Tag Archives: GFSI

Karen Everstine, Decernis
Food Fraud Quick Bites

COVID-19 and Food Fraud Risk

By Karen Everstine, Ph.D.
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Karen Everstine, Decernis

While foodborne transmission of the novel coronavirus is unlikely , the virus has significantly affected all aspects of food production, food manufacturing, retail sales, and foodservice. The food and agriculture sector has been designated as a “critical infrastructure,” meaning that everyone from farm workers to pest control companies to grocery store employees has been deemed essential during this public health crisis.* As a society, we need the food and agriculture sector to continue to operate during a time when severe illnesses, stay-at-home orders and widespread economic impacts are occurring. Reports of fraudulent COVID-19 test kits and healthcare scams reinforce that “crime tends to survive and prosper in a crisis.” What does all of this mean for food integrity? Let’s look at some of the major effects on food systems and what they can tell us about the risk of food fraud.

Supply chains have seen major disruptions. Primary food production has generally continued, but there have been challenges within the food supply chain that have led to empty store shelves. Recent reports have noted shortages of people to harvest crops, multiple large meat processing facilities shut down due to COVID-19 cases, and recommendations for employee distancing measures that reduce processing rates. One large U.S. meat processor warned of the need to depopulate millions of animals and stated “the food supply chain is breaking.” (An Executive Order was subsequently issued to keep meat processing plants open).

Equally concerning are reports of supply disruptions in commodities coming out of major producing regions. Rice exports out of India have been delayed or stopped due to labor shortages and lockdown measures. Vietnam, which had halted rice exports entirely in March, has now agreed to resume exports that are capped at much lower levels than last year. Other countries have enacted similar protectionist measures. One group has predicted possible food riots in countries like India, South Africa and Brazil that may experience major food disruption coupled with high population density and poverty.

Supply chain complexity, transparency and strong and established supplier relationships are key aspects to consider as part of a food fraud prevention program. Safety or authenticity problems in one ingredient shipment can have a huge effect on the market if they are not identified before products get to retail (see Figure 1). Widespread supply chain disruptions, and the inevitable supplier adjustments that will need to be made by producers, increase the overall risk of fraud.

Reconstructed supply chain
Figure 1. Reconstructed supply chain based on recall data following the identification of Sudan I in the chili powder supply chain in 2005. Data source: Food Standards Agency of the U.K. National Archives and The Guardian. Figure from: Everstine, K. Supply Chain Complexity and Economically Motivated Adulteration. In: Food Protection and Security – Preventing and Mitigating Contamination during Food Processing and Production. Shaun Kennedy (Ed.) Woodhead Publishing: 26th October 2016. Available at: https://www.elsevier.com/books/food-protection-and-security/kennedy/978-1-78242-251-8

Regulatory oversight and audit programs have been modified. The combination of the public health risk that COVID-19 presents with the fact that food and agriculture system workers have been deemed “critical” has led to adjustments on the part of government and regulatory agencies (and private food safety programs) with respect to inspections, labeling requirements, audits, and other routine activities. The FDA has taken measures including providing flexibility in labeling for certain menus and food products, temporarily conducting remote inspections of food importers, and generally limiting domestic inspections to those that are most critical. USDA FSIS has also indicated they are “exercising enforcement discretion” to provide labeling flexibilities. The Canadian Food Inspection Agency (CFIA) announced they are prioritizing certain regulatory activities and temporarily suspending those activities determined to be “low risk.” GFSI has also taken measures to allow Certification Program Owners to provide certificate extensions due to the inability to conduct in-person audits.

While these organizations have assured stakeholders and the public that food safety is of primary importance, the level of direct regulatory and auditing oversight has been reduced to reduce the risk of virus transmission during in-person activities. Strong auditing programs with an anti-fraud component are an important aspect of food fraud prevention. Adjustments to regulatory and auditing oversight, as necessary as they may be, increase the risk of fraud in the food system.

There is a focus on safety and sustainability of foods. The food industry and regulatory agencies are understandably focused on basic food safety and food sustainability and less focused on non-critical issues such as quality and labeling. However, there is a general sense among some in industry that the risk of food fraud is heightened right now. Many of the effects on the industry due to COVID-19 are factors that are known to increase fraud risk: Supply chain disruptions, changes in commodity prices, supplier relationships (which may need to be changed in response to shortages), and a lack of strong auditing and oversight. However, as of yet, we have not seen a sharp increase in public reports of food fraud.

This may be due to the fact that we are still in the relatively early stages of the supply chain disruptions. India reported recently that the Food Safety Department of Kerala seized thousands of kilograms of “stale” and “toxic” fish and shrimp illegally brought in to replace supply shortages resulting from the halt in fishing that occurred due to lockdown measures.

High-value products may be particularly at risk. Certain high-value products, such as botanical ingredients used in foods and dietary supplements, may be especially at risk due to supply chain disruptions. Historical data indicate that high-value products such as extra virgin olive oil, honey, spices, and liquors, are perpetual targets for fraudulent activity. Turmeric, which we have discussed previously, was particularly cited as being at high risk for fraud due to “‘exploding’ demand ‘amidst supply chain disruptions.’”

How can we ensure food sufficiency, safety, and integrity? FAO has recommended that food banks be mobilized, the health of workers in the food and agriculture sector be prioritized, that governments support small food producers, and that trade and tax policies keep global food trade open. They go on to say, “by keeping the gears of the supply chains moving and actively seeking international cooperation to keep trade open, countries can prevent food shortages and protect the most vulnerable populations.” FAO and WHO also published interim guidance for national food safety control systems, which noted the increased risk of food fraud. They stated “during this pandemic, competent authorities should investigate reported incidences involving food fraud and work closely with food businesses to assess the vulnerability of supply chains…”.

