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How often to check historical evidence of substitution or adulteration


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#1 karina.j

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Posted 25 November 2015 - 11:27 AM

Hi

Can someone please tell me what period of time I should use to check historical evidence of substitution or adulteration?

Is it ok if I check last 12 months and then check and update, if necessary, risk assessment every 3 months?

thank you

 

karina



#2 DN_QAMGR

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Posted 25 November 2015 - 07:59 PM

During my audit for BRC, I did it every 3 months, to show that I was pro-active about technical data and historical data. 

 

I made sure my references were cited for support.

 

I had no issues with my BRC audit for this section.

Good luck!



#3 Simon

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Posted 25 November 2015 - 08:00 PM

I think for the initial risk assessment you should research historical data and then going forward you need to have access to alerts and updates to help steer your food defense plan.  Do you have access to industry alerts and updates for your product type?

 

Regards,

Simon


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#4 Charles.C

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Posted 26 November 2015 - 08:25 AM

Hi

Can someone please tell me what period of time I should use to check historical evidence of substitution or adulteration?

Is it ok if I check last 12 months and then check and update, if necessary, risk assessment every 3 months?

thank you

 

karina

Hi karina,

 

Note BRC7 para 5.4.1. That and the BRC Guidance imply that both "historic" and "current" concerns are relevant (seems logical after all ?).

 

It is also possible that it may relate to the specific product you are talking about.

 

The usp database suggests that the volume of reports is also of some relevance.

 

However, ultimately, i doubt that  BRC are expecting to encounter Sherlock Holmes in the QA Dept. (unless perhaps a new "horsemeat" erupts in UK)

 

Maybe see the pic. (from a consultant) and  Marshall's (mgourley) comment in these 2 posts -

 

http://www.ifsqn.com...indpost&p=95451

http://www.ifsqn.com...ion/#entry94483

 

Your own supply chain is IMO of more immediate significance to the vulnerability assessment than one event in the 19th century (or more). :smile:


Kind Regards,

 

Charles.C


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#5 karina.j

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Posted 26 November 2015 - 08:29 AM

Thank you for response

 

Im sorry I have not introduced myself :)

Hi, my name is Karina I work in gluten free bakery.

 

I do not how or who changed the topic of my post.

The main problem I have is historical data. How many years back do I have to check?

 

I have access to websites with informations and over 80 ingredients to check.

 

Most of them we get from brokers. And here is another question.

Do I only put in my risk assessment information of length of supply chain (as

or I have to risk assess it all the way.

For example

Black Treacle is purchased from broker, it is manufactured in UK by someone else, and ingredients are from 3 different countries.

Do I trace back all ingredients and risk assess historical/economic factors for those 3 countries?

or just manufacturer country?

 

please help



#6 Charles.C

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Posted 26 November 2015 - 09:04 AM

Hi karina,

 

Sorry no experience of baking.

 

Logically -

 

Question No.1 - Does Black Treacle itself have any reported history of Fraud ? (I have no idea).

Question No.2 - If so, due to what ? If zero, the task presumably becomes easier.

 

I'm not sure how many of the previous related threads here you have seen already.

 

At least 2 approaches to the VA seem to have been OK for BRC -

 

(1) Write down an essay-type format response to the minimal requirements specified in BRC 5.4.1 - 5.4.3 and then make some deductions in the context of a risk assessment, eg via a matrix.

 

(2) Deduce a formula to estimate a score for the Vulnerability which will involve much of the same background as (1) but is hopefully more "persuasive".

 

With respect to "history", the minimum answer appears to require use of databases as detailed previous threads. I daresay you've done that already.

 

To risk assess the ingredients as per 5.4.2, i suppose you could start as per my previous post/link. Maybe it's possible to group some items.

 

I hope you have a team.

 

PS - if you get data-stuck as far as countries are concerned, maybe can apply a general "reputation" factor. eg -

 

http://www.ifsqn.com...ate/#entry94144

 

PPS - this comment may also be of interest -

 

http://www.ifsqn.com...isk/#entry95356


Edited by Charles.C, 26 November 2015 - 09:41 AM.
expanded

Kind Regards,

 

Charles.C


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#7 karina.j

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Posted 26 November 2015 - 02:38 PM

Dear Charles

Thank you for your time and help

I have created matrix , something more complex than in link provided. With scores etc and detailed description, so if someone ask why this was scored as 1 not 4 the information will be provided.

I am stuck on - how much detailed this assessment should be.

