HOT SOURCEEXPERT INSIGHTS INTO SAFE, SUSTAINABLE AND HIGH-QUALITY FOOD

ISSUE 12 • OCTOBER • 2016

MODERN SLAVERY IN THE GLOBAL FOOD SUPPLY CHAIN

ENFORCEMENT OF EU FOOD LABELLING LAW – ARE YOU READY?

GETTING STARTED WITH US FSMA COMPLIANCE

NEW US LABELLING LAW FOR BIOENGINEERED FOODS

MINERAL OIL RESIDUE IN FOOD: HOW SGS HELPS WITH ACCREDITED ANALYTICS

CORPORATE SOCIAL RESPONSIBILITY IN THE SEAFOOD SUPPLY CHAIN

SGS’S FOOD TESTING CAPABILITIES IN HONG KONG

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DEAR READER,After a busy few months of new services, social responsibility issues and US and European regulatory updates, our experts deliver a roundup of the latest food industry news.

Western governments are introducing legislation to combat modern slavery and child labour. The food supply chain, with its global reach, has an important role to play. We summarise new legislation and some surprising statistics on the industry’s preparedness!

Regulatory updates for food safety are nothing new – but that doesn’t make the latest changes any less important. In the EU, food labelling rules issued under Regulation (EU) 1169/2011 will become compulsory on 13 December. Find out all you need to know to comply. Across the Atlantic Ocean, the US FSMA is possibly the most sweeping reform of US food safety laws in more than 70 years. SGS Global FSMA Program Director Hank Karayan explores the first steps to compliance.

Also in the USA, a federal law has been enacted the National Bioengineering Food Disclosure Law, providing countrywide protection and consistency for consumers. Jim Cook, SGS Food Scientific and Regulatory Affairs Manager explains in more detail.

With consumer organisations and retailers taking a zero tolerance approach to the issue of mineral oil hydrocarbons our team in Germany has established an accredited analytical method for their identification.

The seafood industry supply chain is complex and regulated, but NGOs, consumers and the media frequently knock its reputation for sustainability. We look at some of the issues and opportunities for improvement.

In the latest in our series of lab focus articles, we profile SGS’s food testing laboratory in Hong Kong.

For the complete range of SGS services and support visit: www.foodsafety.sgs.com.

SGS AGRICULTURE AND FOOD TEAM

CONTENTS

Modern Slavery in the Global Food Supply Chain – Read Article Page 3

Enforcement of EU Food Labelling Law – Are You Ready? – Read Article Page 4

Getting Started with US FSMA Compliance – Read Article Page 6

New US Labelling Law for Bioengineered Foods – Read Article Page 8

Mineral Oil Residue in Food: How SGS Helps with Accredited Analytics – Read Article Page 10

Corporate Social Responsibility in the Seafood Supply Chain – Read Article Page 12

SGS’s Food Testing Capabilities in Hong Kong – Read Article Page 14

SGS WEBINARS, EVENTS AND SAFEGUARDS

Information on Upcoming Food Webinars, Events and the Latest Food Related Safeguards – go to pages Page 15

EDITORIAL

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MODERN SLAVERY IN THE GLOBAL FOOD SUPPLY CHAINWith western governments introducing legislation to stamp out slavery and child labour, businesses in the food industry must now ensure their supply chains are compliant with global expectations of corporate social responsibility.

With UNICEF estimating 150 million children are involved in child labour, and countless more adults forced into practices commensurate with slavery, many governments are looking at ways to stop companies, who benefit from forced labour, operating within their borders.

High demand for cheap products means that companies take advantage of the economic benefits that can be accrued from a global supply chain. The problem is, businesses at the end of a long supply chain may have no interaction with operators in the early stages of the supply chain. Authorities in the UK and USA are now seeking to place responsibility for the working conditions of those engaged along the supply chain, at the door of the companies that ultimately benefit from their labours. Following a recent report by World Vision Canada into global child labour, there are now calls for similar legislation in Canada, and it is expected that other countries will begin to contemplate comparable laws.

Following US President Obama’s signing of the Trade Facilitation and Trade Enforcement Act of 2015, which included a provision banning the importation of goods produced by child and forced labour, the US Bureau of International Labour Affairs is required to compile an annual list of goods produced by forced labour. Since the law was enacted in February 2016, US Customs and Border Protection has impounded three imported products, including a common food sweetener. The importer has been given three months to prove that it is not manufactured by convict labour.

With western consumers demanding access to dishes and products from around the world, the food industry needs to be particularly vigilant about its supply chains. Companies at the end

of a supply chain need a mechanism whereby they can be assured of the ethical and labour conduct of those further up the supply chain.

Transparency-One, in partnership with SGS, gives companies at the end of a supply line, access to data relating to businesses along their complete supply chain. An open business-to-business network, it allows operators to collect product, ingredient and facility information declared online by suppliers, and their own suppliers. It also means, those at the end of a food supply line can be assured that all businesses along the chain are compliant with food safety legislation and with the minimum labour standards demanded by the destination country or by those at the end of a food supply chain.

Transparency-One works because it is the end user who instigates the supply chain mapping. Once a chain has been created, each company can examine all the facilities they have been given access to and make sure they are compliant with recognised social auditing and certification schemes. The system will also detect non-audited

or non-certified suppliers, alerting the company to a potential business risk and triggering remediation plans. For example, it can help instigate facility inspections to ascertain compliance with industry standards.

