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Primus 18.01.01 - Food Fraud Vulnerability Assessment


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#1 nickjshelton

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Posted 23 December 2018 - 04:06 PM

Hello, 

Any suggestions on how to create a food fraud vulnerability assessment (FFVA) for a produce distribution facility? 

 

Thanks!



#2 Yoda of Quality

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Posted 26 December 2018 - 01:45 PM

Hello, 

 

https://www.foodsafe...rability-tool/ 

 

This is from Food Safety Magazine, it's an article about a tool that helps you develop your food fraud vulnerability assessment. 

 

Hope this helps,

-Joseph



#3 Charles.C

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Posted 26 December 2018 - 01:53 PM

Hello, 

 

https://www.foodsafe...rability-tool/ 

 

This is from Food Safety Magazine, it's an article about a tool that helps you develop your food fraud vulnerability assessment. 

 

Hope this helps,

-Joseph

 

The link seems to be obsolete. Together presumably with all the multitude of other site links in existence :crybaby:

 

"Inconvenience" is a major understatement.


Kind Regards,

 

Charles.C


#4 Yoda of Quality

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Posted 26 December 2018 - 02:01 PM

Hello again,

 

@Charles.C The link doesn't seem to go anywhere, you are right. I would edit my post but I'm unsure how to exactly to do so.

 

Search up on google "Food Fraud Vulnerability Assessment" beyond the training courses that you don't really need is free tools that you can utilize to develop your Food Fraud. 

 

Hope this helps!

 

Kindest Regards,

-Joseph



#5 nickjshelton

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Posted 26 December 2018 - 02:04 PM

Thanks, guys. I have been to that link, looked at the SSAFE tool. I am just not sure it makes sense for us. We handle hundreds of varieties of produce, and I don't think it makes sense for us to assess every item. It all comes in from vendors who have had their own safety audits. We receive the produce, and immediately turn it around and ship it. There has to be a better way.



#6 Charles.C

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Posted 26 December 2018 - 02:18 PM

Hello again,

 

@Charles.C The link doesn't seem to go anywhere, you are right. I would edit my post but I'm unsure how to exactly to do so.

 

Search up on google "Food Fraud Vulnerability Assessment" beyond the training courses that you don't really need is free tools that you can utilize to develop your Food Fraud. 

 

Hope this helps!

 

Kindest Regards,

-Joseph

 

No problem. Thks for the input. In fact it was useful to find out that a ton of IT links have just been rendered unusable. :smile:

 

@nickj - there are a variety of examples of  non-ssafe VA's on this forum (BRC, SQF, fssc22000, IFS) but i don't know what specific requirements Primus have stated (if any). Perhaps you could post (or link) the relevant segment of text ?

 

Regarding the "multitude of items", probably means that a "grouping" will be necessary. Easy to say ...........


Kind Regards,

 

Charles.C


#7 nickjshelton

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Posted 26 December 2018 - 02:19 PM

Ha. Yep.



#8 cindyhaz

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Posted 04 January 2019 - 09:34 PM

Hi Nick,

I'm struggling with this at our produce company. While fraud is huge with other products (olive oil, honey etc), produce is subject to USDA grading requirements. I've seen fraud defined as economically-motivated criminal activity. I don't see the connection with produce because nothing is added to it. It meets US grades or it doesn't. We accept it or reject it. It's either a round tomato or it isn't. Am I missing something? 

 

Mislabeling could mean a grower putting it in another box that doesn't correlate with his farm, but that's a traceability issue. The Produce Safety Rule and FSVP requirements should take care of that - and supplier control is our Preventive Control.

 

I'm doing the USDA Harmonized GAPS+ audit this year after years of Primus, and fraud assessment is a requirement. Probably because they recently received GFSI status.

 

Cindy



#9 amcarthur16

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Posted 14 February 2019 - 03:57 PM

Cindy,

 

I am in the same situation with our upcoming PrimusGFS audit for our Fresh-Cut processing plant.  We also warehouse and distribute hundreds of commodities.  Agree that it makes sense in other segments of the industry but beyond criminal activity, I am not sure how this applies to us???  Did you ever find a good answer?

