18 replies to this topic

[dsafforld]

Does anyone have a Food Fraud Mitigation Plan Template ?

 

I already completed the vulnerability assessment. I am just looking for the a template or example of a Food Fraud Mitigation Plan. I need to create on for SQF 8

 

 

From

 

Donnell

[Dan McCarthy]

This should help.

 

1. Food Defense Mitigation Strategies Database
   http://www.accessdat...tionstrategies/

[Charles.C]

 

This should help.

 

1. Food Defense Mitigation Strategies Database
   http://www.accessdat...tionstrategies/

 

 

Hi Dan,

 

Thanks for input. It's a rather amazing document.

 

From a little playing I think it's (partially??) targetted at what SQF migggght call internal fraud mechanisms, ie a contribution to one part of the SQF/VA..

 

The question of how Food Defense and Food Fraud overlap with regard to different perspectives, eg FDA, FSMA, GFSI is becoming a bit bewildering to me. eg

 

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

 

https://foodsafetyte...efense-program/

[zechzplz]

I agree, the lines often blur in my mind regarding food fraud vs. food defense.

I think it’s because the mitigation strategies and procedures we implement to combat the two often overlap!

 

I found the following MSU article which gives a nice slide to distinguish between food quality, fraud, safety, and defense.

In addition, I think Nestle provides a great paper on Food Fraud. For some reason when I try attaching the document...it doesn't work. But here's the hyperlink! 

 

My company uses the FDA food defense tool (which I agree, accounts for part of our food fraud program!). We also assess every ingredient on their EMA risk using supplier information and what we can gather from the industry and net. We still need to make a food fraud SOP but hopefully this will cover the 2.7.2 element for us! 

 

 

[zechzplz]

Oops, forgot the link for the FDA food defense tool. 

https://www.fda.gov/...s/ucm349888.htm

[zechzplz]

Alright, this is my last post for this topic! haha! 

 

I am doing more research and I think my company will have to do more than just the FDA food defense plan and evaluating EMA risk for our ingredients... since the SQF guidance states:

"Food fraud is often described as EMA, economically motivated adulteration. However, it is more than that. As well as adulteration, food fraud includes substitution, dilution, addition, misrepresentation or tampering of food ingredients or food products. It is in fact illegal deception for economic gain."

 

My team is still working on developing our Food Fraud program, but I think we will look into using SSAFE's tool. It is free and includes a very extensive assessment. 

http://www.ssafe-foo.../our-projects/# <-- go to this link and search through their projects for the Food Fraud Vulnerability Assessment Tool; it has the icon with a picture of honey! 

 

Good luck everyone :) 

 

[safefoodindia]

Hi,

 

I am attaching few files including the Nestle one for reference.

The excel sheet I have just started with few sections for a small spice plant.

 

Hope these help.

 

 Food Defense Plan.xlsx   10.28KB   2742 downloads

 food-fraud-prevention.pdf   1.49MB   2982 downloads

 food defense Guide Food Processing.pdf   290.31KB   1721 downloads

 

[Charles.C]

JFI, the 2nd, 3rd files in previous post are due Nestle, USDA respectively.

 

Note that Nestle's interpretation of "food fraud" is not aligned to SQF.

 

It's rather premature however in view of SQF(8)'s recent Guidance document, I briefly scanned the Net for comments / opinions on SSAFE's "tool". Seemed to be limited feedback but some thoughts are attached below -

 

 ffr1 - Fight against food fraud,2016.pdf   608.9KB   1132 downloads

(translated from French)

 ffr2 - Mitigating food fraud,2017.pdf   145.18KB   1572 downloads

 ffr3 - The risk of food fraud,ca. 2016.pdf   846.64KB   956 downloads

 ffr4 - Assessing food fraud risk,2017.pdf   738.7KB   1497 downloads

 ffr5 - GFSI - Food Fraud Mitigation.pdf   5.07MB   1831 downloads

(Pg 17 et seq/30)

[meerasharma]

Hello 

 

Ca anyone please send me the food fraud vulnerability assessment and mitigation nd mitigation activities designed fr vulnerabilties

[FurFarmandFork]

Hello 

 

Ca anyone please send me the food fraud vulnerability assessment and mitigation nd mitigation activities designed fr vulnerabilties

Example provided here:

http://www.ifsqn.com...272-food-fraud/

[Alex1990]

Buen dia

Alguien me puede ayudar con un ejemplo de evalucion de vulnerabilidades, la finalidad seria entender el metodo utilizado.

