Food Fraud Risk and Mitigation: Arm Your Brand

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Sarah: Hello everyone. Thank you so much for joining our broadcast today. My name is Sarah Curran with Eurofins U.S. marketing. We'd like to welcome you to our presentation of Food Fraud Risk and Mitigation, Arm Your Brand.
Before we get started today, I'll go over just a few housekeeping slides. This webinar is being recorded and a copy of the slides and recording will be available within two business days to everyone who registered or attended the presentation. There will be time for a brief Q & A following the presentation. Any questions that we do not address during the live broadcast will be answered via email within two business days. To submit a question for our live Q & A session, simply use the question bar in your GoToWebinar dashboard, type your question in the dropdown menu, and hit enter to submit.

Before we get started with our presentation, I'll go over a brief description of Eurofins. Eurofins is driven by our mission and vision to contribute to global health by offering the highest quality testing, training, auditing, and consulting services. We strive to listen to our customers and not simply meet, but exceed their expectations of our services. Our footprint is global. With over 30,000 staff in 375 laboratories across 41 countries and a portfolio of over 130,000 analytical methods, Eurofins provides a unique range of analytical testing services to the pharmaceutical, food, environmental, and consumer product industries, and to governments. Eurofins is a full service provider of food safety services including, but certainly not limited to microbiology and chemistry testing. We are your one stop shop for both routine and specialized testing, auditing, training, consulting, and candid expert advice.

Before we get started, we'd like to ask our audience a question to get everyone warmed up. Our first question is, are you likely to attend a training on food fraud within the next 12 months? Go ahead and click the screen to submit your response. We'll give everyone about a minute to respond. Alright, we'll give everyone just a few more seconds here. It looks like 79% of attendees have voted. Alright, and with that I will close our poll and display our results. So it looks like 62% of people attending our webinar today said yes, that they are likely to attend a training course on food fraud within the next year.

With that warm up question behind us, I would like to introduce our wonderful presenters today. First up, I'll be introducing Gary Smith. With a master's in environmental biology from Governors State University and a bachelor's in animal sciences from the University of Illinois, Gary Smith brings over 25 years of industry experience to his duties at Eurofins Food Safety Systems. Gary has worked as a regulator, buyer, supplier, trainer, auditor, head of a certification body, and a head of a standard owner.

With industry experience in produce, meat, bakeries, dairy, warehousing, distribution, packaging, beverage, and confectionary, his broad perspective means Gary is uniquely equipped to help organizations determine which standards offer the best benefits to their business and their most practical strategies for complying with them.
Next, we have Peter Claise from USP. Peter Claise is the marketing director for the Foods Program in the Strategic Marketing and Program Operations division at USP in Rockville, Maryland. Peter joined USP in 2016 and has experience in technical support, sales, and marketing for various technologies, serving multiple end markets. Peter received his bachelor's in biomedical engineering at Vanderbilt University and his MBA from Northeastern University's High Tech MBA program. With that, I will be handing our presentation over to Peter Claise at USP to give us an overview of what USP does and a look into their food fraud database.

Peter: Great. Thank you, Sarah, and good morning everyone. Thanks for joining us today for this webinar. What I'll do is I'll briefly introduce who USP is, for those of you who are not aware. USP, I thought I'd start with our mission. Our mission is to improve global health through public standards and related programs to help ensure the quality, safety, and benefit of medicines and foods. Who we are and where we work. We were founded in the early 1800s. We're a nonprofit, we're private, we're independent, and we're self-funded. Our focus since our inception in 1820 has been on quality standards to protect public health. We have over 1000 employees around the world, mainly focused at our corporate headquarters in Rockville, Maryland. But also we have laboratories in India, in China, in Brazil and Ghana, and offices in Europe, Indonesia, Philippines, and Nigeria. And the way we work is we're really a convening body. We bring together different groups from academia, from industry, from the government to work as expert volunteers to set standards around medicines and foods.

And the areas that we effect. We have pharmaceutical, so we originally founded around the pharmaceutical products and setting standards for those to ensure that what people were getting was of the right quality, the right potency, and the right consistency. We also have standards on food ingredients to ensure safety and quality around certain food ingredients. Healthcare quality, and that's for hospitals, pharmacists, to make sure that around things like compounding, to make sure certain procedures are followed, to ensure safety. Dietary supplements and herbal medicines. Some of you may have seen our logo advertised by Nature Made on dietary supplements, really to help ensure what's in the bottle is what's on the label and ensuring quality and safety there.

