FOOD SAFETY

FOOD FRAUD
GMP/PRP
TRAINING
AUG-25-2018
 Learning Objectives

01 02 03 04
Deepen Review basic Learn about Be able to put
understanding PRPs and GMP Food Fraud into action
of FSSC and its requirements and how to learnings from
requirements identify it the session
 ISO 9001 (QMS : Quality
Management System)

ISO 22000 (FSMS : Food

History of Food Safety Management System)
Safety in MNC
FSSC 22000
 Specifies requirements for a food safety
management system where an organization in
the food chain needs to demonstrate its ability to
ISO 22000 control food safety hazards in order to ensure
that food is safe at the time of human
consumption.
 Schemes recognised by GFSI
« Once certified, accepted everywhere »
Benefits
 Reduced incidences of food safety breaches & investigation
time
 Reduce process training and new staff training
 Reduced litigation and legal fees
 Harmonization of prerequisite programs and industry practice
 Unites large and small manufacturers and retailers under a
commonly agreed set of PRPS for the international control of
hazards
Benefits
 Reduced costs from waste reduction, product failures
and better traceability throughout the supply chain
 Reduced food safety hazards at all levels in the
product and processing environment
 Meets expectations and requirements of food
manufacturing stakeholders such as food retailers and
food service providers
 Assist organizations in operating food manufacturing
processes at the very highest quality level in
accordance with FSSC 22000.
What is FSSC 22000? It is a Food Safety
Management System
What is needed to build such system?
CONTINUOUS
IMPROVEMENT

FSMS:
VERIFICATION &
VALIDATION FSSC 22000

HACCP

PRE-REQUISITE
PROGRAMMES
GOOD MANUFACTURING
PRACTICES
GMP & PRPS
 References:
• ISO/TS 22002-2009
• Codex Alimentarius: Recommended
International Code of Practice General
Principles of Food Hygiene (CA/RCP 1-1969,
PRE-REQUISITE Rev. 4 -2003)
PROGRAMS • AO153 : Guidelines on Current Good
Manufacturing Practices in Manufacturing,
(PRPS) GUIDELINE Packing, Repacking or Holding
(SDGL-GP-003) • P.D. 856 : Implementing Rules and regulations
of Chapter III Food Establishments of the code
of sanitation of the Philippines
• Industrial Hygiene of the Sanitation Code of
the Philippines: IRR on Chapter VII of P.D. 856
Amending A.O. 111 s. 1991
 ISO/TS 22002-1 Requirements
1 Scope
2 Normative References
3 Terms and definitions
4 Construction and lay-out of buildings
5 Layout of premises and workspace
6 Utilities – air, water, energy
7 Waste disposal
8 Equipment suitability, cleaning and maintenance
9 Management of purchased materials
10 Measures for preventing of cross contamination
11 Cleaning and sanitizing
12 Pest Control
13 Personnel hygiene and employee facilities
14 * Rework
15 * product Recall Procedures
16 * warehousing
17 * product information and consumer awareness
18 * Food Defence, biovigilance and bioterrorism
* Additional requirements to clause 7.2.3 of ISO 22000:2005
4 Construction and Layout of Buildings

4.1 GENERAL REQUIREMENTS

Buildings shall be designed, constructed and maintained in a manner appropriate
to the nature of the processing operations to be carried out, the food safety
hazards associated with those operations and potential sources of contamination
from the plant environs.
 5 Layout of Premises and workspace
5.1 General Requirements
Internal Layouts shall be designed, constructed and maintained to facilitate good
hygiene and manufacturing practices. The movement patterns of materials,
products and people, and the layout of equipment shall be designed to protect
against potential contamination sources
 5 Layout of Premises and workspace
5.2 INTERNAL DESIGN, LAYOUT AND TRAFFIC PATTERNS
• Spacing of materials and equipment and traffic of meterials
5.3 INTERNAL STRUCTURES AND FITTINGS
5.4 LOCATION OF EQUIPMENT
• Sufficient space for access, cleaning, maintenance, etc.
5.5 LABORATORY FACILITIES
5.6 TEMPORARY OR MOBILE PREMISES AND VENDING MACHINES
 5 Layout of Premises and workspace
5.7 STORAGE OF FOOD, PACKAGING MATERIALS, INGREDIENTS AND NON-FOOD
CHEMICALS
• A separate, secure (locked or otherwise access controlled) storage area shall be provided for
cleaning materials, chemicals and other hazardous substances.

