Fraud prevention e tampering (wilful tampering) fully fall within the scope of scheme FSSC 22000, for the certification of the system of food safety based on the standard ISO 22000:2005 and subsequent versions.
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 within 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 about a dozen years now, the suitability of this standard – properly integrated with the so-called PRPs (Pre-Requisites Programs, that is GHPs, Good Hygienic Practices). Compared to GFSI Guidelines, which represent 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 for the precise purpose of developing a private certification scheme based on the international standard ISO 22000. This is an essential condition 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 mandatory 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 globally.
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 risk to food safety is what distinguishes fraud and tampering (tampering) from 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. Those that arise from the criminal intent to corrupt the food.
And it is precisely the motive that distinguishes the fields of fraud prevention actions, on one side, and tampering on the other. Two control strategies to face different threats.
Food fraud prevention, Food Fraud Mitigation
The prevention of fraud food is essential to prevent deceit aimed at gaining unjust profits. These may be schemed upstream in the supply chain and/or within the organization itself.
Fraud in commerce – punished in Italy by the penal code, article 515 and following – can be carried out on IdM (Brand Industry) products, as well as on MDD (Distributor Brand, or private label), on goods sold in bulk and pre-packaging. As well as on raw materials, ingredients and additives, as well as on materials and objects intended to come into contact with food.
The concept of 'food fraud' – to date lacking a shared definition at EU level – derived from the notion developed within GFSI:
‘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 within every organization. In particular, within the large organized 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. With a view to defining appropriate control measures to be subjected to audits and reviews. Keeping in mind that every fraudulent act is motivated by the objective of pursuing unlawful profit. At the organizational level – due to inconsistency between the policies 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’, in turn able to gather multidisciplinary skills including human resources and IT system managers, facility managers. Not overlooking the expertise of external consultants.
All possible threats (Threats) – intended not only as external factors but also internal ones (e.g. organizational climate) and define the priorities of control measures (on site, equipment and stakeholder relationship aspects).
For further information on the subject, the free ebook ‘Food Safety, between current regulations 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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