gfsi, brc, sqf and beyond: where food safety is heading ... · gfsi, brc, sqf and beyond: where...

GFSI, BRC, SQF and beyond: Where food safety is

heading and packaging’s role in getting us there

Dr. Claire Koelsch Sand

Founder and Owner, Packaging Technology and Research

Adjunct Professor, Michigan State University

2015 Association of Dressings and Sauces Technical Meeting

Agenda

1. What are we doing and why ?

• GFSI’s meaningful role in packaged food

2. How are we doing?

• GFSI assessment

3. What do we need to do now?

• Address Food and packaging fraud

4. How can we do this?

• Refocus to address food & packaging fraud

• Align value chain to address fraud & next challenge

2

Acknowledgements

• Dr. Ted Labuza

• Department of Food Science and Nutrition University of Minnesota

• Dr. Tonya Schoenfuss

• Department of Food Science and Nutrition University of Minnesota

• Dr. John Spink

• Director of Food Fraud Initiative Michigan State University

3

Agenda




• GFSI assessment






4

GFSI continues to be relevant

2000

“continuous improvement in food safety management systems and ensure confidence in the delivery of safe food to consumers worldwide

2007

2015 Version 7 launches

GFSI 5

GFSI: harmony, transparency efficiency, save $

Goals

• harmonize worldwide food safety standards

• increase transparency

• efficiency in the supply chain

• cut costs for manufacturers

GFSI goals

Best

Practices

GFSI Schemes

ISO 22000

Food Laws and Regulations

Codex – HACCP - GMP

6

GFSI: certifiers

British Retail Consortium

Food Safety System 22000 International Food Standard

Safe Quality Food

7

Dominates in USA food packaging

1994

developed in Australia

2000

Food Marketing Institute (FMI)

2004

GFSI approved at level 2

2014

3 unannounced audits

GFSI: SQF 8

Dominates in USA food packaging

GFSI: SQF 9

(23)

Gaining ground in USA

GFSI: BRC

22,000 certified suppliers in 123 countries

10

(24)

FSSC 22000 Ideal if prior certified ISO 22000

9000+ organizations in 146 countries

GFSI: FSSC 22000

PAS

220

ISO

22000

FSSC

22000 = +

11

IFS often linked with BRC

GFSI: IFS 12

(25)

Agenda




• GFSI assessment






13

How are we doing?

Goals were to:

Harmonize worldwide food safety standards

Increase transparency

Improve supply chain efficiency

Cut costs for manufacturers

GFSI: assessment 14

Food safety standardized

• Standards and holistic approaches guide industry

• Food safety on radar

• Increase in budgets

• Combine food safety into HHS

• Food safety now has a common language

• Import knowledge and transparency demands are up

GFSI: assessment 15

Food safety declined for G20 in 2014

(17)

GFSI: assessment 16

Food safety up and down globally

GFSI: assessment 17

(17)

Salmonella declined 38% in EU

(18)

Salmonella declined 38% in EU since 2008

GFSI: assessment 18

Food safety continues to be an issue

GFSI: assessment 19

2 classes of foods more discernable

(17)

GFSI: assessment 20

2 classes of foods more discernable

GFSI: assessment 21

Supply chains and manufacturing efficiencies

not realized - yet

• Motivation to pursue GFSI:

• 70% to meet customer requirements

• 30% to pursue GFSI to address food safety

• Company audits take resources and time:

• 80% companies see no reduction in company audits

• Suppliers now need to comply with unannounced SQF and

company audits

• Small players bear proportionally higher costs to be GFSI

certified

GFSI: assessment 22

Manufacturer costs may be lower

GFSI: assessment 23

Dressings & sauces - positive results from GFSI

• Dressings and Sauces are a unique packaged product

• Lower inherent food safety risk

• Packaging consistency making packaging COC tenuous

• Multiple ingredients sources increases risk

• Packing frequency creates sourcing challenges

• Shelf life and oil present issue for unintended migration from packaging

GFSI: assessment 24

GFSI: status


• Outbreaks threaten stability

• Consume time and resources

• Shift company focus

• Impact of prevented outbreaks

cannot be measured

• Industry connected by skus and

brands

• Liability and legality

GFSI: assessment 26


• Audits not equal

• 3rd party audits not all equal • FSMA section 307 will equalize

• Pass rates on company audits likely higher

• FSMA implementation for GFSI complaint food manufacturers and

packaging suppliers much smoother

GFSI: assessment 27


• Consolidation decreased sourcing options

• Food safety to more equal footing for large and small manufacturers

• Focused food and packaging industries

GFSI: assessment 28

(26)

