13 replies to this topic

[Julz]

Hi,

I have just completed a WQA audit (Woolworth's Australia) and have been asked for a food fraud policy.  I would like to incorporate this into my food defense plan.  Does anyone have a food fraud policy that I can use as a bench mark or model?

[Cheza0021]

That's a first....what brought that about?

[Julz]

Hi Cheza, the auditor asked what measures had been put in place to ensure our product did not contain unauthorised ingredients since the horse meat substitution issues that had occurred over seas.  They suggested risk assessing suppliers, chemical testing of finished product etc.  I was wondering what others were doing to ensure they were not vulnerable to food fraud.

[Charles.C]

Dear Julie Compton,

 

Well, if the WQA fear was to as to how to avoid Horsemeat type episodes I think the SOP has been literally plastered all over the net.

 

The fundamental issue from memory appeared to be related to traceability, or lack thereof. And the cause appeared to be oficial regulations which although may not have exactly been designed to promote fraud, they were equally not exactly likely to hinder it either.

 

I don't remember the exact details but it seems unlikely the original sources had their FS systems benchmarked to GFSI for starters. And maybe not the routing stages either.

 

you might usefully investigate what the Australian requirements are in the same kind of context. i suspect they will be much tighter than exists (existed?) for EC.

 

It is possible that yr auditor had some doubts regarding the general scope of yr supplier approval program in relation to the WQA standard (which is already a somewhat unique document IMEX) ?

 

The thought of initiating any kind of detailed chemical testing seems simply draconian, unless you are handling obviously sensitive materials ??

 

Perhaps you might consider posting the "elements" of yr current supplier approval program ?

 

Rgds / Charles.C

[Markcra]

Dear Julie

 

I would think that any meat processor in Australia need to be licensed with the State authority, and if they export with AQIS or whatever they are called now. Similarly the primary producer and abattoir also need to be licence and are subject to regular state authority audits.

 

I also think that some of the food safety auditors are asking for requirements far beyond what  the standards require and need to be challenge.

 

Regards Mark

[Cheza0021]

Hi Julie

When I think of "fraud" I think you should get you legal folks involved. Sure you can incorporate plenty of preventive measure into your Food Defense Plan, but what's to stop me from slipping a few horse-burgers between the soy-burgers. However, if your legal establishes an agreement, that will have more weight. 

 

Or am I way off base? Thoughts anyone.  

 

[john.kukoly]

Fraud is becoming a significant topic in the audit world. One of the first steps it is to separate out the source of the fraud (taking an auditors perspective).

 

An outside party (auditor) could assess the potential for the company to be COMMITTING fraud, or their ability to PREVENT themselves from being defrauded.

 

The challenge with trying to figure out if a company is comitting fraud, is by it's very nature, something they would hide (and likely do it well) from the auditor, so many audit techniques ("show me your policy and procedure for fraud, and evidence you follow it" to over simplify it...) just don't work. In general, this is a totally different skill set ,more likey to look closer to a financial audit than a food safety audit.

 

The second one, the companies ability to prevent becoming the victem of fraud, is easier, and will be in your supplier risk assessment, along with safety, quality, and food defence.

 

John

[moskito]

Hi,

fraud , what does it mean in contrast to food safety and food defense. My understanding is related to compliance and consumer misleading.

from IFS: In consequence of the horse meat scandal the experts from manufacturers, retailers and certification bodies from France, Germany, Italy, Netherlands, Spain and the US agreed on the point that the responsibilities of a manufacturer are not only to produce safe products in line with the product specifications, irrespective if the products are their own or customer ones. Manufacturers must also be sure about the authenticity of the raw materials and/ or semi-finished products. Therefore, the IFS International Technical Committee has decided to put more the focus on these concerns in some IFS requirements and has change IFS Food 6 requirement  4.4.1.5 and 5.6.8 (product analysis).

e.g. we are checking - not only from now - whether vanilla or vanilla flavour(vanilla extract is that what we buy and use for claims on regular basis . We check authenticity of extracts by stable isotope ration analysis and by HPLC (see http://pubs.acs.org/...rnalCode=jafcau)  (expensive analytic about 900 € per sample).

 We have done risk assessment for fraud on all our raw materials and defined (as in all other assessments) 4 risk classes and what we are doing.

This is our understanding of fraud and part of our fraud (better anti-fraud) policy (for a bakery).

A few weeks ago we have had a work shop on our compliance where we defined fraud not only from quality or food law point of view.

