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Who poses the threat when considering a food fraud plan?

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#1 pablocap107

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Posted 13 December 2017 - 10:50 PM

Hi All

I developing a Food Fraud Plan, but i have a question. Is this plan made from the point of view that I, like the company, commit the food fraud, or that my suppliers commit it?

 

Best regards, :spoton:



#2 Charles.C

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Posted 14 December 2017 - 04:22 AM

Hi All

I developing a Food Fraud Plan, but i have a question. Is this plan made from the point of view that I, like the company, commit the food fraud, or that my suppliers commit it?

 

Best regards, :spoton:

 

afaik the latter, ie supply chain,  although the glossary is ambiguous. (But, IIRC, SQF takes a more suspicious viewpoint).

 

I wonder where Horsegate fell ?


Kind Regards,

 

Charles.C


#3 Slab

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Posted 14 December 2017 - 04:24 AM

Hi, pablocap107;

 

The risk assessment is based upon what is most likely to occur for economic gain. This threat can easily be just as much external vs internal. Think of all raw materials for input and finished goods being returned from the market.


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#4 Charles.C

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Posted 14 December 2017 - 04:33 AM

Hi, pablocap107;

 

The risk assessment is based upon what is most likely to occur for economic gain. This threat can easily be just as much external vs internal. Think of all raw materials for input and finished goods being returned from the market.

 

Hi Slab,

 

But IIRC, the BRC/IG only discusses external. ? Unlike SQF.

 

Brits are innocent until .....?


Kind Regards,

 

Charles.C


#5 Madam A. D-tor

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Posted 14 December 2017 - 09:32 AM

It seems a little bit strange to me to risk assess the internal deliberate adulteration of my products.

 

If I am applying food fraud (e.g. knowingly wrong labeling, mixing things up, changing land of origin, dilute, etc), I will not be honest enough to document this in my food fraud risk assessment. That is the thing about fraud, that you do things that you are hiding, because no one may know.

This is also the reason why it makes no sense to have a supplier statement or analysis result from your supplier as control measure for food fraud risk. If a supplier is fooling you, he will not state that and it is not that hard to send false analysis result


Kind Regards,

Madam A. D-tor

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#6 pablocap107

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Posted 14 December 2017 - 02:24 PM

It seems a little bit strange to me to risk assess the internal deliberate adulteration of my products.

 

If I am applying food fraud (e.g. knowingly wrong labeling, mixing things up, changing land of origin, dilute, etc), I will not be honest enough to document this in my food fraud risk assessment. That is the thing about fraud, that you do things that you are hiding, because no one may know.

This is also the reason why it makes no sense to have a supplier statement or analysis result from your supplier as control measure for food fraud risk. If a supplier is fooling you, he will not state that and it is not that hard to send false analysis result

Thank you Madam A.

It seems strange to me too, but my consultor says that has been the focus of this program. I did it taking my suppliers as the possible responsibles of a potential food fraud, but she says that is wrong. I really see i little counterproductive to do a plan with that focus



#7 Charles.C

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Posted 14 December 2017 - 02:33 PM

Hi Pablo,

 

The practical requirement of BRC relating to Food Fraud is a vulnerability assessment.

 

If you look at the responses already posted in this Forum, you will see that yr Consultant is mistaken.  It's as simple as that.


Kind Regards,

 

Charles.C


#8 Timwoodbag

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Posted 14 December 2017 - 03:22 PM

Hi All

I developing a Food Fraud Plan, but i have a question. Is this plan made from the point of view that I, like the company, commit the food fraud, or that my suppliers commit it?

 

Best regards, :spoton:

 

Why not both?  Not to say that you specifically or the company president are responsible like Madame is saying, but what about your purchasing team? Do they have checks and balances to make sure they are not purchasing product whose price magically dropped in half overnight?  Or that Operations Managers don't have any pay-based incentive to switch an ingredient without anyone noticing?  Fraud can come from any angle....where are you most susceptible to it?



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#9 Slab

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Posted 15 December 2017 - 02:50 AM

Hi Slab,

 

But IIRC, the BRC/IG only discusses external. ? Unlike SQF.

 

Brits are innocent until .....?

 

Hi, Charles;

 

Yes, I think it is very naive to assume there is no internal risk. Co-mingling, substitution, dilution, etc. have plagued food manufacturing since the beginning of record. External/internal, the risk for fraud through  the food chain is very democratic in this sense. Of course there very well may be companies, industries, etc. which have no internal risk, however this can only be proved with a documented assessment.


