Author: ICS

Recently Clare Winkel attended the World Seafood Congress 2019 in Penang Malaysia. 41 countries were represented to discuss innovation, responsibility, and sustainability for the future, under the conference theme of Seafood Supply Chains of the Future. This conference occurs every 2 years somewhere around the world, in a location usually closely related to the seafood industry. Previous conferences have been at Reykjavik in Iceland, St Johns in Newfoundland & Sydney Australia. The conference is organised by the International Association of Fish Inspectors (IAFI). Clare has been a member since her first conference in Halifax, Nova Scotia in 1999. Clare was very involved in the organisation for the 2007 conference in Dublin, Ireland.  The next World Seafood Congress will be held in 2021 in the city of Peniche, Portugal.

That’s Clare on stage as part of the final World Seafood Congress 2019 wrap up- along with fellow Australians, Jayne Gallagher (first female IAFI President) & Mark Boulter (most recent past IAFI president). Was a busy few days as  Clare, presented on TACCP (Threat Assessment within the seafood industry), moderated a session (Consumer Protection & Food Safety), judged the poster competition & was part of the final Congress wrap up. Then she was promoted from the South Pacific Regional Representative onto the Executive Board of IAFI (International Assoc of Fish Inspectors).  Additionally another project Clare has been working on during 2019 (the risk of Salmonella in the consumption of raw fish products) was presented by Jasmine Lacis-Lee from DTS Food labs in Brisbane.

At each conference a number of awards are given out including the following:

-The poster competition judged by the IAFI board members, with cash prizes sponsored by IAFI.

-Outstanding contributions to the seafood industry deserve to be acknowledged. Nominations can come from anyone and based on their contributions to research achievements, industry or equipment development, patents and achievements in the application of safety and quality systems, training and training development in any seafood related profession, and other areas which positively affected the seafood and fishing industry.

-The Peter Howgate Award which funds the attendance of a young fish technologist to the World Seafood Congress 2019, a career-changing opportunity to gain insights and build networks within the global fishery sector. Persons under the age of 30 are eligible for the Award. For more information, please visit the official Peter Howgate Award website.

Women in Seafood Video Award: winners will be awarded cash prizes of up to 1000 Euro and a ticket to the Congress. Video submissions must be in a short film format, less than 4 minutes long, and feature a woman involved in the seafood industry. For more information, please visit the Women in Seafood website.

The Peter Howgate award for 2019 had 2 winners, that presented a number of times during the conference:

-“Crab Industry in India – an overview” by Justin Sundarrajan, Newport International’s Quality Control Consultant – India.
-“Official Controls, Constraints, Opportunities and the Future plans for the Fisheries and Aquaculture Sector in Uganda”
Stella Mbabazi, Department of Fisheries Resources inspector for the Ministry of Agriculture, Animal Industries and Fisheries – Uganda.

Clare has previously (2013) won an award for her Outstanding contributions to the seafood industry with regard to training.

Here are some links to the 2019 conference  &

Here is the link to the IAFI website

Feel free to email Clare with any questions about this World Seafood Congress or the next one in 2021 in Portugal.

Filed under: Latest News

New GFSI (Global Food Safety Initiative) requirements now include special consideration to be given to food fraud. To address this new requirement, food safety standards, including SQF, mandate certified sites to complete a food fraud vulnerability assessment of a food manufacturer’s entire supply chain with a strong emphasis on ranking raw materials for potential vulnerability. Current retailers & legislation (Australia, USA & UK) require controls within this area, but unlike established food safety risk assessments, there have been very few published methodologies to carry out vulnerability assessments. This presentation will concentrate on methodologies to assess the risk of potential food fraud within the raw material supply chain.

Filed under: Latest News, Uncategorized, VACCP

The BRC Food Safety Americas 2019 Conference was held in San Diego, May 21-22, 2019. Clare Winkel had the pleasure of being a guest speaker. Here is a summary of Clare’s presentation.

What is food fraud?

Food fraud is intentional adulteration of raw ingredients for financial gain.  It is Economically Motivated Adulteration.  It is Not: HACCP hazards: prevention of unintentional/accidental food safety adulteration and it is Not: TACCP: Food Defence threats: prevention of intentional adulteration/ ideologically motivated i.e. bioterrorism and It is Not new, as records on food fraud exist from Roman times at least.