Net: GFSI is working but much more to do

• Industry

• Food industry doing what needs to be done for food safety

• Increased realization on bad apples

• Packaging suppliers can do more

• Smaller companies benefit most

• Food safety is a strategic advantage

“Foodborne diseases impede socioeconomic development by straining

health care systems and harming national economies, tourism and

trade. Food supply chains now cross multiple national borders.” (WHO)

GFSI: assessment 29

• Complexities in abundance

• GFSI will have a positive long term impact

GFSI: assessment

Net: GFSI is working but much more to do

30

Agenda




• GFSI assessment






31

Refocus on food fraud and what is next

• Refocus to address food and packaging fraud

• Align value chain to address fraud and then to meet next

challenge

32

Food fraud is economically motivated (EMA)

Action

Intentional Unintentional

Harm

Public Health,

Economic, or

Terror

FOOD

DEFENSE

FOOD

SAFETY

Economic

FOOD

FRAUD

FOOD

QUALITY

Food fraud-what’s now

Mo

tiva

tio

n

33

(27)

Food fraud prevalence increasing

• Global Food fraud ~ $50 billion (3)

• 10% US food adulterated (4)

Food fraud-what’s now 34

Food fraud prevalence increasing

• 10 of 117 countries are responsible for 60% of all food fraud

Current food of concern

• Seafood: • "Sturgeon caviar" was MS paddlefish

• Catfish fillets replaced expensive fish

• 77% of USA snapper mislabeled

• Cumin

• Honey diluted with beets or corn syrup

• Protein source products

• Olive oil

• Coffee

• Tea

• Wine: Pinot Noir from merlot & syrah grapes

Current packaging of concern

• Recycled paperboard

• PP

• RPET

• Laminate layers


Food fraud increase due to 3 main factors

Food fraud increase is due to:

Consolidated buying that enables:

• Focus on lowest ingredient costs that tempts fraud

• Technology to covertly transact illegitimate deals

• Impedes traceability

Unharmonious regulations

• Lack of enforced processing regulations in much of world

• GMO to produce bioplastics

Increase refrigerated distribution for long-term perishables

• Increased need for and rising cost of product stability

• Increased value of food


Impacts of food fraud

• Declining public trust in packaged food

• Loss of country of origin business

• Increased funds for further fraud

• Loss of brand value

• Companies become enforcers


Food fraud varies

(7, 12)


Food fraud example

Deliberate intent by senior management to deceive customers was

Adulteration & Tampering (5)

1. “Acceptable” mix ratios defined within a manual

• Mixing expired meat with fresh meat

• Mixing chicken skin with breast meat

2. Cunning was a source of pride

• Concealing suspect stock from quality inspectors

• Altering expiration dates

3. Quality control department recorded fraudulent practices

• Dual sets of records kept

– one for the inspectors and one for company


Tortuous Meat fraud

(13)


Food packaging fraud also economically motivated

Packaging fraud-what’s now

Highly competitive and industry

• Competitive converters have same suppliers

• Long term contracts

• Raw material prices flux

Goals not align with customer

• “Meet” environmental goals

• Shelf life and migration data not obtainable

Manufacturing efficiencies

• Long material runs

• Substitute materials

• Additives to speed up production

• Temptation to expand tolerances

41

PET viable to fraud

• Replace RPET with PET as prices fluctuate

• Lack of harmonization on food contact

• EU position paper - food contact RPET if <5% of RPET non-food sources

• RPET COC unsteady

• RPET demand exceeds supply

• RPET vs PET discernable by DSC

Packaging fraud-what’s now 42

Dressings & sauces packaging vulnerability

• Understanding motivation is key

• Profit

• No punishment

• Low risk

• Consistent packaging COC

• Long shelf life

• Infrequent and established pack dates

• Similar to OTC medicine

• Complexities of ingredient hamper:

• Tracing

• Knowledge of fraud (melamine example)

Packaging fraud-what’s now 43

Agenda




• GFSI assessment






44

How to Refocus and address food fraud

1. Embrace GFSI version 7

2. Implement FSMA

3. Add FSMA packaging elements

4. Focus packaging innovation on

prevention and prediction

Refocus to address food fraud

detection & mitigation prediction & prevention

45

Embrace GFSI version 7

Begins to address food fraud


GMA

FSMA

ISO TC 247

Food Chemicals Codex

EP/EU Resolution and Interpol

Corporate Processes and systems

6 sigma and Enterprise Risk Management

46

Support whistle blowing

Whistle blowing most frequent ID of fraud

Refocus to address food fraud 47

(28)

Implement FSMA • New Focus on prevention in:

• SEC 101. INSPECTIONS OF RECORDS.

• SEC 102. REGISTRATION OF FOOD FACILITIES.

• SEC 103. HAZARD ANALYSIS AND RISK-BASED PREVENTIVE CONTROLS.

• SEC 104. PERFORMANCE STANDARDS.

• SEC 105. STANDARDS FOR PRODUCE SAFETY.

• SEC 106. PROTECTION AGAINST INTENTIONAL ADULTERATION.

• SEC 108. NATIONAL AGRICULTURE AND FOOD DEFENSE STRATEGY.

• SEC 109. FOOD AND AGRICULTURE COORDINATING COUNCILS.

• SEC 110. BUILDING DOMESTIC CAPACITY.

• SEC 111. SANITARY TRANSPORTATION OF FOOD.

• SEC 112. FOOD ALLERGY AND ANAPHYLAXIS MANAGEMENT.

• SEC 115. PORT SHOPPING.


• Fraud direction pending

48

http://www.fda.gov/Food/GuidanceRegulation/FSMA/ssLINK/ucm247548.htm#SEC101
















Implement FSMA’s expanded HACCP

HACCP is adaptable to thwart food fraud

5. Review &

Adjust

1. Identify Hazard 2. Understand

Cause

3. Implement

Preventive

Controls

4. Monitor

Effectiveness


Use FSMA’s VA

Vulnerability Assessment focuses efforts with attention to motive

Criticality

• Measure of public health & economic impacts of an attack

Accessibility

• Ability to physically access and egress

from target

Recuperability

• Ability of system to recover from an attack


Use FSMA’s VA

Vulnerability

• Ease of accomplishing attack

Effect

• Measured by loss in production

Recognizability

• Ease of identifying target

Shock

• Combined health, economic and

psychological impacts of an attack


Use same solutions for packaging & food fraud

Refocus to address food & packaging fraud


52

Add packaging to FSMA

• Perform risk analysis

• Biopolymers derived contaminants – plant fibers and allergens

• Conversion process – laminations, coextrusions

• Effect of post package processing - Irradiation/HPP

• Extraction protocol

• Reassess packaging specifications

• Tight and too loose windows

• Identify critical aspects to fraud

Refocus to address food & packaging fraud 53


Add packaging to FSMA now

• Establish supplier testing

protocol

• Extraction for food contact (15)

• EU guidelines (14)

• Complete traceability

• Lots, lines, location, transport,

storage



Add packaging to FSMA now

• Emphasis on material documentation

• Documentation and recall linked to packaging

• Minimize the damaging effects to human health and brand reputation

• Consider changes that alter dynamics

• Supplier financial pressure

• Price fluctuations

• Disasters

• Global strife and success


Packaging innovation for prevention & prediction

• Begin tracking packaging before food is packaged

• Address diversion

• Selective monitoring

• Load monitoring



Use packaging prevent & predict after VA

• Assess innovations on prevention & prediction

• Overt is a deterrent and prevention

RFID

Coded track and trace Integrated with tamper evidency


Use packaging prevent & predict after VA

Assess package innovations on prevention prevention & prediction

Covert is less of a deterrent and more of detection

Combine covert selectively to verify overt

• Steganography

• Digital watermarks

• Coatings and hidden marks

• Covert RFID


(29)

