Food Safety

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Fraud in the HACCP Requirement (2.7.1) and Product Authenticity (5.4)
From: Narongchai Yookittichai
8:38AM 4 August 2018
According to the new BRC GSFS Issue 8, 2.7.1 - Fraud shall be included in the Hazard Analysis. What is the difference between fraud in 2.7.1 and fraud in 5.4 Product Authenticity?
From: John Figgins
3:51PM 17 August 2018
The main reason for including fraud in the HACCP section (clause 2.7.1) is to remind everyone that a good HACCP will consider all product safety risks regardless of the source or origin of the risk. (A similar situation exists for malicious contamination which has been added to this cause and is also covered in section 4.2).
Whereas section 5.4 covers all forms of food fraud such as adulteration, dilution, substitution, etc. regardless of whether there is a food safety hazard or not.
Sites should consider the best way of completing these activities - it is not a requirement to complete fraud assessments twice. It is acceptable for all fraud issues to be covered in a vulnerability assessment and then the HACCP to refer to this information.


Similarly, some sites have asked whether food fraud (section 5.4) and food defence (section 4.2) can be completed as one activity or whether 2 separate plans are needed. The Standard allows either option providing that the site can demonstrate that all risks (ie all food fraud and all food defence) have been fully assessed and where necessary action taken to mitigate the identified risks. Personally, I would keep them as two separate activities, as they are both large activities, and treating them separately makes it easier to ensure everything is thoroughly covered, however, the Standard allows either approach. In either approach the auditor will be looking for evidence that all the risks have been considered and appropriate mitigation strategies introduced.
From: Matteo Sorrentino
7:08AM 5 August 2018


I believe
that the clause 5.4 is referred to a fraud analysis on raw material, like a
prerequisite, the statement of intent of clause is “… minimise the risk of
purchasing fraudulent or adulterated food raw materials…”


while in
2.7.1 must be detailed in what process step can be introduced the fraud hazard


 


I also
think that in 2.7 should serve to specify the unintentional fraud ( eg
conventional product instead Organic or POD), (because I do not think there is
anyone naive enough to show how he adulterate food), after all the HACCP manual
are inspected also by official authority, while in 5.4 detail the fraud
analysis of the raw material.



From: Jakkrit Vipatikom
3:28PM 5 August 2018
Milk and infant formula was contaminated with melamine ( Hazard )  in some country. That was some kind of impacts of this fraud. This risk could be concerned during HA in clause No 2.7.1 ,                                  In some case honey in some season of some area is high risk to be fraudulently adulterated with cheap syrups and water, Not food safety hazard, but impact to quality of your products. That s the case in clause 5.4
From: Matteo Sorrentino
7:07AM 5 August 2018


I believe
that the clause 5.4 is referred to a fraud analysis on raw material, like a
prerequisite, the statement of intent of clause is “… minimise the risk of
purchasing fraudulent or adulterated food raw materials…”


while in
2.7.1 must be detailed in what process step can be introduced the fraud hazard


 


I also
think that in 2.7 should serve to specify the unintentional fraud ( eg
conventional product instead Organic or POD), (because I do not think there is
anyone naive enough to show how he adulterate food), after all the HACCP manual
are inspected also by official authority, while in 5.4 detail the fraud
analysis of the raw material.



From: Matteo Sorrentino
7:06AM 5 August 2018


I believe
that the clause 5.4 is referred to a fraud analysis on raw material, like a
prerequisite, the statement of intent of clause is “… minimise the risk of
purchasing fraudulent or adulterated food raw materials…”


while in
2.7.1 must be detailed in what process step can be introduced the fraud hazard


 


I also
think that in 2.7 should serve to specify the unintentional fraud ( eg
conventional product instead Organic or POD), (because I do not think there is
anyone naive enough to show how he adulterate food), after all the HACCP manual
are inspected also by official authority, while in 5.4 detail the fraud
analysis of the raw material.



From: Jakkrit Vipatikom
6:31AM 5 August 2018
Statement of intent in Clause No 2 focus on only food safety as equivalent to Codex HACCP.  As Hazard defined in Glossary is agent of any type with the potential to cause "harm", so only food safety hazards  mentioned in this clause.  Fraudulent materials in clause 5.4 means fraudulent and intentional substitution , for the purpose of financial gain , by increasing apparent value of the product or reducing the cost of its production.   Authenticity of products means ensuring that all products sold or purchased are of the nature, substance and quality expected. This applies not just to product claims, but includes all products and raw materials with the assurance that they meet the specification.  
Employee Break Rooms
From: prichard
2:13PM 17 August 2018
Can anyone confirm the requirements for break rooms.  I have been to several shellfish processing plants and have been told that there needs to be two separate break rooms and employee entrances to the production plant (one break room for low risk areas and one for high risk areas employees).  I have gone through both Issue 7 and Issue 8 of the standard and do not see the requirement anywhere.
Glass Test Pieces
From: liz.orr@wgrant.com
7:01AM 30 July 2018
Does anyone know if there is somewhere that I could purchase glass test pieces? This is to test the air rinse process on a glass bottling line to validate that it can effectively remove glass contamination.
From: Matteo Sorrentino
10:07AM 1 August 2018
I suggest to use a cover glass of a microscope slide. Just take the precaution to paint it with a felt tip pen (blue)
From: liz.orr@wgrant.com
10:21AM 1 August 2018
Thank you for your response, we currently use coloured glass which is the same as is used in the process. We filter to make sure that there are no pieces smaller than 0.5mm, but have no other way to define size.
Glass Test Pieces
From: liz.orr@wgrant.com
7:00AM 30 July 2018
Does anyone know if there is somewhere that I could purchase glass test pieces? This is to test the air rinse process on a glass bottling line to validate that it can effectively remove glass contamination.