Working with Transparency-One reduces risk to a company and encourages minimum labour standards globally. It will also help a company reduce the possibility of food fraud, unsafe food practices and forced labour appearing in their supply chain. At the same time, Transparency-One can also help enhance supply chain efficiency and build customer confidence, helping to improve brand recognition.

For the complete range of SGS services and support visit www.foodsafety.sgs.com or send an email to food@sgs.com.

GEORGES LE NIGEN Commercial Director Phone: +33 (0)141248888 Email: georges.lenigen@sgs.com

SGS Agriculture and Food

MODERN SLAVERY IN THE GLOBAL FOOD SUPPLY CHAIN

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ENFORCEMENT OF EU FOOD LABELLING LAW – ARE YOU READY?European Union (EU) regulations making it mandatory for prepacked and non-prepacked foods to display certain information came into force in 2013. These rules, issued under Regulation (EU) No 1169/2011 Article 9 (1) point (I), will become compulsory from 13 December 2016.

Prepacked foods will be required to display labels containing data relating to the amount of energy contained within the products, as well as information declaring the amounts of fat, saturates, carbohydrates, sugars, proteins, and salt, contained within the product. In addition, the label will need to present data relating to any nutrient, or other substance, for which a nutrition or health claim has been made for the product.

Figures relating to amounts of nutrients must be expressed in grams (g) per 100g or per 100ml, and for energy values, the figures must be displayed in both kilojoules (kJ) and in kilocalories (kcal) per 100g or per 100ml of food. It is stipulated that the value in kilojoules must be given first, followed by the value for kilocalories. In both cases, the abbreviations – kJ and kcal – are acceptable.

This regulation also allows for additional information to be declared. For example, values relating to ‘per portion’ or ‘per consumption unit’ can also be applied, so long as the portion or consumption unit is easily recognisable by the consumer and the amounts are clearly quantified on the label and in close proximity to the nutrition declaration. Additionally, the number of portions or units contained in the package must also be stated on the label.

The energy value and the amounts of fat, saturates, carbohydrate, sugars, protein and salt may also be expressed as a percentage of the reference intakes specified in the following table per 100g or per 100ml. In addition to, or instead of, such a declaration per 100ml or per 100g, the percentages of the reference intakes can be expressed per portion or consumption unit.

ENERGY OR NUTRIENT

REFERENCE INTAKE

Energy 8400 kJ/2000 kcal

Total fat 70 g

Saturates 20 g

Carbohydrate 260 g

Sugars 90 g

Protein 50 g

Salt 6 g

In cases where the energy value or the amount of nutrient(s) in a product is negligible, the information on those elements may be replaced by a statement such as ‘Contains negligible amounts of …’ to be indicated in close proximity to the nutrition declaration. If space permits, the declaration shall be presented in the form of a table, with numbers aligned. A linear format may be used if there is insufficient space for a table. The declared values shall, according to the individual case, be average values based on:

• Manufacturer’s analysis

• Calculated from the known or average values of the ingredients

• Calculated from generally established and accepted data

The mandatory nutrition declaration may also be supplemented with an indication of the amounts of one or more of the following:

• Monounsaturates

• Polyunsaturates

• Polyols

• Starch

• Fibre

• Any of the vitamins or minerals listed in point 1 of Part A of Annex XIII, and present in significant amounts as defined in point 2 of Part A of Annex XIII of EU Regulation 1169/2011

ENFORCEMENT OF EU FOOD LABELLING LAW – ARE YOU READY?

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The nutrition declaration must be printed in a font size where the x-height of the characters is greater than, or equal to, 1.2mm. For smaller packaging, where the largest surface area is less than 80cm2, the x-height has to be a minimum of 0.9mm.

It should also be noted that a nutrition declaration in the format required by the US and Canada would not be in line with the EU requirements, as both mandatory and voluntary information have to comply with the rules laid down in the EU Regulation. Such labelling might also mislead the consumer because of the different conversion factors used in the US to calculate the energy value and the quantity of nutrients.

For non-prepacked foods, the content of the nutrition declaration is not mandatory, when food is sold to the final consumer or to mass caterers, unless member states have adopted other national measures. Otherwise, it can be limited to the energy value or the energy value together with the amounts of fat, saturates, sugars, and salt.

The nutrition declaration is required for the food as sold, but, instead and where appropriate, it can relate to the food as prepared, provided sufficiently detailed preparation instructions are given. It is therefore possible to include only the nutrition information ‘as prepared’ for consumption on foods, such as dehydrated powdered soup.

EXEMPTIONS

A number of products are exempt for the requirement for a mandatory nutrition declaration, as per ANNEX V of Regulation (EU) 1169/2011. These include:

1. Unprocessed products that comprise a single ingredient or category of ingredients

2. Processed products for which the only processing they have been subjected to is maturing and that comprise a single ingredient or category of ingredients

3. Waters intended for human consumption, including those where the only added ingredients are carbon dioxide and/or flavourings

4. Herbs, spices, or mixtures thereof

5. Salt and salt substitutes

6. Table top sweeteners

7. Products covered by Directive 1999/4/EC of the European Parliament and of the Council of 22 February 1999 relating to coffee extracts and chicory extracts, whole or milled coffee beans and whole or milled decaffeinated coffee beans

8. Herbal and fruit infusions, tea, decaffeinated tea, instant or soluble tea or tea extract, decaffeinated instant or soluble tea or tea extract, which do not contain other added ingredients than flavourings which do not modify the nutritional value of the tea