Agenda




• GFSI assessment






59

Need value chain as an operational solution

raw materials for

packaging

converted

packaging

manufactured

packaging

components

Combined

product and

package

distributed

product and

package

sold

product and

package

discarded

product and

package

Food

Packaging

Value

Chain

Interfaces

• Beyond food safety and food

fraud there are quality and

defense and other challenges

• Need robust system to address

all challenges

• Food packaging value chain

aligns to meet challenges

• Link of food and packaging is

critical

Align value chain to address fraud & next challenge 60

(30)

Technology & regulations offer partial solutions

• Technology offers

temporary solutions

• Regulations offer

inflexible solution

• Value chain offers

operational solution

linking food and

packaging

Align value chain to address fraud & next challenge

Technology

To increase food safety and decrease fraud:

61

Connect tangibly within value chain

Use value chain to connect food safety and food fraud to packaging

by:

1. Inspiring

2. Building tactic knowledge

3. Sharing work and value

4. Rewarding significance


Build tactic knowledge and trust within value chain

• Knowledge means value is understood

• Build tactic knowledge with food and package suppliers

• Expand existing initiatives with safety and fraud focus

• Link on goal of decreasing fraud and increasing safety

• Build knowledge at all levels

• Build trust at all levels

• Build operational processes to align and transfer knowledge that

thwart fraud and increase safety


Lack of trust is an expensive way to run a business

• 85 % of consumers do not trust the words spoken by a corporate

executive (16)

• Many consumers are executives

• Employees and management conduct or are complicit in:

• Poor food safety practices

• Intentional food fraud

• Safety and fraud are often money driven and relate to poor ethics


Share value in an expanded value chain

• Shared value links societal issues (safety and fraud) to business

needs

• Expand partners to increase value of working relationships

• To address food safety and fraud now

• To address next issue


Shared values link with fraud and safety

Increasing food safety and decreasing food fraud relate to many

concerns:

• Decreased unsaleables

• Reduced product diversion and counterfeiting

• Tighter chain of custody

• Reduced out-of-stocks

• Brand erosion

• Environment

• Product utility


Reward significance within value chain

• Food ingredient and packaging suppliers can not sustain and or

improve safety and address fraud if:

• Focus is solely on price

• Product is commoditized

• They are marginalized

• Just as our brands cannot

• Link rewards to prevention and protection of fraud and food safety

• Provide economic incentive to traceability and COC


Expand the value chain

• Minimal links to externals that address value


(22)3

• Create links that are meaningful safety and fraud

Expand the value chain


(22)

Value chain to improve microbial safety -example

• Situation: Product microbial level so high HPP/irradiation can not

reduce it effectively

• Need to address problem for this plant and others

• Focus on prevention and protection


Value chain to improve microbial safety - example

5. Review

& Adjust

1. Identify

Hazard 2. Understand

Cause

3. Implement

Preventive

Controls

4.

Effectiveness

4. Monitor

Effectiveness

Expand knowledge base:

lack of clean water sources

on manufacturing site and

in homes

Expand Knowledge base:

water borne contamination

package seals not consistent

Share work: design an provide clean

water sources for homes and

manufacturing, address tactic knowledge

on washing, manufacturing HACCP, water

testing Share work: Track and stress test

Reward significance:

refined relationship with

suppliers anchored on

safety


Value chain to reduce recalls – tactical example

• Situation: Costly recalls due to repeated

product off-flavors

• Focus away from detection and mitigation to

prevention and protection


Value chain to reduce recalls – tactical example

• Already had COC tactic links with suppliers for sourcing,

tracking processes, verification, recall processes

• Expanded knowledge:

• Product contaminated from package

• Shared work:

• Link migration data to supplier’s converters

• Expanded value chain connected on final product use

and sensitive flavor profile

• Converter financials and motivation

• Prevention vs detection


Value chain holds in a vuca world

• Volatile

• Dynamics of change

• Catalysts

• Uncertain

• Missing predictability

• Complex

• Chaos slightly at bay

• Ambiguous

• Hazy reality

• Misreads


Agenda




• GFSI assessment






75

Checklist

Insist upon GFSI Version 7 compliance

Implement FSMA with packaging initiatives

Forecast vulnerability

Assess packaging technology with focus on prevention & prediction

Refine and develop operational solutions

Connect food and packaging within the Value Chain

Continue to expand issue to pervade relationships within the value chain

Build trust and align to deliver meaningful packaging innovation

Expand to connect with NCFPD and FFI

Share value and work

Consider food safety and fraud as a social issue

Identify key and critical packaging and food suppliers

Develop shared library (ingredients and audit information)

