SQF Edition 8 - Food Fraud Mitigation Strategies
We went thru our SQF audit a couple of weeks ago. I joined the company as SQF Practitioner with only 3 weeks before the unannounced audit began. I did not get a Food Fraud Vulnerability Assessment completed before it began and of course got a non-conformance. So I am working on the FFVA currently. Vast majority of our raw materials are very low risk. Main risks being juice concentrates. My question is what are some of the mitigation strategies that you use in your assessment? I am going in circles in my mind trying to decide what would be appropriate strategies and am unable to find my advice or guidance for this. Thanks.
What kind of product do you manufacture?
Mainly drink bases
So what kind of ingredients? Sugars, citric acid, etc? What kind of quality testing do you perform on the product?
HFCS, flavoring, water, citric acid, emulsions, preservatives, etc.
I do a Raw Material Vulnerability Assessment that asks some questions and assigns a point value based on the answer. The final point value indicates the level of risk for IA/EMA.
Point values are subjective, but should be meaningful and logical to come up with a realistic risk level. (That's the complicated part).
It takes a bit of tweaking, but if you run the model on an ingredient that has a well documented history of IA/EMA, you should come up with a result of at least a Medium, and probably High level of risk.
For example;
1. Ingredient Fraud History
Yes (10)
Possible (5)
No (0)
2. Economic Factors
Likely to Occur (5)
May Occur (2)
Not Likely to Occur (0)
3. Geographic Origins
Foreign Supplier (3)
Domestic Supplier (0)
4. Complexity of Supply Chain
Complex (2)
Simple (0)
5. Ease of Access to Material
Ready Access - Materials are unprotected (5)
Minimal Access - Manufacturer may not have a robust Food Defense Program (3)
Unlikely Access - Nature of material or manufacturing. Manufacturer has a robust Food Defense Program (0)
6. Nature of the Material
Liquid/Powder - requires blending (1)
Natural/Bulk (0)
7. Cost of Materials
High (2)
Medium (1)
Low(0)
8. Supply Chain Confidence
Low (1)
High (0)
9. Supplier History
Bad (1)
Good(0)
10. Ingredient Testing Methods
None (3)
Occasional (1)
Robust (0)
11. Existing Controls
Weak (1)
Strong (0)
There are 34 possible points here. This is how I have my risk levels broken down:
Low 1-12
Medium 13-20
High 21-34
Let's look at how this would work for cinnamon. It has a fraud history (10), it is from a foreign supplier (3) so it's already Medium risk.
You can certainly make this as complicated as you wish, but the FDA guy was fine with my approach.
HTH,
Marshall
Mitigation/control strategies would include your laboratory testing equipment. For instance a density meter for Brix for HFCS would give off readings if trying to be substituted for a counterfeit; also HFCS has a very low index of adulteration because it can be easily replaced by something more economical; instead, HFCS is being added to naturally sugared products like honey, but not in the beverage/bevarage base industry
You would also look at how likely technology would detect adulteration. You could look into equipment like HPLC, Spectrophotometer for external lab analysis
Another control would be supplier approval program/audit.
adulteration of citric acid would be picked up simply by organoleptic sensory. It can be distinguished from other food safe acidulants; if you questioned a supplier you can always send it out for external analysis
I would keep it as fundamental and as simple as possible using science and common sense.
The juice concentrate could be adulterated with HFCS which is common, so supplier verification or testing of batches could be a mitigation strategy. This would depend on what kind of risk you have assigned to your suppliers of juice concentrate
Once you have determined the risk of IA/EMA, you can move on to mitigation strategies.
jdpaul mentions several good ones. There can also be things like locked bulk containers, CCTV, etc. that may be useful mitigation strategies in house to counter any possible issues in your facility.
While it's more suited to "food defense", FDA has a mitigation database that may be helpful.
Marshall
Hi JTQ,
Regarding mitigation strategies, a semi-generic response is here -
http://www.ifsqn.com...ud/#entry122786
Specific mitigation requirements will obviously depend on yr own risk assessment.
Please note that there is a growing encyclopedia of responses/strategies for the SQF food fraud requirements on this forum. Maybe search a little.
From a quick look i deduce that several "solutions" for VA being suggested on this Forum are analogous to "scaled down" versions of one of the methodologies specifically recommended by SQF. Namely the ssafe/pwc free tool/Procedure. (Post 6 is maybe one example).
I think the advantage of the pwc tool (righly or wrongly) is that it potentially bypasses all the in-depth likelihood/impact type subtleties to give a direct, overall. VA score/conclusion. Whether auditors will delve deeply into the basis for the answers inputted into the associated detailed questionnaire has not yet been discussed here afaik. Some published studies using this tool have indicated that the "accuracy" of user's inputs may vary, probably not surprising in view of the subjective/intrusive nature of some of the queries.
The disadvantage seems to be (a) use of the tool involves answering a large set (typically 40-50) of risk-oriented questions. (Hence presumably the attraction of "scaling - down" mentioned above), (b) the tool is not (yet?) designed to offer specific mitigation strategies.
The questionnaire involved is illustrated in this overview -
pwc VA tool.PDF 2.06MB 184 downloads
addendum
some more mitigation strategies -
3 Ways To Mitigate Food Fraud Vulnerability.pdf 555.13KB 206 downloads
(the last one should have already been done for SQF8 Manufacturing)