2015- GFSI, BRC, SQF and beyond where food safety is heading and packaging’s role in getting us there by Dr. Claire Sand

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, PackagingTechnology and Research
Adjunct Professor, Michigan State University
2015 Association of Dressings and SaucesTechnical 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
GFSI5

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: SQF8

Dominates in USA food packaging
GFSI: SQF9
(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: IFS12
(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: 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 globally
GFSI: assessment17
(17)

Salmonella declined 38% in EU
(18)
Salmonella declined 38% in EU since 2008
GFSI: assessment18

Food safety continues to be an issue
GFSI: 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 lower
GFSI: 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

• 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

• 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

• 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
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
IntentionalUnintentional
Harm
Public Health,
Economic, or
Terror
FOOD
DEFENSE
FOOD
SAFETY
EconomicFOOD
FRAUD
FOOD
QUALITY
Food fraud-what’s now
Motivation
33
(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 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 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

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 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
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

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 frau53

Add packaging to FSMA now
• Establish supplier testing
protocol
• Extraction for food contact (15)
• EU guidelines (14)
• Complete traceability
• Lots, lines, location, transport,
storage
Refocus to address food & packaging fraud54

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
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
challenge
62

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
challenge
63

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
challenge
64

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
challenge
65

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
challenge
66

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
challenge
67

Expand the value chain
• Minimal links to externals that address value
challenge
68
(22)3

• Create links that are meaningful safety and fraud
Expand the value chain
challenge
69
(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
challenge
70

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
challenge
71

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
challenge
72

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
challenge
73

Value chain holds in a vuca world
• Volatile
• Dynamics of change
• Catalysts
• Uncertain
• Missing predictability
• Complex
• Chaos slightly at bay
• Ambiguous
• Hazy reality
• Misreads
challenge
74

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

2015- GFSI, BRC, SQF and beyond where food safety is heading and packaging’s role in getting us there by Dr. Claire Sand

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2015- GFSI, BRC, SQF and beyond where food safety is heading and packaging’s role in getting us there by Dr. Claire Sand