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#10 Charles.C

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Posted 15 December 2017 - 07:25 AM

Hi, Charles;

 

Yes, I think it is very naive to assume there is no internal risk. Co-mingling, substitution, dilution, etc. have plagued food manufacturing since the beginning of record. External/internal, the risk for fraud through  the food chain is very democratic in this sense. Of course there very well may be companies, industries, etc. which have no internal risk, however this can only be proved with a documented assessment.

Hi Slab,

 

Frankly, having seen the utter chaos which was generated by BRC's introduction of VA, I am only too grateful that they limited its scope.

Hopefully SQF users will not shortly experience the same confusion by utilising the SQF Guidance's thoughtful recommendations.

 

After looking around the net there seems to be little compiled data on "internal" food fraud events although they certainly exist, eg -

 

Attached File  the situational prevention of food fraud, 2017.pdf   1010.91KB   150 downloads

 

This quote from a 2017 FSSC22000 pilot study suggests that "industry" is currently somewhat underwhelmed as to the significance of Food Fraud -

 

•     89% of the food manufacturers report to be familiar with no to a few fraudulent issues regarding their raw materials.
•     Meanwhile, 88% of the food manufacturers replied to not have any or only ad-hoc fraud detection methods in place.
•     42% of their suppliers do not have or only have a limited food safety management system in place.

 

It is also worth noting that the "FS" in GFSI stands for Food Safety, not Economic Gain. The topic of Food Fraud slipped into GFSI via this definition -

“Food Fraud: A collective term encompassing the deliberate and intentional substitution, addition, tampering or misrepresentation of food, food ingredients or food packaging, labeling, product information or false or misleading statements made about a product for economic gain that could impact consumer health. (Reference: Spink, J. & Moyer, DC (2011) Journal of Food Science, 76(9), 157-163.)”

 

http://foodfraud.msu...sessment-vaccp/

(It is frequently noted that most Food Fraud events have no intentional FS element. But then came melamine etc)

 

@ Pablo - So if you really want to detail both  internal/external opportunities for Food Fraud, you might consider switching to the forthcoming SQF, FS Standard. IIRC, the latter also limits its scope to safety related food fraud which should reduce any relevant FF history by a few logs.


Kind Regards,

 

Charles.C


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#11 Charles.C

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Posted 15 December 2017 - 11:05 PM

addendum

Food Fraud "enthusiasts" will probably appreciate this comment within a quite detailed review of changes in the forthcoming SQF8 -

 

 

 

Food fraud vulnerability is another area dealt with in the systems elements and is responsive to the GFSI Version 7.2 requirement for a, “documented food fraud vulnerability assessment.” In Element 2.4.4.4, SQF requires a food defense plan with actions to secure incoming materials and protect them from sabotage or terrorist activity.

SQF 8.0 also requires an assessment of a site’s vulnerability to raw material adulteration that could impact food safety and further requires this assessment even with materials shipped from other facilities under the same corporate ownership. SQF-certified sites also must establish and implement mitigation steps to address vulnerabilities from ingredients and materials. A documented annual verification and review of both the food defense and mitigation plans is required as well. This upgraded SQF 8.0 requirement has similarities to the FSMA “Mitigation Strategies to Prevent the Intentional Contamination of Foods” regulation.

 

Attached File  sqf8-modifications.pdf   439.49KB   115 downloads

 

Similarities ? Oh dear .....

 

I wonder how much Food Fraud derives from lack of Traceability ?


Kind Regards,

 

Charles.C


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#12 Slab

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Posted 15 December 2017 - 11:43 PM

 

After looking around the net there seems to be little compiled data on "internal" food fraud events although they certainly exist, eg -

 

 

Hi, Charles, good material provided.

 

I think the issue may be reporting and accountability?

 

Perhaps I'm being dense with definitions, but logically all fraud is incurred internally. From a perspective of origin there is a failure of proper assessment and mitigation?

 

 

 

 


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#13 Charles.C

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Posted 17 December 2017 - 08:26 PM

 

Hi, Charles, good material provided.

 

I think the issue may be reporting and accountability?

 

Perhaps I'm being dense with definitions, but logically all fraud is incurred internally. From a perspective of origin there is a failure of proper assessment and mitigation?