[Charles.C]

Buen dia

Alguien me puede ayudar con un ejemplo de evalucion de vulnerabilidades, la finalidad seria entender el metodo utilizado.

 

English Please.

[VanessaV]

I see most of the templates are to create the plan. Yet I wanted to ask,  I received a non-conformance that we do not have reviewed or verified the food fraud vulnerability assessment and mitigation plan. we have a standard operating procedure that includes the guidelines for the vulnerability assessment and vulnerabilities.  However, I will like to know what can be done to satisfy this 2.7.2.3. ?

 

Thank you in advance for your help

[AC2018]

I see most of the templates are to create the plan. Yet I wanted to ask,  I received a non-conformance that we do not have reviewed or verified the food fraud vulnerability assessment and mitigation plan. we have a standard operating procedure that includes the guidelines for the vulnerability assessment and vulnerabilities.  However, I will like to know what can be done to satisfy this 2.7.2.3. ?

 

Thank you in advance for your help

I was just looking for the same answer to this since I just recently had the same non-conformance. I found a document published by the FDA that I think is helpful. 

 

https://www.fda.gov/...105742/download

 

Look at page 14 and 15. I think what needs to be done for verification and review is simply that, reviewing your assessment and mitigation strategies along with any corrective actions related to these procedures. Of course, this review should be documented on a form of some sort. 

 

Hope this helps! 

[Charles.C]

I was just looking for the same answer to this since I just recently had the same non-conformance. I found a document published by the FDA that I think is helpful. 

 

https://www.fda.gov/...105742/download

 

Look at page 14 and 15. I think what needs to be done for verification and review is simply that, reviewing your assessment and mitigation strategies along with any corrective actions related to these procedures. Of course, this review should be documented on a form of some sort. 

 

Hope this helps! 

 

Hi Allison,

 

From the SQF Guidance -
 

 

The food fraud strategy is similar to the HACCP methodology sites are familiar with.  In general terms, it is:

1. Identify the risks (vulnerabilities)

2. Determine corrective and preventative actions (mitigation strategies)

3. Review and verify

4. Maintain records

…………………………………………….

..............................................................

Although SQF requires that the food fraud vulnerability assessment and mitigation plan to be reviewed and verified at least annually, the site should be constantly aware of their supplier history and changes in the supply chain that could impact the vulnerabilities.

 

 

So yes, you are mostly correct. It's intended to mirror haccp.

 

Yr attachment (thank you !)  nicely demonstrates an equivalent response as applied to Food Defense on Pgs 14-15

 

PS - I have attached the file below since links have an unfortunate  habit of vanishing/moving

 

 Mitigation Strategies SECG 081716_FINAL.pdf   121.41KB   685 downloads

[VickieLew]

Hello!

Our Food Fraud/EMA program is in its infancy as well, implemented it about 15 months ago.  I use a Food Fraud Database to determine if there has been an EMA incident associated with each ingredient/ingredient components.  The database I use was originally owned by USP, acquired about a year ago by Decernis, (June 2019, FoodChain ID acquired Decernis;) https://decernis.com...fraud-database/

If an item has a reported incidence of EMA, I then do an initial Vulnerability Assessment screening.  If the result of the screening is medium or high I then do a FULL Vulnerability Assessment.  Food Fraud Advisors, https://www.foodfraudadvisors.com/, has a Vulnerability Assessment tool that I absolutely love.  It is Excel based and very easy to use.  There are 3 main tabs for both VAs; Scope, Likelihood and Consequences.  Each tab contains a series of questions along with links for help interpreting the question and/or links to online resources, there is also a column for comments.  The answers and comments are automatically populated into a printable/savable risk assessment document that includes a visual summary of the results in a risk matrix (likelihood x consequence).  The screening assessment has fewer-more general questions than the Full VA.

