Laboratory reports recently acquired by the Freedom of Information Law from the New York State Department of Agriculture and Markets show the Sol Andino brand ground cumin to contain 1090 ppm lead as well as 259 ppm chromium. The spice was also analyzed by IS:2446, 1980 method, “Detection of Lead Chromate in Chillies, Curry Powder and Turmeric by diphenyl carbizide.” A positive result was given, indicating the presence of hexavalent chromium, which is a component of lead chromate. Lead chromate is a yellow pigment, not allowed in food anywhere in the world as it is toxic, containing both lead and hexavalent chromium. The New York State Department of Agriculture and Markets posted a Class I recall of the Sol Andino ground cumin on July 10, 2017, without mention of the extremely high concentration of lead in the product.
The author could find no record of an FDA recall for the Sol Andino brand cumin powder containing excessive lead.
Some of us remember the four FDA Class I recalls of Pran brand turmeric for excessive lead in October 2013. These recalls were initiated by the New York State Health Department due to an illness complaint—most likely a child with high blood lead levels. The recalled Pran brand turmeric contained 28–53 ppm lead.
“There have been two cases of high blood levels of lead associated with this product to date. Both cases have been reported through the Illinois Department of Public Health, Environmental Health Protection.”
According to the recall, the “Thyme” was found to contain 422 ppm lead.
Wondering if the 422 ppm lead was caused by adulteration of the “Thyme” with lead chromate or another lead pigment, a food chemist at the New York State Food Laboratory (a Division of NYS Dept. of Agriculture and Markets) requested from Illinois a sub-sample of the “Thyme” for analysis. Lab analysis of the spice found 323 ppm lead, 109 ppm chromium and a positive result for the chromate test. Thus, this recalled “Thyme” contains lead chromate.
In both cases, Pran turmeric and Nabelsi Thyme, illness complaints led to the recall of lead adulterated spices.
The New York State Department of Agriculture and Markets has a proactive program. Random samples of spices are sampled from retail markets and subsequently analyzed for unallowed colorants, undeclared allergens and heavy metals. In 2016 this resulted in the Oriental Packing Class I recall of 377,000 lb. of turmeric containing spices for excessive lead. (A typo in the FDA recall attributes the recall to the New York State Health Department, instead of the New York State Dept. of Agriculture and Markets.)
Still, it’s even better to analyze spices being imported into the country at receiving warehouses before the product reaches retail markets. Lead concentrations above 10 ppm can be determined instantaneously with a handheld XRF analyzer.
Many foods, from honey to olive oil to spices, fall victim to fraudsters each year. Often a time-consuming process, conducting research about each product or ingredient can involve combing through many websites and databases for information. To save companies from doing all that heavy lifting, newer tools are aggregating the data into single platforms. One most recent example is the World Factbook of Food, developed by the Food Protection and Defense Institute (FPDI) and funded by the U.S. Department of Homeland Security. The tool was released earlier this year, and Erin Mann, project manager at FPDI, explains how it is helping food companies mitigate the risk of food fraud in their supply chain.
Food Safety Tech: What are the fundamental advantages of using the World Factbook of Food and how is it different from other tools that companies can use to assess their risk?
Erin Mann: The World Factbook of Food is a central reference location for data related for food. It pulls together a lot of high quality data points from a lot of different sources into a single tool.
Companies can look for information on a lot of different food products and a lot of different sourcing regions and countries. We have more than 125 food profiles (and growing) and more than 75 country profiles (also growing). [There are 10 food profiles and 10 country profiles that are available for free] Each of the profiles covers a large number of topics. On the food profile side, there are data points on how the product is used, codes, information about standards and grades; and a lot of data about trends and consumption, production and trade patterns; there’s information about processing and supply chain characteristics; and another section about food defense and food safety.
It’s a resource that can be used anytime a company needs to get up to speed quickly on a product, because it covers a lot of different types of risks. If a company wanted access to information related to risk about past economically motivated adulteration (EMA) or intentional adulteration (IA) incidents, the Factbook has that. There’s also data on past recalls, information about major producing countries around the world—a wealth of information in one place that companies can use broadly for risk assessment—basically any use case where they want access to a lot of information from lots of sources, the Factbook can be a great place for that.
FST: Can you expand on the food defense component of the Factbook?
