2 replies to this topic

[fouziak]

Hello,

 

I m preparing a traning related to the employees duties related to food safety (personal hygiene) or food defense (what they should do to prevent a malicious act) but i don't know if there is something related to food fraud!!!

 

 

What can i add as duties and employees obligations?

 

 

Thank you for your help

[Duncan]

Pretty much, try to identify every instance of an employee carrying out any kind of activity that could be an opportunity to mitigate against food fraud, and integrate instructions into your policies and procedures. Sounds a bit vague, but here’re a couple of examples:

 

Challenge policy/stranger danger

Write a policy that states your company’s intention to challenge any individuals on site if they aren’t recognised. Incorporate this expectation into the induction training for all employees and detail the actions to be taken if they encounter anyone they don’t recognise.

 

Goods intake procedure

Incorporate inspection of vehicles, seals, and packaging integrity into your goods intake procedure and -if appropriate- include documented checks on your intake records. Make sure the procedure details actions to be taken in the event that evidence of tampering is discovered.

 

Storage and handling

Similar to intake controls, any RMs, WIP, or products should be stored covered and ideally in such a way as to prevent tampering. Procedures should detail actions to be taken in the event that evidence of tampering is discovered.

 

Supplier approval and performance monitoring

Include instructions for carrying out a vulnerability assessment at raw material approval. Make sure to include regular review of developing risks and horizon scanning. As a matter of policy, preferentially source raw materials from suppliers with favourable risk profiles over higher-risk sources.

 

Security and movement of people procedure

Make it policy to lock all security entrances and exits at all times when not in use. Include this in your procedure for people traffic and retain training records.

 

IT and cyber security

In general, it’s a good idea to have dedicated training on recognition of suspicious emails and dangerous attachments. There are various ways electronic security can be compromised – ranging from malicious software through phishing scams.

 

Confidential reporting

Make it company policy that if any employee witnesses suspicious or malicious activity, they are expected to escalate using your confidential reporting system.

 

Dispatch and transport

Write a policy to determine whether tamper-evident tape (or similar control) is appropriate for packaged product and incorporate the outcome into manufacturing instructions and include inspection at dispatch.

 

Manufacturing and recipe control

Identify all recipes that could be subject to substitution of raw materials and produce work instructions detailing permissible substitutions. For example, free-range egg may be used in place of caged egg, but caged egg may not be used in place of free-range egg.

 

 

You’ll probably find your facilities and processes have more specific opportunities for fraud risk mitigation, and it’s quite useful to look at each process step for vulnerabilities… But this is the sort of thing you can be looking at to make up a system for control across your business.

[TimG]

Hello fouziak,

Just to clarify, you have the GMP and food defense part locked up, you are just looking for advice on food fraud?

If so, this is typically handled in individual programs. For example, in your receiving program you might have:

• inspections by office of shipping documentation to make sure it was purchased from an approved supplier
• inspections of the product by receiving to make sure they are from an approved supplier.
• inspections of the product to determine labels are correct

There could also be a PnP for any purchasing group that makes sure they follow any requirements regarding approved suppliers (usually handled right in the Approved Supplier policy). 

 

If you're looking for what you can add, I'd suggest a 'See Something Say Something' approach similar to what FDA suggest for food defense. You would be focusing on what little things to keep an eye out for that are specific to your industry. Things like labels covering other labels, off color batches or liquid , texture differences in dry mixes that could be caused by product substitutions from your suppliers are all examples of what may or may not be specific to your industry.