From a food industry perspective, some important considerations include whether businesses have multiple approved suppliers for essential ingredients and the availability of commodities that may affect your upstream suppliers. The Acheson Group recommends increasing supply chain surveillance during this time. The Food Chemicals Codex group recommends testing early and testing often and maintaining clear and accurate communication along the supply chain.1 The nonprofit American Botanical Council, in a memo from its Botanical Adulterants Prevention Program, stated “responsible buyers, even those with relatively robust quality control programs, may need to double- or even triple-down on QC measures that deal with ingredient identity and authenticity.”

Measures to ensure the sufficiency, sustainability, safety and integrity of foods are more closely linked than ever before. In this time when sufficiency is critical, it is important to avoid preventable food recalls due to authenticity concerns. We also need to stay alert for situations where illegal and possibly hazardous food products enter the market due to shortages created by secondary effects of the virus. The best practices industry uses to reduce the risk of food fraud are now important for also ensuring the sufficiency, sustainability and safety of the global food supply.

Reference

  1. Food Safety Tech. (April 24, 2020). “COVID-19 in the Food Industry: Mitigating and Preparing for Supply Chain Disruptions “. On-Demand Webinar. Registration page retrieved from https://register.gotowebinar.com/recording/1172058910950755596

*Foodborne transmission is, according to the Food Standards Agency in the U.K., “unlikely” and, according to the U.S. FDA, “currently there is no evidence of food or food packaging being associated with transmission of COVID-19.”

Christine Charlotte Akselsen, Kezzler
FST Soapbox

Connecting the Dots for Food Safety at GFSI 2020

By Christine Charlotte Akselsen
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Christine Charlotte Akselsen, Kezzler

Representatives at this year’s GFSI conference hailed from 53 countries and spanned the food industry, academia, the public sector and beyond. They came together in Seattle, a city that has long stood at the cutting edge of technological innovation, and as such was a fitting host for this year’s theme: “One Connected World. One Safe Food Supply”.

Speakers at the forefront of their fields shared knowledge and showcased creative methods of delivering connectivity—interpersonal, technology-mediated and otherwise, all geared towards the ultimate goal of helping provide safer food for consumers everywhere.

Meanwhile, there were numerous opportunities to connect with representatives of industry giants such as Costa, Nestle, McDonald’s, Amazon and Starbucks, as well as regulatory agencies, certification & accreditation bodies, NGOs, academia and the media, at the various networking sessions.

Urgent Action Required

As the conference kicked off, it was Peter Freedman, the managing director of The Consumer Goods Forum (CGF), who set out the importance of the task at hand. His message was one of urgency in delivering positive change.

Freedman pointed to recent global events, such as the wildfires in Brazil, as examples of how the world could be at a tipping point. “Action is more urgent than ever”, he told delegates, stating that it is no longer just a matter of responding, but responding urgently. Freedman also pointed to E. coli outbreaks in 2017, 2018 and late 2019 to drive home to industry leaders gathered at the conference that food safety cannot be taken for granted.

The spirit of the event was, as usual, geared towards a collaborative approach. Delegates were asked to leave their commercial interests at the door and work purely towards “a world where all food is safe” for the duration of the event.

“This week is not about us as individuals, it’s about how we come together as a collective of brilliant minds to provide solutions,” GFSI Director Erica Sheward stated. She then invited the audience to stand in recognition of this commitment, and sure enough everyone in the packed auditorium took to their feet demonstrating their commitment to the shared mission.

GFSI’s New Benchmarking Requirements

The GFSI used the conference as a platform to launch its new Benchmarking Requirements Version 2020, which establish a new foundation for food safety. To close the opening session, Sheward joined Mike Robach, Chairman of the GFSI Board, Vice-Chairs Anita Scholte op Reimer and Gillian Kelleher and GFSI Senior Technical Manager Marie-Claude Quentin around a red ‘action button’ to mark their publication.

The requirements are geared towards enabling a common understanding and mutual trust in the supply chain that facilitates trade, improves efficiency and lends nameplate authority to operations certified to a GFSI-recognized program. They incorporate stakeholder input from public consultations and are regularly revised to reflect best practices and evolving needs in the industry.

GFSI positioned the new version as more than just an update, but a complete rethink “representing the beginning of a new generation of recognition”. The two primary objectives of Version 2020, are to achieve transparency and objectivity, with new and strengthened elements that include two new scopes focused on hygienic design, elements of food safety culture and reinforced impartiality of the auditing process and the monitoring of certification bodies.

Shark Tank Sessions

This year’s GFSI program also included a new format to help showcase how the latest technology is being used to further food safety. Leaders in innovation took part in a number of Shark Tank-style breakout sessions to pitch their technology solutions to the sharks and the attendees.

A total of nine cutting-edge companies took to the stage to pitch their concepts to a panel of experts—‘sharks’—who are well-placed to judge their value for the industry. The nine competitors were selected from a large pool of applicants based on their innovative spirit, disruptive potential and feasibility.

Each presenter had 12-minutes to outline the context in which their solution is utilized, the technology supporting it and how it is implemented. Following the pitches, each presenter came under the scrutiny of the sharks who were able to ask clarifying questions.

Kezzler was among the companies to take to the stage with CEO Christine Akselsen sharing insights from work with FrieslandCampina’s infant formula brand, FRISO. Referencing the grass-to-glass case study, she demonstrated how Kezzler’s technology works in practice, tracking information from farms in The Netherlands to consumers in China. Following the sessions an audience vote determined the winner of the competition, which was announced during the final plenary of the conference. Kezzler was also crowned as the first-ever GFSI Shark Tank champion.