• SDGL-GP-013: Chemical control and storage Guideline

• QR-GP-CIL Chemical Inventory Logsheet
Identify the GMP Violation:
6 Utilities – Air, Water, Energy

6.1 General requirements

The provision and distribution routes for utilities to and around processing and
storage areas shall be designed to minimize the risk of product contamination.
Utilities’ quality shall be monitored to minimize product contamination risk.
6 Utilities – Air, Water, Energy
6.2 WATER SUPPLY
6.3 BOILER CHEMICALS
6.4 AIR QUALITY AND VENTILATION
6.5 COMPRESSED AIR AND OTHER GASES
6.6 LIGHTING
Lighting provided (natural or artificial) shall allow personnel to operate in a
hygienic manner
Intensity of the light should be appropriate to the nature of the operations
Light fixtures shall be protected to ensure that materials, products or equipment
are not contaminated in the case of breakages
7 Waste Disposal
7.1 General Requirements

Systems shall be in place to ensure that waste materials are identified, collected,
removed and disposed of in a manner which prevents contamination of products or
production areas
7 Waste Disposal
7.2 CONTAINERS FOR WASTE AND INEDIBLE OR HAZARDOUS SUBSTANCES
• Should be clearly identified for their intended purpose and in a designated area only

7.3 WASTE MANAGEMENT AND REMOVAL

• Proper segregation, storage and removal

7.4 DRAINS AND DRAINAGE

* SDGL-EN-005: Guidelines on Handling and Disposal of Hazardous Waste
* SDGL-GP-017: Waste Management Guidelines
8 Equipment Suitability, cleaning and
Maintenance

8.1 General Requirements

Food contact equipment shall be designed and constructed to facilitate cleaning,
disinfection and maintenance. Contact surfaces shall not affect, or be affected by
the intended product or cleaning system.

Food contact equipment shall be constructed of durable materials able to resist

repeated cleaning.
8 Equipment Suitability, cleaning and
Maintenance

8.2 HYGIENIC DESIGN

8.3 PRODUCT CONTACT SURFACES
8.4 TEMPERATURE CONTROL AND MONITORING EQUIPMENT
8.5 CLEANING PLANT, UTENSILS AND EQUIPMENT
8.6 PREVENTIVE AND CORRECTIVE MAINTAINANCE
8 Equipment Suitability, cleaning and
Maintenance

• PR-GP-004: Preventive and Corrective Maintenance

• Start-up operations checklist (Production)
• CMMS (for PM and CM)
• Equipment Calibration records
• PR-GP-013: HACCP Procedure
• SDGL-GP-013: Chemical Control and Storage Guideline
• PR-GP-007 Calibration Procedure
• PR-GP-009 Verification Procedure for Equipment and Measuring Instrument
 9 Management of Purchased Materials

9.1 General requirements

Purchasing of materials which impact food safety shall be controlled to ensure that
the suppliers used have the capability to meet the specified requirements. The
conformance of incoming materials to specified purchase requirements shall be
verified
 9 Management of Purchased Materials
9.2 SELECTION AND MANAGEMENT OF SUPPLIERS
9.3 INCOMING MATERIAL REQUIREMENTS (RAW/INGREDIENTS/PACKAGING)

• PR-GP-002 Material Requisition

• PR-GP-003 Material Receiving
• PR-MM-005: Materials Procurement
• PR-MM-015: Supplier Approval Procedures
• PR-MM-004: Supplier Evaluation Procedure
• Supplier Audit reports
• Supplier Evaluation reports
 10 Measures for prevention of cross-
contamination
10.1 General Requirements
Programmes shall be in place to prevent, control and detect contamination.
Measure to prevent physical, allergen and microbiological contamination shall be
included.
 10 Measures for prevention of cross-
contamination
10.2 MICROBIOLOGICAL CROSS-CONTAMINATION
10.3 ALLERGEN MANAGEMENT
10.4 PHYSICAL CONTAMINATION

