Recently Clare
Winkel attended the World Seafood Congress 2019 in Penang Malaysia. 41
countries were represented to discuss innovation, responsibility, and
sustainability for the future, under the conference theme of Seafood Supply
Chains of the Future. This conference occurs every 2 years somewhere around the
world, in a location usually closely related to the seafood industry. Previous
conferences have been at Reykjavik in Iceland, St Johns in Newfoundland &
Sydney Australia. The conference is organised by the International Association
of Fish Inspectors (IAFI). Clare has been a member since her first conference
in Halifax, Nova Scotia in 1999. Clare was very involved in the organisation
for the 2007 conference in Dublin, Ireland. The next World Seafood
Congress will be held in 2021 in the city of Peniche, Portugal.
That’s Clare on
stage as part of the final World Seafood Congress 2019 wrap up- along with
fellow Australians, Jayne Gallagher (first female IAFI President) & Mark
Boulter (most recent past IAFI president). Was a busy few days as Clare,
presented on TACCP (Threat Assessment within the seafood industry), moderated a
session (Consumer Protection & Food Safety), judged the poster competition
& was part of the final Congress wrap up. Then she was promoted from the
South Pacific Regional Representative onto the Executive Board of IAFI
(International Assoc of Fish Inspectors). Additionally another project
Clare has been working on during 2019 (the risk of Salmonella in the
consumption of raw fish products) was presented by Jasmine Lacis-Lee from DTS
Food labs in Brisbane.
At each conference a number of awards are given out
including the following:
-The poster
competition judged by the IAFI board members, with cash prizes sponsored by
IAFI.
-Outstanding contributions to the seafood industry deserve
to be acknowledged. Nominations can come from anyone and based on their
contributions to research achievements, industry or equipment development,
patents and achievements in the application of safety and quality systems,
training and training development in any seafood related profession, and other
areas which positively affected the seafood and fishing industry.
-The Peter Howgate Award which
funds the attendance of a young fish technologist to the World Seafood Congress
2019, a career-changing opportunity to gain insights and build networks within
the global fishery sector. Persons under the age of 30 are eligible for the
Award. For more information, please visit the official
Peter Howgate Award website.
–Women in Seafood Video Award: winners
will be awarded cash prizes of up to 1000 Euro and a ticket to the Congress.
Video submissions must be in a short film format, less than 4 minutes long, and
feature a woman involved in the seafood industry. For more information, please
visit the Women
in Seafood website.
The Peter Howgate award for 2019 had 2 winners, that
presented a number of times during the conference:
-“Crab
Industry in India – an overview” by Justin
Sundarrajan, Newport International’s Quality Control Consultant
– India.
-“Official Controls, Constraints, Opportunities
and the Future plans for the Fisheries and Aquaculture Sector in Uganda” Stella
Mbabazi, Department of Fisheries
Resources inspector for the Ministry of Agriculture, Animal Industries and
Fisheries – Uganda.
Clare has previously (2013) won an award
for her Outstanding contributions to the
seafood industry with regard to training.
New GFSI (Global Food Safety Initiative) requirements now include special consideration to be given to food fraud. To address this new requirement, food safety standards, including SQF, mandate certified sites to complete a food fraud vulnerability assessment of a food manufacturer’s entire supply chain with a strong emphasis on ranking raw materials for potential vulnerability. Current retailers & legislation (Australia, USA & UK) require controls within this area, but unlike established food safety risk assessments, there have been very few published methodologies to carry out vulnerability assessments. This presentation will concentrate on methodologies to assess the risk of potential food fraud within the raw material supply chain.
ICS has recently spent an extended period of time consulting in remote parts of PNG. A country with a population of approximately 7.7 million, including the PNG mainland as well as its 600 islands. There are 800 known languages in PNG, some locals still living in traditional huts like the image above. What an interesting and challenging part of the world!
The HACCP support involved a lot of travel by plane and bouncing in LandCruisers on boggy tracks in the highlands of PNG to visit a gold mine, kitchens in camps on offshore islands, warehouses, a coffee factory, kitchens in managed camps and a vegetable depot collecting product directly from (mostly female) growers.