9. Fermented vinegars and substitutes for vinegar, including those where the only added ingredients are flavouring

10. Flavourings

11. Food additives

12. Processing aids

13. Food enzymes

14. Gelatine

15. Jam setting compounds

16. Yeast

17. Chewing-gums

18. Food in packaging or containers the largest surface of which has an area of less than 25 cm²

19. Food, including handcrafted food, directly supplied by the manufacturer of small quantities of products to the final consumer or to local retail establishments directly supplying the final consumer

The rules do not apply to the following foods, which have their own nutrition labelling rules:

• Food supplements

• Natural mineral waters

• Foods for particular nutritional uses, unless there are no specific rules relating to particular aspects of nutrition labelling

The new mandatory nutrition declaration will come into effect on 13 December 2016. Products which have been placed on the market, or have been labelled, prior to 13 December 2016, but which do not comply with point (l) of Article 9(1) of the Regulation (EU) 1169/2011, may be marketed until the stocks of the foods are exhausted.

For the complete range of SGS services and support visit www.foodsafety.sgs.com or send an email to food@sgs.com.

ALEXANDRA DEDEILIA Food Business Manager Phone: +30 210 572 0777 Email: alexandra.dedeilia@sgs.com

SGS Agriculture and Food

ENFORCEMENT OF EU FOOD LABELLING LAW – ARE YOU READY?

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GETTING STARTED WITH US FSMA COMPLIANCEThe US Food and Drug Administration’s (FDA) Food Safety Modernisation Act (FSMA) is considered the most sweeping reform of US food safety laws in more than 70 years. SGS Global FSMA Programme Director Hank Karayan explores the first steps.

The US FDA Food Safety Modernisation Act shifts the focus from responding to contamination to preventing it, and is based on seven foundational rules for compliance:

1. Preventive Controls for Human Food

2. Preventive Controls for Food for Animals

3. Standards for Produce Safety

4. Foreign Supplier Verification Programmes (FSVP) for Importers of Food for Humans and Animals

5. Accredited Third-Party Certification

6. Sanitary Transportation of Human and Animal Food

7. Mitigation Strategies to Protect Food Against Intentional Adulteration

PREVENTIVE CONTROLS FOR HUMAN FOOD

The Preventive Controls for Human Food (PCHF) rule lays the foundation of preventive food safety in FSMA. It applies to domestic and foreign facilities that manufacture, process, pack, or hold human food.

There are modified requirements for certain “Qualified facilities” such as very small businesses or warehouses that solely engage in storage of unexposed packaged food. Seafood, juice, alcoholic beverages and dietary supplements are exempt from hazard analysis and preventive controls (but not GMP) provisions under the rule. All other entities are expected to comply with the full letter of the law.

GETTING STARTED

One of the main questions most facilities ask about FSMA is how to take the first steps towards compliance.

External factors such as geography, food sector and country-specific regulatory requirements influence corporate food safety. However, one of the main internal factors in setting the first compliance steps is the maturity of the existing food system (including systems, preparedness, culture and awareness).

The food safety system in place will determine the required path to FSMA compliance. That’s because food safety in general has witnessed many phases in its evolution from Codex HACCP all the way to current revisions of international standards. At each phase, requirements were adjusted or added to address specific market, product, regulatory and stakeholder needs. In addition, subsequent scheme-specific requirements inject another variable into the formula, thus differentiating one scheme from the other and influencing the path to FSMA compliance.

In general, the more advanced the current management system is, the shorter the path to FSMA compliance. The way the company is positioned on the food safety evolution (or maturity) curve is therefore an indicator of the work required to achieve FSMA compliance.

While GFSI certification is a popular option, the majority of players in the global food supply chain supplying to the US have no GFSI certification. For these entities the food safety compliance scheme of choice remains HACCP, or a combination of HACCP with a management system either as two separate systems (e.g. HACCP & ISO 9001) or a combined system such as ISO 22000. In other cases, suppliers may have no formal food safety system in place except those required by specific clients and verified at client-imposed frequencies. However, as illustrated by Table 1, GFSI certification offers a closer fit to FSMA compliance.

GETTING STARTED WITH US FSMA COMPLIANCE

FSMAApplicability variance Low

High

GMP / 2ND PARTY

HACCP

HACCP + MANAGEMENT SYSTEM

GFSI

Deg

ree

of F

SM

A c

ompl

ianc

e

Food Safety Systems

Table 1 shows the maturity curve and the correlation between food safety systems and FSMA compliance for facilities covered by the regulation, with some scenarios.

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EARLY IDENTIFICATION OF GAPS

Once FSMA applicability criteria are established, the first step would be identifying gaps in the current system through self-assessment or third party gap analysis against FSMA requirements. This essential step also helps you evaluate the time, energy and resources needed to address any gaps in your system.

Next, determine your training needs. Training is a critical success factor in FSMA implementation, and has been identified as a FSMA requirement. The regulation has PCQI (Preventive Controls Qualified Individual), QI (Qualified Individual), Auditors and Sanitary training requirements that must be considered.

FOUNDATION FOR SUCCESS

If you already have a food safety system in place, use it to build your food safety plan. The regulation may have specific terminology in place, but eventually you may want to reference documents from your existing system and include them in your Food Safety Plan.