We also do a lot of work in global public health. And that's working around the world, mostly in developing nations, to help them build infrastructure and regulatory around setting up quality systems to ensure companies can have the resources and can follow a GMP, and other procedures to ensure quality. Our approach, I think, is a little bit different than other organizations in that we're really founded on our independent experts. Here you can see a lot of different organizations. This is all within the Foods Program at USP. Of expert volunteers who dedicate their time on our different expert committees and expert panels that set the standards that we put out. For example, we have our food ingredients expert committee, we have an expert panel on olive oil quality and authenticity, and we're planning on releasing some new standards later this year around olive oil. We have a food adulterants hazards identification expert panel, a food adulteration expert panel, and also an expert panel on non-targeted methods for milk ingredients, such as testing skim milk powder and things like that for adulteration and quality.

What are the things that we produce for the industry? It really can be summed up in three categories. One is our food chemicals codex and reference materials. Our food chemicals codes, that's a book of roughly around 1200, 1300 different standards that are methods for identification and verification of various food ingredients including acceptance criteria and assays on how to test for those. And also associated reference materials to test against those methods. And that book has been around since the 1960s, originally created by The Institute of Medicine.
We also have our food fraud database, which I'll be demoing later today. Our food fraud database is a collection of thousands of ingredients and related records around food fraud. It really enables you to dive deeply and understand what ingredients have been adulterated in the past as it relates to food fraud, what those adulterants were, how to test them, and also some tools around trending, which I'll go into a bit more later.

Lastly, we have food fraud mitigation services. We have a number of services to help food manufacturers perform a vulnerability assessment so they can accurately assess their risk and put mitigation plans in place to reduce that risk. I'll start with talking about, what is food fraud? Food fraud can come in a variety of different ways. It can come in dilution or substitution, so olive oil, I think, is a perfect example. If you're buying extra virgin olive oil, or that's what is on the bottle, but really in the bottle is a lower grade olive oil. That would be dilution or substitution.
It could be artificial enhancement. So think of adding Sudan dyes to paprika or other spices to enhance the color. It could be the use of undeclared or unapproved biocides or antibiotics. So think of using chloramphenicol in shrimp and not declaring that, and then trying to sell that saying that it hadn't been used.

It could be the removal of authentic constituents. So paprika oleoresin might be an example. Someone could extract some of the actual valuable parts of that spice and then you'd be getting a substandard spice. It could be misrepresentation of nutritional values or fraudulent label claims. If you go into the grocery store and you see something is organic or halal, is it really halal or organic? It could be the formulation of a fraudulent product or counterfeits, theft, overruns in the gray market. All of these constitute various types of food fraud.

This slide came from GFSI and I thought it was a really nice slide, really just to differentiate and separate out what's the difference between intentional adulteration, unintentional adulteration, food defense, food fraud, food quality, and food safety. What you can see in this vector diagram is that there's a lot of overlap. Food fraud can overlap with food defense, food quality, and food safety. But food fraud is really economically driven. That's the motivation. Someone is not trying to hurt someone because of food fraud, they're really just trying to enhance their own pockets and make more money.

Whereas another type of intentional adulteration is food defense. That's ideologically driven. The motivation is to cause harm. So it's very different than food fraud in that the goal is to harm people, whereas in food fraud really the goal is not harm people. It's to make money and do something fraudulent so you're making more money and the goal is to not get caught, which is very different than food defense where they want to cause harm and cause public distress. Obviously, if someone is adulterating your product that can have an impact on food quality and that can also have an impact on food safety. I'm sure we're all very well aware of the examples like melamine in milk and infant formula, but there's a lot ... When we did our analysis, looking at our database, which has thousands and thousands of records, we found that actually 25% of the food fraud adulterants were categorized as hazardous to human health. So there's a lot of cases where food fraud, even though it may not be intentionally trying to harm people, does have an impact on food safety.

Why food fraud? Why is USP involved in food fraud, given our history and our mission on public health? I talked a little bit about this, but the prevalence ... This is coming from the U.K. food standards authority information. They said up to 10% of the food supply is affected by food fraud. It may not be the entire packaged good, but it could be a fraudulent ingredient in that final finished product. The impact. We talked about public health. It doesn't happen in all cases, but it certainly does happen and there is that overlap. Another example I can think of in recent history is the food fraud in fake vodka in Europe where 50 people died from drinking fake vodka just last year. Another example. We talked about the melamine crisis, which obviously was a terrible incident and had a huge impact on public health in China and other parts of the world.