As listed by the EU, 2013 products at High risk from food fraud are:

  1. Olive oil                                                        
  2. Seafood                                                        
  3. Organic foods                                              
  4. Milk                                                               
  5. Honey and maple syrup
  6. Grains
  7. Coffee and tea
  8. Spices (saffron and chilli)
  9. Wine                          
  10. Fruit juices

A Closer look at few of these examples

Olive Oil

In 2014 a hostile bacteria — Xylella
— was seen in Europe for the first time, destroying centuries-old olive trees & millions of tonnes of Italian olives. While Spain’s harvest was affected because of hot and dry conditions.  Italy reported a 57% drop in production, Greece and Portugal a drop of 35% and 15% respectively.

In 2018 Global production dipped by over 5% due to bad weather and disease. Italy, Greece, Turkey, Palestine, Argentina, Portugal and Tunisia saw the biggest drops. California had a rough year too.

When the harvest is poor, retail prices skyrocket.  This resulted in bottlers paying up to 40% more for their oil.

Italy’s crackdown on the illegal olive oil trade has resulted in another major seizure of 200 tonnes of oil falsely labelled as coming from the Tuscany region.  Nearly 50 individuals and organisations — including millers, bottlers & traders— have been detained as part of the investigation by the Ministry of Agriculture’s inspectorate for the protection, quality and the repression of fraud in agriculture and food (ICQRF) & Italy’s forestry department. The ploy was discovered thanks to DNA testing of the oil, which revealed a complex scam involving a large number of actors in the olive oil supply chain.

Producers cut the pure olive oil with cheaper oils like palm, sunflower or canola to stretch it further. There is a direct correlation – When the harvest is been poor, rates of adulteration rise!

One of the reasons the Italian Govt has allocated so many resources to fighting food fraud, is part of a larger fight against organized crime. 

Organic Foods

A shipment of 36 million pounds of soybeans sailed in 2016 from Ukraine to Turkey to California. The cargo began as ordinary soybeans, they were fumigated with a pesticide – tablets of aluminium phosphide, a pesticide prohibited under organic regulations.  When they arrived in California, the soybeans had been labelled “organic,” according to receipts, invoices and shipping records which boosted their value by approximately $4 million.  And about 21 million lbs of the soybeans have already been distributed.

But where did all this big production come from? Where are these organic farmers?

Here are some facts: between 2014 & 2016, the amount of organic corn arriving into the USA, from Turkey rose from 15,000 to more than 399 000 tons and the amount of organic soybeans coming from Turkey rose from 14,000 to 165,000 tons.

Under USDA rules, a company importing an organic product must verify that it has come from a supplier that has a “USDA Organic” certificate. It must keep receipts and invoices, but need not trace the product back to the farm.

Some of the soybeans originated from ADM Ukraine, a company that does not produce or trade organic soybeans and did not sell or label them as such.


Australia’s biggest listed honey company and some of the country’s largest supermarket chains face accusations of unwittingly selling “fake” honey. Capilano strongly denied any issues with its products and criticized the type of test — known as Nuclear Magnetic Resonance (NMR) — used to detect the impurities, pointing out that it differed from the official Australian test.  Germany’s Quality Services International (QSI) lab was commissioned by a law firm on behalf of horticulturalist Robert Costa to conduct 2 types of tests of the sampled honey (NMR & C4).

This appears at first to be an open and shut case of fraud but in fact the law firm organizing the lab tests was involved in a hostile takeover bid of the honey company. The honey company has now changed hands. Follow the money and find out who is creating the fraud- its not always obvious.

Regions at High risk from food fraud:

  • The usual suspects: China, Subcontinent (India/Pakistan) & Turkey.
  • But basically everywhere: Italy, Spain, EU, USA, ANZ……

Consider climate change (causing shortages/price rises), trade wars (artificial shortages/price rises/falls) and political instability (i.e. Syria, Venezuela…) as any of these will contribute to food fraud risks.

So what DO YOU really have to do about it?

  • Read
    your BRCGS standard.
  • Know
    the regulations in the countries you produce food AND where you sell your food.
  • Read
    the fine print of your customers standards.
  • Understand
    what risk there really is to your business in the real world.

BRCGS Food Safety requirements issue 8

    Documented risk assessment of each raw material that must consider substitution or fraud.
  • 5.4.2
    Documented assessment of the vulnerability of the raw material supply chain.
  • 5.4.3
    Where raw material are identified at risk then control measures/mitigation measures be put in place.
  • 9.1.1
    Documented risk assessment of each raw material that must consider adulteration or fraud.

BRCGS Storage & Distribution requirements issue 3.

  • 10.1.1
      Supplier risk assessment to include the potential for adulteration or fraud.
  • 10.2.1
      A documented vulnerability assessment taking into account historical evidence of substitution or adulteration.
  • 10.2.2
      Where products are identified as at risk, appropriate assurance/testing methods shall be in place.

