Food Fraud Vulnerability and Mitigation Plan

Hi!

 

Is anyone able to attach a start of their Food Fraud Vulnerability and Mitigation Plan so that I could have an idea of how to begin it. I'm frustrated with this new code. We have a nice Food Defense Plan, but I'm confused on starting this plan up. Are we assessing the suppliers only? I work in a pretty large company, so am I assessing every single one of my suppliers?  

 

Any help would be nice, please and thank you.

 

 

Hi Abby1993 ,

 

I had collected some beneficial documents that may help you in your start to understand the food fraud generally , also you may search in IFSQN for this topic you will find interesting discussions ,

 

Food fraud vulnerability assessment Think like a criminal to fight food fraud

https://www.pwc.nl/n...-assessment.pdf

 

Food Fraud Vulnerability Assessment and Mitigation Are you doing enough to prevent food fraud?

https://www.pwc.com/...on-november.pdf

 

 food fraud vulnerability assessment tool

https://www.pwc.nl/e...fraud-tool.html

 

SSAFE FOOD FRAUD VULNERABILITY ASSESSMENT TOOL

http://www.ssafe-food.org/

 

 

BR,

Ehab

I started off by taking my HACCP flow chart and figuring out at each process step what my vulnerabilities are. After that, I calculated their risk (high, med-high, medium, med-low, low). Then wrote a justification based on the risk rating. 

 

I found the PWC tool that Ehab provided the link for to be beneficial in finding questions that you would not think to ask about your specific product. I printed the copy out and put it in my SQF manual as verification of my program. 

 

Just finished the SQF 8.0 audit last month, and the inspector said the program was well done. It was definitely one of the hardest parts of the new edition. 

Do we need to assess packaging materials? It was my understanding that it was for food raw materials and then our processes.

 

thanks

I started off by taking my HACCP flow chart and figuring out at each process step what my vulnerabilities are. After that, I calculated their risk (high, med-high, medium, med-low, low). Then wrote a justification based on the risk rating. 

 

I found the PWC tool that Ehab provided the link for to be beneficial in finding questions that you would not think to ask about your specific product. I printed the copy out and put it in my SQF manual as verification of my program. 

 

Just finished the SQF 8.0 audit last month, and the inspector said the program was well done. It was definitely one of the hardest parts of the new edition. 

Hi, Do you have an example of what your assessment looked like? Did it end up looking like the Hazard Anaylsis? I am struggling with how to format it. I know HACCP there's an actual guideline to follow, But I don't see anything anywhere on how the format should be for this. 

 

Thanks, 

Loni 

Hi, Do you have an example of what your assessment looked like? Did it end up looking like the Hazard Anaylsis? I am struggling with how to format it. I know HACCP there's an actual guideline to follow, But I don't see anything anywhere on how the format should be for this. 

 

Thanks, 

Loni 

 

Hi Loni,

 

You should try searching here for "pwc" as recommended in the SQF Guidance. Must be 10-20 threads on it by now.

 

Methodology is ideal if you enjoy answering approx. 40-50 questions per ingredient. Afterwards it prints out a nice analysis for you.

 

Alternatively have a look at Scampi's shortened version, maybe only ca. 20 questions.

Hi Loni,

 

You should try searching here for "pwc" as recommended in the SQF Guidance. Must be 10-20 threads on it by now.

 

Methodology is ideal if you enjoy answering approx. 40-50 questions per ingredient. Afterwards it prints out a nice analysis for you.

 

Alternatively have a look at Scampi's shortened version, maybe only ca. 20 questions.

I did see those and I used it, I guess my confusion Is what comes after the assessment? Is that all I need, or do I need another type of format to put the assesment in?

I did see those and I used it, I guess my confusion Is what comes after the assessment? Is that all I need, or do I need another type of format to put the assesment in?

 

Hi Loni,

 

the pwc tool facilitates a vulnerability assesssment. It does not directly answer "Mitigation". For example this quote -

 

The tool does not provide specific mitigation techniques, detect fraud or predict future food fraud incidents, but it does provide guidance on how and where to find solutions.

 

If you find the pwc tool somewhat "overwhelming" (it may indeed supply more "answers" than SQF demands) maybe have a look at the (SQF oriented), integrated Procedure generously offered by "3F" here -

 

http://www.ifsqn.com...ud/#entry122786

Hello everyone!