Ben Schreiber, ActiveSense
Bug Bytes

How ERM Can Simplify Pest Management

By Benjamin Schreiber
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Ben Schreiber, ActiveSense

Whether you work in food manufacturing, distribution or retail, pests are both a fact of life as well as a regulatory disruption. At the same time, pest management solutions aren’t always clear-cut: While there are a variety of effective strategies employed by pest management professionals (PMPs) servicing the food industry, industry challenges—shifting regulatory standards, a lack of proper documentation and more—can complicate the process. For these reasons, short-term rodent problems can become long-term logistical nightmares, leaving food manufacturers in an undesirable situation when a third-party food plant auditor arrives.

Fortunately, emerging technologies in pest management practices are helping facility managers streamline their food and beverage quality assurance processes, reducing the risk of product loss, regulatory action, improper brand management and more. Specifically, electronic remote monitoring (ERM) allows PMPs to detect and monitor rodents in real time, providing you with important information to help reduce risk and increase audit compliance. As such, the value of food safety pest management strategies that incorporate ERM systems is only growing. Seeking out PMPs who use ERM allows you to invest in technologies that protect your margins, ensure the quality of your product and, ultimately, safeguard your most important asset—your reputation.

Modernizing Pest Management With ERM

At first glance, it might seem like pest management practices haven’t drastically changed since they were first implemented in the food manufacturing industry. Many rodent trapping systems remain similar to their original design: Devices designed to trap or kill that must be individually inspected and serviced by professional technicians. Technicians must then relay any risks to facility managers, who have to determine if additional resources are needed to avoid product loss or audit-based infractions.

Upon closer examination, it’s clear that while pests themselves have not significantly changed, both the pest management industry and the modern food supply chain have become increasingly complex. Food facility managers must contend with increasingly stringent food safety standards, and PMPs must rise to meet these needs with evolving pest management strategies.

In many ways, ERM technologies are the structural pest control industry’s response to these challenges, providing technicians with real-time notifications about rodent behavior and allowing them to make risk-based assessments that identify and treat problems before infestations occur. Unlike pest control strategies that rely on periodic service visits from technicians, PMPs who utilize ERM technology can monitor pest activity around the clock, 24/7/365, in virtually any environment. Instead of monitoring individual traps, PMPs can use ERM technology to know exactly when and where pest activity occurs, including in hard-to-monitor areas such as drop ceilings, crawlspaces, shelving undersides and other traditionally overlooked spaces. Technicians then receive valuable analytics from each trap they install, as well as documentation and reporting, that help managers achieve audit and regulatory compliance.

FSMA and ERM

In 2015, the FDA issued the final component of preventative control for human food under FSMA, officially enacting legislation that requires food safety plants to focus on risk-based pest prevention instead of reactive pest control strategies. As a result, quality assurance professionals and facility managers are often tasked with reallocating personnel toward proactive pest control activities in addition to their day-to-day responsibilities.

In many ways, ERM systems go hand-in-hand with FSMA and GFSI regulations. While preparing for a situation that hasn’t yet occurred can be a costly and time-consuming process, ERM has helped PMPs develop custom pest management strategies that assess and control situations in accordance with FSMA and other auditing firm guidelines. In many ways, ERM can provide all parties—PMPs, in-house auditors and third-party regulators—with a track record of pest history that all parties can cross-reference when assessing a facility.

From Risk-Averse to Risk-Based

When it comes to food safety rules and regulations, the only constant is change. In the structural pest control industry, auditors have historically implemented strict guidelines about trap placement that are frequently changing: For instance, traps should be placed every 10, 15, or 20 feet, regardless of facility susceptibility to various pest conditions. Failure to comply with regulations can result in point deductions on audits, even if the conditions that might lead to an infestation are not present. As such, food processing plants often choose to abide by the most stringent audit guidelines imposed upon them by other parties, such as retailers. By utilizing ERM technologies, food safety and quality assurance professionals can use additional pest monitoring analytics to focus on specific compliance issues, rather than spending additional time and money on other strategies.

Additionally, ERM allows PMPs to focus their efforts not only on weekly service visits and station checks, but also on important tasks, including assessing facility vulnerabilities, tracking rodent access points, and providing consultation and additional management strategies to their client—you.

Approaching the Audit with ERM

Food plant managers and retailers alike know that auditor approval is everything. Because ERM is a fast-developing technology, many quality assurance managers and facility owners are curious to know if ERM is audit approved. In truth, there are many kinds of audits, each with different goals, assessment techniques and regulatory standards. When it comes to audits, the gold standard is not necessarily the assessment of the facility and production line itself, but rather how well the assessment matches records kept by the food production plant.

To this end, ERM might be the answer to a streamlined audit process. No matter what kind of audit a plant is currently undergoing, ERM allows PMPs to provide records auditors need to verify that all systems are working properly. ERM can mean the difference between a streamlined process and a laborious audit, acting as a documentation system that helps officials conduct a PMP-verified “second-check.” This kind of verification is invaluable in an industry where there are already more than enough regulatory categories to consider without having to further worry about potential pest infestations.

ERM-Oriented Solutions

Thanks to the many advantages they offer, ERM and other remote pest monitoring technologies are growing in popularity. Many facility managers appreciate that ERM allows them to assess pest activity, prevent infestations before they occur, gather data that helps them remain industry-compliant, and acquire and share information with additional parties. If you’re a facility manager, quality assurance professional or other food safety decision-maker interested in the opportunities ERM technologies provide, consider starting the conversation about your pest prevention system with your PMP and how ERM might help improve it.

Trust, But Verify

There is an overwhelming consensus in the pest control industry that technology should be developed to provide end-users with more information. ERM systems are a natural extension of this belief, providing each component of the food production and distribution supply chain—manufacturers, distributors, retailers, quality assurance officials, technicians and others—with more data about how pest control decisions are made. Without data, it can be difficult to ensure technician service visits end in greater transparency about the issues facility owners will face as they prepare for an audit.

Fortunately, ERM can help provide the level of trust and assurance plant managers need to feel confident in their day-to-day operations. ERM is an important step forward for manufacturer-regulator relations, which require a strong combination of data, trust and transparency to ensure that communication systems don’t break down. After all, there are many industries in which miscommunication can lead to catastrophic consequences, and food production is no exception.

