5 replies to this topic

[FosTerH0ME]

Good afternoon all!

Would you think that the use of GFSI certified suppliers would allow the claim to made that you had adequately controlled the food fraud risk (regardless of the ingredient in question)? This would DRASTICALLY reduce the numbers of ingredients requiring in depth review in our facility and save us many man hours. Thank you for your time!

[mgourley]

Maybe yes, maybe no. If you base your vulnerability assessment on whether or not your supplier is certified to a GFSI scheme, you are assuming a couple of things:

1) The certification scheme ensures that there is NO way that the supplier will source or provide fraudulent or substituted raw materials

2) Your supplier is completely above board and in no way faked any documentation to be certified to a GFSI scheme

3) The CB that audits your supplier completely checks all raw materials that the supplier supplies, to ensure that the supplier is above board.

 

While I have not spent a huge time on the VA required by the latest issue of the BRC Standard, I have done enough to create a fairly simple spreadsheet that seems to meet the intent of the clause.

 

1) Are there historical instances of fraud or substitution for x raw material? 

2) Are there significant (many) historical instances of fraud or substitution for x raw material?

 

If the answers are yes, you need to dig further.

If the answers are no, VA complete. Raw material is low risk.

 

Marshall

[Charles.C]

Maybe yes, maybe no. If you base your vulnerability assessment on whether or not your supplier is certified to a GFSI scheme, you are assuming a couple of things:

1) The certification scheme ensures that there is NO way that the supplier will source or provide fraudulent or substituted raw materials

2) Your supplier is completely above board and in no way faked any documentation to be certified to a GFSI scheme

3) The CB that audits your supplier completely checks all raw materials that the supplier supplies, to ensure that the supplier is above board.

 

While I have not spent a huge time on the VA required by the latest issue of the BRC Standard, I have done enough to create a fairly simple spreadsheet that seems to meet the intent of the clause.

 

1) Are there historical instances of fraud or substitution for x raw material? 

2) Are there significant (many) historical instances of fraud or substitution for x raw material?

 

If the answers are yes, you need to dig further.

If the answers are no, VA complete. Raw material is low risk.

 

Marshall

 

Hi Marshall,

 

(I assume Post 18 was in the context of BRC7).

 

I think you are predicting that  BRC should be satisfied by a vulnerability assessment  of "no further action required"  based on  showing  that the material x  has not been documented  historically  as involved in cases of food fraud.

 

BRC7 para, 5.4.2 seems incompatible with that suggestion ?.

 

It would also seem to imply that your SOP attached in another thread would stop at Item No.B1, ie no need to continue with spreadsheet. I don't see any comment/usage as to that effect?

 

Maybe I have misunderstood yr post ?

 

I agree with yr GFSI comments. In fact, IIRC, GFSI are themselves still pondering as to how best handle this issue within their benchmarking "Standard". After all, the FS aspect is only via Collateral Damage, right ?. Perhaps such a criterion should be included within GFSI to simplify the documentation anguish..

[mgourley]

What I meant was any item with a great history of fraud should be looked at more closely than items that do not have such a history.

Certainly you still have to assess all of your materials (or groups of materials), but since the the whole point of this assessment is to mitigate "adulteration or substitution", if there is no history of adulteration or substitution, then I would think your assessment is pretty much done at that point.

 

Marshall

[Charles.C]

Hi Marshall,

 

Ahh. thanks.

 

I fear you may be overtrusting of databases, eg

 

http://www.theguardi...-1998-rotherham

[mgourley]

Perhaps. But there are not many alternatives out there.

 

Marshall