Review – New FSSC 22000 Version 4 Regarding Food Fraud and Food Defense

Written by: John Spink

Primary Source:  Food Fraud Initiative

Question: Are you compliant with the Food Fraud requirements of the new FSSC 22000 standard — maybe, but probably not yet. Yesterday FSSC released their new Version 4 which follows GFSI direction to require (1) a Food Fraud Vulnerability Assessment (FFVA) and (2) a Food Fraud Prevention Strategy. Addressing Food Fraud in separate assessments and plans will not be optional.

From our Food Fraud Initiative Report (FFIR):

Our Full report is available here: http://foodfraud.msu.edu/wp-content/uploads/2016/12/MSU-FFTT-FFIR-FSSC-22000-update-Edition-4-2017-v8-b.pdf

 The FSSC 22000 Version 4 is available herehttp://www.fssc22000.com/documents/support/downloads.xml?lang=en


Review – New FSSC 22000 Version 4 Regarding Food Fraud and Food Defense

December 23, 2016

By John Spink

SUMMARY

On December 22, 2016, FSSC 22000 released their new “Food Safety System Certification 22000” Version 4. This will be required after an “appropriate transition period for certified organizations to adapt to the implementation of the new requirements,” or reportedly by January 1, 2018. This is one of the first systems or programs that explicitly addresses and emphases “Food Fraud Prevention.”

Aligned with GFSI, the standard requires a separate (1) Food Fraud Vulnerability Assessment and (2) Prevention Strategy for all types of fraud, all products, and across the food supply chain, from raw materials to finished goods supplied to end users.

They also require a separate Food Defense threat assessment and control plan for all types of attacks – e.g. tampering and disgruntled employees, not just the FSMA Intentional Adulteration scope of terrorist-type “wide scale [human] public health harms.”

FSSC 22000 – based on the ISO 22000 Food Safety Management standard – is one of several Global Food Safety Initiative (GFSI) recognized standards. GFSI essentially sets the food safety management system expectation for most of the food industry. So this standard defines what the food industry will do.

CONCLUSION

Current Food Fraud Vulnerability Assessments and Prevention Strategies appear to be compliant as long as the scope covers all types of fraud, all products, and all the way to the end user – some systems or programs only cover ingredient, only adulterant-substances, or combine Food Fraud and Food Defense assessments.

  1. Conducting a Food Fraud Vulnerability Assessment is not optional
  2. Implementing a separate Food Fraud Prevention Strategy is not optional.
  3. There must be a separate assessment for Food Fraud and another for Food Defense.

Most food companies are not currently compliant and will need to expand their Food Fraud Vulnerability Assessments and Prevention Strategies. That said, there are many resources already available. See the SSAFE organization Food Fraud Guidance, the published MSU Food Fraud Initial Screening Tool (FFIS), and our MSU Food Fraud Initiative Executive Education Short-courses or the Food Fraud MOOC (Massive Open Online Course.)

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There is still time until the compliance requirement… but there is no time to waste. Begin by reviewing the GFSI requirements – in relation to FSMA and other requirements such as Sarbanes-Oxley – such as in our previous MSU Food Fraud Initiative Reports. Also, start reviewing the wide range of Food Fraud Vulnerability Assessment and Prevention Plan resources, such as our “Food Fraud Reference Sheet.” We will expand our reports, training, and education to meet this need. FFI

For more education and training resources please see:

  • Food Fraud Business Executive Education Short Course
    • February 7-8-9*, 2017, MSU– OPEN REGISTRATION
    • July 18-19-20*, 2017, MSU (Tentative, based on FSMA & GFSI demand)
    • September 26-27-28*, 2017, MSU

*NOTE: The first day starts at 1pm and the last day ends at Noon for each of the above sessions. (This schedule allows for arriving the morning of the first day and returning home the third day.)

Course Brochure LINK

Registration: https://commerce.cashnet.com/msu_3794

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Food Fraud Initial Screening (FFIS) Vulnerability Workshop

    • February 9-10*, 2017, MSU – OPEN REGISTRATION
    • July 20-21*, 2017, MSU (Tentative, based on FSMA & GFSI demand)
    • September 28-29* 2017, MSU

*NOTE The first day starts at 1pm and the last day ends at Noon for each of the above sessions.  (This course is scheduled to follow the Food Fraud Business Executive Education course if you are attending both.)

Course Brochure LINK

Registration: https://commerce.cashnet.com/msu_3794

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John Spink
Dr. Spink has been focused on product fraud since the Michigan State University’s Food Safety Program and the School of Packaging began research on the topic in 2006. This work expanded to the behavioral sciences and criminology and led to the establishment of the Anti-Counterfeiting and Product Protection Initiative in 2008. In 2009 the work shifted to the School of Criminal Justice where the Initiative evolved into a Program.