While each manufacturing facility, processing plant, distribution center, storage warehouse and retail outlet is different, none are insusceptible to pest infestations, and none can avoid audits required to keep them compliant. Because rigorous oversight is crucial for food producers and consumers alike, working with your PMP to develop pest monitoring strategies that utilize ERM systems and other cutting-edge technologies should be part of your larger pest control consideration process.

In the end, the pest infestation that causes the least damage to your product, profit potential and industry reputation is the infestation that never occurs.

Steve Wise, InfinityQS
FST Soapbox

How SQF Certification Can Be a Contract Manufacturer’s Greatest Advantage

By Steve Wise
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Steve Wise, InfinityQS

Well-known food and beverage brands will often turn to contract manufacturers to produce the quality products that their customers expect and enjoy. With their brand names on the line, these brand owners need assurance that their suppliers can deliver safe and high-quality goods and mitigate the looming threat of recalls.

How do they know if they’re working with a reliable contract manufacturer? Well, many will look to see if they hold certifications from a reputable third-party organization, such as the Safe Quality Food Institute (SQFI). In fact, one in four companies today require that their suppliers have SQF certification, making it one of the most important certifications in contract manufacturing.

SQF certification demonstrates that a supplier has met benchmarked standards—set by the Global Food Safety Initiative (GFSI)—for upholding quality and controlling food safety risks. It’s a form of validation of an organization’s ability to consistently produce safe and high-quality products. Contract manufacturers that have SQF certification are more likely to win contracts and can bid for business on a national or global scale. Thus, it presents a clear competitive advantage to those certified in the various levels of SQF certification.

Certification Tiers
SQF is a three-level certification program, with each tier progressively more rigorous than the last.

  • Level 1: The SQF Safety Fundamentals Program is an introduction to food safety standards for small- to medium-sized food suppliers. Ideal for those with low-risk food products, the program doesn’t meet GFSI standards but establishes a foundation for doing so. Suppliers certified at this level typically sell their services to smaller, local purveyors.
  • Level 2: The SQF Food Safety Program follows GFSI-benchmarked food safety standards. It helps sites implement preventive food safety measures according to Hazard Analysis and Critical Control Points (HACCP) regulations, which ensure scientific analysis of microbiological, physical and chemical hazards are applied at each step of the supply chain. This level is ideal for businesses that would like to work with purveyors that require adherence to GFSI benchmarked standards.
  • Level 3: The SQF Food Safety and Quality Program shows an ability to not only contain safety risks through the HACCP system, but also monitor and control threats related to food quality. This highest level of certification is ideal for large-scale producers, manufacturers, food packaging facilities and distributors that have successfully deployed an SQF Food Safety Program and want to go above and beyond in their quality efforts.

While it’s the most demanding of the three, Level 3 certification is what most contract manufacturers should aspire to because it’s required by many of the world’s largest food and beverage brands. In order to attain this level of distinction, contract manufacturers need an effective way to demonstrably meet all GFSI benchmarked standards and readily access their quality data during an audit. This is where statistical process control (SPC) comes in.

The SPC Gamechanger

SPC is a proven methodology for monitoring and controlling quality during the manufacturing process. SPC enables manufacturers to chart real-time quality data against predefined control limits to identify unwanted trends and product or process variations. If there is an issue, timely alerts will notify responsible parties to take remedial action early on, preventing unsafe or poor-quality goods from entering the supply chain and triggering a recall. This establishes strong controls for food quality and safety in accordance with a Level 3 SQF Program. Audits also become a breeze, as all historical data are stored digitally in a centralized repository. Suppliers can thereby quickly and easily produce auditor-requested reports showing compliance with SQF requirements and GFSI standards.

Statistical process control, InfinityQS
Statistical process control (SPC) is a method for monitoring and controlling quality during the manufacturing process. Image courtesy of InfinityQS

But beyond quality monitoring and facilitating audits, SPC can deliver greater impact by providing suppliers with analytical tools useful for mining historical data for actionable insights. They can run comparative analyses of the performance of different lines, products, processes, or even sites, revealing where and how to further reduce risk, improve consistency, streamline operations, and lower production costs. In this way, SPC lends itself to a profit-positive business model—driving additional savings through process improvement while increasing new business opportunities through contracts won via SQF certification.

A Snacking Success

One contract manufacturer of savory and healthy snacks previously struggled with large variations in product quality. These inconsistencies often resulted in quality holds or process aborts that generated high waste and costs. By implementing SPC, the snack supplier was able to take advantage of a wide range of data—including incoming receiving tracking and quality inspection tracking—to finetune its production processes with effective controls for food quality and safety. In addition to a 30% reduction in customer complaints, SPC has helped the supplier realize a $1 million reduction in product waste and attain Level 3 SQF certification, the latter of which has generated continued new business from several well-known snack food brands.

This snack supplier is a clear example of SQF certification as a competitive differentiator. Working with such SQF-certified and SPC-powered contractors is important to food and beverage brands because they can protect their reputations and ensure continued customer retention by way of safe, consistent, high-quality products. Ultimately, it builds greater trust and integrity in the supply chain among companies and consumers alike.

Laura Nelson, Alchemy

Changing Consumer Preferences and Employee Compliance Training Driving Industry Evolution

By Maria Fontanazza
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Laura Nelson, Alchemy

The food industry is undergoing considerable change, especially as consumers become increasingly more vocal about their preferences and concerns, and as technology improvement and adoption plays a larger role in the conversation. In a recent Q&A with Food Safety Tech, Laura Dunn Nelson, vice president of food safety at Alchemy, shares her thoughts about current industry trends and how they are impacting food companies, where more help is needed, as well as ways in which companies can help advance food safety culture internally.

