Although food defense has been required in various standards, such as IFS Food or BRC, for some time, ambiguities continue to arise in the approach and implementation. The issue of food fraud is also likely to pose challenges for many quality managers. Dr. Georg Sulzer, DQS auditor and expert for food defense and food fraud, reveals what is important for practical implementation.

Dr. Sulzer, at the GFSI level, the requirements regarding food fraud and food authenticity are being hotly debated right now. What consequences could this have for the GFSI-recognized standards?

Dr. Sulzer: Unfortunately, the topic of food adulteration is not new.

Food scandals in recent years have brought the issue of food authenticity to the forefront and into the consciousness of consumers. Recognizing food adulteration or fraud or ensuring the authenticity of food is therefore particularly important. Due to the increased economic pressure on manufacturers and their suppliers, the pressure and, if necessary, the motivation to carry out manipulations and adulterations in the area of raw materials and products is naturally also increasing. The terms "EMA" (Economically motivated adulteration) or Food Fraud summarize this phenomenon.

Complete traceability and verification of the authenticity of food products play a key role in the detection and prevention of such manipulations and adulterations. In addition to existing international standards on this subject (ISO 12931:2012), it is already becoming apparent that GFSI-recognized standards will in future demand requirements on the procedures for preventing counterfeiting and ensuring the authenticity of raw materials, foodstuffs and their packaging in order to be able to counter this growing trend with the right tools.

Authenticity plays an important role in the new version of the BRC Food Standard. What will change specifically for certified sites?

Dr. Sulzer: The new standard version specifically requires a system to minimize the purchase of adulterated raw materials. In addition, it must be ensured that all descriptions and claims of a product are legally compliant, correct and verified. This means that in the future it will no longer be sufficient to believe all declarations and claims, but it must always be possible to verify and prove their accuracy.

This will require increased efforts on the part of both the buyer and the supplier to provide and manage the necessary evidence. Mere labeling of properties without additional proof or evidence of their authenticity and correctness will no longer be sufficient. The extent to which this can and must be analytically proven for practical reasons remains to be seen in the application of the new requirements.

Food defense requirements have been mandatory since the publication of IFS Food Standard Version 6 at the latest. How mature have food defense systems become in, for example Germany, in the meantime?

Dr. Sulzer: Of course, all certified standards are equipped with food defense systems, since the relevant standards (IFS, BRC, FSSC 22000) contain corresponding requirements and the initially granted grace periods for food defense requirements have expired.

However, there are very large differences in the methods used and the depth and meaningfulness of the food defense systems introduced. The range here extends from very well-structured, sophisticated and effective systems to token systems that demonstrate neither a correct understanding of food defense nor a correct application of the procedures and, above all, do not take the concerns fully and comprehensively into account. Unfortunately, not only do many companies still struggle with understanding food defense and implementation, but auditors do as well.

There is still a lot of room for improvement in the design of systems as well as in the choice of methods, the systematics, the vulnerability assessment and especially in the completeness as well as the implementation of Food Defense measures.

The core of any food defense system is the threat analysis. What tools do you recommend companies use to conduct the threat analysis in a structured and systematic way?

Dr. Sulzer: There are a number of different procedures and approaches for hazard analysis. All of these procedures have advantages and disadvantages and may be more or less suitable for one company or another. Basically, almost any risk analysis procedure and risk assessment process can be used. The CARVER+Shock procedure initially developed by the US authorities has proven to be impractical. This is impressively proven by the fact that the U.S. authorities have approved the so-called Food Defense Plan Builder (FDPB) as a more practical instrument and made it available to the public.

The application of the TACCP procedure usually fails due to its proximity to the HACCP concept and the therefore often insufficient delimitation to hygiene and food defense relevant issues. Good results can only be achieved with the help of FMEA if it is applied by employees who have a good command of the instrument, and a good picture of the comprehensive system.

Simple chart procedures with the help of pre-structured work steps and checklists have proven to be very useful and also easy to handle. Here, the basis can be the checklists published by the German Federal Institute for Risk Assessment (BFR) or the FDA checklists and guidance documents can serve well as a basis.

Regardless of the method used, it is crucial for a successful food defense system in any case that the system is well structured and complete. An access control system or a locking system may be an important part of a food defense system, but it does not make a complete system.

Dr. Sulzer, thank you for the interview.

Dr. Georg Sulzer is DQS auditor and owner of an engineering office for management systems in the food sector (quality, food safety, environment, occupational health and safety, energy management). His main activities are consulting, education, training and auditing as well as expert activities of ö.b.u.v. experts. He has written two books on food defense and is working as an expert for the EU Commission on the preparation of an environmental guide for the food industry.

Dr. Thijs Willaert

In this role, he is responsible for the entire ESG service portfolio of DQS. His areas of interest include sustainable procurement, human rights, due diligence, and ESG audits.


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