Hi FoodsafetyQA,
Milk is a known example of a product that is at risk of food fraud. See Impacts of Milk Fraud on Food Safety and Nutrition with Special Emphasis on Developing Countries
BRCGS Food Clause 5.4.4 requires the vulnerability assessment plan to include appropriate assurance and/or testing processes to mitigate the identified risks.
BRCGS Guidance states: It is worth noting that the best controls are proactive and continuous as these are the most likely to prevent an incident from occurring. For example, product testing is a useful tool but it is reactive (i.e. it can only tell you if something has happened; it cannot prevent it from occurring or recurring in future).
So, supplier assurance is as important as testing, this includes:
certificates of analysis from raw material suppliers
supply chain audits
use of tamper evidence or seals on incoming raw materials
enhanced supplier approval checks
mass balance exercises at the raw material supplier
Raw material testing should be carried out on fresh milk routinely anyway such as Freezing Point Depression (FPD), acidity and antibiotics. A FPD test will detect added water which is the most common adulterant used.
Periodic checks for other adulterants such as melamine should also be carried at a frequency based on the level of confidence from your supplier assurance activities.
If you are using milk powder then water will not be a concern but periodic checks for other adulterants should be carried out as above.
Eggs are more liable to fraud when a claim is made such as organic or if the egg is from a species regarded as premium.
Kind regards,
Tony
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