The economic impact. The GMA estimates in a report with A.T. Kearney that the average cost of one incident can be anywhere from two to 15% of annual business revenue. That's a very significant loss. If you think about it, a one billion dollar organization, that makes a billion dollars in revenue, that could be 150 million dollars in a given year of economic loss from a food fraud incident. There are also other reasons for putting food fraud measures in place. One is compliance, and Gary is going to talk more about this later in this webinar, but complying with GFSI standards and FSMA standards. There's also damage to brands. I think we can all think of some of the examples where brands have gone bankrupt or gone under. And also consumer confidence. I think about the recent meat scandal in Brazil, and the impact that's having on the Brazilian economy.

Who is affected? We've talked about the food industry, certainly food manufacturers, food ingredient suppliers or manufacturers are impacted. Governments are impacted. And, at the end of the day, the consumer is impacted.
What I wanted to share with you is really the USP ingredient approach to performing a food fraud vulnerability assessment. This is really outlined in the USP Food Fraud Mitigation Guidance, which is a freely available document, which really outlines a framework on how to do this ingredient based vulnerability assessment. When we think about this, for a given company there is a universe of ingredients that they deal with. That they buy and use in their products and sell. What we really want to do when we're doing a vulnerability assessment is narrow that down into ingredients with potential risks and then really identify those with the greatest risk, and for those with the greatest risk, help put a mitigation plan in place to prevent food fraud from occurring and strengthening that organization's supply chain.

Where do we start? Well, it starts really with a screening step to identify those obvious ingredients and then a more detailed assessment is performed, performing a vulnerability assessment, looking at the impact if fraud were to occur, then weighing the overall risk, and then the final step is developing that mitigation plan to protect that organization and protect the consumers. USP has several tools that can help in this matter. For the screening step we have our food fraud database, which can be used to help do that. We also have a screening tool, a food fraud vulnerability ingredient screening tool that we have, which is really a proprietary algorithm that we use. An organization can give us a list of ingredients and we'll put that through our tool and categorize those ingredients, and come back and say "Out of the 100 ingredients that you provided, 10 of them fall into the highest risk, 50 of them fall into the medium risk, and 40 of them fall into a low risk."

Our Food Fraud Mitigation Guidance can be used for steps one, two, and three as outlined here. And then, finally, all of those, the food fraud database, our mitigation guidance, and our food chemicals codex and reference materials can be used to help develop a mitigation plan. Because the mitigation plan really will accomplish ... There are several tools and factors that can be used to really develop that mitigation plan, which are all outlined in that food fraud mitigation guidance. With that, why don't I bring up the food fraud database and just do a short demo of how the food fraud database looks and how it works. Here you can see our dashboard, when you log in to our food fraud database. We have about 7600 total records, all on food fraud. As you can see, you can look at what's new, what's recently been added. And this is based on the entire system, so over the past 90 days we've added about 400 new adulteration records and that's added 171 new adulterants that weren't in the database before, 98 of which are potentially hazardous to human health.

What you can also see is, in this lower section, this is basically a dashboard based on searches that I've created that are important to me. For example, I have a candy bar group. In that candy bar group there's a certain list of ingredients. There's four new records, six new adulterants, and I can clearly see what some of those are. This is all the new adulterants that have been added based on the groups that I have in my safe search, as well as the geographic distribution of those. What I like to do for any new user of the database, I think it's really important to really set it up to be specific for you. In the management tab, what you can see here is we have user ingredient groups and system ingredient groups. For system ingredient groups, we've gone through and curated a whole number of different ingredient groups based on various categories. We have roughly 4000 different ingredients, so to make it easy if you're working with alcoholic beverages or butter and milk fat products, cheeses, coffee, herbs and spices, you can select one of those and see all the different ingredients that exist within that group.

For example, I've brought up a coffee ingredient group and you can see there's 17 different ingredients that fall into that group. 17 different types of coffee that we've included in that group. One of the nice things you can do with this is you can copy it, and let's say you're a coffee producer and you deal with 14 of those ingredients, you can take out a few different ingredients and customize that to yourself. And you could even add in other ingredients that are relevant to your organization. With that, you can then create your ... Then you have your own user defined ingredients group that is specific to your organization. That can be useful and that ingredient group can be used across the entire database. So what we can do here is, in the search tab we can look under a specific ingredient, but what I like to do is I like to look based on an ingredient group that's specific to my organization. I've created one that's called multigrain bread and I can search that ingredient or that group, and now all of the different records of the ingredients that are located within that group come up.