I was able to group ingredients, I have found notifications and alerts for similar raw materials, its just do I use them if country of origin/manufacturer/supplier are different from those we use? I think yes because its historical data so attempt of fraud on raw material should be considered.

I have asked Purchasing Manager for info regarding changes in prices of raw materials to use it as a base for economic factors,

and person who deals with SAQ and specs for help with supply chain etc.

 

I need a pay rise after completing this task ;)

hehe



#8 Charles.C

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Posted 26 November 2015 - 03:10 PM

Hi karina,

 

thks for feedback.

 

Yes, the historical aspect IMO is intended to provide general context. But it should be relevant to the ingredient.

 

You might consider plugging some numbers into the formula in this post (or others in the thread) -

 

http://www.ifsqn.com...542/#entry95690

 

And, perhaps,  post yr matrix here if not confidential so as to get some (free) comments. :smile:

 

PS - I tried inputting "treacle" into the usp-linked database. Some hits but nothing significant that I could see. Maybe you know more than USP.

PPS - i missed the query in yr previous post regarding backwards depth of data- ideally you cover the "chain" as far as possible but all the factors including the UK manufacturer are potentially interlinked, eg do you have evidence that a UK stage verifies the authenticity of the ingredient ? (see the excel formula queries in my above link).


Kind Regards,

 

Charles.C


#9 karina.j

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Posted 26 November 2015 - 03:53 PM

I did not find anything for treacle

 

reg 2PPS

we created form which was send to suppliers and one of the question was if and how do they verify the authenticity of ingredients and do they have control measures in place 



#10 IzzyP

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Posted 26 November 2015 - 04:01 PM

Hi

 

As part of your risk assessment, you should be able to gauge if the risk to your business is High, Medium or Low (it doesn't have to be a numerical score if you don't want it to be) .

For ingredients (or suppliers, because it is not just ingredients you need to risk assess) that are high (or medium risk), then it may be that you need to revisit your assessment on a more frequent basis as a supplier who is , say low risk. Don't forget, you can only use SAQ's for suppliers that are low risk, so you need to be able to justify why you think they are low risk.

You should be including in your risk assessment historic and EMERGING trends. I would subscribe to such sites as the FSA, RASFF etc. Use your lunch hour to horizon sweep. If you find something you need to document it, and if the risk is escalated, then you need to review your risk assessment accordingly. Ideally for the high risk products, you should go back as far as you can (to source if possible). You 'll be surprised what you can find out from google / Wikipedia etc. because sometimes the supplier won't tell or can't tell you, and really, you should know all about your ingredients to do your HACCP (well you do in my world!)

 

Don't forget, you need to include packaging in all of this.



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#11 JohnWheat

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Posted 26 November 2015 - 04:12 PM

Statement/certificate from supplier also very useful ammunition to keep on file......

 

Original question Karina

EXAMPLES ONLY:

12 months on low risk that have no history of food fraud or low value (no incentive)

6 months on medium risk that have high value (incentive to fraud) or an ingredient that has history elsewhere but no direct fraud.

3 Months on high risk high value and recent history for an ingredient and country of origin as source supply.

 

That's our general approach. We have/use very little added ingredients so does make it a little easier!



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#12 Charles.C

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Posted 26 November 2015 - 04:34 PM

The supplier risk status might presumably vary with the risk status of the ingredient.

 

@Izzy - with respect to Packaging Vulnerability I presume you are referring to Ease of Access, eg tampering ?

 

@karina - i wouldn't expect a rapid reply although in the UK, one would surely expect some degree of heightened control post Hmeat.

 

And, regarding  time periods, a VA may be triggered (similar to a haccp verification) by relevant "changes". i would have thought this would be an "on-going" situation.


Kind Regards,

 

Charles.C


#13 IzzyP

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Posted 26 November 2015 - 04:52 PM

Actually I don't Charles

 

What I'm referring to is ensuring that you have such information as migration certificates for plastic pots or trays and are food safe inks used for pre-printed pots/ bottles/ foils etc



#14 Charles.C

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Posted 26 November 2015 - 04:59 PM

Actually I don't Charles

 

What I'm referring to is ensuring that you have such information as migration certificates for plastic pots or trays and are food safe inks used for pre-printed pots/ bottles/ foils etc

 

The BRC Guidance on VA afai can see does not specifically exclude such aspects but there is zero mention of packaging other than my comment and counterfeited contents.

 

Welcome to be corrected though.

