public health threat since they may have been mishandled. Also, their date or lot codes could have been tampered with.
- “Food Fraud, including the subcategory of economically motivated adulteration, is of growing concern. It is deception of consumers using food products, ingredients and packaging for economic gain and includes substitution, unapproved enhancements, misbranding, counterfeiting, stolen goods or others.”
- “The GFSI Board recognizes that the driver of a food fraud incident might be economic gain, but if a public health threat arises from the effects of an adulterated product, this will lead to a food safety incident.”
It should be emphasized that a holistic Food Fraud prevention plan addresses more than adulteration and expands beyond ingredients. These ingredients may be the most significant risk but others can still lead to food safety incidents. (A future blog post will address the confusing concept that the US Food, Drug and Cosmetics Act could be used to determine a product to be “Adulterated Foods” – unfit for commerce – but there doesn’t need to be an “adulterant.” A stolen good would be classified as “Adulterated Foods.”) The broad definition of Food Fraud is a key concept to help increase transparency in the supply chain.
Requires a Unique Prevention Approach: Food Fraud Vulnerability Assessment and a Food Fraud Control Plan. The paper frequently cites the work of the Food Fraud Think Tank specifically in the development of the foundational concepts. Those base concepts include emphasizing that a different skill set is required than is used for mitigating food safety or food defense threats. The mitigation plan concepts are similar to HACCP or basic quality management systems: identify the vulnerabilities and have a control plan in place.
- “The Think Tank recommends that two fundamental steps are taken by the food industry to aid in the mitigation of Food Fraud: firstly, to carry out a “food fraud vulnerability assessment” in which information is collected at the appropriate points along the supply chain (including raw materials, ingredients, [finished] products, packaging) and evaluated to identify and prioritize significant vulnerabilities for food fraud.”
- “Secondly, ‘appropriate control measures shall be put in place to reduce the risks’ from these vulnerabilities. These control measures can include monitoring strategy, a testing strategy, origin verification, specification management, supplier audits, and anti-counterfeit technologies. A clearly documented control plan outlines when, where and how to mitigate fraudulent activities.”
Auditor Competence – Audit the Plan not Find Bad Guys. GFSI is clear that the expectations are for the auditors to check for the presence of the assessment and the plan. They note this is similar to HACCP audits. Follow-up engagements may include consulting to help the company improve the control of their facility but that is not specifically part of the HACCP “audit.” We included similar statements in our submission to the US FDA’s request for comments on the FSMA Intentional Adulteration draft rule (we will post and discuss our submission in a future blog post).
Implementation – Guidance Document Version 7 in 2016. This is a clear statement that Food Fraud prevention will be required for your company to be “GFSI Compliant.” Version 7 will be published in 2016, and there will also be an additional time period after that during which the GFSI-recognized schemes(1) and audit strategies will be developed. But there is no doubt that Food Fraud prevention requirements are coming. GFSI Compliance is required to sell product to many companies. No GFSI certificate, no sale.
Global Laws and Regulations – Beyond GFSI. It is important to emphasize that while this is a GFSI position paper, governments around the world are working to address Food Fraud. Addressing Food Fraud will eventually be required for regulatory compliance.
While some people may think today’s press release will have huge rippled effects, it really wasn’t earth-shattering. It’s not a surprise to those who have been paying attention. Companies and countries have been rising to meet Food Fraud head-on. Regardless of the compliance requirements, every single day there are Food Fraud vulnerabilities that threaten the safety of the supply chain. Be proactive. Don’t just start going crazy trying to implement programs or countermeasures. Take the first step of getting familiar with reports like the GFSI Food Fraud position paper. Also, reach out for the many education opportunities. For example, see our website for a range of educational programs. JWS.
(1). Regarding the term “scheme”: GFSI uses a more European definition of this term meaning “plan for doing something” rather than the more American insinuation of “a crafty plot,” reference: Webster’s Dictionary.