The requirements of this work has made us reflect on the “first principles HACCP” and not just follow compliance checklists. Our learnings? Don’t assume anything, challenge perceptions, follow people around to see what they are really up to, check backs of utes for chemicals ask the cleaning staff what they know and see, look right up the back of shipping containers to see what is hiding there and listen to kitchen staff. Furthermore, check the books/databases for what the science tells you.
Join our ICS training courses to learn how you too can challenge your food safety plans and controls.
Site Transport
PNG Roads
Vegetable Depot
Is PNG dangerous?
Some people have questioned whether the country is safe to work in, especially as a female. Our client provided excellent site and travel security, secure managed camp accommodation and direct charter flights. We ensured we read and strictly follow the company rules. It was exhausting but very rewarding work that made us think laterally about practical solutions in tough work conditions. We would definitely visit again.
Non work highlights:
Amazing sun rises in the cold clouds of the highlands
Visiting multiple local markets and staying in a 1930’s “Hill Station”- similar to what the British built in places like Darjeeling (India) but built by Australian gold miners, with stunning sprawling tropical gardens and amazing carvings – no doubt collected in the 1920’s from the Sepik region. As it turned out, Clare’s father used to organise weekend “tours” to the same town in the 1960’s, to also buy vegetables i.e. fill a DC3 with fresh produce!
The BRC Global Standard Food Safety Issue 8 was released in August 2018. All BRC audits are now certified against Issue 8, it is imperative you read this update and prepare for your next audit.
Issue 8 addresses a few major areas where the Standard needed to be revised to reflect the changing food safety landscape. For successful certification to Issue 8, sites must implement all of the changes.
What you need to know – Key Changes:
There are now 12 Fundamental clauses not 10, refer to pg.9
Issue 8 places a big emphasis on Food Safety Culture – clause 1.1.2 – site’s senior management shall define and maintain a clear plan for the development and continuing improvement of a food safety and quality culture (measurement of objectives) and clause 1.1.6 – confidential reporting system
Special attention is also drawn to clause 1.1.13 – no BRC logo on packaging or labels
HACCP/Food Safety Plan – HACCP risk assessment clause 2.7.1 – one new word that must be considered in the Hazard Analysis – ‘radiological hazards.’
Food Fraud Risk Assessment (VACCP)clauses – 2.7.1, 3.5.1.1 and 5.4.2
Site Security – section 4.2 You must have a documented ThreatRisk Assessment (TACCP)in addition to your control procedure.
Environmental Monitoring – section 4.11.8 – sites must develop rigorous monitoring techniques and programs within the factory, enabling them to identify potential product contamination risks (pathogens and spoilage organisms) and take timely corrective action before product contamination occurs.
Product Labelling – section 5.2 and 6.2 – updated requirements relating to pack and label control. Change control at goods receipt, control of on-site printing, verification processes to control and monitor labelling. Lots of inspections, checks and records required. The auditor will also inspect the processes used by the site to establish label information.
High-Risk, High-Care and Ambient High-Care Production Zones – section 8 – the requirements remain unchanged but have been relocated into a single, newly created section of the Standard.
Additional Modules:
Traded Products – traded goods module for sites that store and sell food products that are not manufactured, processed or packed on site is now included in section 9 of the Standard.
Changes to the audit protocol:
There have been changes to the way in which the Standard is audited and certified, refer to pg.64.
BRC Issue 8 Certification Audit Findings:
From our recent BRC Issue 8 certification audits it would appear not many sites have carried out an effective internal auditagainst the new Standard consequently resulting in many non-conformities and poor audit outcomes!
Hints for your upcoming BRC Issue 8 Audit:
1. Carry out an effective internal audit against the “system.” Do your company’ s procedures and records meet the current requirements of the BRC Standard? If YES, are your company’s procedures being implemented on the “factory floor?”
2. Carry out the internal audit at least 3 months before your certification audit, so you actually have time to rectify the identified issues.