Food Safety Tech: The food industry is rapidly evolving. What are some of the trends you’re seeing and are these posing different challenges to food manufacturers?

Laura Dunn Nelson: The food industry is rapidly evolving in three key areas: Who produces our food, the variety of our food, and how consumers access our food.

As consumers continue to shift their food preferences toward an increase in healthy ingredients, locally sourced products, and clean labels, companies in turn continue to innovate and reformulate. Mergers and acquisitions continue as larger companies look to partner with niche companies that are focused on products marketed to the health-conscious consumer. Companies like Impossible Foods and Beyond Meat are expanding rapidly, reaching both vegans and meat eaters in the United States and expanding into international markets. Ever-changing consumer preferences create challenges for the industry to accelerate their research and development processes in order to remain competitive in the marketplace.

Changes in product formulas and increases in product lines create the need for new ingredient procurement, changes in production schedules, and new operating procedures. There has been a proliferation of start-up companies using CBD as an ingredient for food and beverages despite the lagging food safety regulations forcing some city and state regulators like New York City to create their own ban of CBD products. As the FDA explores future regulations, producers and consumers are left to determine the safety of these products.

Home delivery of food continues to be a hot trend as the market continues to grow for companies like UberEats, Grubhub, retailers and foodservice companies like Domino’s Pizza where you can Tweet your pizza order. The home delivery service area presents new considerations for food safety including monitoring appropriate product temperatures.

Finally, discussion around blockchain technology continues to gain prominence as companies work to develop transparency within their supply chain. For many companies, this will translate into a significant shift in technology adoption and a move away from disparate data sources and therefore an investment in not only the technology but in revising their procurement processes.

Laura Nelson, Alchemy
Laura Nelson is vice president of food safety at Alchemy and currently serves as the vice-chair of the Food Safety Culture Professional Development Group (PDG) for IAFP.

FST: What are the areas in which you feel companies need a bit more guidance?

Nelson: How we effectively train our employees to ensure learning and comprehension is paramount to our success in the future. IBM Institute for Business Value recently completed their study “The Enterprise Guide to Closing the Skills Gap,” and noted “120 million workers in the world’s biggest economies may need to be retrained as a result of artificial intelligence (AI) and automation in the workplace.” Reskilling will be the new norm as new technologies and automation of equipment disrupt the current state.

Deloitte noted that “reinventing the way people learn” was the number one trend in the 2019 Global Human Capital Trends Report. Many companies are focused almost exclusively on mandatory compliance training and conducting the training the same way they have for years. Typically, orientation food safety training is provided during the employee’s first week of work and annual refreshers are given every year. In the Global Food Safety Training Survey that Alchemy provides to the global industry with Campden BRI, we consistently find that 67% of responding QA managers report that employees do not follow their food safety programs, despite their food safety training. Unfortunately, the emphasis on food safety is often relegated to that one day a year of refresher training with little reinforcement the remaining 364 days of the year. The ‘noise’ of competing priorities of production and customer expectations often distracts employees from their food safety responsibilities.

Some companies still define training as classroom training when, in fact, employees are being trained each and every day by their supervisors and peers. Companies that put additional emphasis in not only their training but validation of training through observations of employees’ food safety behaviors achieve higher food safety compliance. The power of two-way conversations between the employee and the supervisor as a coach creates an environment of communication and trust.

Alchemy worked with independent researchers to determine the effect of active coaching with prescribed behavior feedback on the plant floor. The results were conclusive: every facility included in the study revealed a 38% improvement in aligned employee behaviors.

Ultimately, companies need to evaluate their current learning organization for effectiveness and focus on job competencies and their ongoing assessment of compliant employee behaviors.

FST: What maturity level are you seeing in the industry related to food safety culture and the related implementation of best practices?

Nelson: The food industry is still relatively new to the concept of a mature food safety culture, and even how to define that. The industry focus of this topic has largely been driven by efforts within the GFSI community, particularly with the publication of the position paper “A Culture of Food Safety.” Pioneers in food safety culture research, like Dr. Lone Jespersen, and emerging training assessment tools are working toward pushing these newer concepts to the mainstream of our industry.

As with many important constructs, the QA/QC team is typically tasked with introducing this concept to their organization, defining their company’s level of food safety culture maturity, and establishing a continuous improvement plan. This is a tough ask from individuals who typically have a technical education background with little experience in behavioral science. To address these challenges, there are a growing number of consultants, books, and resources to help define a company’s food safety culture maturity and establish improvement strategies.

To help frame the benefits of a mature culture, a recent publication by Lone Jespersen et al, “The Impact of Maturing Food Safety Culture and a Pathway to Economic Gain,” notes the value of a mature food safety culture in reducing the cost of poor quality and food safety risks. Research indicates that many companies are currently in mid-maturity of their food safety culture. Suggested best practices to help an organization mature their food safety culture include:

  1. Foster cross-company ownership of food safety.
  2. Move from compliance driven operations to risk reduction through continuous improvement.
  3. Improve engagement skills of technical staff.

The first step is an assessment to understand the company’s unique performance gaps, either through an internal review or an external assessment. Once the specific gaps are identified, companies can develop their food safety culture improvement plan and execute. It’s helpful to conduct a reassessment over time to ensure the established improvement strategies are successful.

The effort can be challenging but research confirms that a more mature food safety culture will deliver improved food safety performance of food safety behaviors, improved product quality, and a reduction in food safety risks.

Karen Everstine, Decernis
Food Fraud Quick Bites

It’s All About the Supply Chain

By Karen Everstine, Ph.D.
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Karen Everstine, Decernis

I recently attended two webinars that highlighted distinct perspectives on two challenging aspects of food fraud prevention. First, Chris Elliott from Queen’s University Belfast discussed the current situation with meat fraud. He cited his “top three” fraud-prone foods as meat, olive oil and honey. While we cannot determine the true scope of food fraud globally, looking at the data we have collected from the past 10 years, meat is also in our “top three.”