Mann: One of the primary sources that we pull for the food defense section comes from a complementary tool that we use here at FPDI—our food adulteration incidence registry, called the FAIR tool, which is a database of past EMA and IA incidents. On the technology side, the Factbook is directly linked with the FAIR tool. If you’re looking at a profile for a particular product, it will access the FAIR tool and display relevant incidents for that product. It won’t give you access to the entire FAIR database, but it will give you a high-level summary of what food defense incidents have happened in the past with the product, where they happened, the year and a summary.
What we’ve seen with the FAIR tool is high incidents of food adulteration in products like oils, spices, seafood—those are the major products impacted by food adulteration, particularly EMA.
FST: From what sources are the data curated?
Mann: There’s a source list at the bottom of each profile and all the data points are referenced throughout. In terms of a high-level description of where we pull data from, it includes the USDA, FDA, Codex, the U.S. International Trade commission, United Nations data, and other industry and trade groups. It also pulls data from the World Bank and the FAIR tool.
TraceGains’ latest eBook, An Organic State of Mind, sheds light on the trends and demands that are shaping the organic industry today and how automation technology is changing the game for many organic food manufacturers and producers.
FST: How can companies use the Factbook as part of their overall risk mitigation process?
Mann: One of primary strengths of the Factbook is that companies can use it in many different ways. Our institute has done a lot of work with big data and using multiple data sources, and one of the biggest takeaways we learned through several years in this field is that whenever you use big data or you use lots of data sources, they must produce intelligence and information that is actionable. All of the data and information doesn’t do much good if there’s not a clear summary of what to do with that information.
The Factbook aims to do that. It’s a collection and synthesis of data and clean information that’s in an easy to use and easy to navigate user interface. From there, companies can take a look and see how to use the Factbook where they see a gap in their processes. It’s a great place to access lots of information about a food product in a single place. If we can see several points in an overall risk mitigation process where the Factbook can be used, it could be used to inform decisions related to procurement. [For example], if a company suddenly needed to procure a product from a new source region or if they were developing a new product and had to procure an ingredient that they hadn’t worked with before, the Factbook would be a great place to get smart quickly on that ingredient.
The Factbook could be used for understanding supplier review and specific risks related to that ingredient, or simply horizon scanning—if companies want to take a look at some of the products they’ve determined to be high risk and learn more about the product from a holistic perspective.
As stated in the Q&A, 10 food profiles and 10 country profiles are available for free. Subscribers to the World Factbook of Food pay $600 annually for full access to the tool, and bundled pricing is available for users who are interested in access to both the Factbook and the FAIR tool.
Food defense is the protection of food products from intentional contamination or adulteration, as well as biological, chemical, physical or radiological agents. It addresses additional concerns including physical, personnel and operational security. A traditional food defense program is generally perceived as a program that includes site security, visitors control or even on-site personnel monitoring. However, with the new FSMA Preventive Controls Rules and GFSI Guidance for all the recognized schemes, additional to consumer demand on product transparency, we must now take food fraud into consideration within our food defense program.
What is food fraud? According to the study from Michigan State University, food fraud is a collective term used to encompass the deliberate and intentional substitution, addition, tampering or misrepresentation of food, food ingredients or food packaging, or false misleading statements made about a product, for economic gain. It becomes not just a potential for food safety issues, but also a severe issue that could potentially damage your brand reputation. It is hence critical to have appropriate protection and prevention, as the umbrella encompasses both food defense and food safety.
What does this mean to food manufacturers? The awareness of traceability and transparency certainly should rise. Most facilities should have a food defense program in place to comply with any GMP or GFSI requirements. To make it more competent for food fraud, what could we do? Here are some quick tips to strengthen your food defense program with food fraud prevention:
Tip 1: Review your entire supply chain one more time, considering fraud risks
Tip 2: Use the HACCP concept for food fraud risk analysis
Tip 3: Double-check incoming goods
Tip 4: Make the entire supply chain transparent
Tip 5: Document all records
Tip 1: Review your entire supply chain one more time, considering fraud risks
The unknown could potentially hurt you or your program. You would prefer to be aware of what might go wrong before it goes wrong, which is why a review should be one of the key steps in your food safety program. It might be a familiar terminology in the industry; however, we could not eliminate its importance to your entire food safety management system. To maintain product authenticity, understanding where your ingredients come from and who your business partners and suppliers are become the first step to success. It also gives you an excellent opportunity to analyze the risks and potential risk sources. A thorough review should include all the approved suppliers and vendor information. Knowing the source of your product provides you with a good foundation for your food defense program. How can we efficiently review our own supply chain?
