5 replies to this topic

[Alexandra Joseph Rabbani]

I am completely redoing my Food Fraud Vulnerability Risk Assessment (SQF) and am struggling to differentiate between the mitigation strategies for high-risk and low-risk ingredients. 

We have a robust supplier documentation program, and require third-party audits, letters of guarantee, and COAs for all purchased lot numbers for all of our ingredients regardless of whether the ingredient is high- or low-risk. However, we recently lost a point on our audit for failure to implement more specific measures for the high-risk ingredients (ie. spices and extracts). 

 

Any thoughts or advice would be greatly appreciated! 

 

Thanks! 

[Scampi]

You could perhaps sample spices and extracts on a rotating schedule for identification to ensure they are what they are supposed to be

 

This wouldn't need to be often-say twice a year so that you cover all of your ingredients that you've deemed high risk over a reasonable amount of time

 

Do you currently verify lot numbers on your high risk ingredients at receipt to ensure nothing was switched between issuing you the CoA and you receiving the product?

[Alexandra Joseph Rabbani]

What manner of sampling would be appropriate? Is this yet another thing to send out for lab testing? If so, what manner of lab would be able to do the appropriate analysis? 

 

For all ingredients: 

The lot numbers on the bags/boxes are verified against the numbers on the invoices and everything is logged. 

Then the lot numbers are verified against the CoAs (partially to ensure nothing was switched, and partially to ensure that I have everything on file). 

[Scampi]

Ok-lets take a different approach …what mitigating strategies do you have for your high risk suppliers that you don't for your low?

 

Maybe work your program backwards and REMOVE some of your requirements for low risk suppliers (like a CoA) and leave them for high risk........then it appears that your handling high risk differently

 

Yes, if that's not an option you like, a quick google search will get you labs in your area that are capable of performing that kind of analysis

 

Also, you could go over your risk analysis again, maybe you've got too many high risk when perhaps they are medium  (just a suggestion)  

 

Always more than 1 way to skin a cat

 

If you have WRITTEN procedures that allow you to handle high and low risk differently (even though your approved supplier program asks for all of the docs you listed) then I'd fight for that point back

[Alexandra Joseph Rabbani]

The issue is just for spices and flavors, which any search will show you have a high risk of adulteration. Everything else on our list is low-medium. 

I can easily change the requirements in our procedures to only make the CoAs mandatory for the high risk ingredients, and voluntary for everything else.  

Then the question becomes how to differentiate between low and medium. 

 

I would love to fight for the point back -- The risk analysis hasn't changed since the last audit, but was only "dinged" this year -- but our auditor had the opportunity to take points off for other things this year and didn't, so I don't want to push it. 

 

The issue is that the consultant who compiled the risk analysis didn't distinguish the mitigation strategies between high risk spices/extracts and low risk anything else. They pretty much did a cut-and-paste job, and I deserve a point off for not noticing. So I am taking it upon myself to rewrite the risk analysis properly.

[Charles.C]

Hi Alexandra,

 

Unfortunately, you may need to be more specific as to yr current mitigation strategies/criticisms in order to get meaningful alternative suggestions.