BRC v7 5.4.2: Vulnerability Assessment

Hello, looking for assistance getting started on BRC v7 5.4.2 on the vulnerability assessment.

I am thinking along the lines categories and ratings like

Significance to quality: 1- affects finished product spec and requires modification to labeling , 2- affects appearance or characteristic of product and requires modification to labeling , 3- does not affect spec, characteristics, or labeling

Cost of replacement: 1 Low (more than 15 sources for item), 2 Moderate (Less than 15 sources for item), 3 High (less than 5 sources for item) 

This is just a draft but does it sound like a good track?

Ideas or other thoughts?

Gfdoucette

Example.xlsx   10.9KB   944 downloads

Here is snip of a bigger picture but hope it gets the idea across.  I also plan to add verbiage on testing and access during mfg. 

Well thanks Caz, and your right I do not need something made for me I can put on my big boy pants and make it work was just looking for a path.  We modify and re-dry food starches for reference, and was just wondering if I should lay out process steps and address the points of the standard for each step or make a matrix out if.

I will keep up with the posts so I can be reached. :thumbup:

Hello, check this:

http://www.usp.org/s..._mitigation.pdf

I think is a good tool, specilly the characterization tables

:)

Leila

From the BRC glossary -

Adulteration - the addition of an undeclared material into a food item for economic gain

I thought BRC was a FS Standard.

This presumably (as illustrated in Leila's nice document) implies that the risk assessments should  particularly be oriented towards non - FS related  "hazards"  ? Although sometimes appearances can be deceptive,  eg -
 

The intention of EMA (economically motivated adulteration) is not to cause illness or death, but that may be the result. This was the case in 2008 when melamine was used as a nitrogen source to fraudulently increase the measured protein content of milk, resulting in more than 50 000 babies hospitalized and six deaths after having consumed contaminated infant formula.

The common factor in many cases of EMA is that the adulterant is neither a food safety hazard, nor readily identified, as this would defeat the aim of the attacker.
Common adulterants  include water and sugar; ingredients that may be properly used and declared but improper use is food fraud.

EMA is likely to be more effective for an attacker, and therefore present a greater threat to a food business, upstream on the food supply chain  close to manufacture of primary ingredients. A successful adulteration (from the point of view of the attacker) continues without detection. EMA may need an insider but could be revealed by audit, for example:
• from purchases which are unexplained by recipes,such as sudan dyes which have no place in spice manufacture; or
• where there are differences between quantities sold and quantities purchased, such as beef mince sold and bovine meat purchased, with horsemeat to make up the difference.

(PAS 96)

Rgds / Charles.C

I would have thought that the adulteration of a product with a undeclared or substitute ingredient for economic gain could well be a FS incident, and as such have included it in my studies.

I would have thought that the adulteration of a product with a undeclared or substitute ingredient for economic gain could well be a FS incident, and as such have included it in my studies.


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 Hi Caz,

From the Horse's Mouth perhaps ? :smile:

Rgds / Charles

This clause  (and the one immediately following it) are in direct response to the "horsemeat" scandal that happened recently as well as the increasing light show on incidents of food fraud.  This clause is intended primarily to combat food fraud (substituting cheap crap for the thing you thought you bought).  

Prime examples include: Honey that's actually corn syrup, olive oil that's cut with other oils, dirt cheap fish passed off as expensive fish, diluting maple syrup with various inexpensive fillers, and so on.  

http://foodfraud.msu.edu/Michigan State University has set up a site with information on food fraud.  They also offer free online classes where you can earn a certificate and have a degree program if you feel like parting with $25-50,000.

IFT has a few articles in both Food Technology and The Journal of Food Science regarding food fraud.  

The part that I'm hung up on is the following clause, 5.4.3 which says

"Where raw materials are identified as being at particular risk of adulteration or substitution appropriate assurance and/or testing processes shall be in place to reduce the risk."

So, depending on how much of a stickler you have for an auditor, having paperwork may not be enough.  The issue I see is that everyone in the food chain in many of these instances has all their documentation in order.  They have COA's, they have 3rd party audits,  they have all of that stuff, but someone makes the choice to put horsemeat in the lasagna because it's cheaper.  They dump sunflower oil into the extra virgin olive oil along with some green color because one is $4 a gallon and the other is $40 a gallon.  They put corn syrup in the maple syrup because high grade maple syrup may cost over $100 a gallon while corn syrup is pennies a gallon. 

I'm going to bet that they will want to see independent lab tests confirming that they items you think you are buying are the items you are ACTUALLY buying. 

http://foodfraud.msu.edu/Michigan State University has set up a site with information on food fraud.  They also offer free online classes where you can earn a certificate and have a degree program if you feel like parting with $25-50,000.