List all approved suppliers and contract vendors
Make sure all ingredients are used accordingly and as intended
Keep the supplier registration list up to date
The more you understand your own supply chain, the more helpful it will be to your food defense program.
Tip 2: Use HACCP concept for food fraud risk analysis within supply chain
Hazard Analysis Critical Control Point (HACCP), as defined by FDA, is a management system in which food safety is ensured by addressing through the analysis and control of biological, chemical and physical hazards throughout the entire supply chain. This mentality of HACCP could be used and very helpful to analyze the potential fraud risks. Its seven principles and 12 steps could be implemented to identify your own fraud risks. And it is important for us to identify the hazards from potentially adulterated ingredients to determine the next step for what needs to be controlled. Utilizing the 12 steps, we can list all the key points and steps that could potentially impact your products’ authenticity. The risks can come from personnel, visitors or the ingredients themselves. There are many resources out there; for example, US Pharmacopeia (USP) has developed a global food fraud database that is a good resource for all ingredients that have been falsely used in food products.
Ready or not – here comes organic demand! Consumers everywhere are demanding certified organic products in their homes and on their tables. TraceGains’ latest eBook, An Organic State of Mind, sheds light on the trends and demands that are shaping the organic industry today and how automation technology is changing the game for many organic food manufacturers and producers.
Tip 3: Double-check incoming goods
Many articles address the importance of vulnerability assessments to prevent food fraud plus any documentation your suppliers have provided. Yes, it is critical; however, as one of the important steps in the HACCP program, verification is also important to make sure what goes into your finished products is safe and guaranteed. This could be addressed and monitored by implementing genetic testing. Each product and ingredient has its own DNA, just like our fingerprints. Nowadays, there are many methodologies developed for this type of test. The DNA testing could be a helpful tool to help your facility verify the authenticity of your incoming raw materials. Genetic testing using techniques like polymerase chain reaction (PCR) technology to detect the DNA of the product upon receiving the incoming goods. Moreover, as fast as it can be, facilities can now receive the test results within one to two hours. The testing itself might seem like an extra step with more effort and labor. However, the return is a huge saving on damages caused by food fraud. You can now start to verify and control your supply chain from the beginning to avoid any potential adulteration.
Tip 4: Make the entire supply chain transparent
This transparency not only applies to internal employees but also outward to your customers and vendors. That way you can familiarize yourself with your own supply chain, while at the same time establish brand reputation and confidence to your customers.
Tip 5: Keep all records documented
The records you should keep, besides a registration list of all your ingredients and vendors, should include the inventory list, how ingredients are used, whether it is used outside of its intended use and authorized personnel signatures. The following are some tips for an efficient document control:
Make it clear and straightforward
Categorize it based on your own facility operations
Keep the records in the same order of your supply chain from ingredients to end consumers
After all, with the newly released requirements, as QA professionals, we need to start developing a mindset that considers food fraud as a type of hazard, and develop monitor and control strategies for mitigating it. Just like we are now so familiar with the physical, chemical and biological hazards within our production facilities compared to decades ago, food fraud will no longer be a scary term once it is proficiently understood and properly controlled.
Food fraud is a recognized threat to the quality of food ingredients and finished food products. There are also instances where food fraud presents a safety risk to consumers, such as when perpetrators add hazardous substances to foods (e.g., melamine in milk, industrial dyes in spices, known allergens, etc.).
The tables in Appendix 1 include 17 food categories and are presented in three series:
Information that you should consider for potential food-related biological hazards
Information that you should consider for potential food-related chemical hazards
Information that you should consider for potential process-related hazards
According to the FDA draft guidance, chemical hazards can include undeclared allergens, drug residues, heavy metals, industrial chemicals, mycotoxins/natural toxins, pesticides, unapproved colors and additives, and radiological hazards.
USP develops tools and resources that help ensure the quality and authenticity of food ingredients and, by extension, manufactured food products. More importantly, however, these same resources can help ensure the safety of food products by reducing the risk of fraudulent adulteration with hazardous substances.
Data from food fraud records from sources such as USP’s Food Fraud Database (USP FFD) contain important information related to potential chemical hazards and should be incorporated into manufacturers’ hazard analyses. USP FFD currently has data directly related to the identification of six of the chemical hazards identified by FDA: Undeclared allergens, drug residues, heavy metals, industrial chemicals, pesticides, and unapproved colors and additives. The following are some examples of information found in food fraud records for these chemical hazards.