BRCGS Agents & Brokers issue 2

  • 4.3.1 The company shall assess the potential risks to the security of the products from any attempt to inflict contamination or damage during subcontracted transportation and storage…

Join the BRC Professional courses in October to learn more

What does a Food Fraud Vulnerability Assessment look like? – the weapons you need to fight food fraud.

With vulnerability assessment, severity is not a particularly useful measure as (at the very least) the resultant product will always be illegal and therefore the consequences are always severe, regardless of whether there is an associated food safety issue or not.

Furthermore, most adulteration cases do not have a food safety concern associated with them and the inclusion of severity may, if not handled correctly, lead to an under estimation of the importance of any identified risks.  BRCGS Understanding Vulnerability Assessment section 3.2.

Become an expert in VACCP: Raw material assessments

Summary of VACCP process steps:

  1. List all raw materials.
  2. Collect information on every single raw material: List all raw materials, their country of origin, their suppliers (importers/agent/brokers), source manufacturers, pricing trends & all known testing & sampling activities.
  3. Particularly make sure you have all current certification information on all brokers/agents you buy off & in turn all source manufacturers that actually make the raw materials.
  4. To get the information on certification READ CARTONS& look for GFSI stds logos, go to companies websites to see what stds they may have implemented. Cross check that information back to the GFSI stds databases or ask the certification body listed.
  5. Risk evaluation: ranking of suppliers and raw materials. The more accurate information is used within the assessment the more accurate answer/ranking will be available to the user.
  6. Evidence of past issues of fraud for that product must be assessedfor each raw material.  
  7. Price changes and availability of the raw material must also be collected as this will have a large bearing on future fraud likelihood.
  8. Some raw materials can be grouped if they are derived from the same plant/animal in the same country of origin (i.e. cinnamon from Sri Lanka) or if they are processed by the same source manufacturer (i.e. same factory) and they have provided you with all test methods and all current certifications.
  9. Understand which stds require VACCP assessment as mandatory auditable requirements i.e. BRC Food, SQF vs 8, FSSC 22 000 vs 4.1, but not 3rd party HACCP or any ISO stds.
  10. Control Measures
  11. After all raw materials have been ranked between 1 – 125, the VACCP team members will have to make a decision on at what score will additional control measures be allocated.  This number will indicate the level of significance.
  12. Implement additional control measures as required based on your documented risk assessments of both suppliers supply chains and raw materials.
  13. Record keeping
  14. Document procedures and keep recordsfor each assessment and references.
  15. Horizon scanning for emerging issues (trigger points for action) and review regularly.
  16. Keep records of the review.

Feel Free to contact Clare Winkel at ICS if you need expert advice

Filed under: Latest News

Different countries have different Food Fraud regulations and even different definitions.  If you are exporting you need to know not only what the requirements are, but also the meaning of the term in that region. Food fraud is economically motivated adulteration of food.  It’s all about making money – not sabotage.

Food fraud is not HACCP which is the prevention of unintentional/accidental food safety adulteration i.e. science based, and food borne illness. It also not Food Defence or threats – the prevention of intentional ideologically motivated adulteration i.e. sabotage or bioterrorism.

Some legal definitions of food fraud from around the world include:


  • Intentional adulteration from acts intended to cause wide-scale harm to public health, including acts of terrorism targeting the food supply.
  • Hazard may be intentionally introduced for purposes of economic gain.


  • Food fraud is considered to encompass the deliberate and intentional substitution, addition, tampering or misrepresentation of food, food ingredients, or food packaging, or false or
    misleading statements made about a product for economic gain.


  • Gaining a financial advantage or causing a financial disadvantage through deception or dishonesty.

VACCP (Vulnerability Assessment Critical Control Point) is a method of risk assessing raw materials for the risk of food fraud occurrence. There are several methods that can be used – some require far more resources (staff knowledge, time and ability) that is available in the average food business. Some methods present you with a multi coloured spider-web that looks fabulous but does not give a clear result for ranking of the food fraud hazards.  In addition to the regulations in the country of manufacture and sale, you also need to be aware of the requirements of the standards your company is audited against i.e. BRC, SQF or specific retailer/customer requirements. Some retailers specifically require a ranking of identified food fraud hazards.

All GFSI standards require some type of documented food fraud risk assessment and control plan requirements – but they do vary between the Standards. Some requirements are:

BRC Food Safety Global Std:

  • Documented risk assessment of each raw material that must consider substitution or fraud.
  • 5.4.2 Documented assessment of the vulnerability of the raw material supply chain.