While your existing food safety system will be of help in addressing FSMA requirements, it is important to note that with FSMA, there is a shift in philosophy when it comes to hazard analysis and food safety in general. Your critical control points (CCPs) would become process controls, but you would still need to address other process controls, food allergen preventive controls, sanitation and supply chain preventive controls. It is therefore recommended to complete a separate hazard analysis for FSMA and then determine the elements of your existing food safety system to reference (and include) in your food safety plan. This would be one of the main tasks to be undertaken by the facility PCQI along with the other functions specified under the rule.

Once you have your food safety plan ready for review, consider a gap assessment. This is an objective means of reviewing your food safety plan and verifying its implementation onsite. It would certainly be a valuable exercise in preparation for your FDA inspection.

From conformance to compliance, FSMA has proven to be a game changer in food safety. While voluntary schemes help reduce the gap, FSMA compliance remains a requirement of its own for US and foreign companies covered by the regulation. Soon, foreign suppliers will also have the option of FSMA certification within the Voluntary Qualified Importer Programme (VQIP), opening the door to new possibilities in food safety evolution.

SGS FSMA SERVICES

Using a variety of tools and services SGS is a leader in FSMA compliance:

• FSMA self-assessment by SGS is a complementary online tool for FSMA readiness. Start your self-assessment today.

• SGS offers FSMA PCQI and other FSMA-related courses through public, onsite and virtual classrooms. Check out the SGS training schedule.

• Gap assessment services for facilities and suppliers with or without existing certification, to help prepare for FDA inspection and FSMA certification

SGS can meet all your audit, technical expertise, training and testing needs related to FSMA.

For the complete range of SGS services and support visit www.foodsafety.sgs.com or send an email to food@sgs.com.

HANK KARAYAN Global FSMA Program Director Phone: +1 (514) 402-5810 Email: hank.karayan@sgs.com

SGS Agriculture and Food

UNDERSTAND THE RULES

Applicability Check

IMPLEMENT

Pre-Assessment/Consultative Audit

IDENTIFY GAPS

Self Assessment/Gap Analysis

FSMA COMPLIANT

FDA Inspection/FSMA Certification

DEVELOP SYSTEM

Training/Technical Expertise

GETTING STARTED WITH US FSMA COMPLIANCE

STEPS TO FSMA COMPLIANCE

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NEW US LABELLING LAW FOR BIOENGINEERED FOODSBuilding on the work of individual states in preparing and implementing laws to regulate the labelling of bioengineered foods, the USA has enacted a federal law providing countrywide protection and consistency for consumers. Jim Cook, SGS Food Scientific and Regulatory Affairs Manager explains in more detail.

On July 1, 2016, the USA’s first labelling law, the Vermont Genetically Engineered (GE) food labelling law Act 120 became effective but as of July 29 when President Obama signed the National Bioengineering Food Disclosure Law1 it will no longer be enforced. This new law also eliminated the Vermont’s GE Seed labelling law and Alaska’s GE Salmon labelling law because the federal law supersedes all GE State laws.

Since the Vermont Law came into effect some products shipped to the State of Vermont had labels/packages listing their GE status. Some of the companies involved have already stated that these products will continue to carry this information.

The term bioengineered applies to food for human consumption as defined by the Food, Drug and Cosmetic Act, that contains genetic material that has been modified through in-vitro recombinant deoxyribonucleic acid (DNA) techniques and for which the modification could not be obtained through conventional breeding or found in nature.

THE NATIONAL BIOENGINEERING FOOD DISCLOSURE LAW

The new law (section 293B.2.A and B) requires the United States Department of Agricultural (USDA) Agricultural Marketing Services (AMS), to develop regulations that will require the labelling of bioengineered products, within two years. This law requires the labelling of bioengineered products and possibly products with bioengineered ingredients, but the disclosure of this information provides a few options:

1. Text

2. Symbol (to be determined)

3. Electronic or digital link, excluding internet URLs not embedded in the link

The electronic or digital link that this law refers to is the Quick Response (QR) Code. This code can be accessed by a consumer provided they have access to a device with a QR code scanner application (app) and a reliable internet connection, to determine at the point of purchase whether a food was produced using genetic engineering. However, this may also provide less visibility on labels as to whether it contains bioengineered ingredients or is produced with non-bioengineered ingredients, a problem consumer groups wanting bioengineered food labelling have with this law. The label would have to state “scan here for more food information” or similar, but

as some companies already provide other information via QR codes this phrase may not be an indicator of bioengineered status. Additionally, small food manufacturers will be allowed to provide a website link to information and a phone number with the phrase “call for more food information”, as well as an additional year to comply. There will also be reasonable disclosure options for small and very small packages.

To verify the success of option three, within one year of the enactment of this law, the Secretary of Agriculture must carry out a study to identify potential technological challenges that may impact whether consumers would have access to the bioengineering disclosure through electronic or digital methods.

EXEMPTIONS

There are exemptions for restaurants and similar retail establishment and for very small businesses.

NEW US LABELLING LAW FOR BIOENGINEERED FOODS

1http://www.agriculture.senate.gov/imo/media/doc/Mandatory%20Labeling%20Bill.pdf

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CONSUMER ISSUES

Other problems for consumer groups include the narrowness of the bioengineering definition and the lack of recall authority written into the law.