SDGL-GP-004: MNC Guidelines on Personnel Hygiene

SDGL-GP-010: Incase of Glass and Brittle Plastic Breakage Guideline
SDGL-GP-011: Glass and Brittle Plastic Policy
SDGL-GP-020 Loose Materials and Loose Parts Control
SDGL-GP-014: Allergen Control Plan
SDGL-GP-015 Allergen Spillage Guideline
11 Cleaning and Sanitizing

11.1 General Requirements

Cleaning and sanitizing programmes shall be established to ensure that the food-
processing equipment and environment are maintained in a hygienic condition.
Programmes shall be monitored for continuing suitability and effectiveness
11 Cleaning and Sanitizing
11.2 CLEANING AND SANITIZING AGENTS AND TOOLS
11.3 CLEANING AND SANITIZING PROGRAMMES
11.4 CLEANING IN PLACE (CIP) SYSTEMS
11.5 MONITORING SANITATION EFFECTIVENESS

• SSOPs
• Safety Data Sheets
• Cleaning Checklists
• Post Cleaning Checklists
• Equipment Swab reports
• SDGL-GP-012: Cleaning and control of cleaning tools and materials
• SDRS-GP-015 List of Chemicals in MNC Laguna
12 Pest Control
12.1 General Requirements

Hygiene, cleaning, incoming materials inspection and monitoring procedure shall

be implemented to avoid creating an environment conducive to pest activity
12 Pest Control
12.2 PEST CONTROL PROGRAMMES
12.3 PREVENTING ACCESS
12.4 HARBOURAGE AND INFESTATIONS
12.5 MONITORING AND DETECTION
12.6 ERADICATION
Pest control reports
PR-QA-016: Integrated Pest Control Management Procedure
13 Personnel Hygiene and Employee Facilities

13.1 General Requirements

Requirements for personal hygiene and behaviours proportional to the hazard
posed to the process area or product shall be established and documented. All
personnel, visitors and contractors shall be required to comply with the
documented requirements.
13 Personnel Hygiene and Employee Facilities
13.2 PERSONNEL HYGIENE FACILITIES AND TOILETS
13.3 STAFF CANTEEN AND DESIGNATED EATING AREAS
13.4 WORKWEAR AND PROTECTIVE CLOTHING
13.5 HEALTH STATUS
13.6 ILLNESS AND INJURIES
13.7 PERSONAL CLEANLINESS
13.8 PERSONAL BEHAVIOUR
MNC Guidelines for Personal Hygiene (SDGL-GP-004)
14 Rework

14.1 General Requirements

Rework shall be stored, handled and used in such a way that product safety, quality,
traceability and regulatory compliance are maintained.

14.2 STORAGE, IDENTIFICATION AND TRACEABILITY

14.3 REWORK USAGE

* PR-GP-006 Handling of Potentially Unsafe Products

16 Warehousing
16.1 General requirements
Materials and products shall be stored in clean, dry, well-ventilated spaces
protected from dust, condensation, fumes, odours or other sources of
contamination

16.2 WAREHOUSING REQUIREMENTS

16.3 VEHICLES, CONVEYANCES, AND CONTAINERS

• PR-GP-005 Finished Goods Transfer

• PR-MM-014: Receiving, Storing & Issuance of Indirect Materials
• PR-LG-043 Receiving PR-LG-038 Daily Inventory Monitoring Procedure
• PR-LG-010: Control of Product Returns
• SDGL-LG-002 Receiving Inspection Guideline
But Wait, there’s
more
 16 – Education /  Employee Education and  PRP Guidelines
Training and Training (SDGL-GP-003)
Responsibility  Supervision (Responsibility  Job descriptions
and Authority)  Training Matrix
 Training Records
 CAC/RCP 1-1969 :
Recommended
International Code of
Practice
17 – Production  Receiving of materials  PRP Guidelines
and Process  Production process (SDGL-GP-003)
Control controls (monitoring of  Non-conformity
PRPs, CCPs and OPRPs) Matrix
Additional  Finished product staging
warehouse
 Standard
Specifications (per