Commodities, food draud, Decernis
Top 10 Commodity Groups. Source: Decernis Food Fraud Database

Meat is prone to fraud in many ways, including misrepresenting the animal species, fraudulent labeling of production practices (organic, kosher, halal, etc.), the use of unapproved additives, the addition of non-meat-based protein ingredients, and misrepresentation of geographic origin (among others).

Elliott discussed some of the reasons that meat is prone to fraud, which included the fact that the industry is highly competitive, relies on low profit margins, and the supply network can be complex. Discussing specifically the horsemeat scandal in Europe a few years ago, he cited the “mess of subcontracts” involved in the adulterated meat, which were based primarily on price. He finished his presentation by noting that certain aspects of meat authentication are still challenging from an analytical perspective, such as ensuring country of origin and verifying the claims about animal feed consumption.

The final in a series of food fraud webinars sponsored by the IAFP Food Fraud Professional Development Group (PDG) focused on another aspect of food fraud: E-commerce. One of the big challenges with food fraud is the intentional nature of the crime, which can make anticipation of adulterants and fraud methods difficult.

GFSI has stated “any plans and activities to mitigate, prevent or even understand the risks associated with food fraud should consider an entire company’s activities, including some that may not be within the traditional food safety or even HACCP scope, applying methods closer to criminal investigation.” This is particularly true for fraud involving intellectual property (IP) infringement, which adds another layer of complexity to detection and prevention strategies. We have more than 200 records documenting fraud involving “counterfeit” products. Counterfeit products are a problem both because of the IP infringement and because, often, the actual contents of the product cannot be verified. Many of the records we have documented involve counterfeit vodka, whiskey, and wine, as well as non-alcoholic soft drinks.

As part of the IAFP webinar, Axel Hein from ApiraSol discussed their work using global customs data to detect counterfeit products, so-called “fantasy trademarks,” and geographical indication infringements.

Global customs data, food fraud
Slide used with permission from ApiraSol

Many countries provide public access to customs data which, when aggregated and combined with other sources (such as Alibaba transactions), allows mapping of supply chains and detection of unusual patterns that may indicate fraud. In school, I spent many months digging through U.S. customs data trying to uncover patterns that might indicate fraud, so I was very interested to see this being done on a larger scale.

Although each webinar was distinct in its focus, each highlighted the importance of supply chain control and monitoring in mitigating food fraud risk. To paraphrase a point made by Elliott, each arrow in a supply network is a potential vulnerability. The continued globalization of the food supply requires new and innovative ways to reduce these supply chain vulnerabilities.

Handshake

FSSC 22000 to Host Focus Event During Food Safety Consortium Conference & Expo 2019

By Food Safety Tech Staff
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EDGARTOWN, MA, June 27, 2019 – Innovative Publishing Co., publisher of Food Safety Tech and organizer of the Food Safety Consortium Conference & Expo is pleased to announce a partnership with FSSC 22000 to hold the organization’s Focus Event 2019 at this year’s Food Safety Consortium in Schaumburg, IL.

FSSC 22000, GFSI
The FSSC 22000 Focus Event 2019 takes place on October 1 in Schaumburg, IL.

Taking place on October 1 as a pre-conference workshop, the FSSC 22000 Focus Event will provide a firsthand update of the FSSC 22000 program worldwide and review the new Version 5, which includes the revised ISO 22000:2018. Experts will give attendees an overview of the benefits of the ISO approach and its alignment with FSMA, as well as the role of FSSC 22000 new scopes, including Transport and Storage, with a practical example of the benefits of certification in this new sector. There will also be discussion of the application of the FSSC Global Markets Program to smaller and medium-sized organizations.

“I am excited to welcome stakeholders from the GFSI-recognized food safety management system FSSC 22000 to the Food Safety Consortium as key participants in educating an important part of this industry,” said Rick Biros, president of Innovative Publishing Co., Inc. and director of the Food Safety Consortium Conference and Expo.

Speakers include Cornelie Glerum, Managing Director, FSSC 22000; Cor Groenveld, Market Development Director, FSSC 22000; Jacqueline Southee, North America Representative, FSSC 22000; and Jim Blackmon, President of Carry Transit (invited).

Professionals within the following roles/segments should attend this event: Food and beverage companies; FSSC 22000 certified companies and companies interested in becoming FSSC 22000 certified; certification bodies and contractor auditors; accreditation bodies; and training organizations.

The FSSC 22000 Focus Event is available and included in the Food Safety Consortium Conference registration fee.

Delegates registering for the FSSC 22000 Focus Event 2019 only will also receive complimentary admission to the plenary session of the Food Safety Consortium, presented by Frank Yiannas, deputy commissioner, food policy and response at FDA, and are invited to attend the evening reception in the exhibition hall.

About Food Safety Tech

Food Safety Tech publishes news, technology, trends, regulations, and expert opinions on food safety, food quality, food business and food sustainability. We also offer educational, career advancement and networking opportunities to the global food industry. This information exchange is facilitated through ePublishing, digital and live events.

About the Food Safety Consortium Conference and Expo

The Food Safety Consortium Conference and Expo is a premier educational and networking event for food safety solutions. Attracting the most influential minds in food safety, the Consortium enables attendees to engage conversations that are critical for advancing careers and organizations alike. Visit with exhibitors to learn about cutting edge solutions, explore diverse educational tracks for learning valuable industry trends, and network with industry executives to find solutions to improve quality, efficiency and cost effectiveness in an ever-changing, global food safety market. This year’s event takes place October 1–3 in Schaumburg, IL.