 

Rgds

moskito

 

[Julz]

Thank you all for your comments.    This has at least got me thinking more about the topic, and hopefully has pointed me in the right direction.

[relsbels]

Hi Julie,

 

Consider the potential or known risks to the integrity of the products you supply to woolworths then develop, document and implement procedures for the control of these risks.  In part this clause of 'food fraud' is about making sure the product you supply woolworths meets the product name and/or specificaiton in full.  Consider issues such as:

 

 - adulteration

 -counterfeiting

 - mislabelling

 - dilution of products

 

and ensure to consider food fraud of these types can be either knowingly or not and by woolworths standards are considered critical non-conformances.

 

In my experience not easy for an auditor to audit against but a necessary evil of the WQA standard (2.8)

[Charles.C]

Dear Julie,

 

Of course there is (Safety-related)  Fraud and WQA fraud.

 

Interested to know if you solved the request.

 

Rgds / Charles.C

[cazyncymru]

I suppose its no different to carrying out a vulnerability study for the BRC??

 

Caz x

[bacon]

Fraud is becoming a significant topic in the audit world. One of the first steps it is to separate out the source of the fraud (taking an auditors perspective).

 

An outside party (auditor) could assess the potential for the company to be COMMITTING fraud, or their ability to PREVENT themselves from being defrauded.

 

The challenge with trying to figure out if a company is comitting fraud, is by it's very nature, something they would hide (and likely do it well) from the auditor, so many audit techniques ("show me your policy and procedure for fraud, and evidence you follow it" to over simplify it...) just don't work. In general, this is a totally different skill set ,more likey to look closer to a financial audit than a food safety audit.

 

The second one, the companies ability to prevent becoming the victem of fraud, is easier, and will be in your supplier risk assessment, along with safety, quality, and food defence.

 

John

 

Agreed John.

 

The issue is: is a policy really capable of preventing fraud? The intentional obfuscation by a company?  And is a Food Safety Auditor equipped with the proper tools (still set) to be a detective for discovering intentional obfuscation?

 

My thinking is no; Food Safety Auditors have enough on their plate without the additional burden of being an outright detective for intentional fraud.

 

However, in the case of seafood that comes to mind, "mislabeling" of some fish can make one very ill... that is where evidence of provenience claims and chain-of-custody traceability come into play: personally, I would address it there.

 

As part of "Food Defense/Security/what-have-you", cross-docking is often the culprit... it could be potentially address there...

 

"Food" for thought... horse-meat or hamburger.

-B

[bacon]

I was recently at a conference addressing the "Food Defense" issue. Although I did not hear everything that had to be said, I did hear some good points.

 

Handel it in a HACCP framework. Apart from internal, think about some of your major threats, particularity up stream, really amounting to "How well do you know your suppliers?"

 

List out the situations when fraud becomes more of a threat (i.e. product substitution when purchasing from suppliers, unknown suppliers, bulk ingredients, etc). In the HACCP analysis, substitute Bio, Chem and Foreign Object hazards with potential points in the supply chain in which Fraud can be introduced. Basically it is a Risk Analysis assessing vulnerability in YOUR supply chain.

 

Yea, I know, that does not help much when you have an audit coming down the pipeline but here is a good start: http://www.fda.gov/d...e/UCM303901.pdf

 

And some others I found:

 

FSIS “Safety & Security Guidelines for the Transportation & Distribution of Meat, Poultry & Egg Products”
http://www.fsis.usda..._Guidelines.pdf

FSIS “Guidelines for the Disposal of Intentionally Adulterated Food Products and the Decontamination of Food Processing Facilities”
http://www.fsis.usda..._Guidelines.pdf

World Health Organization (WHO)–“Terrorist Threats to Food–Guidelines for Establishing and Strengthening Prevention and Response Systems” (ISBN 92 4 154584 4)
http://www.who.int/f...l/terrorism/en/

U.S. Food and Drug Administration (FDA)–Food Defense & Terrorism
http://www.cfsan.fda...ms/defprog.html

U.S. Food and Drug Administration (FDA)–“Retail Food Stores and Food Service Establishments; Food Security Preventive Measures Guidance”
http://www.cfsan.fda...s/secgui11.html

U.S. Food and Drug Administration (FDA)–ALERT: The Basics
http://www.cfsan.fda...~dms/alert.html

Center for Infectious Disease Research and Policy (CIDRAP), Academic Health Center, University of Minnesota
http://www.cidrap.um...osec/guidelines

County of San Diego, Department of Environmental Health, “Guidelines for Food Safety and Security”
http://www.sdcounty....ecurity_217.pdf