PRPs 
product)
SDGL-GP-006:
Guidelines on
Product Coding for
Production
 SDGL-GP-005:
Reference Guideline
in Handling Nutrients
and its Stability
 PR-GP-006 Handling
of Potentially Unsafe
Products
 18 – Self-  GMP and Warehouse  PRP Guidelines
inspection Audits (SDGL-GP-003)
 5S Audit  CAC/RCP 1-1969 :
 Halal Audit Recommended
 Internal Audit (including International Code
HACCP Audit) of Practice
 PR-RI-001 Internal
Audit Procedure
 PR-RI-002 Correction
and Corrective
Action Procedure
 PR-QA-010: GMP
and Warehouse
Additional 19 –  Control of Documents & 
Audit
PRP Guidelines

PRPs Documentation


Records
Review of Documents
Reproduction of

(SDGL-GP-003)
PR-DC-001 Control
of Records /
Documents Documents
 Control of Obsolete  PR-DC-002
Documents Document Review
Procedure
 PR-DC-003
Reproduction of
Documents
 PR-DC-004 Deletion
of Documents
 20 – Sample Retention  Samples retained  PRP Guidelines (SDGL-
 Sampling plans GP-003)
 SDRS-QA-055:
Reference Sample
Matrix for In-Process
Samples and
Imported Finished
Goods
21 – Quality Assurance  Management of inputs /  PRP Guidelines (SDGL-
results of verification GP-003)
activities  PR-GP-022: Validation
 Shelf-life evaluation Procedure
 SDGL-GP-005:
Reference Guideline
Additional in Handling Nutrients
and its Stability
22 – Control of  Accreditation of contractors  PRP Guidelines (SDGL-
PRPs contractors / services  Evaluation of contractors

GP-003)
SDGL-EN-003:
Guidelines for 3rd
Party Contractors
 SDGL-EN-010: MNC
Personnel Hygiene
Guidelines for
Contractors
 SDGL-GP-009 Product
Standard Specification
and Guideline for Toll
Packer
ISO 22000
 ISO 22000 Requirements
0 Introduction 7 Planning and Realization of Safe Products
1 Scope 7.1 General
2 Normative Reference 7.2 Prerequisite programmes (PRPs)
3 Terms and Definitions 7.3 Preliminary steps to enable hazard analysis
4 Food Safety Management Systems 7.4 Hazard Analysis
4.1 General Requirements 7.5 Establishing the operational prerequisite programmes (PRPs)
4.2 Documentation Requirements 7.6 Establishing the HACCP Plan
5 Management Responsibility 7.7 Updating of preliminary information and documents
5.1 Management Commitment specifying the PRPs and the HACCP Plan
5.2 Food Safety Policy 7.8 Verification Planning
5.3 Food Safety Mgt Sytem Planning 7.9 Traceability System
5.4 Responsibility and Authority 7.10 Control of nonconformity
5.5 Food Safety Team Leader 8 Validation, verification and Improvement of the food
5.6 Communication safety management system
5.7 Emergency preparedness and response 8.1 General
5.8 Management Review 8.2 Validation of control measure combinations
6 Resource Management 8.3 Control of monitoring and measuring
6.1 Provision of Resources 8.4 Food Safety Management systems verification
6.2 Human Resources 8.5 Improvement
6.3 Infrastructure
6.4 Work Environment
 THREE TYPES OF HAZARDS IN FOOD SAFETY

1. Biological – bacteria, viruses, parasites

2. Chemical – pesticides, additives, cleaning chemical, allergen
3. Physical – glass, stones, plastics, bolts & nuts

44
 Hazard Analysis
1. Hazard identification 2. Hazard Evaluation
• Brainstorm a list of potential • Determine significance of
hazards which may be hazard
introduced, increase or
controlled in each step
 Hazard Analysis
Total Is hazard
significant?