Now I can see that vinegar was adulterated. I can look at what it was adulterated with, acetic acid, brewed vinegar, distilled. I can look at flour. I can filter, based on adulterants or based on ingredients. I can filter based on things that are just hazardous to human health. Or even I could filter based on produced locations or distributed locations. So let's say I only buy vinegar from a certain area of the world, I can filter based on that if I wanted to.
The other thing I wanted to point out in this, as you can see we have different record types. Under record type here we have inference records and incident records. We have four different record types. And the reason we've done that is to really make it, allow you to find exactly what you feel would be most meaningful for your organization. So what you can do is, incidents means food fraud occurred. It occurred in a specific location, it occurred at a specific time of the year, and there was a specific impact. In this example here we see organic barley was substituted with non-organic barley. That happened in Italy and we see that it happened from 2007 to 2010. We can see the reference, we can see the reason for adulteration, and in this case we have multiple references associated with that. An inference record, in contrast, is let's say there is a report or let's say there was a peer review publication of food fraud occurring. That would be captured as an inference.

The reason we've done that is because someone did an analysis and wrote a peer review publication on detecting ... And I can bring up a specific example. Here we have one of vinegar. That vinegar report I was looking at that was adulterated with another type of vinegar. It was dilution or substitution for misrepresentation of geographic origin.
Someone wrote a peer review publication on this. We don't know that is occurring, but the fact that someone took the time to develop a method, write a peer review publication, and they're most likely funded by some organization to do this, we can infer that this type of fraud is occurring. But we can't say for sure, definitively, that it occurred on this date, in this location, and where. So that's another type of report. We also have surveillance records, method records. Surveillance is looking at how broadly around the world did fraud occur and we can also look at methods. Methods contains specific methods for, for example, detecting vinegar from a different source or different geographic location. That can be useful.

Some of the other things we've built into the database are analytics, so you can look at time series and how frequently adulteration has occurred over time. You can compare ingredients. You can look at geographic distribution, analytical methods, and in an easy tabular display. Some of these can be really useful especially geographic distribution to look at where around the world fraud is occurring and is it in places where I buy my ingredients from? And ingredient comparison. For example, if you have a lot of different ingredients how do you know which ones ... This provides a way to identify which ingredients have the highest number of records of fraud and have the most number of different adulterants that you'd have to look for. For example, here is wheat flour. It was adulterated, it has 19 different adulterants that were associated with it and 11 different records of adulteration occurring as it relates to wheat flour.

Those are just some of the tools that really allow you to assess how vulnerable some of your ingredients are or have been historically to fraud. Lastly, I'll just point out we also have a tool called an EMA Hazard Identification Report Builder. What this allows you to do is put in our ingredient group and we can run a report that basically takes all the ingredients that we have and creates a report that says which of these ingredients have been adulterated with something hazardous and what that hazardous adulterant was. So that's something that can be very useful especially to support some of the FSMA requirements in the preventive controls rule. That's just a little bit of highlight of the food fraud database. And with that, I'll pass this over to Sarah.

Sarah: Alright, thank you so much, Pete, for your presentation. I'm going to take the screen back over here.
Before I hand it over to Gary to get started, I'm going to ask our audience one more question. And that is, if you will be completing a vulnerability assessment for food fraud in the next 12 months, what is your plan to complete it? I'll give everyone about a minute to vote here. Alright, I'll give everyone just a couple more seconds here to get your responses in before I close the poll and display our results. Alright. I've shared our results on the screen here. It looks like a fair portion of the audience claim to complete their vulnerability assessment on their own. With that warm up, I will hand our presentation over to Gary Smith.

Gary: Alright, thank you Sarah. And thanks Peter for that excellent job in talking through the database and a little bit about USP. I'm going to go ahead and advance. Okay. I just wanted to talk just a little bit about Eurofins food safety systems, which is our complement to our testing functions that we do. We are a full service training provider and we're excited that in offering all of the GSFI recognized schemes including all of the ... In addition to the FSMA preventive controls for human food and animal food, environmental monitoring, and food safety auditing, and we can take all those training courses on site to your location as well.

We're also excited to be in collaboration with USP next year and we're going to be offering a food fraud workshop in conjunction with USP at a few locations throughout the year. And, certainly now that you're in our system, we will send you information about that. We also offer in our training and consulting group a full suite of consulting services including program development, GAP analysis, HACCP plan facilitation, FSMA GAP analyses, and again we're going to be talking a little bit later on about our ability to perform a vulnerability assessment on your behalf as well.
In our other group that is in our food safety team, we have a full auditing capability for all of our Eurofins branded audits, good manufacturing practices, distribution center, HACCP verification and we work with many of our industry partners like the International Bottled Water Association, the GFSI Global Markets Program, and some of those other folks you see there.

