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#1 Sarahb3339

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Posted 21 August 2018 - 03:57 PM

Hello, 

 

I am trying to find a template for a Food Fraud Vulnerability assessment that captures all of the new FSMA requirements.  I am currently SQF certified. 



#2 Ryan H.

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Posted 21 August 2018 - 05:43 PM

I attached a template for a Food Fraud Vulnerability Assessment. You might have to adjust it to your needs. 

 

Good Luck! 


All the best, 

 

Ryan Heavner 


#3 Ryan H.

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Posted 21 August 2018 - 05:44 PM

Sorry, please find the Food Fraud Vulnerability Assessment Attached here.. 

 

Good Luck! 

Attached Files


Edited by Ryan H., 21 August 2018 - 05:46 PM.

  • brnd.pnd and Sarahb3339 like this

All the best, 

 

Ryan Heavner 


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#4 Sarahb3339

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Posted 21 August 2018 - 06:03 PM

Thank you so much, Ryan.  Do you know of any data base or website that would have ingredients listed and their hazzards maybe?  We make dietary supplements and we use just basic fillers, micro crystalline, silicone dioxide, and some herbs. I'm having trouble trying to identify how to "rank" them for food fraud. 



#5 Ryan H.

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Posted 21 August 2018 - 06:15 PM

Food Fraud Database to support Vulnerability Assessment..HELP!

 

Search the above title in this forum and it should take you to a discussion on food fraud that could prove useful. 

 

 

 

Most food fraud websites require an annual fee. Your best bet is to search reputable websites like http://www.foodqualityandsafety.com/ for example to try and find some answers about specific items. 

 

Also depending on what your selling, you would look into the ingredients to see if any of them our at a risk for food fraud practices.


All the best, 

 

Ryan Heavner 


#6 Sarahb3339

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Posted 21 August 2018 - 06:24 PM

Yes! I noticed that!  And they are quite expensive!  Do I have to do the "consequence part" or can I just add that in on my Food Fraud vulnerability SOP and Mitigation plan?



#7 Ryan H.

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Posted 21 August 2018 - 07:13 PM

Do you mean the economical consequence? 

 

I would do it if that is what your referring too. You would need to make a determination on what that would be given your process what you make and how much of one ingredient you use. 


All the best, 

 

Ryan Heavner 


#8 Sarahb3339

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Posted 21 August 2018 - 07:36 PM

Sorry, no I meant the memberships to access those sites. We just make dietary supplements.  Primarily workout supplements so ingredients like beta alanine , Caffeine, etc.  Blended powders.  I already had a risk assessment in place but not one that got into the food fraud vulnerability assessments. I actually have an audit next week for SQF.



#9 Ryan H.

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Posted 21 August 2018 - 07:40 PM

Next week! Your going to be busy. Good Luck to you! Is this your first? Or is this a re-audit? 

 

I think if you get the template filled in properly you should be good. 

 

When you do reserch via the internet, book, etc., be sure to copy the website, book down somewhere to prove what you looked at. 

 

Best of Luck. 


All the best, 

 

Ryan Heavner 


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#10 Sarahb3339

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Posted 21 August 2018 - 07:42 PM

Thank you ! What type of manufacturing does your company do?



#11 Ryan H.

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Posted 21 August 2018 - 07:53 PM

We are a Bakery and we manufacturer items like Croissants, Danish's and Sweet Rolls like Cinnamon Rolls. 


All the best, 

 

Ryan Heavner 


#12 Charles.C

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Posted 21 August 2018 - 08:12 PM

Hi Ryan,

 

Not wishing to be overly negative  but IIRC the template in Post 3 was initially posted here approx. 3-4 years ago around when BRC started the Vulnerability Boom.

 

At that time, from a BRC POV, it was poorly evaluated/critiqued and afaik sort of disappeared from view.

 

I'm rather uncertain that it now matches the SQF expectations ?

 

May i ask if you have  used it yourself for SQF audit purposes ?


Kind Regards,

 

Charles.C


#13 Charles.C

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Posted 21 August 2018 - 08:17 PM

addendum

 

@Sarah - As Ryan indicated there are very few free databases around at this time. Two which have been recently suggested are at these links -

 

http://www.ifsqn.com...se/#entry116201

(trello)

http://www.ifsqn.com...se/#entry126619

(RASFF)

 

There are several other VA "templates" on this forum but only 2-3 afaik specifically intended for SQF.


Kind Regards,

 

Charles.C


#14 Ryan H.

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Posted 21 August 2018 - 08:26 PM

Hi Charles. 

 

I have a bunch of templates! That's for sure. Most are mine, but i do have plenty others from colleagues and i have even pulled some from this forum to grade against mine own. I cannot say where got this one from... it was just on my templates folder! 