 

The price on this IMHO is absolutely crazy, and the program is hard to get into, they have more people than spaces and its an online program.

"Where raw materials are identified as being at particular risk of adulteration or substitution appropriate assurance and/or testing processes shall be in place to reduce the risk."

 

So, depending on how much of a stickler you have for an auditor, having paperwork may not be enough.  The issue I see is that everyone in the food chain in many of these instances has all their documentation in order.  They have COA's, they have 3rd party audits,  they have all of that stuff, but someone makes the choice to put horsemeat in the lasagna because it's cheaper.  They dump sunflower oil into the extra virgin olive oil along with some green color because one is $4 a gallon and the other is $40 a gallon.  They put corn syrup in the maple syrup because high grade maple syrup may cost over $100 a gallon while corn syrup is pennies a gallon. 

 

I'm going to bet that they will want to see independent lab tests confirming that they items you think you are buying are the items you are ACTUALLY buying. 

I think you're right and again this type of testing isn't cheap and continues to drive the price of food up. 

Geez, can't people just do it right?!!

When is a crab not a crab?

Sorry being flippant again, but that's the thought that crossed my mind when I read that clause!!

When is a crab not a crab?

 

Sorry being flippant again, but that's the thought that crossed my mind when I read that clause!!

When is a crab not a crab?  When you pawn off cheap crab from different locations as expensive crab from specific locations.  Fire up da Google and search for "Chesapeake Bay Blue Crab Fraud" or really any "(insert crab here) fraud" and you'll get a zillion hits.  

BTW, if you aren't BRC certified, don't think this excitement won't be in your plan soon.  

http://www.foodproce...-on-food-fraud/

Click link, see your future.  ALL GFSI programs will have a food fraud component soon.

Is there anywhere specific to get food fraud alerts and historical information to help with part of our food fraud assessment, ideally I would like one with automatic alerts for future fraud cases identified.  I have pursued getting access to UK FSA food fraud database with access denied.    I have already signed up to food recall alerts.  Can anyone point me in the right direction?  

Thanks

Is there anywhere specific to get food fraud alerts and historical information to help with part of our food fraud assessment, ideally I would like one with automatic alerts for future fraud cases identified.  I have pursued getting access to UK FSA food fraud database with access denied.    I have already signed up to food recall alerts.  Can anyone point me in the right direction?  

Thanks

Dear kiwilass,

http://www.globalmea...early-next-year

But NZ didn't see anything coming. Maybe nothing to report. :ninja:

Rgds / Charles.C

PS - if you google "food fraud alerts" there are some intriguing, non-official looking, sites listed but maybe ensure a top, active, anti-virus system installed on yr PC first.

Hi

Can you post what you've done. I'm having difficulty in visualising it.

I have completed mine, I still have the 3 main categories (P,M,C) but I also have a "Other" category where I can capture stuff like allergens, human intervention, acts of gods etc. I've have scored it (L I R)  but I have put in a narrative at each step to demonstrate the control measures.

Caz x

I used this to work out some trend analysis

I'm sure it will send you alerts (have a look, i've not checked)

 

http://www.foodstand...es/default.aspx

 

Caz x

Hi Caz,

I entered "fraud' into the search box and the screen seemed a bit agitated. Followed by silence. :smile:

Fascinating list of current recalls available though (eg crocodile meat). :thumbup:

Rgds / Charles

I don't think people like the FSA have quite got up to speed with Food Fraud. By they need too, FAST!

I would have thought that the current Food Safety issue of nut protein in cumin (and today paprika has been implicated) should be a priority for the FSA, but it doesn't seem to be. The implications from this are far more serious than horsegate. There is a real chance that someone could die here! They should be shouting from the roof tops, but it's hardly made the national news here. As a consumer, I'd want to know if there was a potential killer out there on the market place! However, I have had an email from the Cooperative regarding carrying out supplier mapping and unannounced checks.  This should be driven by the FSA not a retailer! We have not learnt a bloody thing from horsegate. It's infuriating, worrying and diabolical. And we all know what the outcome will be; yet more pressure on the manufacturers. I feel for those who today are working in the ready meal sector as yet again, your going to get a kicking! I can just see Tesco et al rubbing their hands on how they can extract yet another drop of blood (money) from the manufacturers with their unannounced audits, and getting things tested at a "retailer" approved lab!

This raised its head more than a month ago in the USA when Whole Food Markets recalled a raft of products because of contaminated cumin. So where the hell have we been until now???

Rant over.

And if I can be of any help to those caught up in it, even if its just to swear and shout at, please feel free!

Caz x