And, of course, we are a full certification body as well. An accredited certification body. So we handle and perform all of the GFSI recognized major manufacturing food safety schemes including SQF, BRC, FSSC 22000, IFS out of our Europe colleges and then we have some of our non-GFSI certification programs like FAMI-QS for animal feed, gluten free, et cetera. And then certainly at Eurofins we strive to provide competent and consistent performance of our services using industry experts, giving competitive pricing, and, as Sarah mentioned, we like to think of ourselves as a one stop shop, a full service provider who can access our global network to assist our partners and customers all around the world. And, most importantly, what we like to say is that it's our personalized customer service in spite of all the technical and all the competency and all the consistency opportunities that we have, it's that customer service and that personalized service that really sets us apart. And we'd like to welcome you to join us in those opportunities to service you.

Real quickly here, what I wanted to go through is focused on and compliments Peter's role on the database and USP and how the database works together. I want to talk and shift gears a little bit and focus more on why the big push now for food fraud? For those folks who have certification, what is it going to be looking like? What's an auditor going to be focusing on? And then just real quickly give some offers of examples of mitigation strategies.
Peter had done a great job of mentioning some examples. I'll tell you, some of the most common products that we get requests for testing, one of them includes honey and we do a lot of that here in our Des Moines location. This was a case where we actually had a public case of antibiotic substitution or additions, inclusions in honey, which is illegal here in the United States. It came from overseas and caused some major concerns and some product recalls.
Another example, which Peter mentioned quite a bit, olive oil. Which, again, we do in our laboratories here. We get quite a bit of requests for oil testing and authenticity testing specifically. As you see there, quite a few of olive oils, especially the extra virgin, were considered adulterated. You see our reference there is USP for that example as well.

One that I worked on specifically in my previous life was seafood. We actually had grouper down in Florida, the grouper fish, which was substituted with a Vietnamese catfish, Pangasius, obviously due to economic considerations. We had to work with the University of Florida to come up with some protein testing for that, which is much more commonly available now. And then, of course, probably everyone remembers the horse meat over in Europe, the horse meat substitution concerns. So just some examples where food fraud and substitution or inclusion has caused major disruptions within the food industry. Peter actually referenced this paper. The Global Food Safety Initiative started much of the conversation back in 2014, '15 with a lot of attention and a lot of activity around the food fraud. Actually, Eurofins partnered with the GFSI to author this position paper on food fraud, which is still available on the GFSI website and really kind of started the ball rolling of GFSI incorporating food fraud into its recent requirements document.

Starting basically in 2017, those standards which have GFSI recognition are going to have to include food fraud within them. And I'm going to cover the major food manufacturing standards here in North America next just to focus on exactly what it is that is being required and what you're going to have to present, essentially, to an auditor starting in 2018 to comply with that portion of your audit. GFSI has had a huge influence on the food fraud and all the attention that food fraud is getting. Certainly, I would say, the other thing that has driven a lot of the attention around food fraud, of course, has been consumers and, customers and retailers who want to really protect their brand and don't want to be known with a horse meat scandal or a seafood scandal or an olive oil scandal or a spice scandal or anything like that, and have really driven a lot of requests into their supply chain mapping to see what their risks are. And, more importantly, what can their mitigation strategies be? And we'll talk more about that in just a minute.

What I want to do now is focus on exactly what the languages that GFSI has entered into it's guidance document, now called the requirements document. What we're going to see is a theme. When I pull up the certified program owners or the scheme owners requirements, you're going to see the major theme. And this basically falls around two pieces. The first, the food fraud vulnerability assessment. And, again, what GFSI is basically saying is the standard shall make sure that the facility, the supplier, the manufacturing facility, conducts a food fraud vulnerability assessment with a risk type activity associated with it.

A documented procedure in which to do that with. That's number one. Number two is the mitigation plan. Obviously, once you do the vulnerability assessment and you determine what risks are within your supply chain, what are you going to do about it? And have a documented mitigation plan. And, again, there you see work it within the food safety management system within the organization. And the key within GFSI is that the food fraud plan should really focus on those food safety issues. As Peter mentioned, 25% of food fraud in the USP database had a food safety potential cause or effect, and that's where the GFSI is really having the focus be on those instances of food fraud, which are going to have a food safety ramification.

