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#1 kbraswe2

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Posted 08 January 2018 - 03:09 PM

I am currently working on creating a Food Fraud Mitigation Plan (SQF 2.7) for the company I work for. We purchase many raw ingredients that have a history of food fraud (spices, oils, fruit juices, and honey). We are a smaller company, so I am not sure how sending raw ingredients off to a lab for authenticity testing would fit into our budget. My question is, is lab testing really necessary for a Food Fraud Mitigation Plan? Probably about 95% of our raw ingredient suppliers have a long-standing relationship with us and we do have a supplier approval program. I have read article after article on food fraud mitigation and I am still unsure if we will get dinged for not sending product out for testing. 

 

Does anyone have an example of steps their company takes to help mitigate food fraud? So far I have:

 

-Require suppliers be audited by a 3rd party (GFSI)

-Require documentation (COA, COO, Spec Sheet, etc.) from suppliers

-Use only approved suppliers

-Source ingredients from domestic (U.S.) suppliers when at all possible

-Ensure packaging is intact and does not appear to be tampered with upon arrival

 

Any guidance would be greatly appreciated.

 

Thank you

 


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#2 Charles.C

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Posted 08 January 2018 - 06:27 PM

I am currently working on creating a Food Fraud Mitigation Plan (SQF 2.7) for the company I work for. We purchase many raw ingredients that have a history of food fraud (spices, oils, fruit juices, and honey). We are a smaller company, so I am not sure how sending raw ingredients off to a lab for authenticity testing would fit into our budget. My question is, is lab testing really necessary for a Food Fraud Mitigation Plan? Probably about 95% of our raw ingredient suppliers have a long-standing relationship with us and we do have a supplier approval program. I have read article after article on food fraud mitigation and I am still unsure if we will get dinged for not sending product out for testing. 

 

Does anyone have an example of steps their company takes to help mitigate food fraud? So far I have:

 

-Require suppliers be audited by a 3rd party (GFSI)

-Require documentation (COA, COO, Spec Sheet, etc.) from suppliers

-Use only approved suppliers

-Source ingredients from domestic (U.S.) suppliers when at all possible

-Ensure packaging is intact and does not appear to be tampered with upon arrival

 

Any guidance would be greatly appreciated.

 

Thank you

 

Hi kbraswe,

 

Have you performed a Vulnerability Assessment ?

Using SSafe ?

 

This should determine the necessity (or otherwise) of a Fraud Mitigation Plan.


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Kind Regards,

 

Charles.C


#3 FurFarmandFork

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Posted 08 January 2018 - 07:35 PM

Hi Kbraswe2,

 

The methods of mitigation are up to you. But ultimately I think it's going to be hard to argue for anythnig other than testing or ultimately some sort of certification regarding the quality of the commodity in question, since food fraud assumes that your supplier is lying to you, its hard to go on what they provide...

 

I don't think you will be asked to do testing if you're truly a small company in both employees and revenue. However before you assume you can't afford testing, keep in mind that the interval is up to you. E.g. if you wanted to do a verification test on one of your high risk ingredients each year and rotate through them, that plan would give you solid evidence for $1-200 per year.

 

No one said you had to verify every lot, if you have longstanding suppliers you could use it as a one time verification you performed to establish the relationship.


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QA Manager and food safety blogger in Oregon, USA.

 

Interested in more information on food safety and science? Check out Furfarmandfork.com for more insights!

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#4 ACS Food Safety

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Posted 08 January 2018 - 07:55 PM

Hi kbraswe,

 

Have you performed a Vulnerability Assessment ?

Using SSafe ?

 

This should determine the necessity (or otherwise) of a Fraud Mitigation Plan.

I tried the Food Fraud Vulnerability assessment, I have a green report icon but I am not able to access the report. Nothing was emailed to me either. Any help with pwc assessment would be terrific.


