Food fraud, including the subcategory of economically motivated adulteration, is of growing concern to food processors and others in the food chain everywhere. As a result, the Global Food Safety Initiative (GFSI), the global consortium dedicated to improving food safety for consumers, proposes adding two requirements to its GFSI Guidance Document – which apparently will result in new rules in 2016 for its recognized and widely mandated inspection programs.
The organization has issued a position paper on the problem; some of the highlights include:
GFSI defines food fraud as the deception of consumers using food products, ingredients and packaging for economic gain. It includes substitution, unapproved enhancements, misbranding, counterfeiting, stolen goods or other actions.
Unlike food defense, which protects against tampering with intent to harm, the consumers’ health risk of food fraud often occurs through negligence or lack of knowledge on the fraudsters’ part and can be more dangerous than traditional food safety risks because the contaminants are unconventional. High profile food fraud incidents with an impact on consumers’ health include the oft-cited melamine crisis, in which adulterated milk powder led to infant hospitalizations and even fatalities; knowingly shipping Salmonella-contaminated peanuts and mislabeled recycled cooking oil.
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. In the context of the GFSI’s efforts to provide “safe food for consumers everywhere,” the board has been supporting a Food Fraud Think Tank to investigate and recommend how companies could strengthen their food safety management system to protect consumers from the potential harm caused by food fraud practices. The work of the Food Fraud Think Tank emphasizes that mitigating food fraud requires a different perspective and skill-set than food safety or food defense, because socio-economic issues and food fraud history are not included in the traditional food safety or food defense risk assessments. Vulnerabilities relating to food fraud can also occur outside the traditional manufacturing, processing or distribution systems of a company.
The Think Tank recommends two fundamental steps are taken by the food industry to aid in the mitigation of food fraud:
- Carry out a ‘‘food fraud vulnerability assessment" in which information is collected at the appropriate points along the supply chain (including raw materials, ingredients, products, packaging) and evaluated to identify and prioritize significant vulnerabilities for food fraud.
- Put in place appropriate control measures to reduce the risks from these vulnerabilities. These control measures can include a 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.
The GFSI board has decided to follow the recommendations of the Food Fraud Think Tank and proposes to incorporate them in the next GFSI Guidance Document.
The vision is that, like the introduction of food defense into the guidance document a few years ago, the mitigation of food fraud and the potential impact on consumers’ health becomes an integral part of a company’s food safety management system. During a food safety certification audit, conducted against GFSI recognized schemes, the auditor will review the documentation related to the vulnerability assessment process and confirm that a comprehensive control plan, as outlined in the appendix, has been developed and implemented by the company. 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.
The GFSI board will specify any additional auditor competence needed for these added requirements. The board recognizes the importance of food fraud mitigation and the urgency to start performing food fraud vulnerability assessments and implementing associated control plans.
GFSI recognizes there are several initiatives under way to address this issue; in particular, GFSI said it continues to support the work of SSAFE, a more agricultural-oriented consortium. SSAFE's initiative aims to develop and publish guidelines for companies on how to assess and control food fraud vulnerabilities within their organizations and supply chains. SSAFE is working to have these guidelines available before the release of Version 7 of the GFSI Guidance Document, so that companies and scheme owners can prepare their organizations before the new requirements are effective.
"The GFSI Board decided to issue this position paper to express its intent and defer the incorporation of the new food fraud mitigation key elements, along with any additional auditor competencies, until the next full revision of its Guidance Document (Version 7) to be released in 2016."