I have not had an edition 8 audit yet in which they will be looking at food fraud, but i have had a CB auditor visit and he liked the one i was using, which is similar to the one i attached. I do not typically post forms i am using in my plant, but this one is similar to it. 


All the best, 

 

Ryan Heavner 


#15 Charles.C

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Posted 21 August 2018 - 08:45 PM

Hi Charles. 

 

I have a bunch of templates! That's for sure. Most are mine, but i do have plenty others from colleagues and i have even pulled some from this forum to grade against mine own. I cannot say where got this one from... it was just on my templates folder! 

I have not had an edition 8 audit yet in which they will be looking at food fraud, but i have had a CB auditor visit and he liked the one i was using, which is similar to the one i attached. I do not typically post forms i am using in my plant, but this one is similar to it. 

 

Hi Ryan,

 

Thks for comment.

 

Indeed this IMO is the constant problem with VA. Half the time the auditors have no better idea what to expect than the auditee.! Especially when it has just been introduced.

 

There was at least a 1-year initiation period when BRC kickstarted this all and during that time their auditors afaik accepted almost everything resembling VA in sight.

 

However the BRC approach is far more specific/condensed than the one SQF have launched which i suspect will only accentuate the headaches. Plus SQF are clearly promoting PWC et al for reasons only known to themselves.

 

One obvious snag with the template under discussion is how on earth to estimate the economic column (an idea borrowed from USP). On the other hand some of the column entries in other proposed approaches also look equally intuitive so maybe the auditors will just let it go. Shades of HACCP.

Another snag is 2 of the columns (5-6) look almost the same to me.

Another snag afaik is the 7th column (mitigation) normally comes after the VA ?

 

Regardless, if at least one auditor liked it ........


Edited by Charles.C, 21 August 2018 - 09:45 PM.
expanded

Kind Regards,

 

Charles.C


#16 Ryan H.

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Posted 21 August 2018 - 09:00 PM

Yes the VA is before the MS. In this case once the VA is completed you would need to develop a MS to add all of the relevant information onto. The economic piece is difficult, but you use the information you have. If you have one ingredient supplier, there your biggest supplier too, and their is a food fraud issue with them, that could be costly, it could cause big problems. You would do your best to determine what that impact would be.

 

And sorry i am not seeing what your referring too. Again it's a template, mock it up as needed. Revised it to suit you. I believe the one i attached had a column missing in column 6 so i'm not sure what your referring too.

 

Remember a good vulnerability is meant to assess the kind ingredient (fish is always a big one in the world of food fraud) and the supplier. Choose the ingredients and review the suppliers. 

 

Charles do you have any other templates that might be more useful in regards to food fraud? 


All the best, 

 

Ryan Heavner 


#17 Charles.C

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Posted 21 August 2018 - 09:28 PM

Yes the VA is before the MS. In this case once the VA is completed you would need to develop a MS to add all of the relevant information onto. The economic piece is difficult, but you use the information you have. If you have one ingredient supplier, there your biggest supplier too, and their is a food fraud issue with them, that could be costly, it could cause big problems. You would do your best to determine what that impact would be.

 

And sorry i am not seeing what your referring too. Again it's a template, mock it up as needed. Revised it to suit you. I believe the one i attached had a column missing in column 6 so i'm not sure what your referring too.

 

Remember a good vulnerability is meant to assess the kind ingredient (fish is always a big one in the world of food fraud) and the supplier. Choose the ingredients and review the suppliers. 

 

Charles do you have any other templates that might be more useful in regards to food fraud? 

 

Hi Ryan,

 

By (5-6) I meant that (IT search for Fraud")  looks ~= ("Fraud findings")

Yes, i agree with you about the Economic. It's certainly easy enough to guess. Less easy to answer auditor queries though.

 

There are several other complete forum templates here but unfortunately  I think none were intended for SQF (eg see Post 7 in last link below).

 

Three SQF-specific VA contributions that i can recall are -

 

http://www.ifsqn.com...es/#entry126181

(mgourley - textual-template VA)(actually not 100% sure this was SQF)

http://www.ifsqn.com...ts/#entry124637

(Scampi - scrambled textual template VA)

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

(3f - overview VA procedure / detailed mitigation strategy)

 

I guess it should also be remembered that SQF has some specific requirements in the relevant Food Fraud clause (see the details in last link above).


Kind Regards,

 

Charles.C


#18 Ryan H.

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Posted 21 August 2018 - 09:39 PM

Charles: That would be intended to add where you searched and what it was (website / book / article). Then the results next to it. 

 

Thanks for all of the links. It will surely be useful!

 

And yes the SQF guidance documents are most helpful in regards to this! 


All the best, 

 

Ryan Heavner 


#19 Charles.C

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Posted 21 August 2018 - 09:49 PM

Charles: That would be intended to add where you searched and what it was (website / book / article). Then the results next to it. 