About FSSC 22000

FSSC 22000 (Food Safety System Certification 22000) offers a complete certification program for the auditing and certification of Food Safety Management Systems (FSMS) and Food Safety and Quality Management Systems (FSSC 22000-Quality). Based on the internationally accepted ISO 22000 family of standards and benchmarked by the Global Food Safety Initiative (GFSI), FSSC 22000 sets out the requirements for companies throughout the supply chain for meeting the highest food safety standards. FSSC 22000 is recognized and relied upon by some of the world’s largest food manufacturers, is widely accepted by Accreditation Bodies worldwide and supported by important stakeholders like FoodDrinkEurope (FDE) and the American Grocery Manufacturers Association (GMA).

Karen Everstine, Decernis
Food Fraud Quick Bites

Food Fraud: Where Do I Start?

By Karen Everstine, Ph.D.
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Karen Everstine, Decernis

I attended the Safe Food California Conference last week in Monterey, California. Food fraud was not the main focus of the conference, but there was some good food fraud-related content. Craig Wilson gave a plenary session about the past, present and future of food safety at Costco. As part of that presentation, he discussed their supplier ingredient program. This program was implemented in response to the 2008 Salmonella Typhimurium outbreak in peanut paste but has direct applicability to food fraud prevention.

Food Fraud: Problem Solved? Learn more at the 2019 Food Safety Supply Chain Conference | May 29–30, 2019 | Attend in Rockville, MD or virtually Jeanette Litschewski from SQFI gave a breakout presentation on the most common SQF non-conformities in 2018. She presented data from 7,710 closed audits that cited 44,439 non-conformities. Of those, 756 were related to food fraud requirements. While this presentation was not focused on the specifics of the food fraud non-conformities, Jeanette did mention that many of them were related to broad issues such as not having completed a food fraud vulnerability assessment or appropriately documenting that each of the required factors was addressed in an assessment.

I was invited to give a breakout presentation with an overview of food fraud issues globally and a brief outline of some of the tools currently available to assist with conducting vulnerability assessments. Although many of the attendees had already began implementation of food fraud measures, there was a lot of interest in this list of tools and resources. Therefore, I am recreating the list in Table I. The focus is on resources that are either complimentary or affordable for small- and medium-sized businesses, with recognition that “full-service” and tailored consulting services are always an option.

Food Fraud Resources (Table I)
Food Fraud Mitigation Training Food Fraud Vulnerability Assessments Food Fraud Data/Records
Michigan State Massive Open Online Courses for Food Fraud SSAFE/PwC Decernis Food Fraud Database
Food Fraud Advisors Online Training Courses USP FFMG FPDI Food Adulteration Incidents Registry
Food Fraud Advisors Vulnerability Assessment Tools (downloadable spreadsheets):

The USP Food Fraud Mitigation Guidance referenced in Table I is a great source of general information on food fraud mitigation, as is the “Food Fraud Prevention” document created by Nestle. Many of the GFSI Certification Programme Owners have also released guidance documents about vulnerability assessments, such as BRC, FSSC 22000, and SQF.

The Decernis Food Fraud Database and the FPDI Food Adulteration Incidents Registry (see Table I) are two sources of historical food fraud data that are referenced specifically in the SSAFE/PwC tool. Companies can also track official information about food safety recalls and alerts (including related to food fraud) from public sources such as the FDA Recalls, Market Withdrawals, & Safety Alerts; Import Refusals; Warning Letters; USDA Recalls and Public Health Alerts; EU RASFF, and many others.

Of course, there are quite a few companies that offer tailored tools, training and consulting services. Companies that offer courses in food fraud mitigation and assistance in creating a vulnerability assessment (or FDA-required food safety plan) include NSF, Eurofins, AIB International, SGS, and The Acheson Group.

Also available are services that compile food safety recalls and alerts (including those resulting from food fraud) from multiple official sources, such as FoodAKAI and HorizonScan. EMAlert is a proprietary tool that merges public information with user judgment to inform food fraud vulnerability. Horizon Scanning is a system that can monitor emerging issues, including food fraud, globally.

Food fraud mitigation, vulnerability assessment
Vulnerability assessments should help focus resources towards those ingredients truly at risk of fraudulent adulteration.

In short, there are many resources available to help support your food fraud vulnerability assessments and mitigation plans. If I have unintentionally missed mentioning any resources you have found to be helpful, please let us know in the comments.

Melody Ge, Corvium
FST Soapbox

Changes in the Food Safety Industry: Face Them or Ignore Them?

By Melody Ge
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Melody Ge, Corvium

“A new era of smarter food safety is coming,” said Frank Yiannas, FDA’s deputy commissioner of food policy and response, at the GFSI Conference 2019 in Nice, France. He went on to explain, “a smarter food safety is people-led, FSMA-based and technology-enabled.” Afterwards, Yiannas announced the need for a greater budget for the FDA to invest in modern food safety for 2020 and beyond.

Now the question is, when this new era comes, are you ready?

The food industry is relatively behind on technology compared to other industries, or even within our daily lives. Take a look at the cell phone you have now compared to what you had 10 years ago; it has come a long way with all of its handy and useful features. Why can’t the food industry also benefit from technology? Of course, every coin has two sides, but no one would deny that technology played a significant role in bringing the world closer and making it more efficient nowadays.

The scary part of change is that it’s hard to predict what and when they will come to us, however, they also force us think outside of the box. Instead of debating whether incorporating advanced technology into our daily operations makes sense, why don’t we take a look at our current processes in place and see where technology can truly help us? We now have the opportunity to take advantage of technology to enhance our food safety and quality culture at our own facility. Here are some thoughts to share.

1. Identify what can be automated in your current process with technology

Certain things just can’t be replaced by technology, such as risk assessment or hazard identification (at least for now). However, inventory, temperature checking, testing results recording, or anything executing a command from you or implementing a part of your SOPs can potentially be automated. Execution is also the part where the most error could occur, and technology can help improve accuracy and consistency. Identify those steps systematically and understand what data needs to be captured to help your food safety management system.

