GFSSI POSITION
N ON M
MITIGA
ATING
G THE PUBLLIC HEEALTH
H RISK OF FO
OOD FFRAUD
D Ju
uly 20
014 GFSI PO
OSITION
N ON MITIGATING THEE PUBLIC
C HEALTTH RISK OF FOO
OD FRAU
UD INTRODU
UCTION Food fraud,, including the subcateggory of econnomically mo
otivated adulteration, is of growing concern. It is deception o
of consumerrs using foo
od products, ingredientss and packag
ging for ecoonomic gain and includees substitution
n, unapproveed enhancem
ments, misbbranding, cou
unterfeiting, stolen goodds or otherss. Unlike foo
od defence, which protectts against ta
ampering witth intent to harm, the consumers’ health risk of food frau
ud n
orr lack of knoowledge on the fraudste
ers’ part andd can be mo
ore dangerou
us often occurrs through negligence than traditiional food safety s
risks because thee contaminants are unconventional . High profile food frau
ud incidents w
with an impact on consumers’ healthh include the oft‐cited melamine m
crrisis, in which adulterateed milk powdeer led to infaant hospitalizations and even fatalities; knowing
gly shipping Salmonella contaminateed peanuts and
d mislabelled
d recycled co
ooking oil. The GFSI Bo
oard recognises that the
e driver of aa food fraud incident might be econnomic gain, but b if a publlic health threaat arises from
m the effects of an adultterated prod
duct, this will lead to a foood safety in
ncident. In th
he context of the GFSI’s efforts e
to provide “safe food for co
onsumers everywhere”, tthe GFSI Bo
oard has beeen 1
supporting a Food Fraud
d Think Tankk to investiggate and reco
ommend to tthe GFSI Boaard, how com
mpanies could strengthen their food ssafety managgement systeem to protect consumerrs from the potential ha
arm caused b
by practices. food fraud p
The work off the Food Fraud Think T
Tank emphassizes that miitigating food
d fraud, andd the potential harm thesse incidents caan bring to public p
health
h, requires aa different perspective p
and a skill‐set than food safety s
or foo
od defence, beecause socio‐‐economic isssues and foood fraud histtory are not included in tthe tradition
nal food safetty or food defence risk asssessments. V
Vulnerabilitiees relating to
o food fraud can also occcur outside tthe traditional manufacturring, processsing, or distribution systeems of a com
mpany. The Think TTank recom
mmends that two funda mental step
ps are taken
n by the foood industry to aid in th
he mitigation o
of food fraud
d: firstly, to carry out a ‘‘food fraud vulnerability
y assessmennt’ in which iinformation is collected att the approp
priate pointss along the supply chain
n (including raw materiaals, ingredients, productts, packaging) and evaluateed to identifyy and priorittise significan
nt vulnerabilities for foodd fraud. GFSI PO
OSITION
N ON MITIGATING THEE PUBLIC
C HEALTTH RISK OF FOO
OD FRAU
UD ace to reducce the risks ffrom these vvulnerabilitiees. Secondly, appropriate ccontrol measures shall bbe put in pla
These contrrol measuress can include
e a monitorinng strategy, a testing stra
ategy, originn verification, specificatio
on managemen
nt, supplier audits and a
anti‐counterffeit technolo
ogies. A clearly documennted control plan outlinees when, wherre and how tto mitigate frraudulent acctivities. GFSI POSSITION The GFSI Bo
oard has deccided to follo
ow the reco mmendation
ns of the Foo
od Fraud Thhink Tank and
d proposes tto incorporatee the two foo
od fraud mittigation stepps in the form
m of two new key elemeents in the G
GFSI Guidancce Document tto; 1. Require a co
ompany to p
perform a foood fraud vuln
nerability asssessment 2. Have a conttrol plan in p
place. The vision iis that, like the t introducction of foodd defence in
nto the Guidance docum
ment a few years y
ago, th
he mitigation of food frau
ud and the potential im
mpact on co
onsumers’ health becom
mes an integgral part of a management system. company’s ffood safety m
During a food safety ceertification audit, conduccted against GFSI recognised schemees, the audittor will review the documentation rellated to the
e vulnerabiliity assessme
ent process and confirm
m that a co
omprehensivve control plan, as outlined in the Appendix, A
haas been devveloped and implementeed by the company. c
Th
he aud or affirm
m that an antti‐fraud prog
gram is capa ble of “preventing fraud
d”. auditor is not expected to detect fra
This approaach is very much in line w
with the veriffication of a HACCP plan during the foood safety audit. The GFSI Board will furthermore specify any a
additional auuditor compe
etence needed for the abbove activities. The GFSI Bo
oard recognises the impo
ortance of foood fraud miitigation and the urgencyy to start performing foo
od fraud vulnerability assessments and
d implement ing associate
ed control plans. There aare many inittiatives across would like to
o continue to
o lead this fieeld, provide direction an
nd the industryy related to this key topiic and GFSI w
ensure aliggnment of the various initiatives. On the oth
her hand, th
he GFSI Boaard also app
preciates thaat companies and schemee owners need to preppare for thiss new challe
enge and neeed time to
o develop th
he nowledge and
d skills. required kn
oard decided
d to issue this position ppaper to exp
press its intent and deferr the incorpo
oration of th
he The GFSI Bo
new food frraud mitigattion key elem
ments, alongg with any ad
dditional aud
ditor compettencies, untiil the next fu
ull revision of iits Guidance Document ((Version 7) too be released in 2016. The GFSI Board will support SSAFE
E’s2 initiativee which aims to develop
p and publissh practical guidelines fo
or o assess and control foood fraud vuln
nerabilities within w
their organization
ns and supp
ply companies on ‘how’ to
ng to have th
hese guidelinnes available
e before the release of V
Version 7 of the Guidancce chains. SSAFE is workin
ompanies an
nd scheme owners can
n prepare their t
organiisations beffore the new Document, so that co
nts are effecttive. requiremen
GFSI PO
OSITION
N ON MITIGATING THEE PUBLIC
C HEALTTH RISK OF FOO
OD FRAU
UD APPENDIIX: PROPO
OSED KEY ELEMENTTS FOR FOOD FRAUD MITIGA
ATION The below key elementts were prep
pared by thee Guidance D
Document Te
echnical Worrking Group based on th
he recommend
dations of the Food Fra
aud Think TTank. Consultation will continue c
du ring the development of o
Version 7 off the Guidan
nce Documen
nt. The standard shhall require that the org
ganisation hhave a documented ‘Food frau
ud vulneraability food
d fraud vullnerability assessment a
in place too identify potential assessmentt’ requireme
ents vuln
nerability andd prioritise food fraud vu
ulnerability ccontrol meassures. ganisation hhave a documented The standard shhall require that the org
plan
n in place thhat specifies the control measures thhe organisattion has t public health h
risks ffrom the identified ‘Food frau
ud vulneraability implemented too minimize the food
d fraud vulne
erabilities. control plan
n’ requireme
ents Thiss plan shall ccover the relevant GFSI scope and shhall be suppo
orted by the organisationn’s Food Safe
ety Managem
ment System
m. REFEREN
NCES 1
The Food FFraud Think Tank T
was con
nvened to furrther advance
e the food fra
aud topic; it bbrought together experts in analytical tessting, certificaation, supply cchain security and criminolo
ogy as well as manufacturinng and retailin
ng companiess. 2
SSAFE (Safee Supply of Afffordable Food Everywheree) is a non‐profit organisation addressinng pre‐compettitive issues fo
or the food indu
ustry through public private partnershipps.