While this law will apply to food regulated by the Food, Drug and Cosmetic Act, it will only apply to meat (including siluriformes such as catfish), poultry and processed egg products, if the predominant ingredient is that regulated by the Food, Drug and Cosmetic Act. However, if the predominant ingredient is broth, stock, water or similar then the secondary ingredient would have to be regulated by the food Drug and Cosmetic act in order for this to apply to the product. On August 19, the USDA Food Safety Inspection Service (FSIS) announced that they will issue guidance2 that will allow meat (including siluriformes such as catfish), poultry and processed egg products to list non-bioengineered claims in accordance to this law and subsequent regulations.

NON-BIOENGINEERED STATUS

While the bioengineered status of a product may be readily known, the non-bioengineered status of a product is in evidence through non-bioengineered certification programmes and organic certification labelling, thus providing products to customers that were clearly non-bioengineered or products produced with non-bioengineered ingredients.

UNIFORMITY ACROSS THE USA

As this regulation is developed there will be input from both public and industry. However, what is certain is that the USA will have a bioengineered food disclosure standard and consequently a law that applies uniformly throughout the States and its Territories.

SGS NO GE SUPPLY CHAIN CERTIFICATION SERVICES

SGS is offering the NO GE Ingredients Supply Chain Process Verification Standard (US Version), a robust system to verify the process of preparing non-genetically engineered (non-GE) ingredients or (pet) food and beverage products for sale in the USA. The standard may be used by any entity in the supply chain including an ingredient or finished food manufacturer, vendor, or services provider like transport or storage facilities. The standard is based primarily on product traceability with a focus on the control of cross-contact or co-mingling between genetically engineered (GE) and non-GE ingredients at every level of the supply chain and manufacturing process, as well as an effective product market removal plan.

This version of the Standard has been developed for the U.S. market, taking into consideration US federal and state guidance, proposed and passed laws, and subsequent regulations.

Verification against the standard consists of the independent third party assessment and approval by SGS of the management system of the applicant for the supply chain of non-GE product from the seed through cultivation and harvest, transportation, collection, storage and processing until it reaches the retail market. The product must maintain its original non-GE status, and it must be managed to avoid cross-contact or co-mingling with GE ingredients throughout the supply chain. The implementation of the requirements of the standard and verification against the standard does not substitute for the compliance with any applicable law or regulation in force.

2http://www.fsis.usda.gov/wps/wcm/connect/70fd4b42-5dce-463a-9041-a4d6918ec6ae/2016-0027.pdf?MOD=AJPERES

The Standard was originally developed in accordance with EU legislative labelling requirements for GE ingredients (EU Regulations 1829/2003 and 1830/2003), but the standard has a global application and can be adapted for country-specific markets.

Further details and access to the standard is available on www.sgs.com/no-gmo

For the complete range of SGS services and support visit www.foodsafety.sgs.com or send an email to food@sgs.com.

JIM COOK Global Food Inspection Technical Manager Phone: +1 973-461-1493 Email: james.cook@sgs.com

SGS Agriculture and Food

NEW US LABELLING LAW FOR BIOENGINEERED FOODS

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The food industry uses cardboard packaging to protect and transport dry, durable products such as pasta, rice, semolina, baking mixtures, high-fat products and confectionery. Paperboard and corrugated cardboard or recycled paper and newsprint are widespread and may be potential entry sources for contamination in food. Components from mineral oil hydrocarbon compounds – adhesives and printing inks containing mineral oil from production, for example – may migrate into packaging materials.

Mineral oil hydrocarbon contamination comes in two forms:

• Mineral Oil Saturated Hydrocarbons (MOSH)

• Mineral Oil Aromatic Hydrocarbons (MOAH)

Harmful substances can find their way into food through direct or indirect contact. The risk of contamination rises or falls depending on the food, on the pollutant concentration in the cardboard, and on the type, intensity and duration of contact, as well as on the storage temperature.

Manufacturing processes may also provide other sources of contamination. In food and packaging production, plants use mineral oil as lubricants or release agents. A further possibility is that substances of the MOSH/MOAH fraction may have entered the foodstuff during production; during harvesting or transport, for instance.

NO LEGALLY-BINDING LIMIT VALUE AND STANDARDS

Although potentially harmful to health, there are currently no EU-wide regulatory framework or binding tolerance values for MOSH/MOAH contaminants in food. Since becoming

MINERAL OIL RESIDUE IN FOOD: HOW SGS HELPS WITH ACCREDITED ANALYTICS Mineral Oil Hydrocarbons (MOSH/ MOAH) can transfer from packaging to foodstuffs. Legal limit values do not exist. However, consumer organisations and retailers are demanding zero tolerance. Many products are affected. SGS Germany has established an accredited analytical method for MOSH/MOAH.

aware of the problem in 2010, the German authorities, the food industry and laboratories have been working on strategies to minimise this. For example, instead of using recycled cartons, the industry is increasingly moving towards alternatives or adding layers that act as a barrier for dry foodstuffs packed in paper and/or paperboard.

At the same time, all market participants are experiencing intense pressure over the issue. Over the past five years, products contaminated with MOSH/MOAH have often been the focus of public scrutiny. The German consumer organisation, Stiftung Warentest, first referred to MOSH/MOAH residue in children’s chocolate advent calendars over the Christmas period in 2012.

In the years that followed, other German NGOs repeatedly published their own test reports. However, reliable toxicological studies on the health risks of mineral oil residue are so far lacking.

The German Federal Institute for Risk Assessment (Bundesinstitut für Risikobewertung, BfR) published a reference value of 12 mg/kg for MOSH with carbon chain lengths of C10 to C16. For MOSH with a chain length of C17 to C20 carbon atoms, the recommended limit is 4 mg/kg food. For MOSH with a carbon chain length of C20 to C35, no recommendation for a maximum permitted level has so far been given.