If the result for the full VA is "Medium" or "High", the tool also has a tab for "Controls", prevention, detection, and mitigation activities.  A controls report is generated from entries in this tab. 

There is guidance included in the tool with regards to what action should be taken for each risk level:

Key

Red areas = high risk; urgent action is required and regular monitoring may be needed

Yellow areas = medium risk: action is needed with occasional monitoring to mitigate the risk

Green areas = low risk

 

I know a few SQF auditors that are familiar with this tool and recommend it.

One last thing...this is a VERY reasonably priced tool.

Hope this is of some help to you or someone.

thanks

Vickie

[Charles.C]

Hello!

Our Food Fraud/EMA program is in its infancy as well, implemented it about 15 months ago.  I use a Food Fraud Database to determine if there has been an EMA incident associated with each ingredient/ingredient components.  The database I use was originally owned by USP, acquired about a year ago by Decernis, (June 2019, FoodChain ID acquired Decernis;) https://decernis.com...fraud-database/

If an item has a reported incidence of EMA, I then do an initial Vulnerability Assessment screening.  If the result of the screening is medium or high I then do a FULL Vulnerability Assessment.  Food Fraud Advisors, https://www.foodfraudadvisors.com/, has a Vulnerability Assessment tool that I absolutely love.  It is Excel based and very easy to use.  There are 3 main tabs for both VAs; Scope, Likelihood and Consequences.  Each tab contains a series of questions along with links for help interpreting the question and/or links to online resources, there is also a column for comments.  The answers and comments are automatically populated into a printable/savable risk assessment document that includes a visual summary of the results in a risk matrix (likelihood x consequence).  The screening assessment has fewer-more general questions than the Full VA.

If the result for the full VA is "Medium" or "High", the tool also has a tab for "Controls", prevention, detection, and mitigation activities.  A controls report is generated from entries in this tab. 

There is guidance included in the tool with regards to what action should be taken for each risk level:

Key

Red areas = high risk; urgent action is required and regular monitoring may be needed

Yellow areas = medium risk: action is needed with occasional monitoring to mitigate the risk

Green areas = low risk

 

I know a few SQF auditors that are familiar with this tool and recommend it.

One last thing...this is a VERY reasonably priced tool.

Hope this is of some help to you or someone.

thanks

Vickie

 

Hi Vickie,

 

I assume the above was not advertising.

 

Thanks for yr details. Indeed the 2 Methodologies mentioned have been previously discussed here.

 

As you note, these Packages are not free.

 

The  2 Products are undoubtedly competent tools  however, from a purely "GFSI-VA-auditory"  POV, some of the free alternatives posted/referenced on this forum have seemingly proved equally (audit) acceptable and are IMO sometimes (but not always) less complex to implement.

 

Unfortunately, afaik, all the free options suffer from one major, practical, limitation - lack of a freely accessible,  comprehensive, Literature database. Several possibilities have been proposed on this Forum but none probably match the scope/flexibility of some of the non-free options, eg the ex-USP System.

 

PS - actually the SQF Guidance does "recommend" alternative (free) Procedures although I anticipate these can be lengthy if fully implemented and, afaik, still need a competent database.

[VanessaV]

Thanks everyone for the feedback and information. All very helpful. 

[ranainam5343]

 keep it up good work.

Thanks specially to Charles.C. The guru of food safety.

 Guru( this guru word from  hindi/urdu meaning master of masters)

Edited by ranainam5343, 24 July 2019 - 12:12 PM.