SQF Systems Elements Ed 8- Manufacturing:

  •  Sites food fraud vulnerability assessment including the site’s susceptibility to raw material or ingredient substitution, mislabelling, dilution and counterfeiting … impacting food safety.
  •  Food Fraud vulnerability assessment include the site’s susceptibility to product substitution, mislabelling, dilution, counterfeiting or stolen goods which effect food safety.

And the FSMA rulings (Federal US regulations): Mitigation Strategies to Protect Food Against Intentional Adulteration:

  • A vulnerability assessment, to identify:  Significant vulnerabilities and actionable process steps.

The VACCP (Vulnerability Assessment Critical Control Point) methodology developed by ICS is a simple but effective tool of risk ranking raw materials for potential food fraud occurrence. It uses the existing skills of the HACCP team and utilises a 3-variable matrix (Likelihood x Detectability x Profitability) with a resulting score between 1 (overall very low risk) – 125 (overall extremely high risk).  This allows raw materials to be clearly ranked for risk.  The result is a fully documented assessment against a specific raw material that is easily reviewed at least annually. ICS have used it to assess over 600 different raw materials with the resulting scores between 1 and 60.

ICS have public, virtual and online training courses (and technical support services) in Food Fraud awareness, Food Fraud requirements (Regulatory, GFSI and retailer standards) and VACCP Food Fraud assessment methods.

Here is a presentation on a specific food fraud case presented by Clare Winkel at the 2018 SQF conference :

Filed under: Latest News, VACCP

By Margaret Balfour

While the concept of HACCP-based risk assessments for food safety (chemical, biological and physical) has been very well established globally, much of the food industry has yet to come to terms with the development of risk assessments focusing on vulnerability, authenticity and threats.  To further complicate matters, multiple terms are used globally for these topics (oftentimes incorrectly).  Despite this, all GFSI Standards (BRC, SQF, Global Gap, FSSC22000 and IFS) and most major retailer Standards require food fraud (VACCP) and food defence (TACCP) risk assessments.

What is VACCP?

VACCP (Vulnerability Assessment Critical Control Points) is a risk assessment focused on risks from the vulnerability of your raw materials, supply chain and your finished product from adulteration, substitution, mislabelling, counterfeit or any other attempt to change the products for economic gain.  The VACCP risk assessment is designed to identify risks from food fraud.

The global cost of food fraud is estimated to be US$30-40 billion dollars per year.  In many cases, there is no impact on consumer health, but the damage to business reputation and indirect costs can be massive.

Significant food fraud events globally have included the melamine contamination of baby formula in 2008 in China resulting in 300,000 reported illnesses and six consumer deaths.  The three key staff members involved were punished: one with life imprisonment and two with the death penalty.  Ironically, melamine contamination in the food chain was first identified in May 2007 when the US Department of Agriculture reported that the contaminant had been found in pet food fed to hogs and chickens destined for human consumption.  Hundreds of dogs and cats either died or suffered health problems as a result of consuming the pet food.

The scare widened in the US after it was found to have entered the human food chain after pet food scrap was used as a feed supplement at a number of hog and chicken farms.  The question that begs to be answered in all this is whether the wider food industry should have been aware of this event and considered it in their risk assessments?

Food Fraud is Not New

Multiple publications have been released as early as A Treatise on Adulteration of Food & Culinary Poisons was penned by Frederick Accum in 1820. There is plenty of historical data on food fraud and the risks associated with each and every ingredient and food product.  Not all contamination events are purely for economic gain, however.  When the contamination or damage is intentional and designed to cause harm, the term “threat” is used rather than “vulnerability.”  Hence the term TACCP (Threat Assessment Critical Control Points).

What is TACCP?

TACCP is a risk assessment focused on risks from threats to your raw materials and could include intentional contamination of food products, sabotage of the supply chain, and using food or drink items for terrorism or criminal purposes.

Food is the number one product stolen when under transportation in the USA.  More than USD$30 Billion is stolen annually in the USA and then resold on the black or grey markets, potentially having been contaminated first. And, while theft opens the door to the possibility of significant danger to human life and brand integrity,  significant damage can also be achieved through simple malicious intent.

Recently Australia has been subject to a nationwide recall of strawberries in peak season due to malicious tampering with sewing needles.  Initially an isolated event in Queensland, the incident escalated to other states and territories. Only a few instances were believed by authorities to be associated with the original event, with most other instances believed to be multiple hoax or “copycat” events.

Risk assessments are only as good as the input or information used to conduct the assessment.  Horizon scanning and keeping up to date on threats, vulnerabilities and emerging risks are the only genuine defence we have in the HACCP, TACCP and VACCP risk assessment game

Filed under: Latest News, TACCP, VACCP