The toxicology of individual compounds is evaluated differently among the MOAH but it is not currently possible to analyse compounds and determine which are high-risk and which are risk-free. Hence, the difficulty in setting maximum levels for mineral oil residues in food.

MINERAL OIL RESIDUE IN FOOD: HOW SGS HELPS WITH ACCREDITED ANALYTICS

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IMPORTANT NOTE: TAKE AND SEND SAMPLES TO THE LAB PROPERLY

To obtain meaningful output data for a food analysis of MOSH/MOAH, it is essential that the samples are properly taken and correctly dispatched. A laboratory sample of at least 50 grammes (g) of the foodstuff and at least 10 g of packaging material is required for the analysis to be reliable. The sample amount must always be representative of the batch to be tested. When sending samples for testing, ensure that only sample collection equipment, transport containers and packaging that cannot be an entry source for mineral oil contamination are used.

As pollutants can migrate through direct and indirect contact or via the gas phase, samples should be kept in uncontaminated – preferably diffusion-

TECHNICAL FEASIBILITY COMPLICATES REGULATION

A national “Mineral Oil Ordinance” drafted by the German Ministry of Food and Agriculture (BmEL) includes restrictive tolerance values for the migration of MOSH/MOAH into food. Given the difficulties of putting this into practice, the proposal met with resistance from the German paper, packaging and food industry.

Since companies in these sectors rely on raw materials and suppliers from overseas on the one hand and also supply other markets in Europe on the other, companies and associations called for a cross-national, uniform European regulatory framework. Currently, market players from consumer protection and the food industry are increasingly propagating a kind of zero tolerance for MOSH/MOAH in foodstuffs.

SGS INSTITUT FRESENIUS IN BERLIN OFFERS SUPPORT WITH ACCREDITED MOSH/MOAH ANALYTICS

Since demand for laboratory controls for food manufacturers and the packaging industry in this troubled market environment is on the increase, SGS has expanded its capabilities for systematic risk-based screening. SGS Institut Fresenius has established an accredited analysis method for MOSH/MOAH, which impresses through its high sensitivity.

Samples are reduced to small pieces, homogenised and the saturated (MOSH) and aromatic (MOAH) hydrocarbons are extracted together. The extract is then separated into MOSH and MOAH fractions by automated, on-line coupled liquid chromatography-gas chromatography (LC-GC) with connected flame ionisation detection (FID) and measured simultaneously. Quantification is performed in line with internal standards.

This validated LC-GC-FID method allows the simultaneous qualitative and quantitative determination of MOSH and MOAH in all foodstuffs and many packaging materials in the range from 2.0 mg/kg to 0.5 mg/kg, depending on the matrix.

proof – containers. Otherwise there is a danger that samples free of MOSH/MOAH become contaminated on their way to the testing laboratory. Permissible packaging is first and foremost glass or PET containers and also aluminium foil. Food can also be sent to the lab in its original packaging.

For the complete range of SGS services and support visit www.foodsafety.sgs.com or send an email to food@sgs.com.

CONSTANCE VOIGT Dipl. Ing. Food Technology / Labmanager Pesticides SGS Institut Fresenius, Berlin (Germany) Phone: +49 (0)30 346 07-700 Email: de.food@sgs.com

SGS Agriculture and Food

MOSH/MOAH OVERVIEW

MOSH MOAH

Mineral oil saturated hydrocarbons Mineral oil aromatic hydrocarbons

Problem A wide array of chemical substances per fraction with different toxicological potential

Food affected Flour, semolina, rice, coffee, cocoa powder, cocoa butter, milk powder, spices, breadcrumbs and breakfast cereals, palm oil, coconut milk, olive oil, sunflower oil, rape-seed oil, chocolate, confectionery, butter, vegetable fats, meat products

Contaminant sources

Packaging material (paperboard, paper, jute, etc.) additives, adhesives (hot-melt), printing inks, release agents and lubricants in facilities for food production and packaging, exhaust fumes from harvesting machinery

Contamination Direct contact, indirect contact, gas phase

Health risk Accumulation in the body, partially carcinogenic; toxicological studies are inadequate

Statutory limit values

None (reference value BfR for MOSH fraction C10 – C16: 12 mg/kg; MOSH fraction C17 – C20: 4 mg/kg)

Analytical method

Sample preparation/extraction, purification, separation MOSH/MOAH, analysis by means of LC-GC-FID

Limit of quantification

2.0 mg/kg to 0.5 mg/kg depending on matrix

Required sample volume

Foodstuff: 50 g Packaging material: 10 g

Taking a sample Representative, without adhesive residue, packaging in glass or PET containers, aluminium foil

Contact for technical queries

Tel: +49 (0)30 346 07-700 E-Mail: de.food@sgs.com

MINERAL OIL RESIDUE IN FOOD: HOW SGS HELPS WITH ACCREDITED ANALYTICS

PAGE 12

CORPORATE SOCIAL RESPONSIBILITY IN THE SEAFOOD SUPPLY CHAINThe 140 billion USD global seafood industry is complex, highly regulated and continuously monitored. Sustainability is vital for the wild caught, and aquaculture segments.

Traditional aquaculture is currently favoured as a long-term solution to global animal protein shortages, and it is reinventing itself with technical adaptations. Nonetheless, consumers, NGOs, the media, and the scientific community are defining sustainability more broadly, to include management systems, procedures and practices. Given the industry’s supply chain complexity, there has never been a better time for stakeholders to collaborate, and build longer-term sustainable solutions.