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Thank you 

 

- Sri 

For more on GFSI Document Prep www.acsfoodsafety.com

 


#5 kbraswe2

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Posted 08 January 2018 - 08:50 PM

Charles.C,

 

I have done the Food Fraud Vulnerability Assessment and adulteration of some of our raw materials (ie. spices, oils) would not be very complex and to detect adulteration, we would probably have to do lab testing (simple visual inspection would not yield any results). So, it is looking like we will probably need to send some raw materials to a lab for authenticity testing. The question is...how often? I guess that is   up for us to decide. How would I justify the frequency of testing? 

 

 

 

 

FurFarmandFork

 

Thank you. I think we probably should send some of our raw ingredients out for testing. Now I am just unsure of how I justify the frequency of testing. 


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#6 Charles.C

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Posted 08 January 2018 - 10:02 PM

Charles.C,

 

I have done the Food Fraud Vulnerability Assessment and adulteration of some of our raw materials (ie. spices, oils) would not be very complex and to detect adulteration, we would probably have to do lab testing (simple visual inspection would not yield any results). So, it is looking like we will probably need to send some raw materials to a lab for authenticity testing. The question is...how often? I guess that is   up for us to decide. How would I justify the frequency of testing? 

 

 

 

 

FurFarmandFork

 

Thank you. I think we probably should send some of our raw ingredients out for testing. Now I am just unsure of how I justify the frequency of testing. 

 

IMO it is indeed extremely difficult to see how you could avoid doing some testing.

 

I assume no official procedure for yr product type exists as far as you know.

The classic procedure for "interval" is that you guesstimate a number in excess of yr preferred ultimate interval and get some data. If the data is OK over a few months test period you can reduce the frequency. If not, well you know the rest ......

 

There are official procedures based on this semi-intuitive approach posted on this forum.

 

@ACS FoodSafety - various people hv previously reported similar difficulties. Probably means you hv to try, try, try  again.


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Kind Regards,

 

Charles.C


#7 Karenconstable

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Posted 30 January 2018 - 12:04 AM

There is one other thing you could put in your mitigation plan:

 

- amend your purchasing contract to require your suppliers to alert you if they become aware of any authenticity issues with their product

 

However, as the other posters said, at least a few authenticity tests might be unavoidable.  

 

As FurFarmFork said, start with doing one high risk material per year and see if your auditor is happy with that.  This is most likely to succeed if - before the audit - you create the sampling plan for the next few years and add it to your food fraud mitigation plan so the auditor can see that you have a well-considered long term strategy. 

 

As an alternative to testing, if it is cheaper for you to visit one or two of your high risk suppliers to review their food fraud prevention procedures that might prove to be more cost effective.  After the visit your report should include how long you have been purchasing from them, a brief background check of the company owners and managers (are they trustworthy) and comments on whether you have confidence in their supplier approvals systems and the food fraud prevention systems they have implemented to meet their GFSI standard(s).  Do they do their own authenticity testing or could their suppliers be de-frauding them?  If they are a local manufacturer (say of juice) and you can see for yourself that their mass balances and manufacturing processes are sound then that would be reason to down-grade the material from 'vulnerable' to 'less-vulnerable' to food fraud in which case you won't need to test.

 

How to prioritise testing:  

Start with the ingredient(s) that carry a significant food safety risk (particularly allergen-contamination risk) from likely adulterants - as an example, there are known problems with garlic powder being contaminated with peanut protein.

Follow with ingredient(s) that are characterising ingredients, which, if they were not authentic present a risk to your brand.

Follow with ingredients that are used in larger quantities or in more of your products  and which, if adulterated, would give rise to a bigger recall.

Follow with ingredients that are very expensive.

 

I am sure you will do fine, your awareness of the issues is much better than many other people's.


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#8 LovedayFS

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Posted 15 February 2018 - 01:47 PM

FYI,

 

The Food Fraud Assessment at PWC is now functional. (https://ffv.pwc.com)

 

I also had the problem that the Get Report button wasn't generating a report, so I contacted PWC via e-mail. And within a couple of days I had a response back saying that they released an update. And sure enough, it works for me!

 

I did receive a "No Network Connection" popup the first time I tried to "Get Report" but the 2nd time worked.

 

- Jon


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