Undeclared allergens: In addition to the widely publicized incident of peanuts in cumin, peanut products can be fraudulently added to a variety of food ingredients, including ground hazelnuts, olive oils, ground almonds, and milk powder. There have also been reports of the presence of cow’s milk protein in coconut-based beverages.
Drug residues:Seafood and honey have repeatedly been fraudulently adulterated with antibiotics that are not permitted for use in foods. Recently, beef pet food adulterated with pentobarbital was recalled in the United States.
Heavy metals:Lead, often in the form of lead chromate or lead oxide which add color to spices, is a persistent problem in the industry, particularly with turmeric.
Industrial Chemicals: Industrial dyes have been associated with a variety of food products, including palm oil, chili powder, curry sauce, and soft drinks. Melamine was added to both milk and wheat gluten to fraudulently increase the apparent protein content and industrial grade soybean oil sold as food-grade oil caused the deaths of thousands of turkeys.
Pesticides: Fraud in organic labeling has been in the news recently. Also concerning is the detection of illegal pesticides in foods such as oregano due to fraudulent substitution with myrtle or olive leaves.
Unapproved colors/additives: Examples include undeclared sulfites in unrefined cane sugar and ginger, food dyes in wine, and tartrazine (Yellow No. 5) in tea powder.
Because of its high nutritional value and distinctive flavor, natural honey is a premium product with a price tag significantly higher than that of other sweeteners. As a result, honey is often the target of adulteration using low-cost invert sugar syrups. This article looks at two analytical approaches based on isotope fingerprint analysis using isotope ratio mass spectrometry (IRMS) that can be used to detect honey adulteration and safeguard product integrity.
Honey is a complex mixture of sugars, proteins and other compounds, produced in nature by honeybees from flower nectar or honeydew. The extent to which its sugars are present is heavily dependent on the floral source and differs significantly between honeys produced in different regions. Climate, processing and storage conditions can also have an effect on the amounts of these sugars.1
Fructose and glucose are the major components of honey, and account for 85–95% of the total sugars present. The remaining carbohydrates are a mixture of disaccharides, trisaccharides, and larger oligosaccharides, which give individual honeys their own characteristic taste.
These distinctive flavors, combined with honey’s renowned nutritional benefits and a growing consumer demand for natural, healthy ingredients, have contributed to a substantial increase in honey sales over the past few decades. However, this demand has also helped to raise costs, with some varieties, such as Manuka honey, reportedly selling for as much as $35 for a 250 gm jar.
Just like many other food products that have a premium price tag, intentional adulteration is a significant concern for the honey industry. The fraudulent addition of cheaper sweeteners, such as sugar derived from cane, corn and beet sources, to extend product sales, is unfortunately common within the marketplace.
Honey producers and suppliers therefore require reliable and accurate analytical techniques to profile the composition of honey to identify cases of adulteration. Using analytical data, honey adulteration and counterfeiting can be routinely identified and product integrity can be maintained.
Carbon Isotope Fingerprints of Honey
Analysis of honey is commonly undertaken using isotope ratio mass spectrometry (IRMS) for the detection of adulteration. Honey has a fingerprint, a unique chemical signature that allows it to be identified. To visualize this fingerprint, IRMS can be used to identify the botanical origin of its constituent sugars.
Two ways that carbon can be incorporated into plants by photosynthetic CO2 fixation are the Calvin cycle (also known as the C3 cycle) and Hatch-Slack cycle (the C4 cycle). The nectar used by bees to produce honey comes from plants that produce sugars via the C3 pathway, while the sugars derived from sugar cane and corn are produced by the C4 pathway.
Carbon naturally exists as two stable isotopes that behave in the same way, but possess different atomic mass numbers. Carbon-12 is the most abundant in nature (98.9%), whereas carbon-13 is far less common (1.1%). By measuring the ratio of carbon-13 to carbon-12 (13C/12C) using IRMS, the carbon isotope fingerprint of the honey can be determined. As more carbon-13 is incorporated in sugars produced by the C4 pathway, the adulteration of honey with sugar cane and fructose corn syrups, rich in C4 sugars, can be detected.
