Summary: Even though Food Fraud (FF) and Economically Motivated Adulteration (EMA) are not a compliance requirement for FSMA‐IA, this final rule provides important insight into FSMA and assessments: 1. Addressing all types of Food Fraud is a requirement – and subject to a recall – under the Food, Drug & Cosmetics Act (FDCA). 2. FDA specifically reiterated the FDCA compliance requirement in sections on “Adulterated Foods” and “Misbranded Foods.” 3. FSMA‐IA stated that stolen goods (various types of theft) that lead to a public health hazard are clearly defined and expected to be covered under FSMA‐PC. 4. There were no more clarifications of key terms such as reasonably foreseeable hazard, significant vulnerability, rare occurrence, credible threat, or the threshold of acceptable or unacceptable.
Summary: The US Food Safety Modernization Act Produce Safety Final Rule (FSMA‐PS) does not directly address Food Fraud (FF) or Economically Motivate Adulteration (EMA) other than referring to the FSMA Preventative Controls rule (FSMA‐PC) and the US Food Drug & Cosmetics Act (FD&C). FSMA‐PS focuses on biological health hazards only and not physical or chemical contaminants. As such, there are no additional FF/EMA regulatory compliance requirements for FSMA‐PS. This Final Rule does provide insight to other FSMA compliance questions.
Summary: The Global Food Safety Initiative (GFSI) published the GFSI Food Fraud Technical Document titled “Tackling Food Fraud through Food Safety Management Systems.” This publication supports the previous reports on GFSI food fraud position paper (2014) and GFSI Benchmarking Document (2017). This new document reinforces the previous statements and supports the efforts to “just get started.” This new document is a key for confirming the definition, scope, starting point, and the expectation for the first compliance requirements.
Summary: On February 8th GFSI issued a public request for comments on the new Guidance Document Issue 7 including new Food Fraud requirements which is open until February 19th. Instructions and links to provide comments are included below. Both FSMA and now the GFSI require food producers and distributors to address economically motivated food safety hazards or Food Fraud health hazards (FFH, as opposed to Food Fraud economic threats or FFE). There are four new Food Fraud clauses that are included in each of the thirteen GFSI sections. Addressing Food Fraud is not optional. For FSMA and now GFSI, to address all economically motivated food safety hazards, addressing all types of Food fraud is not optional.
Summary: A review of International Standards Organization (ISO) published standards revealed that the core food fraud-related terms have been used across many disciplines (e.g. integrity, authenticity, authentication, adulterant, adulteration, adulterated, and product fraud from https://www.iso.org/obp/ui/#search). Table 1 includes a keyword search summary of entries in the “Terms & Definitions” sections of ISO standards. An expanded Table 2 includes detailed quotes and Table 3 includes adulterant and product fraud.
The Risk of Document Fraud in the Food Supply Chain: Preliminary Findings from the Food Document Fraud Survey – Coming Soon
Summary: Food fraud is a global problem that can have devastating economic effects and poses considerable risks to public health, safety, and food security. While prevention is the key to alleviating it, the risks must be identified and the fraud opportunities have to be reduced. One such risk is document fraud, however, our understanding of this problem in the food supply chain is limited. The purpose of this backgrounder is to introduce you to the document fraud concept and highlight the preliminary findings resulting from the Food Document Fraud Survey.
Summary: For combating food fraud, a holistic and all‐encompassing approach includes specialized methods to assess past incidents in the marketplace, review the fraud opportunity, conduct assessments, connecting to enterprise‐wide decision‐making systems such as Enterprise Risk Management, and refine internal control systems. This report builds upon previous food fraud prevention and food fraud Enterprise Risk Management research to provide a case study example of a complex food fraud management system. The case study was on the Kerry Group’s specific Global Supply Quality Risk and Vulnerability Management and Governance system. Results: The report and case study demonstrate how a holistic and all‐encompassing approach to food fraud prevention created control systems and risk communication for an enterprise. Conclusion: The entire Food Fraud Prevention Cycle provides a foundation for a rational and integrated approach that “connects everything to everything.”
Summary: An enterprise‐wide risk perspective such as Enterprise Risk Management (ERM) provides a widely adopted and structured approach for managing Food Fraud prevention. ERM supports resource‐allocation decision‐making through plotting the Food Fraud Vulnerability Assessment on a Corporate Risk Map. … [JS1] GFSI has been leading this through specifying a (1) Food Fraud Vulnerability Assessment (FFVA) that covers all products and a (2) enterprise‐wide Food Fraud Prevention Plan (FFPP). … . A missing link in Food Fraud prevention was an enterprise‐wide correlation of the risk to all other portfolio risks. An enterprise could be a private company, a government-owned the company, or a government. Fortunately, most companies have already implemented COSO based Enterprise Risk Management (ERM) type systems for securities or financial audit compliance.