 

Thanks in advance,

Adam


Edited by amcarthur16, 14 February 2019 - 03:57 PM.


#10 nickjshelton

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Posted 14 February 2019 - 05:41 PM

Cindy,

 

I am in the same situation with our upcoming PrimusGFS audit for our Fresh-Cut processing plant.  We also warehouse and distribute hundreds of commodities.  Agree that it makes sense in other segments of the industry but beyond criminal activity, I am not sure how this applies to us???  Did you ever find a good answer?

 

Thanks in advance,

Adam

 

We just finished our audit and scored perfectly on this question. We kept it VERY simple. We developed an assessment system where we score each vendor (and the products they carry) based on their likelihood of fraud. We only use approved vendors, and if we think there is a risk of fraud, we eliminate the vendor (which is our protection plan). I have attached a screenshot of what our assessment looks like. 

Attached Files



#11 Charles.C

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Posted 14 February 2019 - 09:14 PM

We just finished our audit and scored perfectly on this question. We kept it VERY simple. We developed an assessment system where we score each vendor (and the products they carry) based on their likelihood of fraud. We only use approved vendors, and if we think there is a risk of fraud, we eliminate the vendor (which is our protection plan). I have attached a screenshot of what our assessment looks like. 

 

Hi Nick,

 

I think you were fortunate in that yr auditor probably lacked knowledge of food fraud.

 

The form is borrowed from early approaches to food fraud vulnerability assessments.

 

Previously substantially criticized..

 

On the other hand, a lot of material in this area is, IMO, a waste of space from a safety POV so perhaps yr auditor possessed a similar viewpoint.

 

PS - not my area but i noticed this food fraud summary -

 

Attached File  Food Fraud, Fruit and Vegetables.pdf   136.66KB   68 downloads

 

PPS - FWIW "fresh produce" seems to so far be considered relatively insignificant this arena based on, afai could see, lack of linkages in the recent, voluminous book on food authenticity/Eurofins


Kind Regards,

 

Charles.C


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#12 Food Safety Katie

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Posted 15 March 2019 - 06:25 PM

Hi Nick, 

I'm in the same situation with the food fraud vulnerability assessment. We are just a grower and pack our own produce. When you used the template you attached did you use that for your pest control company, water testing lab, etc also? I have no ingredients  except for suppliers of pest control, packaging, etc. 

Thanks

Katie 



#13 cluna10491

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Posted 02 July 2019 - 06:56 PM

Hi Katie! I am in the same boat! We grow and pack our own produce. Just curious if you included your water testing lab/ pest control company in your assessment.

Kind regards,

 

Claudia

Hi Nick, 

I'm in the same situation with the food fraud vulnerability assessment. We are just a grower and pack our own produce. When you used the template you attached did you use that for your pest control company, water testing lab, etc also? I have no ingredients  except for suppliers of pest control, packaging, etc. 

Thanks

Katie 



#14 Willow Pearl

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Posted 24 July 2019 - 08:14 AM

Our audit is scheduled this week. I am concerned about our FFVA as well. Can anyone share theirs? I followed the above shared assessment. We're a handler of only potatoes. 



#15 Charles.C

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Posted 24 July 2019 - 08:38 AM

Our audit is scheduled this week. I am concerned about our FFVA as well. Can anyone share theirs? I followed the above shared assessment. We're a handler of only potatoes. 

 

I'm sort of surprised that  "potatoes" even  has a VA. :smile:

 

Species substitution ?

 

PS - post 10's form was recently reported as well-received in a SQF thread here despite, IMO, having major limitations.

 

Perhaps auditors have currently lost interest in this topic (no major disasters recently ?)  as compared to other FS areas.


Edited by Charles.C, 24 July 2019 - 08:58 AM.
expanded

Kind Regards,

 

Charles.C


#16 Willow Pearl

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Posted 24 July 2019 - 08:55 AM

I'm sort of surprised that  "potatoes" even  has a VA. :smile:

 

Species substitution ?

