10 replies to this topic

[Peppin1981]

Hi IFSQN Team.

 

Firstly just want to say what a great website this is.  I have only been looking at it for the past month and it certainly is a great place of information sharing.

 

I have created a document for use at the company in which I work for relating to the requirements under BRC Issue 7 for 'Vulnerability Assessment' as well as the prior requirements to risk assessment for foreign body, microbiological, chemical and significance to quality. 

 

I would love if I can get some constructive comments on the document and where it may fall down in terms of meeting the criteria set out in Issue 7?  The document is a 'word document' and is locked so you can only enter in the fields where necessary.

 

I hope you like and thanks in advance for taking the time out to take a look.

 

Ian T Savage

Attached Files

•  QF 0022 Raw Ingredient Approval Record.docx   24.73KB   861 downloads

Edited by Charles.C, 06 September 2015 - 08:07 AM.
personal data removed - spam magnet

[Charles.C]

Hi Ian,

 

Thanks for yr Input and Welcome to the Forum !

 

This topic is somewhat uncharted territory since little actual audit feedback has appeared on this forum. Or anywhere else to my knowledge. The uncertainty of what BRC expects with respect to basics/detail is evident in the the threads already running on this forum which I assume you have studied. And seemingly in the general literature also. I also have regrettably limited knowledge of the economics/opportunities of fraud in the cheese business.

 

With the above caveats, the basic approach of yr vulnerability assessment (VA) looked, in principle, plausible to me within the context of 5.4.(1 - 3). There possibly should also be some cross-linking to 3.5.1.1. (and maybe 1.1.6[3^rd item]).  Some comments -

 

(1) I wondered what the cheese was being used for ? Packaging when received ?

 

(2) VACCP afaik is not mentioned in BRC7. Vulnerability assessment (VA) is.

 It may just be a matter of opinion but I would have thought that a  “VACCP” presentation would involve some specific noting of presence/absence of  “CCP”s.

 

(3) I anticipate expanded Validatory/Explanative material for the table presented for VA will be required.  I daresay this is available in which case some cross-referencing may help.

 

In particular, it may be necessary to directly address all the elements of 5.4.2  within the context of yr VA table / overall supply chain and perhaps the RPN methodology itself, ie

 

•  historical evidence of substitution or adulteration

•  economic factors which may make adulteration or substitution more attractive

•  ease of access to raw materials through the supply chain

•  sophistication of routine testing to identify adulterants

•  nature of the raw material

 

(4) Didn’t quite understand the connection (if any) of High Quality within the context of Low Profitability.

 

Once again, please note that the above comments are speculative in view of zero auditory precedents. IMO, BRC will necessarily be accepting a wide variety of possible approaches within the Standard’s specified requirements.

 

PS - what is PIFF ?

[blue275]

This Risk Assessment is similar to what I have done and we just passed our audit to BRC V7 with an AA grade! only 4 minors!

 

I did have a few more categories as suggested by Charles and did the vulnerability assessments on a separate Excel spreadsheet, then referenced the final score on the main Raw Material Risk Assessment spreadsheet.

So on the Vulnerability Assessment had the names of the raw materials across the top and the categories down the side as follows and then filled in what I could find out from online searches and internal knowledge into each section.

 

Likelihood of Occurrence

Historical Incidents          Historical evidence of substitution or adulteration of the ingredient

Current / Emerging concerns        Any emerging issues and information identified

Economic Factors which may make substitution or adulteration more attractive

Cost/value of material

Geographic origin/supply chain    Country of origin               Length and complexity of the supply chain

Ease of Access   to raw materials though the supply chain

Nature of the Raw Material          The nature of raw material may change the potential for food fraud e.g. spice blend, single ingredient

Availability          for example, a poor harvest may restrict availability and may increase the potential for adulteration

Availability of adulterants / complexity and cost of committing fraud

 

 

Likelihood of Detection

Geographic origin / Supply Chain Country of origin               Length and complexity of the supply chain

Physical Form                                                 

Existing Supplier Controls

Routine Testing                 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

Relevant Audits                

 

Vulnerability - Conclusions

Based on the risk matrix published by BRC in their webinar about Vulnerability assessments - scored each of Likelihood of Occurrenece and Detection and came up with Low/Medium/High risk.

 

The above is a combination of methods gleaned from other posts on this forum and the BRC Webinar and guidelines.

 

The PIF is a Product Information Form issued by the Australian Food And Grocery Council. Link as follows:

http://www.afgc.org....ation-form-pif/

 

It is an excellent form used by most companies in Australia and New Zealand and a lot elsewhere too, and gives all the information required to conduct VITAL analysis.

 

Thanks for all the ideas I used in developing our Vulnerability Assessment.

