Hi Atessa,
The key elements here are communication, risk assessment, control and verification. The extent of which will depend largely on your ingredients/product and the risk assessment.
Here are some useful bits from BRC:
GLOBAL STANDARD FOOD SAFETY ISSUE 7 INTERPRETATION GUIDELINE
5.4 PRODUCT AUTHENTICITY, CLAIMS AND CHAIN OF CUSTODY
Interpretation
The objectives of this section of the Standard are to ensure:
• sites have assessed their raw materials and supply chain for vulnerability to food fraud activities such as the dilution or substitution of ingredients prior to delivery to the site
• the site has appropriate controls (based on the assessment) in place to minimise the risk of purchasing fraudulent or adulterated raw materials
• all claims relating to raw materials used in products can be substantiated and that the BRC audit process provides a suitable evaluation of the site’s management of the chain of custody, where claims are made relating to primary agricultural schemes such as GlobalGAP
5.4.1 The objective of this clause is therefore to ensure that sites remain up to date with emerging issues and are able to adapt their systems to protect their products against new and existing threats.
5.4.2 The aim of the assessment is not to assess the potential for fraud at the site, but to examine the supply chain for potential concerns or weaknesses, thereby identifying those raw materials that are at particular risk of adulteration or substitution, so that appropriate controls can be put in place (clause 5.4.3).
Typical information to incorporate into the assessment includes:
• any emerging issues and information identified in clause 5.4.1
• historical evidence of substitution or adulteration of the ingredient
• cost/value of the material
• availability – for example a poor harvest may restrict availability and may increase the potential for adulteration
• sophistication of routine testing to identify adulterants – if testing within the supply chain is comprehensive and specifically focused on potential fraud issues, then the likelihood of adulteration is reduced (e.g. fruit juice is often tested for a comprehensive range of parameters, including DNA, isotopic analysis, added sugars and added water to prevent potential fraud)
• country of origin
• length and complexity of the supply chain.
The BRC Standard does not define the exact process that the site must follow when completing the vulnerability assessment; however, it is likely to incorporate the following steps:
• draw up a list of raw materials (or groups of raw materials) and the controls (e.g. product testing, traceability systems or supply chain audits) that are already in operation
• consider the information obtained from clause 5.4.1 for each ingredient
• complete a risk assessment on the vulnerability of each ingredient.
The output of the vulnerability assessment should be a ranking or scoring of the materials to identify those which need additional controls. The ranking and actions required could, for example, be as follows:
• Very high – a high-profile raw material with recent reports of adulteration published by regulatory authorities – action or monitoring is required to ensure only genuine materials are purchased.
• High – a high-profile material that provides an attractive target for potential adulteration – some action and/or monitoring is required to ensure only genuine materials are purchased.
• Low – this material is unlikely to be a target for substitution or adulteration; however a re-assessment may be necessary if new information becomes available.
• Negligible – no further action required as the material is extremely unlikely to be a target for food fraud.
A number of risk assessment tools have been published. These include some specialist vulnerability assessment tools such as CARVER/Shock and TACCP (Threat Assessment Critical Control Points), which may be used to achieve a structured approach to the assessment process.
5.4.3 Depending on the perceived risk, assurance controls may include:
• certificates of analysis from raw material suppliers
• raw material testing
• supply chain audits
• use of tamper evidence or seals on incoming raw materials
• enhanced supplier approval checks
• mass balance exercises at the raw material supplier
• changes to the supply chain (e.g. a change of supplier or a move to a shorter supply chain).
Regards,
Tony