3. If you choose an external consultant, make sure you check their qualifications beforehand. Are they a registered BRC auditor or BRC Professional? If NOT, how do you expect they will know more than you?
4. It is a BRC requirement that you have a copy of qualifications for all internal auditors used onsite.
5. Read the new Standard and attend an official BRC Training Course for Site Conversion from issue 7 to 8.
The BRC Food Safety Americas 2019 Conference was held in San Diego, May 21-22, 2019. Clare Winkel had the pleasure of being a guest speaker. Here is a summary of Clare’s presentation.
What is food fraud?
Food fraud is intentional adulteration of raw ingredients for financial gain. It is Economically Motivated Adulteration. It is Not: HACCP hazards: prevention of unintentional/accidental food safety adulterationand it is Not: TACCP: Food Defence threats: prevention of intentional adulteration/ ideologically motivated i.e. bioterrorism and It is Not new, as records on food fraud exist from Roman times at least.
As listed by the EU, 2013 products at High risk from food
fraud are:
Olive oil
Seafood
Organic foods
Milk
Honey and maple syrup
Grains
Coffee and tea
Spices (saffron and chilli)
Wine
Fruit juices
A Closer look at few of these examples
Olive Oil
In 2014 a hostile bacteria — Xylella
fastidiosa — was seen in Europe for the first time, destroying
centuries-old olive trees & millions of tonnes of Italian olives. While
Spain’s harvest was affected because of hot and dry conditions. Italy reported a 57% drop in
production, Greece and Portugal a drop of 35% and 15% respectively.
In 2018 Global production dipped by over 5% due to bad weather and
disease. Italy, Greece, Turkey, Palestine, Argentina, Portugal and Tunisia saw
the biggest drops. California had a rough year too.
When the
harvest is poor, retail prices skyrocket.
This resulted in
bottlers paying up to 40% more for their oil.
Italy’s crackdown on the illegal olive oil trade has
resulted in another major seizure of 200 tonnes of oil falsely labelled as
coming from the Tuscany region. Nearly
50 individuals and organisations — including millers, bottlers & traders— have been detained as part of the
investigation by the Ministry of Agriculture’s inspectorate for the protection,
quality and the repression of fraud in agriculture and food (ICQRF) &
Italy’s forestry department. The ploy was discovered thanks to DNA testing
of the oil, which revealed a complex scam involving a large number of
actors in the olive oil supply chain.
Producers
cut the pure olive oil with cheaper oils like palm, sunflower or canola to
stretch it further. There is a direct correlation – When the harvest is been
poor, rates of adulteration rise!
One of the reasons the Italian Govt has allocated so many resources to
fighting food fraud, is part of a larger fight against organized crime.
Organic
Foods
A shipment of 36 million pounds of soybeans sailed in
2016 from Ukraine to Turkey to California. The cargo began as ordinary soybeans,
they were fumigated with a pesticide – tablets of aluminium phosphide, a
pesticide prohibited under organic regulations.
When they arrived in California, the soybeans had been labelled
“organic,” according to receipts,
invoices and shipping recordswhich boosted their value by
approximately $4 million. And about
21 million lbs of the soybeans have already been distributed.
But where did all this big production come from? Where
are these organic farmers?
Here are some facts:
between 2014 & 2016, the amount of organic
corn arriving into the USA, from Turkey rose from 15,000 to more than 399 000 tons and the amount of organic soybeans coming from Turkey
rose from 14,000 to 165,000 tons.
Under USDA rules, a company importing an organic product
must verify that it has come from a supplier that has a “USDA Organic”
certificate. It must keep receipts and invoices, but need not trace the
product back to the farm.
Some of the soybeans originated from ADM Ukraine, a company
that does not produce or trade organic soybeans and did not sell or label them
as such.