 

I am too. I'm not sure if there's even a substitution. We're a handler. We are contracted to remove dirt and debris from incoming harvest field trucks and then the product is shipped out to the processor who contracted the farmers to grow for them. They then take the potatoes and package microwave steamer containers. So do I form the assessment based on the processor? They could mislabel the product... sell as organic when potatoes are not. Sell excess unreported product. All extremely unlikely. ....I'm not sure. Since a potato is a whole product, you can't add ingredients to. 



#17 Charles.C

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Posted 24 July 2019 - 09:04 AM

I am too. I'm not sure if there's even a substitution. We're a handler. We are contracted to remove dirt and debris from incoming harvest field trucks and then the product is shipped out to the processor who contracted the farmers to grow for them. They then take the potatoes and package microwave steamer containers. So do I form the assessment based on the processor? They could mislabel the product... sell as organic when potatoes are not. Sell excess unreported product. All extremely unlikely. ....I'm not sure. Since a potato is a whole product, you can't add ingredients to. 

 

Hi WP,

 

TBH, I had assumed that "handler" in post 14 meant/included processor, Not sure how Primus scope differentiates Pre/Postgate stages ?  (BRC/SQF differ from each other in this aspect for a finished product "processor").

 

So what is the Fraudulent History of the Potato ? Zero ?


Kind Regards,

 

Charles.C


#18 tsebring

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Posted 24 July 2019 - 11:29 AM

The Primus reference is 1.08.01 (v3) and the language they use in their interpretation guidelines is as follows:

 

1.08.01: Is there a written food fraud vulnerability assessment (FFVA) and protection plan for all types of fraud, including all incoming and outgoing products?
 
Total compliance (5 points). There should be a vulnerability assessment and comprehensive protection plan for all types of food fraud. This includes economically motivated hazards, economically motivated food safety hazards, adulterant substances, theft, tampering, simulation, diversion or gray market, intellectual property rights and counterfeiting.
 
I've had my first v3 audit and went overkill on this one, because they were so vague, with three different types of assessments.  I looked at it within a HACCP model, by contributing factors, and also used the SSAFE tool to create an assessment.  In talking with the auditor, it was my impression that at this point, they are looking to see it being approached holistically, but as Primus hasn't mandated specific guidelines (and that this is new), only large glaring omissions would warrant a downscore.  
 
The SSAFE tool comes across as overkill, but is free and can be filled out over and over (till you get a final report that you are happy with).  The direct link to that tool is here: https://ffv.pwc.com/vsat/#/
 
I wasn't happy with what I did for the the contributing factors approach, so I'll leave that out, but the HACCP style template I created is attached if that helps anyone.  
 
My advice is to get something thoughtful put together and you should be fine.  They know it is new and that there isn't a specific standard out there to date.  Michigan State has a lot of free Food Fraud resources if someone needs more of a background on it.  http://foodfraud.msu.edu/
 
Anyway, hope this helps.  
 
Good luck,
Todd
 
PS: It's ok to say that you have a low possibility for the different types of fraud.  I know I did.

Attached Files


Edited by tsebring, 24 July 2019 - 11:32 AM.


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#19 potato cowgirl

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Posted 29 July 2019 - 01:33 PM

We had our audit back in May, we are a potato farm that grows, harvests, packs and ships whole potatoes. 

 

We completed the assessment : https://www.pwc.com/...assessment.html, printed that and created an SOP for the assessment. We received full points for the question.


Edited by potato cowgirl, 29 July 2019 - 01:33 PM.


#20 Charles.C

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Posted 29 July 2019 - 04:43 PM

We had our audit back in May, we are a potato farm that grows, harvests, packs and ships whole potatoes. 

 

We completed the assessment : https://www.pwc.com/...assessment.html, printed that and created an SOP for the assessment. We received full points for the question.

 

Thks input.

 

Indeed, most Audit bodies seem happy with this "system".

 

Unfortunately it tends to be noticeably  "heavy" on effort required (eg 40+ questions) compared to some other techniques unless a condensed version is employed.

 

I presume you still needed access to a food fraud database, which one did you use ?


Kind Regards,

 

Charles.C





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