Let's take a look at some of the major standards. Of course, the largest standard here in North America under GFSI is the SQF. SQF, you may or may not know, has got a new version coming out. Edition eight, which starts January 2, 2018. Within it is the new section on food fraud, which basically states that you have to have a documented vulnerability assessment, which includes those activities that Peter had talked about. Substitution, mislabeling, dilution, counterfeiting or stolen goods. The facility must have a documented procedure to map their supply chain and consider those types of food fraud activities. Again, a vulnerability assessment. Conversely, then secondly, a food fraud mitigation plan shall be developed when the vulnerability assessment determines there are risks that need to be controlled and they shall be reviewed and verified annually. And then we must maintain a record.
I will mention here also that within the SQF world, in their manufacturing standard, as well as in their storage and distribution standard, food fraud is in both. So even under the storage and distribution world, food fraud requirement with vulnerability assessment is required to be in place.

Let's move over to BRC, who's been under version seven for a couple of years now. And they actually were the first standard to introduce what they called product authenticity. They don't use the term "food fraud," but that's essentially what they mean. And that came out in July of 2015, so BRC has actually had it out for a little while. BRC, the largest standard for manufacturing for food safety certification globally. Over 30,000 certificates to food safety have been issued to the BRC. Basically what they say is that again, shall have a process in place to access information on threats to the supply chain of raw materials, conduct a vulnerability assessment. You see that word again. You're going to see that theme over and over again. Again, based on risk it shall be reviewed annually. Where risks are identified, must have a process in place to do something to address the risk.

Appropriate assurance and/or testing procedures. That means the mitigation plan shall be in place to reduce the risk. You'll notice that, as BRC was one of the first to come out, their language on vulnerability assessment, food fraud, mitigation, strategies was a little behind some of the other standards which are later like SQF and FSSC. And you'll see a little different language as the standards come out. I will say, BRC is in the process of going to a version eight, which will happen in 2018 and 2019, and I'm sure they will update their language to match what we see in SQF and FSSC. FSSC version 4.1, which is going into effect in again early 2018, again talks about a vulnerability assessment. Identify vulnerabilities, develop control measures, prioritize them. Again, that's all risk based. And again, shall have mitigation steps to control those identified vulnerabilities. We see this same theme. We have to have a documented risk assessment, the vulnerability assessment, and we have to have, when the risks are identified what are we going to do about it?

So let's talk through that a little bit and what are those steps that you have to go through. It's important to know. GFSI has got over 13,000 certified facilities here in North America, in the U.S., Canada, and Mexico. And again, all of these folks ... If you hold any one of those certifications you will have to be handing a documented vulnerability assessment to your auditor starting in January 2018. So how do you do that? How do you come up with that vulnerability assessment? Obviously, as Peter talked about, first you have to think about your supply chain. Where do your ingredients come from? What are the ingredients? Conduct that vulnerability assessment. Identify the impacts. If there is substitution, what's the consequence going to be? What are the risks? How likely is it? How could I know if they do substitute it? Can you even tell? And, again, what's the frequency? What are the opportunities? And then prioritize those findings based on what are the biggest risks. Create that mitigation plan. What can we do about it?

If we do feel there is a concern, what can we do about it? And then implement track and again each standard talked about an annual review, and communicate that with your internal stakeholders, as well as your supply chain as well. When you're asking yourself those questions of what do we ... Looking at the supply chain, what should I be worried about? Here are some specific questions that may help you. Again, reviewing your raw materials. Are there any specific unique claims that are used to identify that ingredient? Even simple things like, is it supposed to be organic? Is it supposed to be kosher? Is it supposed to be halal? Is it really? In some cases you can look for the certification to help that. What about antibiotic free or hormone free? We see a big push for antibiotic free in the poultry industry. A big push for hormone free. Obviously, non-GMO. Gluten free. Again, there are certifications in place for gluten free. Spring water, oil, certain types of oil, certain types of honey, certain types of spice. Any of those types of traits or ingredients that are within.

Even if you have a spice pack that comes with it, that's already blended by somebody else, there's a chance for substitution. Also something to think about, is there a specific concentration of a mineral or a vitamin that you get, that you expect to get? Does that unique trait provide a substantial economic difference in the value of the raw material? Do you pay more for kosher ingredients or organic ingredients than you do non-organic? Do you pay more for non-GMO? How much more? Is it worth the risk for substitution? How easy would it be to intentionally or unintentionally substitute? Again, can you tell? Is it easy to see? Is it not? And then, finally again, how easy, is there a test method? Is it a visual? Is there any available assessment to determine if a substitution or an inclusion has been made? Those are some very basic questions that can help you get started in doing that risk assessment.

