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How to prepare a Food Fraud Statement?

Food Fraud / Protection

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#1 PQEdwards

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Posted 21 June 2018 - 02:45 PM

Hi,

 

I am responsible for product safety at a producer of Silicon Dioxide which includes products supplied as free flow/anticaking aid to food and animal feed applications (E551 and E551a). We have a various certifications including; cosmetic GMP (EFfCI) and animal feed GMP (FAMI-QS) but no formal food safety certification, though we apply HACCP principles to meet UK Food Safety regs and to meet the animal feed requirements..

 

My company recently received the following request from a Canadian customer;

 

"Food Fraud / Food Protection  Statement

 

  • Basically what we’re looking for here is a statement that confirms your Corporation has a program in place to ensure that their products have not been subject to food fraud of any kind (adulteration, dilution, substitution, concealment, mislabeling, unapproved enhancements or counterfeiting). We already have a letter of guarantee on file however we would like information on how the product is guaranteed to have not been adulterated or misbranded"

 

To put this in perspective the process is predominantly closed and we supply the product in paper sacks of 15kg, which are palletised on the plant.

 

Does anyone have any advise on what sort of information the customer might be looking for in response to this? And would this apply from the point of palletisation or before?

 

Thanks in advance for your help



#2 jdpaul

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Posted 21 June 2018 - 03:08 PM

You should do a food fraud vulnerability assessment which looks at a lot of criteria and ranks your product between a low or high risk category based on current controls, technology, etc.

 

Silicon dioxide is a polymer and can be easily determined if substituted as something else; methods such as NMR, infrared and ramen spectroscopy exist and would detect any other polymer being substituted.

 

If you are supplying the silicon dioxide and sd derived products you can send COAs to the customers


Edited by jdpaul, 21 June 2018 - 03:10 PM.


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#3 PQEdwards

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Posted 26 June 2018 - 01:42 PM

You should do a food fraud vulnerability assessment which looks at a lot of criteria and ranks your product between a low or high risk category based on current controls, technology, etc.

 

Silicon dioxide is a polymer and can be easily determined if substituted as something else; methods such as NMR, infrared and ramen spectroscopy exist and would detect any other polymer being substituted.

 

If you are supplying the silicon dioxide and sd derived products you can send COAs to the customers

 

Thanks! We manufacture send pure silicon dioxide (>96%) and confirm silicon dioxide content by WD-XRF and can identity product by FTIR.



#4 Quality Is the Goal

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Posted 26 June 2018 - 02:08 PM

Hello PQEdwards.
 
Please see attached file, this is the example of my Food Fraud Summary.
 
If You have any questions please let me know.
 

Quality Is The Goal

Attached Files



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#5 janland

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Posted 16 August 2018 - 06:13 PM

Hi there

 

I'm a grain processor and we are being asked for the same type of document.  We purchase all our grains direct from the farmers and do testing several times prior to receipt to confirm quality.  I'm not sure what type of fraud could be executed on our bulk products but I'd like some insight on how draft a statement.  We are HACCP certified. 

 

Please advise

Thanks



#6 Scampi

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Posted 16 August 2018 - 06:20 PM

janland, this article may be of assistance, it says grains are in the top 5 for fraudulent foods......and if you're organic you've upped the anty significantly

 

Fraud is covered by both SQF and BRC, so that is probably why you're being asked to provide some information

 

Quality does not equal unadulterated.........

 

https://www.pwc.nl/n...-assessment.pdf                 this is a good process (it's the one I used)  it gives you a report at the end based on the information you provide and it's free


Because we always have is never an appropriate response!


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#7 PQEdwards

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Posted 20 August 2018 - 08:56 AM

Hi there

 

I'm a grain processor and we are being asked for the same type of document.  We purchase all our grains direct from the farmers and do testing several times prior to receipt to confirm quality.  I'm not sure what type of fraud could be executed on our bulk products but I'd like some insight on how draft a statement.  We are HACCP certified. 

 

Please advise

Thanks

 

Hi,

 

So we are not BRC or 22000 certified but our customers are and they are pushing back on us to provide assurances on vulneratibility and threat to fraud. 

 

The members of this forum have offered some useful ideas and in particular the PWC and the is an excel TACCP assessment too. The TACCP assessment we found useful and I followed this through. Then with the customer service team we have produced a statement based on this assessment and also the types of questions we get in questionairres.

 

I can't provide a copy of this because it contains information I don't want to circulate to such a large audience but essentially we broke it down into;

 

Context - the product, how it is used

Supply Chain - no of steps (raw material suply, production, storage, distibution etc)

Site Security

Raw Materials - supplier location, supplier relationship, supplier approval, testing 

Registrations - ISO9001, FAM-QS, EFfCI etc

Personnel - training, ratio of permanent to temporary etc

Manufacturing controls - HACCP, closed process etc

Storage and transport - transport approval, security during transport etc

 

Now we are waiting to see if this satisfy the requirement, but we can also show the completed TACCP assessment.

