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

1. 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

2. 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

3. 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

5. 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

6. 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

7. GFSI: certifiers British Retail Consortium Food Safety System 22000 International Food Standard Safe Quality Food 7

8. 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

9. Dominates in USA food packaging GFSI: SQF9 (23)

10. Gaining ground in USA GFSI: BRC 22,000 certified suppliers in 123 countries 10 (24)

11. FSSC 22000 Ideal if prior certified ISO 22000 9000+ organizations in 146 countries GFSI: FSSC 22000 PAS 220 ISO 22000 FSSC 22000=+ 11

12. IFS often linked with BRC GFSI: IFS12 (25)

14. How are we doing? Goals were to:  Harmonize worldwide food safety standards  Increase transparency  Improve supply chain efficiency  Cut costs for manufacturers GFSI: assessment14

15. 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

16. Food safety declined for G20 in 2014 (17) GFSI: assessment16

17. Food safety up and down globally GFSI: assessment17 (17)

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

19. Food safety continues to be an issue GFSI: assessment19

20. 2 classes of foods more discernable (17) GFSI: assessment20

21. 2 classes of foods more discernable GFSI: assessment21

22. 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

23. Manufacturer costs may be lower GFSI: assessment23

24. 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

25. GFSI: status

26. 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

27. 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

28. 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)

29. 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

30. • Complexities in abundance • GFSI will have a positive long term impact GFSI: assessment Net: GFSI is working but much more to do 30

32. 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

33. 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)

34. Food fraud prevalence increasing • Global Food fraud ~ $50 billion (3) • 10% US food adulterated (4) Food fraud-what’s now34

35. 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-what’s now35

36. 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 Food fraud-what’s now36

37. 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-what’s now37

38. Food fraud varies (7, 12) Food fraud-what’s now38

39. 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 Food fraud-what’s now39

40. Tortuous Meat fraud (13) Food fraud-what’s now40

41. 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

42. 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

43. 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

45. 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

46. Embrace GFSI version 7 Begins to address food fraud Refocus 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

47. Support whistle blowing Whistle blowing most frequent ID of fraud Refocus to address food fraud47 (28)

48. 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. Refocus to address food fraud • Fraud direction pending 48

49. 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 Refocus to address food fraud49

50. 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 Refocus to address food fraud50

51. 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 Refocus to address food fraud51

52. Use same solutions for packaging & food fraud Refocus to address food & packaging fraud detection & mitigation prediction & prevention 52

53. 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

54. 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 Refocus to address food & packaging fraud54

55. 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 Refocus to address food & packaging fraud55

56. Packaging innovation for prevention & prediction • Begin tracking packaging before food is packaged • Address diversion • Selective monitoring • Load monitoring detection & mitigation prediction & prevention Refocus to address food & packaging fraud56

57. 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 Refocus to address food & packaging fraud57

58. 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 Refocus to address food & packaging fraud58 (29)

60. 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)

61. 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

62. 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 Align value chain to address fraud & next challenge 62

63. 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 Align value chain to address fraud & next challenge 63

64. 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 Align value chain to address fraud & next challenge 64

65. 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 Align value chain to address fraud & next challenge 65

66. 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 Align value chain to address fraud & next challenge 66

67. 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 Align value chain to address fraud & next challenge 67

68. Expand the value chain • Minimal links to externals that address value Align value chain to address fraud & next challenge 68 (22)3

69. • Create links that are meaningful safety and fraud Expand the value chain Align value chain to address fraud & next challenge 69 (22)

70. 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 Align value chain to address fraud & next challenge 70

71. 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 Align value chain to address fraud & next challenge 71

72. 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 Align value chain to address fraud & next challenge 72

73. 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 Align value chain to address fraud & next challenge 73

74. Value chain holds in a vuca world • Volatile • Dynamics of change • Catalysts • Uncertain • Missing predictability • Complex • Chaos slightly at bay • Ambiguous • Hazy reality • Misreads Align value chain to address fraud & next challenge 74

76. 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

77. 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

78. 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

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

Packaging Technology and Research, LLC

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