Honey
Australia’s
biggest listed honey company and some of the country’s largest supermarket
chains face accusations of unwittingly selling “fake” honey. Capilano strongly denied any issues with its
products and criticized the type of test — known as Nuclear Magnetic Resonance
(NMR) — used to detect the impurities, pointing out that it differed from the
official Australian test. Germany’s Quality Services
International (QSI) lab was commissioned by a law firm on behalf of
horticulturalist Robert Costa to conduct 2 types of tests of the sampled
honey (NMR & C4).
This
appears at first to be an open and shut case of fraud but in fact the law firm
organizing the lab tests was involved in a hostile takeover bid of the honey
company. The honey company has now changed hands. Follow the money and find out who is creating the fraud- its not always
obvious.
Regions at High risk from food fraud:
The
usual suspects: China, Subcontinent (India/Pakistan) & Turkey.
But
basically everywhere: Italy, Spain, EU, USA, ANZ……
Consider climate change (causing shortages/price
rises), trade wars (artificial shortages/price rises/falls) and political
instability (i.e. Syria, Venezuela…) as any of these will contribute to
food fraud risks.
So what DO YOU really have to do about it?
Read
your BRCGS standard.
Know
the regulations in the countries you produce food AND where you sell your food.
Read
the fine print of your customers standards.
Understand
what risk there really is to your business in the real world.
BRCGS Food Safety requirements issue 8
3.5.1.1
Documented risk assessment
of each raw material that must consider substitution or fraud.
5.4.2
Documented assessment of the vulnerability of the raw material supply
chain.
5.4.3
Where raw material are identified at risk then control
measures/mitigation measures be put in place.
9.1.1
Documented risk assessment
of each raw material that must consider adulteration or fraud.
BRCGS Storage & Distribution requirements issue 3.
10.1.1
Supplier risk assessment to
include the potential for adulteration or fraud.
10.2.1
A documented vulnerability assessment
taking into account historical evidence of substitution or adulteration.
10.2.2
Where products are identified as at
risk, appropriate assurance/testing methods shall be in place.
BRCGS Agents & Brokers issue 2
4.3.1 The company shall assess the potential risks
to the security of the products from any attempt to inflict contamination or
damage during subcontracted transportation and storage…
What does a Food Fraud Vulnerability Assessment look like? – the weapons you need to fight food fraud.
With vulnerability assessment, severity is not a particularly useful measureas (at the
very least) the resultant product will always be illegal and therefore the
consequences are always severe, regardless of whether there is an associated
food safety issue or not.
Furthermore, most adulteration cases do not have
a food safety concern associated with them and the inclusion of severity may,
if not handled correctly, lead to an under estimation of the importance of any
identified risks. BRCGS Understanding
Vulnerability Assessment section 3.2.
Collect information on every single raw material: List all raw materials, their country of origin, their suppliers (importers/agent/brokers), source manufacturers, pricing trends & all known testing & sampling activities.
Particularly make sure you have all current certification information on all brokers/agents you buy off & in turn all source manufacturers that actually make the raw materials.
To get the information on certification READ CARTONS& look for GFSI stds logos, go to companies websites to see what stds they may have implemented. Cross check that information back to the GFSI stds databases or ask the certification body listed.
Risk evaluation: ranking of suppliers and raw materials. The more accurate information is used within the assessment the more accurate answer/ranking will be available to the user.
Evidence of past issues of fraud for that product must be assessedfor each raw material.
Price changes and availability of the raw material must also be collected as this will have a large bearing on future fraud likelihood.
Some raw materials can be grouped if they are derived from the same plant/animal in the same country of origin (i.e. cinnamon from Sri Lanka) or if they are processed by the same source manufacturer (i.e. same factory) and they have provided you with all test methods and all current certifications.
Understand which stds require VACCP assessment as mandatory auditable requirements i.e. BRC Food, SQF vs 8, FSSC 22 000 vs 4.1, but not 3rd party HACCP or any ISO stds.
Control Measures
After all raw materials have been ranked between 1 – 125, the VACCP team members will have to make a decision on at what score will additional control measures be allocated. This number will indicate the level of significance.
Implement additional control measures as required based on your documented risk assessments of both suppliers supply chains and raw materials.
Record keeping
Document procedures and keep recordsfor each assessment and references.