POINTS OF REFERENCE/CURRENT REGULATIONS

Seafood buyers, compliance/CSR managers and CEOs of many retail and manufacturing brands, are aware of the brand risk of non-compliance, and the cost of managing a response.

United States

The California Supply Chain Transparency Act requires a company to disclose on its website its initiatives to eradicate slavery and human trafficking from its direct supply chain for the goods offered for sale. A company must disclose to what extent it:

• Engages in verification of product supply chains to evaluate and address risks of human trafficking and slavery

• Conducts audits of suppliers

• Requires direct suppliers to certify that materials incorporated into the product comply with the laws regarding slavery and human

trafficking of the countries in which they are doing business

• Maintains accountability standards and procedures for employees or contractors that fail to meet company standards regarding slavery and human trafficking

• Provides employees and management training on slavery and human trafficking

KnowTheChain.org has reported that a 2015 study found that 47% of its survey on companies subject to the Act, were not disclosing sufficient information on their websites.1

Additionally, the HR 644 Trade Facilitation and Trade Enforcement Act of 2015 bans US imports of slave-produced goods. Shipments in which forced labour is suspected will be seized, and further imports blocked.

United Kingdom

The Modern Slavery Act of 2015 makes provisions about slavery, servitude and forced or compulsory labour, and about human trafficking, including provision for the protection of victims; an Independent Anti-slavery Commissioner; and connected purposes.2 It clearly sets out definitions, requirements and penalties, including imprisonment. As no corporation could afford the loss of critical staff, the urgency for due-diligence, transparency and collaboration in the supply chain has increased.

However, in March 2016, Supply Management reported that 75%3 of small to medium size enterprises would not know how to respond if supply chain slavery was uncovered. Moreover, 67% reported that they had done nothing to tackle supply chain slavery.

CORPORATE SOCIAL RESPONSIBILITY IN THE SEAFOOD SUPPLY CHAIN

1https://knowthechain.org/wp-content/uploads/2015/10/KnowTheChain_InsightsBrief_093015.pdf 2http://www.legislation.gov.uk/ukpga/2015/30/contents/enacted/data.htm 3https://www.cips.org/Documents/Knowledge/Procurement-Topics-and-Skills/4-Sustainability-CSR-Ethics/Sustainable-and-Ethical-Procurement/UK-SMEs-unaware-Modern-Slavery-Act.pdf

PAGE 13

European Union

The Council of the European Union (EU) has endorsed proposals authorising Member States to ratify the International Labour Organisation’s (ILO) new Protocol to the Forced Labour Convention and recommending they do so by the end of 2016. Countries that ratify the ILO Protocol agree to:

• Prevent the use of forced labour, in particular in the context of trafficking in human beings

• Improve the protection of victims

• Provide access to compensation4

CURRENT FINDINGS

Notwithstanding the media’s focus on forced labour, or conditions at sea, there is still scope for improvement with respect to compliance with local laws and third party ethical and labour standards. Some of these improvement areas are described below. Lack of enforcement of existing laws is a common thread across international boundaries.

Management Systems: Lack of a corporate social compliance programme, lack of transparency of any system beyond tier one suppliers. If there is a plan, there must also be training and implementation of the plan into the supply chain.

Employment Freely Chosen/Forced Labour: Once policymakers and industry align on the removal of excessive recruitment fees, an end could be expected to the practice of bribes to enforcement agencies, and to the egregious practices of some labour agencies.

Health & Safety: Building safety and fire code violations, blocked or missing fire escapes and extinguishers, lack of adequate emergency lighting and evacuation plans, neglected maintenance of dormitories, insufficient and or employee-paid personal protective equipment.

Working Hours: Local limits exceeded and employers failing to allow workers their legal time off. Training programmes often focus on the trade-off between production and fatigue, turnover and potential food safety consequences.

Compensation: Overtime compensation does not match legal requirements. Workers paid hourly, or by the piece suffer as a result of non-conformities in calculating differences against minimum wage requirements. Frequent underpayment of overtime to factory staff.

Discrimination: Gender and age discrimination may occur more frequently at labour agencies than at seafood operations.

Collaboration and training within the supply chain is critical to correcting these issues and building more sustainable supply chains.

TRENDS AND ACTIONS

Lack of transparency and the speed of social media have resulted in negative news about the seafood industry, a business that the world needs to trust as a sustainable and healthy source of protein. There is a benefit to transparency. Moreover, there has been greater interest in tackling parallel challenges to supply chain sustainability including illegal, unregulated and unreported (IUU) fishing, which deprives legal fisherman and coastal communities of up to 125 billion USD per year.5

The Chartered Institute for Procurement & Supply (CIPS) and Walk Free Foundation together published an introduction for procurement professionals on Modern Slavery. The section entitled “How businesses should respond”, cites three essential elements:

• Understanding and commitment

• Leadership on auditing

• Accountability6

Applied equally, the seafood industry can use these broad responses. Stakeholders must continue to engage governments and policy makers to enforce existing laws, and/or amend laws to close gaps. Removing the dark shadows in its supply chain, the industry will win back the trust and buying power of consumers and help ensure its longevity.