 

 

Hi Slab,

 

Terminologically, I sort of extrapolated from SQF’s Guidance phraseology quoted below (although the “question’s” relevance to food safety  was opaque to me) –

 

Within the site, vulnerabilities may include the potential for intentional or accidental substitution, dilution, or adulteration.  The question that needs to be asked is “who benefits financially from internal food fraud?”

 

 

PS – some additional / BRC comparative comments here –

 

http://www.ifsqn.com...889#entry118889

 

I’m not sure if available FF databases distinguish historic (product) food fraud events which are also FS-related. If yes  the differentiation of  Food Fraud responses for SQF Manufacturing and Quality Codes is facilitated. If not, seems likely to be a challenge.


Kind Regards,

 

Charles.C


#14 Dan McCarthy

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Posted 18 December 2017 - 07:45 PM

I'm working on the same procedure.  I've found a few good sources to start with below. 

 

  1. The plan is prepared with the Food Defense Plan Builder:
    https://www.fda.gov/...s/ucm410909.htm
  2. Suggested resource:
    http://www.accessdat...ining/index.cfm
  3. The plan is prepared using the Food Fraud Vulnerability Assessment Tool:
    http://www.ssafe-foo.../our-projects/#
  4. Food Defense Mitigation Strategies Database
    http://www.accessdat...tionstrategies/


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#15 Charles.C

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Posted 19 December 2017 - 12:35 AM

 

I'm working on the same procedure.  I've found a few good sources to start with below. 

 

  1. The plan is prepared with the Food Defense Plan Builder:
    https://www.fda.gov/...s/ucm410909.htm
  2. Suggested resource:
    http://www.accessdat...ining/index.cfm
  3. The plan is prepared using the Food Fraud Vulnerability Assessment Tool:
    http://www.ssafe-foo.../our-projects/#
  4. Food Defense Mitigation Strategies Database
    http://www.accessdat...tionstrategies/

 

Actually, i haven't probed the SQF recommendations in their Guidance but i did get the impression that the refs were intended to handle the whole FF thing, at least from a SQF perspective.

ie no need for FDA Food Defense offerings ?

 

I sincerely hope SQF are not creating a monster maze ! :smile:

 

also see this post -

 

http://www.ifsqn.com...te/#entry119870


Kind Regards,

 

Charles.C


#16 GMO

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Posted 20 December 2017 - 08:48 AM

It is long winded but in a way I like the M&S (UK - Marks and Spencers) approach where rather than considering internal risk of food fraud, they ask you to consider internal risks of errors and, in a lot of ways that not only is more likely but also going to capture potential food fraud too.  While I understand everyone's points around "if you're going to commit fraud, you're not going to be honest about it", it assumes the people on the fraud team are also the people likely to commit the fraud which is probably not true. 

 

So for example, I'm making a lemon tart with Sicilian lemons but I also have regular lemons on site.  It's quite likely that there could be accidental substitution of the ingredient with a claim with one which hasn't because someone picks up the wrong thing.  It's also possible that this substitution could happen if you were short of the Sicilian lemons one day or if someone wanted to save on cost.  So what you'd do is make labelling really clear, do some internal auditing to make sure labelling is clear and the correct ingredients are being used but also focus internal trace with mass balance on high value ingredients with claims.

 

I think we can all say that we've come across a "can of worms" moment in factories we've worked in where you find something which was going on that you didn't know about.  I can also say many times in my career I've had information withheld from me by key people who should have been more open.  For sure both of those are signs of an immature food safety and quality culture but I suspect I'm not alone.  I think to assume you're immune from these kinds of things is dangerous.

 

Ooh I've thought of a real life situation.  In one factory I worked in, unbeknownst to me, we were selling product below it's use by to a processor who were then stripping packs and selling to market stalls.  As soon as I found out, I stopped the practice as, erm, it's illegal! 



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#17 Madam A. D-tor

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Posted 22 December 2017 - 10:05 AM

[...]

So for example, I'm making a lemon tart with Sicilian lemons but I also have regular lemons on site.  It's quite likely that there could be accidental substitution of the ingredient with a claim with one which hasn't because someone picks up the wrong thing.  It's also possible that this substitution could happen if you were short of the Sicilian lemons one day or if someone wanted to save on cost.  So what you'd do is make labelling really clear, do some internal auditing to make sure labelling is clear and the correct ingredients are being used but also focus internal trace with mass balance on high value ingredients with claims.

 

[...]