Different countries have different Food Fraud regulations and even different definitions. If you are exporting you need to know not only what the requirements are, but also the meaning of the term in that region. Food fraud is economically motivated adulteration of food. It’s all about making money – not sabotage.
Food fraud is not HACCP
which is the prevention of unintentional/accidental food safety adulteration
i.e. science based, and food borne illness. It also not Food Defence or threats – the prevention of intentional
ideologically motivated adulteration i.e. sabotage or bioterrorism.
Some legal definitions of
food fraud from around the world include:
FSMA (USA):
Intentional adulteration from acts intended to
cause wide-scale harm to public health, including acts of terrorism targeting
the food supply.
Hazard may be intentionally introduced for
purposes of economic gain.
UK:
Food fraud is considered to encompass the
deliberate and intentional substitution, addition, tampering or
misrepresentation of food, food ingredients, or food packaging, or false or
misleading statements made about a product for economic gain.
Australia:
Gaining a financial advantage or causing a
financial disadvantage through deception or dishonesty.
VACCP (Vulnerability Assessment Critical Control Point) is a method of risk assessing raw materials for the risk of food fraud occurrence. There are several methods that can be used – some require far more resources (staff knowledge, time and ability) that is available in the average food business. Some methods present you with a multi coloured spider-web that looks fabulous but does not give a clear result for ranking of the food fraud hazards. In addition to the regulations in the country of manufacture and sale, you also need to be aware of the requirements of the standards your company is audited against i.e. BRC, SQF or specific retailer/customer requirements. Some retailers specifically require a ranking of identified food fraud hazards.
All GFSI
standards require some type of documented food fraud risk assessment and
control plan requirements – but they do vary between the Standards. Some
requirements are:
BRC Food Safety Global Std:
3.5.1.1 Documented risk assessment of each raw material
that must consider substitution or
fraud.
5.4.2 Documented assessment of the vulnerability of the raw material supply chain.
SQF Systems Elements Ed 8- Manufacturing:
2.4.4.5 Sites food fraud vulnerability assessment including the site’s susceptibility
to raw material or ingredient substitution, mislabelling, dilution and counterfeiting … impacting
food safety.
2.7.2.1 Food Fraud vulnerability assessment include the
site’s susceptibility to product substitution, mislabelling, dilution,
counterfeiting or stolen goods which effect food safety.
And the FSMA
rulings (Federal US regulations): Mitigation Strategies to Protect Food Against Intentional
Adulteration:
A vulnerability assessment, to
identify: Significant vulnerabilities
and actionable process steps.
The VACCP (Vulnerability Assessment Critical Control Point) methodology developed by ICS is a simple but effective tool of risk ranking raw materials for potential food fraud occurrence. It uses the existing skills of the HACCP team and utilises a 3-variable matrix (Likelihood x Detectability x Profitability) with a resulting score between 1 (overall very low risk) – 125 (overall extremely high risk). This allows raw materials to be clearly ranked for risk. The result is a fully documented assessment against a specific raw material that is easily reviewed at least annually. ICS have used it to assess over 600 different raw materials with the resulting scores between 1 and 60.
ICS have public, virtual and online training courses (and technical support services) in Food Fraud awareness, Food Fraud requirements (Regulatory, GFSI and retailer standards) and VACCP Food Fraud assessment methods. http://integritycompliance.com.au/
While the concept of HACCP-based risk assessments for food
safety (chemical, biological and physical) has been very well established
globally, much of the food industry has yet to come to terms with the development
of risk assessments focusing on vulnerability, authenticity and threats.
To further complicate matters, multiple terms are used globally for these
topics (oftentimes incorrectly). Despite this, all GFSI Standards (BRC, SQF, Global Gap,
FSSC22000 and IFS) and most major retailer Standards require food fraud (VACCP)
and food defence (TACCP) risk assessments.
What is VACCP?
