Hi Mandark,
It is not something that I have considered doing but BRCGS Guidance does state that you can consider food defence and food fraud together, if that is a more effective use of time and resource. Whilst there is some cross-over there is quite a lot of difference in criteria as outlined below.
4.2 Food defence
The following clauses mirror those concerning food fraud (section 5.4), so the site can choose to consider food defence and food fraud together, if that is a more effective use of time and resource, or separately if the company prefers, providing both food authenticity and food defence are robustly assessed and managed.
5.4 Product authenticity, claims and chain of custody
Note that the security of products, while under the management control of the company, is also an important aspect of fraud prevention. Security of products is covered in section 4.1 and food defence in section 4.2; this section focuses on the sourcing of raw materials and their vulnerability within the supply chain.
BRCGS Global Standard for Food Safety Issue 9 Clause 4.2.2 Guidance for Documented assessment of security:
The company must undertake a threat assessment of the risks inherent to the operation
to prevent malicious intervention. The threat assessment needs to consider both external threats (e.g. individuals or organisations gaining unauthorised access to the site, building or products) and internal threats, such as malicious tampering by staff who are authorised to be on site.
Each area (e.g. warehouses, processing areas and external storage areas) needs to be assessed in terms of how vulnerable the product is to contamination. Sensitive or restricted areas, such as open product areas, are likely to be the most vulnerable; the vulnerability of the packaged product will depend on the nature of the packaging. Details of IT systems and data protection should also be included in the assessment.
BRCGS Global Standard for Food Safety Issue 9 Clause 5.4.3 Guidance for Food Fraud Vulnerability Assessment:
Typical information to incorporate into the assessment includes:
• any emerging issues and information identified in clause 5.4.2
• historical evidence of substitution or adulteration of the ingredient
• cost/value of the material
• availability (e.g. a poor harvest may restrict availability and may increase the potential for adulteration)
• sophistication of routine testing to identify adulterants
• country of origin
• length and complexity of the supply chain
• supply chain model
• controls that are already in the supply chain.
Food Fraud should also be considered as part of Section 3.5 Supplier and raw material approval and performance monitoring, particularly clauses:
3.5.1 Management of suppliers of raw materials and packaging
3.5.2 Raw material and packaging acceptance, monitoring and management procedures
Kind regards,
Tony