SEAFOOD SERVICES FROM SGS

SGS offers social responsibility audits against private, food retail and manufacturing codes of conduct as well as the recognised, third party standards including SA8000, BSCI, SMETA, and addendums through GlobalGap GRASP, and GAA Best Aquaculture Practice (BAP), leading to certification where appropriate. Certification helps you to satisfy customer expectations by demonstrating the plans, programs and systems that each standard demands. We are active in dialogues regarding the monitoring of fishing vessels and expect to report further on this important segment.

For the complete range of SGS services and support visit www.foodsafety.sgs.com or send an email to food@sgs.com.

KEVIN EDWARDS Director Business Development & Technical Support Phone: +1 973-461-7903 Email: kevin.edwards@sgs.com

SGS Agriculture and Food

4http://ec.europa.eu/social/main.jsp?catId=89&langId=en&newsId=2377&furtherNews=yes 5http://www.noaanews.noaa.gov/stories2011/20110907_iuufishing.html 6https://www.cips.org/Documents/About CIPS/Ethics/CIPS_ModernSlavery_Broch_WEB.pdf

CORPORATE SOCIAL RESPONSIBILITY IN THE SEAFOOD SUPPLY CHAIN

PAGE 14

SGS’S FOOD TESTING CAPABILITIES IN HONG KONG

INTRODUCING SGS IN HONG KONG

SERVICES

ACCREDITATIONS

EXPERIENCE AND EXPERTISE

CONTACT SGS HONG KONG

PRODUCTS COVERED

• Established: 1959

• Employees: 36 (dedicated to food testing)

• Laboratories: 1

• Laboratory space: 4,300 sq. ft.

• Location: Hong Kong

ISO 17025 and Macau Productivity and Technology Transfer Centre (CPTTM) accredited for food and drug testing, SGS’s Hong Kong laboratory is also accredited by the Hong Kong Laboratory Accreditation Scheme (HOKLAS) and the Deutsche Akkreditierungsstelle GmbH (DAkkS), for food and food container testing.

With extensive experience and expertise, our lab in Hong Kong can support food and food product clients on the widest range of projects, offering high technical capability, fast turnaround times and competitive prices.

To find the SGS laboratory best equipped to meet your needs, contact:

TONY CHAN Head, Hong Kong Food Department T: +852 2765 3635 E: tony.chan@sgs.com

SGS Agriculture and Food

Offering a broad range of food testing services, SGS’s Hong Kong food laboratory can cater for produce and products including:

• Beverages

• Breads and pastries

• Cereals

• Chocolates and confectionery

• Convenience goods

• Dairy

• Delicatessen

• Fats and oils

• Frozen foods

• Fruits and vegetables

• Herbs and spices

• Meat and poultry

• Preserved food

• Seafood

SGS’S FOOD TESTING CAPABILITIES IN HONG KONG

Equipped with state of the art equipment and staffed by experienced and knowledgeable scientists and technicians, this facility delivers a full and diverse range of testing services for food and food products. These include:

• GMO screening, identification and quantification

• Nutritional testing and vitamins

• Microbiological testing – indicators, pathogens and spoilage organisms such as E. coli, Salmonella, Listeria etc.

• Food chemical analysis like artificial colours, food additives, preservatives and sweeteners

• Norovirus identification by polymerase chain reaction (PCR)

• Physical and sensory testing

• Shelf life studies

• Food contaminant testing:

• Pesticide residues

• Heavy metals

• Antibiotic residues

• Melamine

• Allergens

• Mycotoxins

• Antioxidants

• Phthalates

In addition, SGS Hong Kong adds value by offering a range of complementary services including auditing, certification training and technical services.

PCR Laboratory

PAGE 15

SGS WEBINARSFor a complete list of SGS seminars, courses and webinars, please check our events calendar.

WEBINAR LANGUAGE WEBINAR STATUS & LINK

Integrating FSMA with Exisiting Food Safety Systems EN Oct 11 - Register Here

BRC Packaging EN On-demand

BRC Issue 7 EN On-demand

BRC Agents and Brokers EN On-demand

Halal Certification EN On-demand

GFSI Special Session Recap: Shaping Food Safety Culture in Food Service EN On-demand

SGS WEBINARS, EVENTS AND SAFEGUARDS

UPCOMING SGS FOOD EVENTSFor more events, please check the online events calendar.

EVENT COUNTRY LOCATION DATES EVENT TYPE STAND #

SQF Conference USA Orlando, FL October 25-27 Conference 22

Gulfood Manufacturing United Arab Emirates Dubai November 7-9 Tradeshow S1-C21

3rd Dairy Asia Pacific Summit Singapore Singapore November 15-18 Tradeshow

Next Level Symposium USA Indian Wells, Ca December 6-7 Conference TBD

Food Safety Consortium USA Schaumberg, IL December 7-8 Conference 125

SAFEGUARDSSafeGuards, are SGS technical bulletins concentrating on new product standards, regulations and test methods. Subscribe to SafeGuards: www.sgs.com/ConsumerSubscribe Browse the SafeGuards Library: www.sgs.com/safeguards

THE LATEST SAFEGUARDS

• Japan Proposes to Amend MRLs for Erythromycin in Foods – View

• Australia Amends MRLs for Six Pesticides in Various Food Commodities – View

• US GMO Disclosure and Labeling, National Bioengineered Food Disclosure Law – View

• EU Amends the Analysis of Inorganic Arsenic, Lead and PAHs in Foodstuffs – View

• Germany Proposes Criteria for Labeling Food as “Vegetarian” and “Vegan” – View

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