 

For those that have used the SSAFE & PWC tool, I need your advice please. Have you done an assessment for each of your products and ingredients? or Have you grouped them? Also, the online information that is available for this tool mentions that you can do one company-wide assessment. Do you know what this means? How do you do a company-wide assessment?

 

Thank you so much for your help! We want to use this tool for our GFSI audit.

 

 

Hello everyone!

 

For those that have used the SSAFE & PWC tool, I need your advice please. Have you done an assessment for each of your products and ingredients? or Have you grouped them? Also, the online information that is available for this tool mentions that you can do one company-wide assessment. Do you know what this means? How do you do a company-wide assessment?

 

Thank you so much for your help! We want to use this tool for our GFSI audit.

 

Hi Silvialima,

 

I presume you are referring to this (not sure where you saw the "one", IMEX you can open as many "projects" as you like) -

 

 

• The tool is applicable to any type of food business irrespective of size or geographical location
• The tool can be applied all the way along the food supply chain, from animal feed and primary production to manufacturing and catering
• The tool can be used to assess vulnerabilities to fraud at an ingredient, product, brand, facility, country or company wide level

 http://www.ssafe-foo...g/our-projects/

 

I anticipate that last line above is referring to the scope of the vulnerability study which determines the source(s) for the answers to the various (ca. 50) questions involved.

 

IIRC the tool's guidelines suggests grouping items where such is possible.

Thank you for the soon response Charles!

So, if we can use this tool for either food groups or company-wide, what option should we do for GFSI? GFSI mentions that you need to do a vulnerability assessment for all your food items, but at the same time it needs to be company -wide. If I only do it company-wide (only one assessment for my whole organization), will a GFSI auditor disagree with this?

Thank you for the soon response Charles!

So, if we can use this tool for either food groups or company-wide, what option should we do for GFSI? GFSI mentions that you need to do a vulnerability assessment for all your food items, but at the same time it needs to be company -wide. If I only do it company-wide (only one assessment for my whole organization), will a GFSI auditor disagree with this?

 

Hi Silvialima,

 

I deduce you are talking about multi-site certification for which GFSI seemingly has defined sampling requirements (Pt 4) ?

 

afai can see (didn't burrow through all the GFSI intricacies) the GFSI direct related text is -

 

FSM 22 -  Food fraud vulnerability assessment - The standard shall require that the organisation have a 

documented food fraud vulnerability assessment procedure in place to identify potential vulnerability and 

prioritise food fraud mitigation measures.

 

FSM 23 - Food fraud mitigation plan - The standard shall require that the organisation have a documented plan in place that specifies the measures 

the organisation has implemented to mitigate the public health risks from the identified food fraud vulnerabilities.   

This plan shall cover the relevant GFSI scope and shall be supported by the organisation’s Food Safety Management System.

 

Unfortunately i am not a GFSI jargon expert. Other users here may hopefully know more than me. If not my suggestion is to ask yr intended auditor.

Silvialima

 

I would target your food items and no worry about "company wide" stuff....that really belongs with head office. If you work for a very large multi site company, they probably have an 'official statement of policy" for fraud that you can include in the evaluation

 

The last very large company I worked for when audited to FSSC didn't give two hoots about corporate policy-with 1 exception-the recall plan, for obvious reasons (they would be the ones issuing press release et all)

 

Corporate cannot help you if you don't have control over your facility and what happens inside those walls.....which isn't to say a head office purchasers couldn't knowingly or unknowingly approve a vendor who generates "fraudulent" raw materials 

 

Like this "Researchers in India have found two of nine samples of black pepper to have been adulterated with chilli powder. India is the world's largest exporter of spices. 24/08/2016 Powdered spices are at very high risk of fraudulent adulteration, substitution and dilution. The risk is expected to remain high for the foreseeable future."  So if corporate is responsible for approving vendors, then you MUST include the corporate plan AND FOLLOW IT

 

Does that help?

Thank you for your help. 

 

Yes, I was referring to a multi-site organization. I do work in corporate, and for the first time we will go through a GFSI audit. 

 

Thanks,

 

Silvialima