Again, at Eurofins we certainly would love to partner with you and talk about some of the solutions that we have for you to provide a solution for your food fraud program. And one of them is self-guided. We are a very proud reseller of the USP database. I'll talk a little bit about how you get to that in just a second. The guidance to conduct that vulnerability assessment online is provided to you so we can be your solution provider for that database if you want to do it yourself. Secondly, we can do it for you. And happy to do that, conduct that ingredient screen, provide you that documented vulnerability assessment that you can have for your facility, assess your risk for you, make recommendations on what your mitigation strategy should be.

If you want to do it yourself we have the tools to help you to do that. If you want to have us just do it for you, we certainly have the expertise in-house to do that for you. I mentioned the access to the USP database. It's right on our website there at the link. And, again, this will be in a presentation that Sarah sends out to everyone after the fact. You can go to see our food fraud services on our website and if you click on the little box there that says food fraud database, that gets you right into the registration system. We're actually offering a special right now for $1000.00 access to the database for 12 months. Normally it's $1200.00, so $200.00 off right now if you go online and want to access that database and conduct your vulnerability assessment on your own.

From an auditor's standpoint. I have the partnership with SQF, I actually participate in the SQF lead auditor trainings with SQF, as well as training our Eurofins auditors on food fraud and what are we going to expect to see and what are they going to be asking for in 2018? Some of the questions that we're getting the auditors queued up to be asking specifically and talk about, does the facility their auditing understand food fraud?
Peter mentioned food fraud versus food safety, versus food defense. I know sometimes we get confused with things like traceability versus product recall, what's the difference? So the auditor is going to make a general assessment of do the folks understand what is food fraud and what are the risks. Have they conducted that vulnerability assessment and is it documented?

The auditor will expect to see a document that says this is our vulnerability assessment, this was how we mapped our supply chain, here's how we evaluated the risks, here's what we thought was low, medium, high or red, yellow, green, whatever it is we use, and here's the tools we used to evaluate those risks. The auditor will make sure they've considered all raw materials, which could easily be substituted, their products within scope to make any claims or have unique attribute selling points. Again, if they offer organic, if they offer halal, GMO free, antibiotic free. Those are all products that potentially could have some substitution made and enhances that product marketability because of that claim.

Do they have any specific mitigation steps identified? Which again is the second part of the standard. That's the second part that the auditor's checking. If they've identified risks, what are they doing about it? Are those documented and do they have records that those steps have been taken? So that's what an auditor is going to be asking for. Obviously, the food fraud section of your GFSI audit is 10 or 15 minutes of a 2 or 3 day audit, but it's new and each of the auditors are being trained on that right now, as to how to go in and do that assessment, and what do they expect that vulnerability assessment to look like. What do they expect it to cover and what do those mitigation plans have to be?

Speaking of mitigation plans, let's talk briefly about that, real fast. Basically, there are two main types of mitigation that you can do. If you have risks within your supply chain for food fraud, for substitution, for inclusion, what are the two things that you can do about it? One, potentially authenticity testing. Eurofins is a leading provider of authenticity testing to the food industry. It's actually how our company was founded. You can do routine monitoring. A certificate of analysis on a concentration or a certain strength or requiring of a certificate of the facility saying it's gluten free or non-GMO or organic. You can do periodic verification where you just will pull a sample and occasionally test it for authenticity of oil or spice or honey or anything like that, juices.

Again, some of those common analyses include spices, oils, honey, juice, seafood, some of the products that we've mentioned. All very at risk, as it were, for substitution. And those would all be considered high risk. If any of those fall within your supply chain, and many more, but specifically if any of those types of products fall within your supply chain you definitely have a higher risk. The other mitigation activity that we can do for you is auditing. As we mentioned, the auditing that we have, certainly GFSI. Obviously, there's going to be a portion of food fraud in all the GFSI audits going forward. There is a food fraud certification that we offer that is part of our identify preservation program.

We also have built an addendum that you can add on to a non-GFSI audit to a GMP audit, just to get some verification that there is a food fraud program in place, a documented risk assessment, and mitigation activities when those are needed to be put in place. Basically, in summary, food fraud is a new set of criteria within the food safety certification standards being pushed through GFSI, but we know that authenticity concerns are not new. The main push for food fraud is economic, but it's the food safety concern that is what we're focused on when substitution can cause a food safety issue. Manufacturers are responsible for understanding their risk within their supply chain and any and all substitution or inclusion concerns. And you must ensure that those verification activities occur when your risks are determined through your vulnerability assessment, that you need to be able to take those.