In unadulterated honey, the carbon isotope fingerprint will be similar to that of the natural protein precipitated from the honey. However, if cane sugar or high fructose corn syrup has been added, the isotope fingerprint of honey and protein will be significantly different.
Detection of Adulteration by EA-IRMS
One approach that has traditionally been used for the detection of honey adulteration is elemental analysis interfaced with IRMS (EA-IRMS).2 This highly robust, rapid and cost-effective technique is able to reliably detect the addition of C4 sugars in honey at levels down to 7%.3 The analytical approach complies with the official method for the analysis of C4 sugars in honey, AOAC method 998.12.4
In EA-IRMS, bulk honey is combusted in the presence of pure oxygen to form CO2 for analysis. The CO2 produced from the combustion of the bulk honey, including all sugars and the protein fraction, is analyzed by IRMS. Figure 1 shows carbon isotope fingerprints of four unique samples, including bulk honey and the proteins extracted from those honeys, determined using an EA-IRMS system. In each case of adulteration, shown in the grey columns, the honey δ13C value becomes more positive relative to the protein value, moving towards the carbon isotope fingerprint of C4 plants. The natural variation of δ13C in honey is shown by the red lines.5
Detection of Adulteration by LC-IRMS
While EA-IRMS can be used to identify cases of honey adulteration using the bulk sample, the analysis of low levels of added C4 sugars and C3 sugars (i.e., beet sugars) to honey reveal that a compound specific technique with more powerful separation capabilities is needed. Furthermore, as fraudsters develop more sophisticated adulteration techniques and effective ways of concealing their actions, it can be necessary to utilize other IRMS techniques.
Much lower limits of adulteration detection can be obtained from liquid chromatography interfaced with IRMS (LC-IRMS). This technique permits the analysis of very small sample amounts without the need for extensive preparation or derivatization, and can also identify C3 sugar adulteration, which EA-IRMS cannot readily achieve, and therefore serves as a strong, complimentary isotope fingerprint technique. There are IRMS portfolios available that allow for sequential automated analysis of both analytical techniques.
Using LC-IRMS, the sample is oxidized within the aqueous solvent eluting from the HPLC column. The oxidation reagent consists of two solutions: The oxidizing agent itself and phosphoric acid. Both are pumped separately and added to the mobile phase. Within this mixture, all individual organic compounds eluting from the HPLC column are oxidized quantitatively into CO2 upon passing through a heated reactor. In a downstream separation unit, the generated CO2 is then separated from the liquid phase and carried by a stream of helium gas. The individual CO2 peaks in the helium are subsequently dried in an on-line gas drying unit and admitted to the isotope ratio mass spectrometer via an open split interface.
As global competition continues to grow and supply dwindles in many areas, food fraud is a major concern. The value of the food authenticity market, which was around $5 billion last year, is expected to reach $8.3 billion by 2023, achieving a compound annual growth rate (CAGR) of 7.7%, according to Allied Market Research.
Last year, polymerase chain reaction (PCR) technology took up about one third of the market and is expected to achieve a 8.3% CAGR from 2017 to 2023. Processed food (includes infant formula, packaged food, wine, and bakery and confectionary products) accounted for another third of the global market from a revenue standpoint. Meat speciation is expected to achieve the highest revenue growth, with a 8.2% CAGR.
According to Allied Market Research, Asia-Pacific is expected to experience the highest growth between 2017 and 2023, while Europe continues to lead the worldwide market in this area. North America, which is the second-leading revenue contributor worldwide, is anticipated to achieve a 7.4% CAGR in revenue.
Americans consume an estimated 600 pounds of milk and milk-based products annually, according to the USDA. In an effort to minimize the hazards in the milk supply and prevent food fraud, IBM Research and Cornell University are joining forces. Combining next-generation sequencing with bioinformatics, the research project will collect genetic data from the microbiome of raw milk samples in a real-world situation at the Cornell University dairy plant and farm in Ithaca, New York.
Specifically, IBM and Cornell will sequence and analyze the DNA and RNA of food microbiomes, which will serve as a raw milk baseline, to develop tools that monitor raw milk and detect abnormalities that could indicate safety hazards and potential fraud. The data collected may also be used to expand existing bioinformatics analytical tools used by the Consortium for Sequencing the Food Supply Chain, a project that was launched by IBM Research and Mars, Inc. at the beginning of 2015.
