Fraud prevention e tampering (willful tampering) fully enter in scheme FSSC 22000, for the certification of the system of food safety based on the standard ISO 22000:2005 and subsequent.
ISO 22000 and FSSC 22000, global standard and certification scheme for reference safety
ISO 22000:2005 represents the international reference standard for the development and continuous evolution of food safety management systems in organizations throughout the entire supply chain, from farm to fork o from stable to table.
The Board of GSFI (Global Food Safety Initiative) has recognized, for over a dozen years now, the suitability of this standard – properly integrated with the so-called PRPs (Pre-Requisites Programs, that is the GHPs, Good Hygienic Practices). Compared to the GFSI Guidelines, which express the updated synthesis of the various private certification schemes (e.g. IFS, BRC, SQF, Dutch Haccp).
The FSSC Foundation (Food Safety System Certification) was established with the precise purpose of developing a private certification scheme based on the international standard ISO 22000. This condition is essential to obtain formal recognition of equivalence with certification schemes such as IFS and BRC.
FSSC 22000, due to its purely technical nature and the continuous evolution of binding rules applied to the supply chain, it has therefore undergone several revisions. Its latest version, 4.1, dates back to 2017 and marked the milestone of 15,000 certificates worldwide.
FSSC 22000, Food Fraud Mitigation e Food Defense
Food Fraud Mitigation e Food Defense are the subject of specific guidelines, recently approved by Board of Stakeholder of the FSSC Foundation. (1) Strategic planning https://www.greatitalianfoodtrade.it/iso-22000/iso-22000-pianificazione – historically rooted in the so-called HACCP (Hazard Analyses and Critical Control Points) – thus considers specific risks that are particularly relevant.
Intentionality of the phenomenon associated with a food safety risk is what distinguishes fraud and tampering (tampering) compared to hazards – accidental or otherwise unintentional – traditionally considered in self-monitoring. The hazards considered are actually the same: physical contamination (e.g., allergens), chemical (e.g., pesticide residues), or microbiological (e.g., pathogenic bacteria).
Food Fraud Mitigation e Food Defense
However, while addressing the same basic hazards studied in HACCP, they aim to prevent intentional adulterations. That is, those arising from the criminal intent to corrupt the food.
And it is precisely the motivation that distinguishes the areas of fraud prevention actions, on one hand, and tampering on the other. Two control strategies to tackle different threats.
Food fraud prevention, Food Fraud Mitigation
The prevention of fraud is essential to prevent deceit aimed at gaining unjust profits, which can be orchestrated upstream in the supply chain and/or within the organization itself.
Fraud in trade – punished in Italy by the penal code, article 515 and following – can be carried out on branded products (IdM, Brand Industry), as well as on private label products (MDD, Distributor Brand, or private label), on goods sold loose and pre-packaged items, as well as on raw materials, ingredients, and additives, as well as materials and objects intended for contact with food.
The concept of 'food fraud' – to date lacking a shared definition at EU level – is derived from the notion developed within the GFSI framework:
‘Food Fraud is the collective term encompassing the intentional substitution, addition, tampering or misrepresentation of food/feed, food/feed ingredients or food/feed packaging, labelling, product information or false or misleading statements made about a product for economic gain that could impact consumer health’ (GFSI BRv7:2017).
A ‘Food Fraud Mitigation Team’ should be established and formed at every organization. In particular, within organized large-scale retail chains (GDO). A team of professionals with multidisciplinary skills, for example in legal and regulatory fields, purchasing, safety and quality, research and development, production, marketing.
All areas of possible vulnerabilities (Vulnerabilities) must be identified and reviewed. In view of defining appropriate control measures, to be submitted to audits and reviews. Keeping in mind that every fraudulent act is motivated by the aim to pursue illicit profit. At the organizational level – due to inconsistency between the policy corporate and operational procedures, or in any case problems of governance – or of individual persons, possibly associated in a pactum sceleris.
Prevention tampering, Food Defense
The Food Defense is the process aimed at preventing adulterations motivated by ideological factors whose ultimate goal is to cause harm to the organization or the community.
Also in this case, every organization should establish a dedicated team. The ‘Food Defense Team, which in turn is able to gather multidisciplinary skills including human resources and IT systems managers, facility managers. Without neglecting the expertise of external consultants.
All possible threats (Threats) – understood not only as external factors but also internal ones (e.g. organizational climate) and define the priorities of control measures (on site, equipment, and aspects of stakeholder relations).
For further information on the topic the free ebook ‘Food Safety, between current rules and voluntary standards’, by the author, at https://www.greatitalianfoodtrade.it/libri/sicurezza-alimentare-regole-cogenti-e-norme-volontarie-il-nuovo-libro-di-dario-dongo
Dario Dongo
Notes
(1) The FSSC 10.4.18 guidelines on Food Fraud Mitigation and Food Defense are available at the link https://www.fssc.com/wp-content/uploads/fssc-22000-guidance-on-food-defense-final-100418.pdf
Dario Dongo, lawyer and journalist, PhD in international food law, founder of WIISE (FARE - GIFT – Food Times) and Égalité.
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