And certainly we know there's going to be a learning curve now that ... Food fraud has come a long way, even in the last 12 months. And we know as the conformance and compliance requirements for the GFSI audits come into play in 2018, we're sure there's going to be a lot more learning opportunities there as well.
With that, I will turn it back over to Sarah.

Sarah: Alright, thank you Gary. Before we jump into our question and answer, I'm going to ask our audience just one more question. If you will be conducting mitigation activities to address food fraud in the next 12 months, what activities do you plan to complete? Go ahead and vote and then use your extra time to submit any questions that you might have for Peter or Gary during our question and answer. Alright, we'll give everyone a few more seconds. Go ahead and get your questions in as well. Okay, so I'll close our poll and present our responses. Alright. So let's jump into our question and answer. One of our attendees has asked, what about when an ingredient is seasonal or unavailable? What is acceptable and what is not?

Gary: As far as conducting the ... Well, I think all ingredients have to go through, and all suppliers have to go through your approved supplier program. The fact that an ingredient is seasonal, it still must be assessed within your vulnerability assessment. I guess the seasonality may potentially lead into a higher risk in that it may be only available for certain parts of the time and maybe not available other parts of the season.
So if you have to have that ingredient all year round, either you have identified other potential sources or you certainly leave yourself open to risk for substitution if all of a sudden the ingredient is available when it's not in that season. I don't know if Peter has any other thoughts on that, but I would say it certainly has to be considered within your vulnerability assessment and having it a limited availability may increase it's risk.

Sarah: Alright. Peter, a question for you. Someone's asked, how was the data for the food fraud database collected?

Peter: Great question. It's really a continual basis. Here at USP we have a team of scientists who are dedicated to finding records around the globe using various analytical search capabilities. We collect it. A lot of it is media reports. We get peer review publications. We get some from, directly from, a lot from government reports around the globe. We translate them, we analyze them, and then we put them into a format that allows them to go into our database to make them searchable and to be able to use in reports and analytics and things like that.
It's really collected all the time. Every day we're entering in new records and it's from around the globe from a lot of various sources through government, even Freedom of Information Act, and through trade associations as well.

Sarah: Alright, thanks Peter. One attendee, Barbara, has asked what is the food allergen in the olive oil adulteration incident? Peter, do you have the answer to that?

Peter: You know, that's a good question. There's a lot of records of food fraud, so I'm not familiar with every incident of adulteration or that specific one, unfortunately. I can certainly look into it and follow up with Barbara if I get her contact information. But I'm not aware of that specific incident. I don't know if, Gary, if you're aware of that specific incident?

Gary: Yeah, I have heard of some instances of peanut oil, an non-soluble treated peanut oil being substituted for olive oil and sometimes soybean oil substituted. And depending on how they're creating those oils, a lot of times they'll bleach them or they'll use some chemical reagents to denature the proteins. And sometimes they don't, so it kind of depends on how those are built. How those are made, those oils, and if they're using a non-soluble treated protein oil like peanut or soy into an extra virgin olive oil, and cutting it, as it were, with inclusion, diluting it, that could certainly lead to an allergenic reaction.

Sarah: Someone has asked a clarifying question. What's the difference between the USP database and Eurofins? Gary, do you want to explain our collaboration?

Gary: Sure, Sarah. And thanks, that's a great question and that's the crux of our webinar here today. Eurofins and USP have collaborated, so basically we are providing access to our customers to the USP database. The database that Peter described there. And basically we're giving you the option to say, look, if you want to access the database you can do so through us, we can give you that special pricing and you can go in and conduct your vulnerability assessment on your own. Or if you'd rather partner with us and just say, you know what Eurofins you do it for me, I don't have to access the database, Eurofins is willing to access the database for you. We will map your supply chain. We will conduct your ingredients screen. We will develop your vulnerability assessment for you and make recommendations for your mitigation plan. So, basically we're collaborating with USP. We're using a lot of the tools that USP has available and offering to you whatever options you want available to be able to comply with that requirement of that documented vulnerability assessment.

Sarah: Awesome. Well, it looks like we're running over time and people are starting to jump off. With that, I would like to thank you, Peter, from USP one final time, and you, Gary Smith, from Eurofins one final time. Thank you to all of our attendees who tuned in today.
As I said before, we'll follow up on any unanswered questions via email and you will all be sent a copy of the slides and the recording within two business days. Thank you everyone and have a great day.