As defined by Michigan State University, a collective term used to encompass the deliberate and intentional substitution, addition, tampering, or misrepresentation of food, food ingredients, feed, or food packaging and/or labelling, product information; or false or misleading statements made about a product for economic gain. It may also include gray market or stolen goods.
220.127.116.11 requires the site to identify their vulnerability to food fraud through all inputs including mislabeling, ingredient substitution and counterfeiting.
18.104.22.168 requires the site to mitigate identified vulnerabilities.
22.214.171.124 the site is to provide instruction on food fraud mitigation strategies which surely includes how to identify situations that poses a risk of food fraud and what actions to take when such risks are identified; receiving procedures; identifying approved suppliers; and access to raw materials, ingredients, labels, and finished product.
126.96.36.199 the site is to review annually the plan documentation to ensure all finished products, ingredients, labels, raw materials, and packaging are addressed by the plan and any product formulation changes whether internal or from suppliers are reviewed and addressed. The site will also want to review their technical resources, for example if an ingredient data base is used to be sure the information provided is current, complete, accurate, and provided in a timely manner. All records of these reviews are to be maintained.
2.7.2 This is a mandatory clause.
Ingredient substitution and deliberate misrepresentation of food for economic gain is far more prevalent than many realize. What may be thought as an innocent substitution – one white fish species for another - may cost the industry millions of dollars, jeopardize the environment, and could put allergic or intolerant consumers at risk for severe health issues.
A vulnerability assessment is the site’s first step. A list of all ingredients, raw materials, finished product, packaging, and labels serves as a guide. Many sites find the use of an ingredient database or government tracking website useful in identifying potential threats, but depending upon the site’s inputs and products, this is not always necessary. University and government resources are available, particularly if there is a regulation in the country of production or sale requiring a food fraud plan. Additionally, a threat assessment matrix may be used to categorize and rate each identified vulnerability.
The mitigation plan then specifies the methods by which the identified vulnerabilities are controlled. Determine which aspects of the supplier approval, site security, employee training, purchasing, receiving, storage and label control plans are adequate to manage the identified threats and strengthen the programs as necessary.
Due to the breadth of threats, employee training is likely to span all personnel, but verify what is appropriate for the site. The food fraud plan will be useful in identifying who needs to be trained and on what. Again, look to available resources from universities, government agencies and trusted experts for guidance.
Retain all program development, verification, training, and annual review records.
The following are examples of records and/or documents to assist in the implementation and review of this topic:
The following are examples of people to interview to assist in the implementation and review of this topic:
The following are examples of interview questions to ask to assist in the implementation and review of this topic:
The following are examples of observations to assist in the implementation and review of this topic:
Updated Date: 2021/04/01