2. Work with your technology developer to build technical requirements

Explain to the technology developer exactly how you want the program to operate daily. List the operating steps along with responsibilities step-by-step, and identify what requirements are needed for each step. Translating the paper SOP to a computer program plays an important role in this transition. Not only does it set the foundation for your future daily operation, but it also ensures that the control parameter is not lost during the transition.

3. Keep the integrity of the food safety management system through verification and validation

Once processing steps are done by technology, it doesn’t mean that we no longer have to do anything. We need to verify and validate the technology with certain frequency to ensure the steps are controlled as intended. Confirming that the software or system is capturing the right data at the right time becomes key to ensure the integrity of control risks is not compromised.

4. Utilize “preventative maintenance” on all technology used on site

Just like all equipment, food safety technology needs a preventive maintenance schedule. Check whether it is properly functioning on a certain frequency based on the safety impact in your process flow and take actions proactively.

5. Learn from your own records

The time saved from traditional ways allows us to have more time for looking at control points and records received to identify areas for continuous improvement. There are many ways of studying the data with modeling and trend analysis based on your own facility situation. Either way, those records are your own supporting documents of any changes or modifications to your food safety management system, as well as strong support to your risk assessment for justifications.

Just like Yiannas said, a smarter food safety system is still FSMA based. The goal has never changed; we want to produce sustainable, safe and high-quality products to our consumers, whether we use traditional or advanced approaches. After all, we are utilizing technology as a modern way to help us enhance and simplify our food safety management system; the outcome from the automated technology is still controlled by us.

So when the era comes, we all want to be ready for it.

Karen Everstine, Decernis
Food Fraud Quick Bites

How Food Fraud Happens

By Karen Everstine, Ph.D.
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Karen Everstine, Decernis

The food industry has been hard at work over the past few years implementing food fraud mitigation plans in response to Global Food Safety Initiative (GFSI) certification program requirements. GFSI defines food fraud as:

“A collective term encompassing the deliberate and intentional substitution, addition, tampering or misrepresentation of food, food ingredients or food packaging, labelling, product information or false or misleading statements made about a product for economic gain that could impact consumer health.” (GFSI Benchmarking Requirements, 2017)

GFSI then further defines the terminology of food fraud by citing seven categories (shown in the following diagram).

GFSI, Food Fraud
Used with permission from GFSI

In the Food Fraud Database, we categorize food fraud records using the following terminology (with examples):

  • Dilution/substitution
    • Substitution of an entire fish fillet or partial dilution of olive oil with another oil
  • Artificial enhancement
    • Addition of melamine to artificially increase the apparent protein content of milk or the addition of coloring agents to spices
  • Use of undeclared, unapproved, or banned biocides
    • The use of chloramphenicol in honeybee populations (where not permitted) or the addition of hydrogen peroxide to milk
  • Removal of authentic constituents
    • The sale of “spent” spice powder (used in the production of an oleoresin) as a whole spice powder
  • Misrepresentation of nutritional value
    • Infant formula that does not contain the required nutritional content
  • Fraudulent labeling claims
    • Misrepresentation of label attributes related to production method (organic, kosher, halal, etc.)
  • Formulation of an entirely fraudulent product (using multiple adulterants and methods)
    • The sale of “100% apple juice” that consists of sugar, water, malic acid, flavor, and color
  • Other
    • This includes counterfeits, theft, overruns, etc.

Harmonization of food fraud terminology is frequently discussed, so I thought it might be useful to provide information on how our definitions relate to the GFSI terminology:

GFSI category “Dilution”: This category maps directly to our category dilution/substitution. The reason we combine these into one category is that the intent is the same: To replace the weight or volume of a product. This can occur either through partial or full substitution of a liquid product, a granulated product, or swapping an entire intact product such as a fish filet. One of the GFSI examples for substitution is “sunflower oil partially substituted with mineral oil”, which could just as accurately be described as dilution.

GFSI category “Substitution”: As noted above, this category maps directly to our category dilution/substitution. However, we would not consider the use of hydrolyzed leather protein in milk (one of the cited examples) to be dilution/substitution because it is not used to replace weight or volume. We would view that as artificial enhancement of the protein content of milk.

GFSI category “Concealment”: We do not include a category focused on concealment because all food fraud involves concealing some aspect of the true contents of the food. One of the examples cited in this category is “poultry injected with hormones to conceal disease.” The use of antibiotics, anti-fungal agents or other substances to reduce bacterial load or mask deterioration would be classified, in our system, as the use of undeclared, unapproved or banned biocides. The use of coloring agents on fruit to improve appearance would also be classified as artificial enhancement.

GFSI category “Mislabeling”: Since all food fraud is, to some extent, mislabeling, we reserve the use of the term fraudulent labeling claims to those label attributes that describe production processes (organic, kosher, etc.). With the exception of falsification of expiration dates, the other examples cited would not be classified by us as mislabeling. The sale of Japanese star anise, which is potentially toxic, as Chinese star anise (a different species) is dilution/substitution and a health risk to consumers. The sale of cooking oil that has been recovered from waste streams and illegally produced is also a form of substitution that poses a potential health risk to consumers.

GFSI category “Unapproved enhancements”: This GFSI category aligns nicely with our category artificial enhancement, and both examples cited are nicely illustrative of the concept, which involves the fraudulent addition of a substance specifically for its function (not as a replacement for weight or volume).

GFSI Category “Gray market production/theft/diversion”: The production and sale of food products through unregulated channels would all be classified in our category called other. Because these forms of food fraud involve the sale of food outside of regulatory control, prevention measures will generally be substantially different from the prevention of fraud within legitimate supply chains.

GFSI Category Counterfeiting: This GFSI category is similar to the gray market production/theft/diversion category in that it involves intellectual property infringement and production outside of regulatory control. It would similarly be classified in our other category.