 

I hope that is of some use.

 

John

Attached Files



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#8 Charles.C

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Posted 20 August 2018 - 10:37 AM

Hi PQ Edwards,

 

The attachment looks identical to the template posted here -

 

http://www.ifsqn.com...ed/#entry121799

 

JFI - The BRC forum contains further vulnerability "templates".


Kind Regards,

 

Charles.C


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#9 PQEdwards

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Posted 21 August 2018 - 07:21 AM

Hi PQ Edwards,

 

The attachment looks identical to the template posted here -

 

http://www.ifsqn.com...ed/#entry121799

 

JFI - The BRC forum contains further vulnerability "templates".

 

Hi Charles,

 

Yes you are I believe you are correct and I downloaded this spreadsheet from one of the topics on IFSQN.

 

Thanks for finding referencing the source.



#10 janland

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Posted 21 August 2018 - 01:43 PM

Hi,

 

So we are not BRC or 22000 certified but our customers are and they are pushing back on us to provide assurances on vulneratibility and threat to fraud. 

 

The members of this forum have offered some useful ideas and in particular the PWC and the is an excel TACCP assessment too. The TACCP assessment we found useful and I followed this through. Then with the customer service team we have produced a statement based on this assessment and also the types of questions we get in questionairres.

 

I can't provide a copy of this because it contains information I don't want to circulate to such a large audience but essentially we broke it down into;

 

Context - the product, how it is used

Supply Chain - no of steps (raw material suply, production, storage, distibution etc)

Site Security

Raw Materials - supplier location, supplier relationship, supplier approval, testing 

Registrations - ISO9001, FAM-QS, EFfCI etc

Personnel - training, ratio of permanent to temporary etc

Manufacturing controls - HACCP, closed process etc

Storage and transport - transport approval, security during transport etc

 

Now we are waiting to see if this satisfy the requirement, but we can also show the completed TACCP assessment.

 

I hope that is of some use.

 

John

 

Hi Charles,

 

Yes you are I believe you are correct and I downloaded this spreadsheet from one of the topics on IFSQN.

 

Thanks for finding referencing the source.

 

Hi,

 

So we are not BRC or 22000 certified but our customers are and they are pushing back on us to provide assurances on vulneratibility and threat to fraud. 

 

The members of this forum have offered some useful ideas and in particular the PWC and the is an excel TACCP assessment too. The TACCP assessment we found useful and I followed this through. Then with the customer service team we have produced a statement based on this assessment and also the types of questions we get in questionairres.

 

I can't provide a copy of this because it contains information I don't want to circulate to such a large audience but essentially we broke it down into;

 

Context - the product, how it is used

Supply Chain - no of steps (raw material suply, production, storage, distibution etc)

Site Security

Raw Materials - supplier location, supplier relationship, supplier approval, testing 

Registrations - ISO9001, FAM-QS, EFfCI etc

Personnel - training, ratio of permanent to temporary etc

Manufacturing controls - HACCP, closed process etc

Storage and transport - transport approval, security during transport etc

 

Now we are waiting to see if this satisfy the requirement, but we can also show the completed TACCP assessment.

 

I hope that is of some use.

 

John

 

 

janland, this article may be of assistance, it says grains are in the top 5 for fraudulent foods......and if you're organic you've upped the anty significantly

 

Fraud is covered by both SQF and BRC, so that is probably why you're being asked to provide some information

 

Quality does not equal unadulterated.........

 

https://www.pwc.nl/n...-assessment.pdf                 this is a good process (it's the one I used)  it gives you a report at the end based on the information you provide and it's free

Thank folks - this is more involved than I had anticipated but the templates look like a good place to start so I really appreciate it.  



#11 janland

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Posted 10 September 2018 - 05:11 PM

janland, this article may be of assistance, it says grains are in the top 5 for fraudulent foods......and if you're organic you've upped the anty significantly

 

Fraud is covered by both SQF and BRC, so that is probably why you're being asked to provide some information

 

Quality does not equal unadulterated.........

 

https://www.pwc.nl/n...-assessment.pdf                 this is a good process (it's the one I used)  it gives you a report at the end based on the information you provide and it's free

 

 

Hi Scampi

Looking at the document and the types of food fraud, I don't get how grains can be MORE fraudulent.  As mentioned, we are whole grain supplier, so if one raw material suppliers were to mix poor quality grains or foreign grains/materials, we would catch that on receipt and either reject to clean it out.  If is was a milled grain such as flour, or Organic then yes I could see your point.






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