8 replies to this topic

[carolinedougan]

Hello

Does anyone have any suggestions as to how I can guage the likelihood of detection when we do not own the products and therefore carry out no tests. I need to put something in re. Section 5.4 of the standard and I am not sure how.

We are a frozen food contract packer of low risk products that are not RTE. (Veg, Potato, Coated Fish and Chicken etc). Customers send us products to repack i.e. 10kg into 5 x 1kg. That's a basic example of what we do and we basically handle all products that are not RTE.

I am wondering if a letter sent to all our customers would be sufficient asking them to sign to confirm that they are responsible for the quality and legality of product and will not ask us to do anything to compromise the authenticity of the product. The main issue I can see is country of origin since we generally handle single products i.e. Strawberries, hash browns etc.

Many thanks

[redfox]

hello caroline,

 

Look these files. These may help. 

 

regards,

redfox

 

 Campden, vulnerability assessment.pdf   1.1MB   178 downloads

 vul1 - USP guidance on food fraud mitigation.pdf   1.08MB   113 downloads

 vul2 - food fraud and EMA, 2014.pdf   697.02KB   106 downloads

 Vulnerability Assessment.pptx   5.58MB   150 downloads

 Vulnerability-Assessment-Template.xlsx   32.55KB   179 downloads

[Charles.C]

Hi redfox,

 

Thks for the attachments but please avoid ones which are copyright.

 

@ Caroline -

 

Do you not anyway have to fulfil clause 3.5.1.1 ?

[carolinedougan]

We risk assess packaging materials. The only risk assessment we can do on products is the risk they pose during packing i.e. Allergens.

We have no control, or idea, where the product comes from as that is the responsibility of our customer.

I have attached a document that I am thinking we could send our customers. This is not completed yet and needs more wording under product declaration.

I realise this sounds like we are passing the buck but I honestly don't know how else to approach this.

[redfox]

Hello Charles,

 

Thanks for the reminder. I may have overlooked it is copyright docs.

 

regards,

redfox

[redfox]

Hello caroline,

 

If you are only the packer (contractor) and not involved in selling the product to distributors and retailers, IMO, you're not responsible in determining the authenticity of the product. It's your customer responsibilities. Your concern must be on how you pack the product compliant to food safety and legality, of which your customer must requires you to do.

 

regards,

redfox

[carolinedougan]

Thank you Redfox.

That is exactly what we thought but sometimes auditors (not BRC) seem to be expecting us to do more.

[Charles.C]

Hi Caroline,

 

I don't really understand why you feel you have any involvement regarding BRC or any other FS Standard.

 

Seems to me that you are the Company "X" as referred to in BRC clause 3.5.4 so that obligations to BRC (if any) are essentially the responsibility of the Company who is contracting you (I presume this is what Post 6 meant by "customer").

 

Nonetheless, based on previous threads, you may still have certain FS obligations regarding UK's due diligence "rules". For example -

 

http://www.ifsqn.com...l-declarations/

 

http://www.ifsqn.com...ng-obligations/

[Karenconstable]

Hi Caroline,

 

It seems that you are doing a vulnerability assessment for 5.4 of BRC 7, and specifically trying to determine the likelihood of detection of fraudulent adulteration in the food you are receiving.

 

No matter what type of product you are repacking or where you got it from, the detection part of the vulnerability assessment requires you to ask: "If something is wrong (fraudulent or inauthentic) with the material WHEN WE RECEIVE IT, would we notice?"  If you don't do any testing or verification* then the answer is "we probably wouldn't notice" - that is,  you might not realise that the food was fraudulent in some way.  So the likelihood of detection should be classified as low/unlikely.  *Verification in this instance would include verifying paperwork, such as checking that the country of origin declaration is correct. 

 

Don't despair, though, if your products are unlikely to be fraudulently adulterated in the first place then you could say that there is a low likelihood of occurrence and so your final vulnerability result would still be low/ok.  For example, you might say that fraud is unlikely to occur because the foods that you buy come in whole, recognisable forms like whole strawberries, or are packed in tamper-resistant packaging or perhaps you can show that fraud is unlikely because your suppliers are doing their own checks or have their own controls.

 

Auditors prefer honesty in a vulnerability assessment ("yes, we probably wouldn't detect fraudulent adulteration if it was present but we think it is very unlikely to occur in our raw materials") rather than "it's not our problem, our suppliers are supposed to do the right thing".  If you have identified that country of origin is an issue, then that is great: write it down in your vulnerability assessment too.

 

Good luck!

 

Karen

Edited by Simon, 19 October 2016 - 07:19 PM.
Removed web link