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Food Fraud Procedure and Food Fraud Mitigation Plan

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lynnicesanchez

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Posted 08 August 2018 - 02:36 PM

Our company have completed a Vulnerability Assessment for our facility, but we are unsure how to go about writing a Food Fraud Procedure or food Fraud Mitigation Plan... 

 

Can anyone assist with this??



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Ryan H.

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Posted 08 August 2018 - 07:57 PM

For each vulnerability, a mitigation strategy must be implemented to drastically reduce, control or eliminate the vulnerability you have. So it must be some sort of documented process step that your employee(s) are trained on.

 

It would be helpful to know what kind of process and/ or product you manufacture/ store/ etc. at your facility.


All the best, 

 

Ryan Heavner 


012117

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Posted 09 August 2018 - 06:25 AM

Hi, lynnice.

 

Based on the output of your food fraud assessment then you can create your mitigation strategies. Prioritize which you think is the highest risk.

 

E.g. for example you have identified RM A to be of the highest risk due to source from different country with poor regulations, is the type of material that can be easily altered with difficulty in detection and highest economical gain.

 

On my mitigation plan I may write.

Increase in test for possible adulterant for that material, increase audit frequency that includes food fraud as one of the section or possible to replace supplier with alternative vendor with more rigorous test or country with stricter regulation. 

 

The action depends on the assessment.

 

AS for the procedure, may detail what is the process for conducting food fraud (that may include multi disciplinary team, trained conducted fraud for highest risk material to lowest, what is my prioritization schemes, what are the possible action and link to crisis management or emergency preparedness- what ever you may call it).



Ashfaq Hussain

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Posted 09 August 2018 - 07:27 AM

Our company have completed a Vulnerability Assessment for our facility, but we are unsure how to go about writing a Food Fraud Procedure or food Fraud Mitigation Plan... 

 

Can anyone assist with this??

Hi,

 

This will help you.

https://www.fda.gov/...s/ucm376791.htm



FurFarmandFork

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Posted 09 August 2018 - 01:34 PM

I wrote a helpful post from an SQF perspective on meeting the requirements.

 

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


Austin Bouck
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Consulting for companies needing effective, lean food safety systems and solutions.

Subscribe to the blog at furfarmandfork.com for food safety research, insights, and analysis.

Charles.C

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Posted 09 August 2018 - 05:20 PM

Our company have completed a Vulnerability Assessment for our facility, but we are unsure how to go about writing a Food Fraud Procedure or food Fraud Mitigation Plan... 

 

Can anyone assist with this??

Which FS Standard is involved ?

 

You have posted in Food Defense,

 

This is not Food Fraud.

 

Please clarify.

 

If you think yr VA is food fraud, I suggest you upload it so that people can suggest a Procedure.


Kind Regards,

 

Charles.C


AudreyB

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Posted 10 August 2018 - 01:20 PM

Our company have completed a Vulnerability Assessment for our facility, but we are unsure how to go about writing a Food Fraud Procedure or food Fraud Mitigation Plan... 

 

Can anyone assist with this??

 

Typically, your Food Fraud procedure should have been completed prior to completing your vulnerability assessment as the procedure will outline the steps you take during your assessment, which fraud factors you are assessing, and how to develop and implement your mitigation strategies. 

 

There are a number of great position papers available which can serve as a basis of understanding for developing your procedure. I would suggest at a minimum looking at the "GFSI Position on Mitigating the Public Health Risk of Food Fraud", available on the GFSI website and "Appendix XVII: Food Fraud Mitigation Guidance" available on the USP website. 

While reading these and writing your procedure you may realise that your vulnerability assessment needs to be modified. 

 

For your mitigation plan, think about what type of additional control actions you can put into place to monitor whether your product and/or supplier is conducting food fraud. The mistake I see most often in mitigation plans if that companies rely on their already implemented procedures as mitigation strategies. A mitigation strategy must be something you are doing in addition to your regular procedures for the products and/or suppliers you have identified in your vulnerability assessment. Common mitigation strategies may include: additional lab analysis, increased supplier audit frequency, additional documentation requested, etc. You strategies will depend on your industry and your supply chain. 

 

Good luck! 



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