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SQF 2.7.2.3 Food Fraud Vulnerability Assessment

Fraud Vulnerability Assessment

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#1 Jean Carmona

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Posted 18 December 2019 - 02:25 PM

Hello Guys,

 

Can someone help me out with an example of an scenario to verify and review the food fraud vulnerability assessment and mitigation plan?

 

Thanks in advance,



#2 Charles.C

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Posted 19 December 2019 - 02:14 AM

Hello Guys,

 

Can someone help me out with an example of an scenario to verify and review the food fraud vulnerability assessment and mitigation plan?

 

Thanks in advance,

 

Hi Jean,

 

May assist to supply some context.


Kind Regards,

 

Charles.C


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#3 Jean Carmona

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Posted 19 December 2019 - 01:38 PM

Hello Charles C., 

 

I have a minor in the clause 2.7.2.3 the auditor shared "food fraud assessment and mitigation plan was not reviewed and verified inthe last twelve months"

 

Now, if i contact one of my suppliers to put a label in one of the raw materials as contaminated and document the excersice if my floor personnel catches it would that be a compliance? Also add this program to the annual review program and revise it?

 

Thanks Charles!!!

 

Happy holidays!! 



#4 FurFarmandFork

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Posted 19 December 2019 - 03:47 PM

 

 

I have a minor in the clause 2.7.2.3 the auditor shared "food fraud assessment and mitigation plan was not reviewed and verified inthe last twelve months"

 

 

 

 

It looks like you just didn't document a review of the plan within the last year, is that true? Verification of your food fraud plan is going to be included in your annual review where you would evaluate whether your strategies are still going to be effective or not. This could be a review of recent fraud events in the news etc. to make sure your strategies would have identified those issues or not.

 

The auditing guidance doesn't imply that any more verification other than an actual review is necesssary:

 

 
The auditor must avoid pre-determining site’s food fraud vulnerabilities or making a quick decision on 2.7.2
Food Fraud. Food fraud is a new and inexact science, and there is no prescribed methodology for determining
vulnerabilities or their mitigating actions. It is based on the information that the site has available at the
time.
The auditor will seek evidence of compliance to this requirement by review of documents and records, and
interview. Evidence may include:
• There is awareness within senior management of the need for a food fraud vulnerability assessment and
mitigation strategies.
• There is a current, documented vulnerability assessment in place that identifies key ingredient
vulnerabilities including justification for their inclusion. The methodology for selecting the key ingredient
vulnerabilities shall be available.
• The vulnerability assessment shall include an evaluation of the site vulnerabilities including from staff,
contractors, and other associates.
• There are documented mitigation (ie prevention) strategies in place for all identified vulnerabilities, which
identify what is to be done and who is responsible.
• The mitigation strategies are active, and are being reviewed for effectiveness.
• The vulnerabilities and mitigation strategies are reviewed at least annually.
• There are records available of review of the food fraud program.

 

 

So your policy/vulnerability assessment should be reviewed against new information or new products/ingredients you work with to make sure it will still be effective, that way you can "verify" it. If you haven't updated or reviewed in the last year then this obviously didn't happen and that would be a minor.


Austin Bouck
Owner/Consultant at Fur, Farm, and Fork.
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.

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#5 Charles.C

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Posted 20 December 2019 - 03:45 AM

Hi Jean,

 

I do agree that the SQF Code text is ambiguous however the Guidance implies (sort of by omission :smile: ) that verification here only involves reviewing the "plan" generated data as detailed in Post 4.

 

In fact the "Audit guidance" chunk (see above) makes no specific mention of Verification !


Kind Regards,

 

Charles.C






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