About Codex Alimentarius

I've been wanting to write this particular blog for awhile now.  In my professional career the Codex Alimentarius has been mentioned by the SQF / BRC standards, by teachers of HACCP, as well as GFSI consultants.  What has not occurred is,  anyone showing me the code.  I needed to look for it myself - which anyone can (the standards and documents are free).

A bit of History

Codex Alimentarius is Latin for "Food Code".  As my teachers, standards, etc said - the codex is a set of guidance documents based on Science.  The codex is (in the English version) a set of 324 documents.  This body of work has been compiled by an organization that was formed by the WHO (World Health Organization) and the FAO (Food and Agricultural Organization of the United Nations).   GFSI sources this code for their standards which, in turn, SQF / BRC / FSSC 2200 draw their standards.  Knowing the Codex, I have found, helps in the understanding of the various food accreditation schemes.


What is in the Codex?

 There are five types of documents in the codex:

1. Standards - Specific to various foods
2. Guidelines - items such as Nutritional Labeling
3. Miscellaneous - example, glossary of terms
4. MRL (one document) - Maximum Residual Limits for substances like pesticides
5. Codes of Practice - such as Principles for Food Hygiene

Of course, federal and regional governments may have laws that differ/exceed the Codex and must be adhered to.  It is also interesting to note, the Codex does reference ISO documents.  ISO is a great resource in understanding what is required of food production and safety.  ISO can also show where the codex will be in regard to new and updated standards.  For example, I am of the belief that "Food Security" and "Food Anti-Fraud" standards / guidelines will be more developed in the next few years because ISO is currently developing standards in these areas. 

Some Specific Documents to get You Started!

1. CAC/GL79-2012 - Control of Viruses in Food.  Interesting that this particular document looks at Design of Facilities in Section 4.  Specifically, that toilet facilities can be located next to processing areas but not with "direct access to" the processing area.  I did always wonder where this stipulation came from.  Canadian guidelines state that this is needed only for meat processing facilities or facilities supplying the meat processor.  I like what the Codex has stated - the toilets in all food processing facilities can not be accessed directly from the food processing areas.
2. CAC/GL50-2004 - Guidelines on Sampling.  Procedures on statistically relevant plans for the commodity being sampled.  Both for Quantitative and Qualitative data (see my blog of June 21, 2013).  This document also references ISO information and gets heavily into statistics.
3. CAC/GL60-2006 - Traceability Guidelines.  I found this very basic and looks to be something for governments to use and expand upon.
4. CAC/RCP1-1969 - General Principles of Food Hygiene.  This doc reads similar to the above "virus control" document.  It is intended to be used from primary production to the final consumer.  It describes areas such as Design and Layout, Water Supply, Monitoring Equipment, Cleaning, and Storage and Transport.  Effectively a facilities HACCP pre-requisite standards.  It finishes with HACCP basics and HACCP application.  This particular document (in my opinion) is a must read and a must learn.
5. Others - WOW! Docs for canning, dried fruit, eggs, frog legs, edible oils, corned beef, etc, etc, etc.  Lots of information to sink into and learn.

To see the Codex documents, click on the link below:

 www.codexalimentarius.org

Quantitave vs Qualitative Data

Back on March 29, 2013 I blogged about how to use Histograms as part of Statistical Process Control.  The Histogram I used dealt with numerical data (quantitative).  However, there is another type of data - Qualitative.  How do we plot this qualitative information?

Let's review the previous blog which included quantitative histograms.

In essence, a histogram is a collection of data points from a set of samples - let's say, for example, the weights of jelly filled donuts.  To get a reasonably accurate histogram will take about 50 data points.  These data points will outline the variability (measurement distribution) in the process - the variation of donut weights in our example.  For most processes, we will see a "normal" or bell shaped curve, as show below.  If you see multiple peaks, there is something affecting your variation that needs investigating.

 

Constructing the above histogram takes a few steps.  Step one is to gather your data.  Step two and three is to determine the data range and the number of classes (columns in the graph).  Step three is collecting the data into a frequency table (again the columns that will be used in the graph). Last step is to plot the columns into your histogram.  I do have to say that Excel does a great job on taking your data and quickly sorting it into a histogram ready form.  So here is our example below.

OK - the above is quantitative histograms, i.e. usage of measurement data.  Usage of a histogram is great for this type of information. Qualitative information is a bit different.  In qualitative date we talk in terms of items such as hair colour, gender, type of donut purchased.  The information does not lend itself to sorting into a chart such as a histogram.  In real life an example of this type of data is customer complaints received by customer service.  Yes, there is numerical information (# of jelly donuts with no jelly) but the type of information is qualitative.  This lends itself in being formed into Pareto, general bar graph, pie graphs.  An explanation of a Pareto is below.

A Pareto Chart is a very simple method of Data analysis that, at its heart is the 80 / 20 rule.  80% of the problems are from 20% of the causes.  Pareto charts can be used in charting events like customer complaints, where there are several types of issues.  The best way to proceed is to first collect the complaints and then organize them from most to least frequent.  Excel can do this task from a complaint list which is summarized in pivot table.  This pivot table can be charted and you can also add a line that tallies the frequency of each complaint.  When you reach 80% of the complaints, you focus on the issues that make-up that 80% amount.