 

Thanks for all of the links. It will surely be useful!

 

And yes the SQF guidance documents are most helpful in regards to this! 

 

Understood  but it seemed like cheating to me to score both of them. ;)


Kind Regards,

 

Charles.C


#20 mgourley

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Posted 21 August 2018 - 10:33 PM

Since the OP specifically addressed "food fraud" as part of FSMA, it might be worth the time to understand that FDA addresses "food fraud" and "EMA" two places in the FSMA Final Rule amd that GFSI schemes address them differently.

 

This email, that I got today, sort of breaks them out, and just makes the waters more muddy. FDA has specific templates in their Draft Guidance for Intentional Adulteration, but it's not the same thing as "food fraud".

 

Marshall


Edited by mgourley, 21 August 2018 - 10:33 PM.


#21 Charles.C

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Posted 21 August 2018 - 11:19 PM

Since the OP specifically addressed "food fraud" as part of FSMA, it might be worth the time to understand that FDA addresses "food fraud" and "EMA" two places in the FSMA Final Rule amd that GFSI schemes address them differently.

 

This email, that I got today, sort of breaks them out, and just makes the waters more muddy. FDA has specific templates in their Draft Guidance for Intentional Adulteration, but it's not the same thing as "food fraud".

 

Marshall

 

Hi Marshall,

 

Thanks.

 

Question 1 response i frankly found incomprehensible. Probably on me.

 

Question 2 response is demonstrably incorrect if one compares SQF8 Manufacturing Code's stated food fraud requirements. (An unfortunate consequence of SQF attempting to issue a genuine FS Code).

 


Kind Regards,

 

Charles.C


#22 mgourley

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Posted 21 August 2018 - 11:38 PM

Charles,

 

FSMA and their intentional adulteration rule necessarily states that EMA is rare and facilities really only need to account for items that have a history of EMA.  
Then again, it's draft guidance for industry.

 

BRC specifically addresses "food fraud" and requires that all raw materials be assessed. One could take that to mean that GFSI is actually ahead of FDA in their thinking. 

FDA has specific templates in their draft guidance, BRC does not. It's all a bit confusing, but if you meld the two, you will meet FDA requirements and overkill BRC.....except that FDA has specifically mandated the HA and mitigation strategies for what they consider "intentional adulteration".

Several years ago FDA came out with guidance on where in the process intentional adulteration could occur, that they were concerned about. But that was before the "Intentional Adulteration" Rule. It was at the time, the basis for their "Food Defense Plan Builder." 
FDA has since withdrawn that tool, because it does not meet the intent of the intentional adulteration rule as part of FSMA.

It's my understanding that, for whatever reason, Food Defense and Intentional Adulteration are not the same things in the eyes of FDA.

Even though they should both be parts of the same thing IMHO.

 

Marshall



#23 Charles.C

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Posted 22 August 2018 - 12:16 AM

Charles,

 

FSMA and their intentional adulteration rule necessarily states that EMA is rare and facilities really only need to account for items that have a history of EMA.  
Then again, it's draft guidance for industry.

 

BRC specifically addresses "food fraud" and requires that all raw materials be assessed. One could take that to mean that GFSI is actually ahead of FDA in their thinking. 

FDA has specific templates in their draft guidance, BRC does not. It's all a bit confusing, but if you meld the two, you will meet FDA requirements and overkill BRC.....except that FDA has specifically mandated the HA and mitigation strategies for what they consider "intentional adulteration".

Several years ago FDA came out with guidance on where in the process intentional adulteration could occur, that they were concerned about. But that was before the "Intentional Adulteration" Rule. It was at the time, the basis for their "Food Defense Plan Builder." 
FDA has since withdrawn that tool, because it does not meet the intent of the intentional adulteration rule as part of FSMA.

It's my understanding that, for whatever reason, Food Defense and Intentional Adulteration are not the same things in the eyes of FDA.

Even though they should both be parts of the same thing IMHO.

 

Marshall

 

Hi Marshall,

 

Thks for above. I understood over half of it but that's because I'm no longer up-to-date with the FSMA juggernaut.

 

This topic IMO has now become just a great, big, mess of conflicting terminologies/interpretations. It's OPRP all over again.

 

The fact that FDA's VA is not the same as GFSI's also continuously screws up one's reading.

 

So far i credit BRC as having easily given the best explanation of what they want you to do and which apparently does not require an Encyclopedia. Pity it's not free though.


Kind Regards,

 

Charles.C


#24 mgourley

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Posted 22 August 2018 - 12:30 AM

Charles,

 

Indeed.

 

As if it's not already complicated enough.

 

Marshall



#25 gud2ya

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Posted 27 September 2018 - 06:34 AM

Thanks for this






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