 

PS - one correction, mislabelling is noted


Kind Regards,

 

Charles.C


#15 karina.j

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Posted 27 November 2015 - 08:18 AM

Thank you all for the information

at least now I know what to do  :smile:

 

I did not find information that packaging have to be included but we have migration certificates (brought up in one of the audits) so if someone ask this part will be covered

 

karina



#16 karina.j

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Posted 27 November 2015 - 10:12 AM

I am stuck again:/

where can I find information regarding risk factor - Geographical region of raw material?

or what do I look for?

 

karina



#17 karina.j

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Posted 27 November 2015 - 10:43 AM

I found this

https://www.gov.uk/g...14-28may15a.pdf

 

might be useful for assessment of UK producers



#18 IzzyP

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Posted 27 November 2015 - 11:55 AM

So do you not consider that food contact packaging can be an area of risk? that it can be counterfeit or substituted? PP sent instead of PS, your migration certificate won't be much use then if its not the right material. How many of your operators will look at the bottom of a plastic cup and check its the right material? probably wouldn't realise until you had a ream of complaints because its not sealed properly.

 

I consider packaging, because whilst the clauses of the BRC V7 may not say "Packaging" per se , I still consider it as a raw material that can affect the vulnerability of my (final) product.



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#19 Charles.C

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Posted 27 November 2015 - 02:31 PM

So do you not consider that food contact packaging can be an area of risk? that it can be counterfeit or substituted? PP sent instead of PS, your migration certificate won't be much use then if its not the right material. How many of your operators will look at the bottom of a plastic cup and check its the right material? probably wouldn't realise until you had a ream of complaints because its not sealed properly.

 

I consider packaging, because whilst the clauses of the BRC V7 may not say "Packaging" per se , I still consider it as a raw material that can affect the vulnerability of my (final) product.

 

Hi Izzy,

 

I'm not disagreeing with yr opinions but maybe the BRC7 Glossary definition is relevant to para 5.4.2 -

 

Food raw materials - Food ingredients, additives and processing aids used in the manufacture of a product.

Kind Regards,

 

Charles.C


#20 IzzyP

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Posted 27 November 2015 - 02:56 PM

So it does Charles, yet 5.4.1 talks about raw material, and doesn't mention food and 5.4.2 talks about groups of raw materials too (without saying food groups). But then, that's just my interpretation, and I do like to think outside the box.

 

Lets hope there isn't a food scare around packaging eh, at least I'll be ahead of the game!



#21 Charles.C

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Posted 27 November 2015 - 03:23 PM

So it does Charles, yet 5.4.1 talks about raw material, and doesn't mention food and 5.4.2 talks about groups of raw materials too (without saying food groups). But then, that's just my interpretation, and I do like to think outside the box.

 

Lets hope there isn't a food scare around packaging eh, at least I'll be ahead of the game!

 

Hi Izzy,

 

You might also have quoted para 3.5.1.1 in support of yr hypothesis. Although possibly to be then superceded by 5.4.2 ?

 

There is no doubt that BRC is not incapable of moving in mysterious ways. :smile:

 

Out of curiosity, how did yr auditor respond to yr packaging VA(s) ? Were there many Historical (or non-Historical) Events ?


Kind Regards,

 

Charles.C


#22 IzzyP

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Posted 27 November 2015 - 03:31 PM

My auditor thought my vulnerability was further ahead than most he had seen, in a lot more depth, and he was impressed that I had included packaging as part of the risk assessment.

 

And I didn't get any non-conformances for it

 

My retail customers also like my assessments, how i've set them out, and what I've included.



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#23 Charles.C

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Posted 27 November 2015 - 03:47 PM

Hi Izzy,

 

I deduce that the auditor would also have been fully satisfied if not presented with any Packaging VAs ?

 

How about the Historic data ? Offhand, I cannot recall seeing any significant  Packaging incidents headlined (insufficient profit margins?) but maybe didn't make the front page.

 

Does a database exist in relation to Packaging - specific Fraud ?


Kind Regards,

 

Charles.C


#24 karina.j

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Posted 27 November 2015 - 03:55 PM

Thank you for all information, I will take every point under consideration

 

have a nice weekend 

 

karina



#25 IzzyP

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Posted 27 November 2015 - 04:02 PM

I've no idea Charles, I'm not the BRC auditor. I just presented to him what I had. He might have been satisfied with packaging not on there. I'm not the expert on BRC V7, I just do what I can to protect my products.

 

As for a database, again I have no idea, I did my research and looked at areas of vulnerability (or what I thought were areas of vulnerability). There may be something out there (or an opportunity for someone)






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