 The above is a quick example of jelly donut issues at a retail store.  The left axis is the number of complaints and the right axis is the cumulative frequency of complaints.  Ordered in this way, it is easy to see "filling squirting out"  is the largest complaint but is this the only complaint to focus on?  The cumulative frequency reaches 80% at "donut crumbled".  So, to correct 80% of the problems we need to solve both the jelly squirting and donut crumbling issues.

ASPECTS OF FOOD FRAUD - PART 3 of 3

In the first two parts, of this series, I explained the different types of food fraud and why food fraud is such a large problem - not only from a safety point, but from a supply chain management and risk management perspective.  But how do we combat food fraud?  After all, food fraud has been around for as long as food has been bought and sold.

THE ANSWER????

Is the answer to prosecute the fraudster?  In part, yes.  However - even if we jail 4 of every 5, there would still be 1 fraudster doing what we don't want.  Plus, getting the evidence takes time and cooperation with government agencies (the police and customs for example).  As a company, do you wish to have the increased risk on your product for enough time to get the evidence needed to prosecute?  The risk is for the upper management to determine.  I believe the better way is prevention.




ITEMS NEEDED FOR PREVENTION

1. True "buy in" from Upper Management.  In other words a clear strategic direction, resources, and training.
2. Knowledge of national and international legislations and related Documents (the below is not an exhaustive list).  Learning a common language so you can talk about the issues, not only in the company but with subject matter experts at places like Michigan State University.
• ISO 31000 - Risk Management practices
• ISO 28000  - Security Management systems
• ISO 22000 - Food safety
• USP - US Pharmacopeia - methodologies to discovering adulterated products
• GS1 - Supply Chain Standards, best practices
• GFSI (codex) - Global Food Safety Initiative
• FD&C act chapter 4 section 401 subsection 342 - food adulteration(American Federal Food, Drug, and Cosmetics Act)
• TC 247 - Anti-Theft practices and becomes ISO 12931
• Canadian Food and Drug Act
• US Food Modernization Act
3. Potential designation of an employee who's main focus is looking at fraud
4. Finding out how food fraud can occur in your company - where are the weaknesses in your systems and procedures.
5. Detailing of the risk cost analysis stemming from the loss due to potential fraud.  This will need the help and advisement from account departments.  After all, QA and packaging personnel generally have little knowledge about business finance.  What is the tolerance level of risk for your company?
6. Being Watchful.  You will not be able to stop all fraud.  The fraudsters will continue to find new ways to get around you and your procedures.  Looking for trends (market monitoring, seizures, NCFPD database - EMA) and unusual occurrences is important.  Check out foodfraud.org - which is the USP

SUMMARY

Prevention of Food Fraud will take involvement and ideas from criminology, food science, Quality Assurance, Packaging, Procurement, sociology, economics, and others.  The point is to reduce the opportunity for the fraudster to penetrate your company and supply chain.  Increase the difficulty of fraud, increase the risk of getting caught, and decrease the economic advantages to the fraud.  Difficulty can be increased with better traceability, tamper proof packaging, authentication exercises, and security measures against theft.  These actions can be Overt (holograms on packaging), Covert (watermarks or black light marks), or Forensic (lab tests).

ASPECTS OF FOOD FRAUD - Part 2 of 3

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How serious is FRAUD?  Let me pose a couple questions.

 - I mix 10% high fructose corn syrup into honey and sell it as 100% pure Honey.  I make more margin and it is not hurting anyone.
 - People can eat horse - so I mix horse meat into my beef - so what?
 - People can't tell the difference between Tilapia and Red Snapper.  So I make more money and sell the Tilapia as Snapper - it's still good quality fish!
 - I can get more by smuggling my green coffee from country X into country Y, re-bag and then sell it as country Y.
 - There is a lower import tariff on my cabbage if I say it comes from Mexico and not Canada.  It is still cabbage and a good product.  I am not hurting anyone.
 - The product is still good, it is OK to change the best used by date.

These are all statements to get several points across.  The first is that the fraudster is doing this to make/save money.  In the case of the honey, the corn syrup is not an allergen and is a safe, lower cost substitute.  The problem is, with this example and the others, there is no transparency to the supply chain.  If there is a problem with the corn syrup - good luck doing a recall because there will not be a record of this raw material adulteration.  Neither will you be able to do a complete hazard analysis because there is no information on the manufacturing conditions of the corn syrup.  Thus, you will not know how extensive the problem is in your product.

Secondly, Tilapia is half the price of Red Snapper.  From a consumer perspective - I am not getting the quality that I am expecting.  If I purchase a Lamborghini - I expect a Lamborghini engine, not a Volkswagen engine.  Not that there is anything wrong with a Volkswagen - it is just the fact that it is not what I purchased.  Money is tight for many people - why should we give money away so some one else can live better (without honestly working for it).

Third - The reason for import Tariffs is to discourage product dumping.  And again, when a country of origin is changed, any issue with the product cannot be traced back to the originator.  I seriously doubt that the company/people in country X have kept documentation of the change stating "produced in country Y". 

Fourth - By changing the ingredient, country origin, date coding, location of where the product can be sold, etc. You are increasing the food safety risk to the consumer.  You loose transparency on issues such as allergens, sanitation, pesticides, heavy metals, antibiotics, and quality - just to name a few.

Fraud is a crime of opportunity which may or may not cause a food safety issue.  The fraud could endanger customers, consumers, brand equity, employment, and trust in a company. 

In part three - how to combat food fraud.