Ooh I've thought of a real life situation.  In one factory I worked in, unbeknownst to me, we were selling product below it's use by to a processor who were then stripping packs and selling to market stalls.  As soon as I found out, I stopped the practice as, erm, it's illegal! 

 

Dear GMO,

Thanks for your illustrative examples.


Kind Regards,

Madam A. D-tor

#18 Charles.C

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Posted 22 December 2017 - 12:49 PM

Dear GMO,

Thanks for your illustrative examples.

 

Yes,  but afaik  GFSI/SQF requires "intentionality"


Kind Regards,

 

Charles.C


#19 Slab

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Posted 22 December 2017 - 03:08 PM

Yes,  but afaik  GFSI/SQF requires "intentionality"

 

Yes, the entire premise of fraud assessment is the intentional or deliberate act towards adulteration of food for gain.

 

It is my understanding that previous/current risk based programs tend to focus more on 'indigenous' hazards of either process and product.


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#20 GMO

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Posted 27 December 2017 - 10:21 AM

Yes,  but afaik  GFSI/SQF requires "intentionality"

 

What is unintentional about selling food after it's use by date?  What is unintentional about using a different grade of lemon due to lack of supply or cost?  IME the errors which can be genuine "mix ups" are just as easy to be true "fraud" as for one, if found out the company can hold up their hands and say "whoops!" even if it was purely a cost driven and deliberate act.



#21 Charles.C

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Posted 27 December 2017 - 12:29 PM

What is unintentional about selling food after it's use by date?  What is unintentional about using a different grade of lemon due to lack of supply or cost?  IME the errors which can be genuine "mix ups" are just as easy to be true "fraud" as for one, if found out the company can hold up their hands and say "whoops!" even if it was purely a cost driven and deliberate act.

 

It's quite likely that there could be accidental substitution......

 

 

But yes, i agree with you, when is a mistake not a mistake ? Based on the Specification ? Magnitude ?

 

Regardless, I'm confident you would never intentionally sell expired  "best before/Use By " labelled food for economic gain.

(Although Australia, USA might be legitimate, non-fraudulent, exceptions).


Edited by Charles.C, 27 December 2017 - 12:35 PM.
edited

Kind Regards,

 

Charles.C


#22 GMO

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Posted 27 December 2017 - 12:46 PM

But yes, i agree with you, when is a mistake not a mistake ? Based on the Specification ? Magnitude ?

 

Regardless, I'm confident you would never intentionally sell expired  "best before/Use By " labelled food for economic gain.

(Although Australia, USA might be legitimate, non-fraudulent, exceptions).

 

The difference between fraud and a mistake is intention.  I can tell you that the sale of goods past use by date was for economic gain (it got more cash than selling to animal feed).  If a production manager says "use the normal lemon juice as the Sicilian one has run out", that is not a mistake, that is intentional.  If someone picks up the wrong lemon juice, that is a mistake.



#23 Charles.C

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Posted 28 December 2017 - 04:26 AM

This was the OP -

 

Hi All

I developing a Food Fraud Plan, but i have a question. Is this plan made from the point of view that I, like the company, commit the food fraud, or that my suppliers commit it?

 

Best regards, :spoton:

 

--------------------------------------

This is BRC  Glossary -

 

Fraudulent and intentional substitution, dilution or addition to a product or raw material, or misrepresentation of the product or material, for the purpose of financial gain, by increasing the apparent value of the product or reducing the cost of its production.

 

But BRC7 Interpretation Guide  implies that only supply chains are "expected" to be evaluated.

 

So, assuming the OP is the manufacturer,  the BRC answer to  OP is the (OP's) "latter" (although technically the IG is not auditable material.)

------------------------------------------

JFI this is the SQF8 Manufacturing Code Glossary -

 

As  defined  by  Michigan  State  University,  a  collective  term  used  to  encompass  the deliberate  and  intentional  substitution,  addition,  tampering,  or  misrepresentation of food, food ingredients, or food packaging; or false or misleading statements made about a product, for economic gain.

 

But SQF8 FS Manufacturing  Code limits the FF scope to Safety-related events.

-------------------------------------------

 

It appears that a variety of responses for Food Fraud - Vulnerability Assessments can soon be expected to appear. O Lucky Auditors !

----------------------------------------------

JFInterest, SQF's Glossary definition of a "threat" is - An  identified  risk that  has  the  potential, if  not  controlled,  to  affect the  quality  of  a product.

(BRC's Glossary offers no definition)


Kind Regards,

 

Charles.C






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