BRC V7 5.4.2 Documented Vulnerability Assessment

How are you Documenting your Vulnerability Assessment ?

I wrote a document that showed the resources that I used (web sites) to perform the assessment, then have the assessment itself in table form.  The document also detailed the rationale for the assessment.

Martha

Would you mind sharing the websites you used?

I have used www.foodfraud.org - but are there others?

Thanks

This document from Michigan State University

Food and Drink Federation

As far as the OP goes, some variation on the attached file would work.

Marshall

Pasted below is the basic rationale for the VACCP analysis.  I can't paste the table because it names our suppliers, which is confidential.  And I'm sure that no one else uses pulp as a raw material, but this should help you with the general idea.

1. Purpose and Rationale:  While HACCP and Food Defense assess risks, which can be statistically evaluated based on historical occurrences, vulnerabilities are assessed by consideration of all possible methods to defraud that could be utilized, even if they have not occurred yet.  A VACCP assessment must consider all possible scenarios, and determine how to counter them proactively.
2.  Raw Materials Considered:  The raw materials that were considered were the various pulps (bamboo, wheat and softwood), and the psyllium husk powder that is used in the CreaSplend blends.
3. Resources Used for Researching Possibilities:  The VACCP assessment was generated by looking at the possible means that an entity could use to defraud (How could this be done?), determine the potential for economic gain (How much would the perpetrator gain?), consider the history of fraud concerning a particular product (Has this ever been done before?), and the corruptibility of a country to assess the likelihood of a citizen considering using fraud (How much corruption exists where the raw material originates?).  The following resources were used:
   1. US Pharmacopeial Convention database: www.foodfraud.org
   2. Transparency International:  www.transparency.org
   3. European Anti Fraud Office (OLAF): http://ec.europa.eu/anti_fraud/index_en.htm
   4. A general Google search for fraud using the products.
4. Resuts of Analysis:
   1. Possible means that could be used to defraud:  Lower quality materials, less expensive materials from a different species of wood, or stolen materials could be substituted for the materials that we think we are ordering.  We obtain Chain of Custody certifications from our vendors, so this makes this more difficult to perform.  Our materials are sealed during transit, so they are protected from substitution on route. 
   2. There is a limited potential for economic gain, since material that would pass a visual inspection is not readily available.  We test the incoming psyllium, and there are strict standards that it must pass.  This is a limited market and we purchase specialty items.  These facts would make it difficult to substitute another material.
   3. There has not been a recorded fraud on any of the resources used for pulp or processed cellulose.  Historically, it has not been an attractive means to defraud buyers.
   4. The hardwood and softwood pulps that we purchase are fully from the United States, which has a low perception of corruptibility from Transparency International.  The Bamboo and Wheat pulps originate in China, which has a higher perception of corruptibility on Transparency International, but it still is not the highest level. The psyllium originates in India, which has a moderate perception of corruptibility.
5. Analysis of Vulnerability Probability:  Our suppliers depend on the continued purchases from us and other customers.  Perpetrating a fraudulent act would be most likely from the supplier, who could have access to a lesser quality product to substitute, and the expected gain from a few substitutions would not gain them enough to warrant performing the fraud.  Our psyllium is purchased from a supplier who has sold product to internationally known pharmaceutical firms, and who needs to protect his reputation in the market.  Overall, our vulnerability for fraud is very low, and we can have confidence that as long as we have the certifications from our suppliers, we will not be defrauded.

Hi maara,

Also see this thread -

http://www.ifsqn.com...res/#entry91284

 

Pasted below is the basic rationale for the VACCP analysis.  I can't paste the table because it names our suppliers, which is confidential.  And I'm sure that no one else uses pulp as a raw material, but this should help you with the general idea.

 

1. Purpose and Rationale:  While HACCP and Food Defense assess risks, which can be statistically evaluated based on historical occurrences, vulnerabilities are assessed by consideration of all possible methods to defraud that could be utilized, even if they have not occurred yet.  A VACCP assessment must consider all possible scenarios, and determine how to counter them proactively.
2.  Raw Materials Considered:  The raw materials that were considered were the various pulps (bamboo, wheat and softwood), and the psyllium husk powder that is used in the CreaSplend blends.
3. Resources Used for Researching Possibilities:  The VACCP assessment was generated by looking at the possible means that an entity could use to defraud (How could this be done?), determine the potential for economic gain (How much would the perpetrator gain?), consider the history of fraud concerning a particular product (Has this ever been done before?), and the corruptibility of a country to assess the likelihood of a citizen considering using fraud (How much corruption exists where the raw material originates?).  The following resources were used:
   1. US Pharmacopeial Convention database: www.foodfraud.org
   2. Transparency International:  www.transparency.org
   3. European Anti Fraud Office (OLAF): http://ec.europa.eu/anti_fraud/index_en.htm
   4. A general Google search for fraud using the products.
4. Resuts of Analysis:
   1. Possible means that could be used to defraud:  Lower quality materials, less expensive materials from a different species of wood, or stolen materials could be substituted for the materials that we think we are ordering.  We obtain Chain of Custody certifications from our vendors, so this makes this more difficult to perform.  Our materials are sealed during transit, so they are protected from substitution on route. 
   2. There is a limited potential for economic gain, since material that would pass a visual inspection is not readily available.  We test the incoming psyllium, and there are strict standards that it must pass.  This is a limited market and we purchase specialty items.  These facts would make it difficult to substitute another material.
   3. There has not been a recorded fraud on any of the resources used for pulp or processed cellulose.  Historically, it has not been an attractive means to defraud buyers.
   4. The hardwood and softwood pulps that we purchase are fully from the United States, which has a low perception of corruptibility from Transparency International.  The Bamboo and Wheat pulps originate in China, which has a higher perception of corruptibility on Transparency International, but it still is not the highest level. The psyllium originates in India, which has a moderate perception of corruptibility.
5. Analysis of Vulnerability Probability:  Our suppliers depend on the continued purchases from us and other customers.  Perpetrating a fraudulent act would be most likely from the supplier, who could have access to a lesser quality product to substitute, and the expected gain from a few substitutions would not gain them enough to warrant performing the fraud.  Our psyllium is purchased from a supplier who has sold product to internationally known pharmaceutical firms, and who needs to protect his reputation in the market.  Overall, our vulnerability for fraud is very low, and we can have confidence that as long as we have the certifications from our suppliers, we will not be defrauded.

 

WOW MWidra  THAN YOU. This really helps

Hi

I have found this document (from WWW.usp.org) to be very useful.

Hope it helps

Maxine

Sorry, it looks like I missed out a step when attaching the document  :doh:

Minnie