VACCP
(Vulnerability Assessment Critical Control Points) is a risk assessment focused
on risks from the vulnerability of your raw materials, supply chain and your
finished product from adulteration, substitution, mislabelling, counterfeit or
any other attempt to change the products for economic gain. The VACCP
risk assessment is designed to identify risks from food fraud.
The global cost of food fraud is estimated
to be US$30-40 billion dollars per year. In many cases, there is no
impact on consumer health, but the damage to business reputation and indirect
costs can be massive.
Significant food fraud events globally have included the melamine contamination of baby formula in 2008 in
China resulting in 300,000 reported illnesses and six consumer deaths.
The three key staff members involved were punished: one with life imprisonment
and two with the death penalty. Ironically, melamine contamination in the
food chain was first identified in May 2007 when the US Department of
Agriculture reported that the contaminant had been found in pet food fed to
hogs and chickens destined for human consumption. Hundreds of dogs and
cats either died or suffered health problems as a result of consuming the pet
food.
The scare widened
in the US after it was found to have entered the human food chain after pet
food scrap was used as a feed supplement at a number of hog and chicken
farms. The question that begs to be answered in all this is whether the
wider food industry should have been aware of this event and considered it in their
risk assessments?
Food Fraud is Not New
Multiple publications have been released as early as A Treatise
on Adulteration of Food & Culinary Poisons was penned by Frederick
Accum in 1820. There is plenty of historical data on food fraud and the risks
associated with each and every ingredient and food product. Not all
contamination events are purely for economic gain, however. When the
contamination or damage is intentional and designed to cause harm, the term
“threat” is used rather than “vulnerability.” Hence the term TACCP
(Threat Assessment Critical Control Points).
What is TACCP?
TACCP is a risk
assessment focused on risks from threats to your raw materials and could
include intentional contamination of food products, sabotage of the supply
chain, and using food or drink items for terrorism or criminal purposes.
Food is the number one product stolen when under
transportation in the USA. More than USD$30 Billion is stolen annually in
the USA and then resold on the black or grey markets, potentially having been
contaminated first. And, while theft opens the door to the possibility of
significant danger to human life and brand integrity, significant damage
can also be achieved through simple malicious intent.
Recently Australia
has been subject to a nationwide recall of strawberries in peak season due to
malicious tampering with sewing needles. Initially an isolated event in
Queensland, the incident escalated to other states and territories. Only a few
instances were believed by authorities to be associated with the original
event, with most other instances believed to be multiple hoax or “copycat”
events.
Risk assessments
are only as good as the input or information used to conduct the
assessment. Horizon scanning and keeping up to date on threats,
vulnerabilities and emerging risks are the only genuine defence we have in the
HACCP, TACCP and VACCP risk assessment game
The past few years have seen some significant changes in the requirements of retailer and GFSI Standard and 2018 is shaping up to be another big year of change. The BRC Global Standard Food Safety Issue 8 is to be released in mid-2018 and as BRC Approved Training Providers, ICS are prepared for delivery of training and technical support to industry, certification bodies and auditors in October 2018.
Additionally, SQFI have released a new version of the SQF Standard requiring upgraded requirements relating to Approved Suppliers, HACCP, Allergen Controls, environmental swabbing and the introduction of both VACCP and TACCP. Furthermore, businesses with HARPs and SQF certification under Code 35 will no longer be able to use SQF as their GFSI base standard. The only GFSI standard available for this sector of the industry, will be the BRC Agents and Brokers standard.
To meet this demand ICS is running recognised BRC Agents and Brokers Standard training for both auditors and industry early in 2018. This will be the first time that this training has been offered in this region. Courses will be delivered in:
– Melbourne: 23 January 2018
– Brisbane: 24 January 2018
– Auckland: 30 January 2018
Please free-call us on 1300 367 810 to book on this course or email your registration enquiry [email protected].
2017 has been a very busy year indeed at ICS with ongoing and significant technical support provided to auditors, industry, certification bodies and Standard specifiers. Our team have been instrumental in supporting the success of the business and our customers through exceptional customer service, dedication and professionalism. I couldn’t be prouder of what the team has achieved in 2017 and look towards 2018 with excitement.
