gfsi, brc, sqf and beyond where food safety is heading and packaging’s role in getting us there by...

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

Agenda1. 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

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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

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GFSI continues to be relevant2000

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

worldwide”

2007

2015Version 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 Australia2000

Food Marketing Institute (FMI)

2004GFSI approved at level 2 2014

3 unannounced audits

GFSI: SQF8

Dominates in USA food packaging

GFSI: SQF9

(23)

Gaining ground in USAGFSI: BRC

22,000 certified suppliers in 123 countries

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(24)

FSSC 22000 Ideal if prior certified ISO 22000

9000+ organizations in 146 countries

GFSI: FSSC 22000

PAS 220

ISO 2200

0

FSSC 2200

0=+

11

IFS often linked with BRCGFSI: IFS12

(25)





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How are we doing?

Goals were to: Harmonize worldwide food safety standards

Increase transparency

Improve supply chain efficiency

Cut costs for manufacturers

GFSI: assessment14

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: assessment15

Food safety declined for G20 in 2014

(17)

GFSI: assessment16

Food safety up and down globallyGFSI: assessment17

(17)

Salmonella declined 38% in EU

(18)

Salmonella declined 38% in EU since 2008

GFSI: assessment18

Food safety continues to be an issueGFSI: assessment19

2 classes of foods more discernable

(17)

GFSI: assessment20

2 classes of foods more discernable

GFSI: assessment21

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: assessment22

Manufacturer costs may be lowerGFSI: assessment23

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: assessment24

GFSI: status

Dressings & sauces - positive results from GFSI• 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: assessment26

Recent cases• Hummus• Ice cream• Peanuts• Ingredients

Dressings & sauces - positive results from GFSI

• 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: assessment27

Dressings & sauces - positive results from GFSI• Consolidation decreased sourcing options• Food safety to more equal footing for large and small

manufacturers• Focused food and packaging industries

GFSI: assessment28

(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: assessment29

• Complexities in abundance

• GFSI will have a positive long term impact

GFSI: assessment

Net: GFSI is working but much more to do

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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

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Food fraud is economically motivated (EMA)

ActionIntentionalUnintentional

HarmPublic Health, Economic, or

Terror

FOOD DEFENSE

FOOD SAFETY

Economic FOOD FRAUD

FOOD QUALITY

Food fraud-what’s now

Mot

ivat

ion

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(27)

Food fraud prevalence increasing•Global Food fraud ~ $50 billion (3)•10% US food adulterated (4)

Food fraud-what’s now34

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 factorsFood 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 exampleDeliberate 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

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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 now42

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 now43





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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

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Embrace GFSI version 7Begins to address food fraud


GMA

FSMA

ISO TC 247

Food Chemicals Codex

EP/EU Resolution and Interpol

Corporate Processes and systems6 sigma and Enterprise Risk

Management

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Support whistle blowingWhistle blowing most frequent ID of fraud

Refocus to address food fraud47

(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 CONTR

OLS.• 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

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















Implement FSMA’s expanded HACCPHACCP 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 VAVulnerability 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 VAVulnerability • 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


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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 fraud53

Add packaging to FSMA 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 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 VAAssess package innovations on prevention prevention & predictionCovert 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)





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Need value chain as an operational solution

raw materials for packaging

converted packaging

manufacturedpackagingcomponents

Combinedproduct andpackage

distributedproduct and package

soldproduct and package

discardedproduct and package

Food Packagin

gValue 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

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(30)

Technology & regulations offer partial solutions

• Technology offers temporary solutions

• Regulations offer inflexible solution

• Value chain offers operational solution linking food and packaging


Regulations

Technology

To increase food safety and decrease fraud:

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Valu

e ch

ain

Connect tangibly within value chainUse 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


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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


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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


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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


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Shared values link with fraud and safetyIncreasing 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


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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


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Expand the value chain • Minimal links to externals that address value


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(22)3

• Create links that are meaningful safety and fraudExpand the value chain


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(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


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Value chain to improve microbial safety - example

5. Review & Adjust

1. Identify Hazard 2. Understand

Cause

3. Implement Preventive Controls4. Monitor

Effectiveness4. Monitor Effectiveness

Expand knowledge base: lack of clean water sources on manufacturing site and in homes

Expand Knowledge base:water borne contaminationpackage 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


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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


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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


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Value chain holds in a vuca world• Volatile • Dynamics of change• Catalysts

• Uncertain • Missing predictability

• Complex• Chaos slightly at bay

• Ambiguous • Hazy reality• Misreads


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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)

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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, 519-5272. 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: 84–944. NSF, 2014. The ‘new’ phenomenon of criminal fraud in the food supply chain White Paper.5. 2014-07-21 08:11 Shanghai Daily Web Editor6. 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 Initiative8. 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: 839–8669. Percy, B., 2011. GFSI Compliance and Automated Food Safety Management Systems. Cereal Foods World. 56, 4; pg. 14410. 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 Defense12. 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 Guardian14 http://ec.europa.eu/food/food/chemicalsafety/foodcontact/eu_legisl_en.htm

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15.http://www.fda.gov/Food/GuidanceRegulation/GuidanceDocumentsRegulatoryInformation/IngredientsAdditivesGR ASPackaging/ucm081818.htm16. 2013 survey by public relations agency Edelman17. 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):399119. 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: 569e57621. Mensah, L.D., Julien, D. 2011. Implementation of food safety management systems in the UK. Food Control 22 1216e122522. 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.com26. http://www.informationclearinghouse.info/article36743.htm27. 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.

Relevant Sources and References

http://www.fda.gov/Food/GuidanceRegulation/GuidanceDocumentsRegulatoryInformation/IngredientsAdditivesGR%20ASPackaging/ucm081818.htm





http://foodsecurityindex.eiu.com/

http://www.brcglobalstandards.com/

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

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