 

 

[Peppin1981]

Hi Charles and Blue275.

 

Appreciate your assistance and taking the time out to reply to my question earlier this month.  The information you both have provided is invaluable, so thankyou.

 

I did have three questions though for hopefully the two of you to answer;

 

1.  Could you give me an idea as to was there any particular websites which you found more helpful than others to determine a Raw Material Vulnerability Assessment, or is going onto Google the best method.

2.  When you did a Raw Material Vulnerability check on a raw ingredient, how long was it taking you to achieve one ingredient?  I would have thought 10 minutes maximum on a raw ingredient, or if possible a group of similar products?

3.  With regards to an ingredients Risk Assessment relating to possible foreign body, microbiological, chemical possibilities, would you have used the information contained inside a Suppliers PIFF document as being suitable enough? 

 

Once again Charles and Blue275, thanks for your help.

[Charles.C]

Hi Charles and Blue275.

 

Appreciate your assistance and taking the time out to reply to my question earlier this month.  The information you both have provided is invaluable, so thankyou.

 

I did have three questions though for hopefully the two of you to answer;

 

1.  Could you give me an idea as to was there any particular websites which you found more helpful than others to determine a Raw Material Vulnerability Assessment, or is going onto Google the best method.

2.  When you did a Raw Material Vulnerability check on a raw ingredient, how long was it taking you to achieve one ingredient?  I would have thought 10 minutes maximum on a raw ingredient, or if possible a group of similar products?

3.  With regards to an ingredients Risk Assessment relating to possible foreign body, microbiological, chemical possibilities, would you have used the information contained inside a Suppliers PIFF document as being suitable enough? 

 

Once again Charles and Blue275, thanks for your help.

 

Hi Ian,

 

1.

(a) I tried one or two such as the one you mention (foodfraud). Worthwhile attempt (from memory), maybe one of the best available, but seemed limited in scope.

 

(b) The FSA webpage has an interesting comment - "updated July 2012".

http://www.food.gov....odfrauddatabase

 

(c) The USFDA seem to have a somewhat different interpretation of vulnerability assessment. Daunting instruction list on their mitigation database which may well be anyway unrelated (not targetted on supply chain ?).

http://www.fda.gov/F...s/ucm295900.htm

http://www.accessdat...tionstrategies/

 

(d) Some ideas scattered in, for example, threads below and maybe the attachments, eg the PAS96 document,

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

http://www.ifsqn.com...ding-to-brc-42/

 

(e) Googling "food fraud database" (minus quotes) throws up a few more options.

I guess databases take time and money. The USA is perhaps initially focussing more on overt/covert/accidental health-related possibilities ?

 

2.

10min sounds like a software solution. Are there any ?

 

3.

It depends on the situation/data in the PIFF.

[Karenconstable]

Hi,

 

Although this topic was started some time ago, the difficulty of finding food fraud databases is still with us.

 

I have complied a list of food fraud databases that are free and accessible to all (most).  Unfortunately the free USP database is only available until 12th September 2016, after which it will be replaced with version 2.0, which unfortunately requires a subscription of $1200.00 per year. 

 

• FoodSHIELD was created by The Food Protection and Defense Institute, which is part of the University of Minnesota and partially funded by the USA Department of Homeland Security.  FoodSHIELD resources, including a database of economically motivated adulteration incidences, are available to members who must first pass a membership checking process to ensure they are eligible to access the information. http://www.foodfraud.../ema-incidents/
• The US Pharmacopeial Convention (UPS) has created a database of food fraud incidents at www.foodfraud.org.  The database is accessible to anyone and has a simple-to-use search function.   http://usp-ffd1.food...org/search/site.  After 12th September 2016 use this link instead:  www.foodfraud.org
• The Rapid Alert System for Food and Feed (RASFF) is managed by a group of European national food safety authorities and alerts its member states to incidences of food and feed safety and integrity.  RASFF publishes a searchable database for investigating incidences of food fraud.  To learn more about RASFF click here.  For direct access to the database, open the RASFF Portal.
• The IUU Fishing and Seafood Fraud Web Portal is operated by the USA National Ocean Council Committee on IUU Fishing and Seafood Fraud.

Enjoy your searches!

[JohnWheat]

You'll have to register etc. but we use this........

 

https://horizon-scan.fera.co.uk

[Charles.C]

You'll have to register etc. but we use this........

 

https://horizon-scan.fera.co.uk

 

Hi John,

 

It looks non-free ?

[JohnWheat]

Ah - that might be the case!! Oops

[JohnWheat]

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[Charles.C]

 

 

Sorry, my eyesights not that magnifiable.

 

But i did initially note the words - Free Trial >>>> Subscription