Please critique my Vulnerability Risk Assessment for Fraud (VACCP)

I have attached a VACCP - Vulnerability Risk Assessment for Fraud - template.

I am looking for critique or your thoughts.

Thanks!

Jason

Here is a database for Food Fraud

http://www.foodfraud.org/search/site  - USPC Food Fraud Database

Attached - updated VACCP March 30, 2015

VACCP Edit 3-30-2015.docx   17.81KB   2171 downloads

I am still requesting feedback and critique.

Jason

Classic,

The first part of the assessment is the supplier has met the conditions of the site's Supplier Approval Program.  Which will be specific to a site and how the site determines potential risks of suppliers and ingredients.

Once the VACCP identifies "high risk to fraud", V-CCP, then BRC 5.4.3 needs to be addressed: "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."

The answer to 5.4.3..... it depends what the fraud is, did the fraud originate at the supplier or the supplier's supplier?  Maybe the fraud is within this ingredient group, but your supplier uses other sources of ingredient and a simple email clarification is satisfactory.

I believe the "appropriate assurance and/or testing process" will be dependent on each individual "fraud" scenario.

Jason

I looked at your chart. I would say you are on your way to having great audit pass grades because it covers what most auditors may be looking for as proof of well developed "VACCP". So what I am about to say has nothing to do with criticizing your chart. Irrespective of the chart used, after the fancy documentation of VACCP that we are now being forced to develop, would we have achieved any more fraud protection than we currently have? Granted, even fraudsters audited against these schemes will be developing similar documentation.  What if the supplier has actually done fraudulent things but has never been caught, their history would have to be rated as clean, wouldn't it?

See what they are making us do? The hide and seek game continues. We may have nicely documented "VACCPs" that say all is well but fraud, underground, as it often is, will continue to play us for fools. I think that too many "smart" ideas are driving us crazy. Don't forget that fraudsters are also very smart people in the first place, albeit in a crooked way.

 

 "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."

It is not so much the raw material, but fraudulent merchants of raw materials that pose risks of its fraudulent adulteration. Name any raw material, it can be adulterated, or otherwise subject to other forms of fraudulent activities. Raw material testing also does not reveal all fraudulent activities. Let's say it does. The need to test for fraud detection may soon grow to testing everything. Otherwise, the assurance about absence of fraud through the testing method is immediately lost where testing has not been done.

I think it is great!  I was looking for some kind of example on how to go about this and this truly helps.

Thank you!

Z

Hi Guys I've been reading your thoughts and comments, an I am trying to make sure we have our ducks in a row with clause 5.4.2.

What puzzles me is how do you pre-empt something like this. As fraudulent activity is something we cannot foresee and its always something new, and to my knowledge never a repeated activity of the same type. How do you ask yourself if there is potential without sound history and facts? Can this not be addressed through our internal audit procedure as well as the supplier approval and monitoring procedure? Does this need to be included as a risk assessment?

Thanks for your feedback

Triona

I have just started working on this section of our BRC program and was looking too see what others were doing.  Jason I think you have a good form in place.  The form I started to build has what you have but I also added complexity of supply chain, cost of the ingredients and geographical origins.  But I guess the additions I have would be dertermined on where your ingredients come from around this great big world. 

As for Triona question I think it may boil down to trust in your suppliers and testing the product in the end.  I hope we never get that far but you never know.

Jim

Hi Guys,

Which certifications are covering Food Frauds ?

Could you please help to find out the names e.g BRC , IFS????

Thank you in advance!

Zia, IFS v. 6 covers authenticity here:

-        IFS Food 6 requirement  4.4.1.5 (purchase):

The purchased products shall be checked in accordance with the existing specifications and their authenticity. The schedule of these checks shall, as a minimum, take into account the following criteria; product requirements, supplier status (according to its assessment) and impact of the purchased products on the finished product. The origin shall be additionally checked, if mentioned in the specification.

-        IFS Food 6 requirement 5.6.8 (product analysis):

Based on any internal or external information on product risks which may have an impact on food safetyand/ or quality (incl. adulteration and fraud), the company shall update its control plan and/ or take any appropriate measure to control impact on finished products.

And BRC covers food fraud at clause 3.5.1.1.

Hi Guys,

 

Which certifications are covering Food Frauds ?

 

Could you please help to find out the names e.g BRC , IFS????

 

Thank you in advance!

Hi Guys,
 
Which certifications are covering Food Frauds ?
 
Could you please help to find out the names e.g BRC , IFS????
 
Thank you in advance!

Hi Zia,

I assume you mean food fraud as interpreted by gfsi (ie via a Vulnerability Assessment)

Afaik, currently only BRC

Hi Jason,

It's a bit late comment but  yr document might perhaps be compared with the Guideline VA material issued by BRC (note this is only a Guideline).

Based on the above and the specific text of BRC7, yr OP attachment appears to require substantial revision.

Various procedures were subsequently (to example in OP) posted on this Forum which proposed numerical approaches for VA analogous to the BRC guidelines methodology.

Regardless, i would not exclude the possibility that yr basic approach could still satisfy BRC since afaik there has been limited feedback from BRC on what level of sophistication is expected from the BRC7, VA Procedure in practice.

(there appear to have recently been few(any?) UK Food Fraud (GFSI) Incidents of Horsegate magnitude so the VA issue may currently be of diminished BRC priority.

Hello Jason,

You need to include the level of detection (fraud). The least detectable you say 5 points then to the very detectable is 1 point. Please see attach file.

regards,

redfox

Hi redfox,

Sorry to remove file but it's copyright. Please avoid attaching.

I have attached a VACCP - Vulnerability Risk Assessment for Fraud - template.

 

I am looking for critique or your thoughts.

 

Thanks!

 

Jason

Hi, country from where raw material is being purchased and the state of raw material (Liquid/Powder/Solid) also can be added in the checklist.