Likelihood, L

Severity, S
Hazard If LxS >5,
(B) - Biological LxS = ? Control Measure
Process Justification
(P) - Physical Must undergo for the Identified Hazard
(C) - Chemical OPR /CCP Place
determination Yes if >5
No if ≤ 5
Production scheduling No identified significant hazard.
Preparation of premixes (C) Allergen - Wheat, Allergen Control Plan
>Inherent from raw materials (For SS) 5 3 15 Yes
and manual weighing of Soy, Milk and Sulfite
raw materials
>From possible cross-contamination during Cleaning and Sanitation Program:
(C) Other Allergens 3 3 9 Yes
preparation. SSOP For Production Implements
Ensure absence of unsealed entry points
(P) Pest/ Insects >From unsealed entry points at preparation area. 3 2 6 Yes
through periodic facility checking
(P) Pest/ Insects >From poor housekeeping in preparation area. 3 2 6 Yes Ensure cleanliness of preparation area
Cleaning and Sanitation Program for
Dust (P) >From preparation area and previous process. 3 1 3 No
Preparation Area
(B) Clostridium
> Inherent from raw material (For Hot Filled SS) 1 3 3 No Reference: Supplier Control
Perfringens
> From material received with an unacceptable Reference: Certificate of Analysis from
(C) 3-MCPD 1 3 3 No
level of 3-MCPD. (For SS) Supplier
>From plastic shovel and plastic crates (For SS)
Ensure absence of cracks through periodic
(P) Hard Plastic >From plastic measuring cup and plastic pails 1 3 3 No
checking of condition of brittle materials
(For Paste)
Ensure plastic gloves are intact and no torn
(P) Soft Plastic > From torn plastic gloves of weighing personnel 1 2 2 No
parts
(C) Cleaning Chemical Use of correct concentration for cleaning
>From inadequately cleaned weighing utensils 1 2 2 No
Residues agents
Proper implementation of Cleaning and
Sanitation Procedure:
(B) E. Coli > From inadequately cleaned weighing utensils 1 3 3 No
SSOP for Cooker (For SS)
SSOP for Stephan Cooker (For Paste)
> From weighing personnel through fecal-oral Personnel hygiene and sanitation:
(B) E. Coli 3 3 9 Yes
route. handwashing, use of hand gloves
 • CCP = Critical Control Point
Identify Hazard
• OPRP = Operational Pre-requisite
• programme

Hazard Analysis • PRP = Pre-requisite programme

Significant Hazard Non-significant Hazard

Control under CCP or OPRP Control under PRP or no control

if risk is negligible or very low
CONTROL MEASURES
Any action and activity that can be used to prevent or eliminate a food
safety hazard or reduce it to an acceptable level

More than 1 control measure maybe required to control a hazard and,

more than 1 hazard maybe controlled by a control measure

Two Types of CM:

1. Specific control measure – CCP
2. General Control measure – PRP
 Corrective Action
• Codex: Corrective Action is any action to be taken when the
results of monitoring at critical control point (CCP) indicate a
loss of control.
Includes :
Correction:
- Adjust process/conditions
- Disposition of affected product
Corrective Action:
-to prevent recurrence
Actions include:
• Quarantine until rework or disposal or downgrade to permissible
animal feed (within feed specification)
• Rework (ie. Rerun through the working CCP)
• Disposal/destruction
Effective procedure for Control of Non Conforming product
Only safe product is released.
FOOD FRAUD
What is Food Fraud?
• “Intentional deception using food for economic gain”
• It is a criminal act
• A threat to the economic stability of a company
• Opportunities + Motivation – Control Measures = Food Fraud
How does Food Fraud happen?

COMPANY

FOOD FRAUD
VULNERABILITY
CONTROL
MEASURES
Food Fraud
• Dilution
• Substitution
• Concealment
• Mislabelling
• Unapproved enhancement
• Counterfeiting
• Theft/Diversion
Opportunities – taken advantage of
• Physical Characteristics
• Availability of knowledge/technology
• Simplicity/complexity of method
• Access to process chain
• Detectability of fraud
Motivation – continue or spread food fraud
• Economic Factors • Cultural Factors
• Value determinants • Personal gains
• Financial Strain • Ethical practices
• Competition • Corruption
• Pricing • Victimisation
• Competition • Competition
• Economic Health • Blackmail
Control Measures
• Information management
• Traceability
• Documentation
• Mass balance
• Verification Systems
• Whistleblowing protection
• Code of ethics
• Contracts and legal binding agreements
• Integrity alignment and screening
FOOD DEFENSE
FOOD DEFENSE
“The process to ensure the security of food and drink from all forms of
intentional malicious attack including ideologically motivated attack
leading to contamination.” (GFSI 2017)

• The motivation or root-cause is the intent to cause harm to the

companies or consumers.
THANK YOU! 