76

Relevant Sources and References

• Food Fraud Initiative at Michigan State University

• National Center for Food Protection and Defense (NCFPD) at University of Minnesota

1. Lupien, J., 1997. Food packaging, international standards related to food safety and quality, and trade. Food Additives and

Contaminants, Vol. 14, No. 6-7, 519-527

2. Sand, C.K. 2015. Bringing in Innovation with the Packaging Value Chain. IFT Webcast February 26, 2015.

3. José Cuesta, J., Htenas, A., and Tiwari, S., 2014. Monitoring global and national food price crises. Food Policy 49: 84–94

4. NSF, 2014. The ‘new’ phenomenon of criminal fraud in the food supply chain White Paper.

5. 2014-07-21 08:11 Shanghai Daily Web Editor

6. Brody, A, Sand, C. Sabbagha, F., 2014. RFID in Packaging using Value Chain. Food Technology. October

7. Spink, J. and Moyer, D., 2011. Developing a Food Fraud Prevention Program. MSU Food Fraud Initiative

8. Reig, C., Lopez,A.D., Ramos, M.H., Ballester, V., 2014. Nanomaterials: a Map for Their Selection in Food Packaging

Applications. Packag. Technol. Sci. 27: 839–866

9. Percy, B., 2011. GFSI Compliance and Automated Food Safety Management Systems.

Cereal Foods World. 56, 4; pg. 144

10. Busta, F., 2011. Defending the safety of the global food system from intentional contamination. National Center for Food

Protection and Defense. University of Mn.

11. National Center for Food Protection and Defense

12. Spink, J. and Moyer, D., 2011. Defining the Public Health Threat of Food Fraud. Journal of Food Science Vol. 76, Nr. 9,

13. adapted from Guardian

14 http://ec.europa.eu/food/food/chemicalsafety/foodcontact/eu_legisl_en.htm

77

15.http://www.fda.gov/Food/GuidanceRegulation/GuidanceDocumentsRegulatoryInformation/IngredientsAdditivesGR

ASPackaging/ucm081818.htm

16. 2013 survey by public relations agency Edelman

17. http://foodsecurityindex.eiu.com/

18. The European Union summary report on trends and sources of zoonoses, zoonotic agents and food-borne outbreaks in

2013. 2015. European Food Safety Authority & European Centre for Disease Prevention and Control. EFSA Journal

2015;13(1):3991

19. Consumer Product Fraud: Deterrence and Detection. AT Kerney, 2010.

20. Chen, E., Flint, S., Perry, P., Perry, M., and Lau, R., 2015. Implementation of non-regulatory food safety management

schemes in New Zealand: A survey of the food and beverage industry. Food Control 47: 569e576

21. Mensah, L.D., Julien, D. 2011. Implementation of food safety management systems in the UK. Food Control 22

1216e1225

22. Exploring new values and new directions in the Forest, Paper & Packaging industry., 2011. PWC.

24. http://www.brcglobalstandards.com/

25. http://www.ifs-certification.com/index.php/en/

23. SQFI.com

26. http://www.informationclearinghouse.info/article36743.htm

27. Spink, J., 2006, The Counterfeit Food and Beverage Threat, Association of Food and Drug Officials (AFDO), Annual

Meeting.

28. ACFE, 2012. Report to the Nations.

29. US Patent 8,674,834,132.

30. Sand, C., 2007. Packaging Value Chain. DesTech Publishing.

78

Relevant Sources and References

http://www.fda.gov/Food/GuidanceRegulation/GuidanceDocumentsRegulatoryInformation/IngredientsAdditivesGR ASPackaging/ucm081818.htm




http://foodsecurityindex.eiu.com/

http://www.brcglobalstandards.com/

http://www.ifs-certification.com/index.php/en/



http://www.informationclearinghouse.info/article36743.htm