“As nature’s most perfect food, milk is an excellent model for studying the genetics of food. As a leader in genomics research, the Department of Food Science expects this research collaboration with IBM will lead to exciting opportunities to apply findings to multiple food products in locations worldwide.” – Martin Wiedmann, Gellert Family Professor in Food Safety, Cornell University.
“Characterizing what is ‘normal’ for a food ingredient can better allow the observation of when something goes awry,” said Geraud Dubois, director of the Consortium for Sequencing the Food Supply Chain, IBM Research – Almaden, in a press release. “Detecting unknown anomalies is a challenge in food safety and serious repercussions may arise due to contaminants that may never have been seen in the food supply chain before.”
Cornell University is the first academic institution to join the Consortium for Sequencing the Food Supply Chain.
The Food Safety Supply Chain conference brought together industry stakeholders from FDA, CFSAN, GFSI’s certification programs, academia and food companies to discuss strategies and challenges of the supply chain in a more complex global environment. The two-day event was held earlier this month at U.S. Pharmacopeial Convention in Rockville, Maryland. Here’s what some of the speakers had to say.
(Click images to enlarge)
You can’t build safety at the border; you have to build in safety before you get to the border… The Foreign Supplier Verification rule requires importers for first time to share responsibility of products that are coming into country. We have written this rule with a lot of flexibility. – Sharon Mayl, senior advisor for policy to the deputy commissioner for foods and veterinary medicine, FDA, on the FSMA FSVP rule
Transportation of food is a piece that doesn’t get a lot of attention, but it’s a very important part in ensuring the safety of food…[FDA is] in the process of developing a small entities compliance guide. We’re also revising the guidance we did in 2010 to ensure that it’s consistent with the rule. – Jennifer Thomas, director, division of enforcement, office of compliance, CFSAN, on the FSMA Sanitary Transportation of Human Food rule
Food fraud can lead to a public health threat—and should be managed under a food safety management system. – John Spink, Ph.D., director and assistant professor, Michigan State University, on supply chain transparency and food fraud
When you’re looking at the Foreign Supplier Verification Program, you also have to approve your suppliers. There are several aspects to this—you have to check their record with FDA, whether they have any warning letters or on import alert. That doesn’t mean you can’t buy from them, it just means you have to investigate what the problem is. – Russell Statman, executive director, Registrar Corp., on the FSVP rule
FDA doesn’t have jurisdiction over aquaculture farms. So we’re working with countries that do. Any country that has a significant industry has good aquaculture practice programs (GAqP)— every country now has one—so we’re working with them now to make them better. – Brett Koonse, consumer safety officer, FDA, on aquaculture and food safety
[The Sanitary Transportation of Human Food rule is important because of] the role that transportation has played in the past regarding foodborne outbreaks. We have to be proactive. We can’t learn from our mistakes anymore. – Debby Newslow, president, DL Newslow & Associates
Food safety should not be about just meeting the regulations. Suppliers must still meet the standards of your business. – Jorge Hernandez, chief food safety officer, Wholesome International
Collaboration and partnership are the only way your going to gain the transparency you need in the supply chain and build your brand for the protection it needs. – Melanie Neumann, president and global food safety attorney, Neumann Risk Services, LLC
One of reasons retailers take [visibility] seriously is that we’re the last line of defense. If you buy something at the grocery store and you get sick, you don’t remember the manufacturer of the product, you remember where you [bought] the product. – Terry Levee, senior director of food safety, Giant Eagle
The complimentary webinar, Top Tips to Mitigate Food Fraud, takes place on June 22 at 1 pm ET. Register now.Recently, the topic of food fraud has been discussed with increasing urgency. From understanding the basics of what is food fraud to navigating the regulatory requirements, quality assurance, compliance and procurement professionals must have a general understanding of the components.
An upcoming free webinar will review the hazard analysis requirements surrounding the FSMA Preventive Control for Human Food, GFSI requirements for raw materials and risk assessments and food fraud mitigation plans. Attendees will also learn about food fraud mitigation implementation strategies. The speakers participating in this webinar are Jeff Chilton, vice president of professional services at Alchemy Systems and Peter Claise, marketing director for foods programs at USP.
Recorded June 22, 2017: This webinar will cover FSMA Preventive Controls for Human Food Hazard Analysis requirements, GFSI requirements, including raw materials risk assessments, and food fraud mitigation plans and implementation strategies including tools, program development and sustainment to include new raw materials and finished products. Sponsored by Alchemy and USP