BRCGS 5.4.4 - Food Fraud Risk
We are small bakery in Canada and our BRC Audit is coming soon, I was reviewing BRC guidelines and finds that 5.4.4 that annual testing is required for High risk ingredients, We do not use honey, olive oil, we only use milk and Egg product for mixing. Does it need to test for food fraud?
This takes some research into the ingredients you handle, specifically to find whether these commodities have been subjected to food fraud in the recent past. From a quick search on sites like this, you'll find commodities recently defrauded include:
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
Yes you need testing.
Hold the phone
You said you're in Canada correct? If you are buying eggs and milk that are only product of Canada AND you're not buying organic or products with added nutrients, you're risk is very very very slim
Both of these commodities are supply controlled, meaning a federal body is ultimately responsible for not only the amount sold/produced but also quality--- I would be including that in my PCP and/or risk assessment
https://dairyfarmersofcanada.ca/en
when it comes to eggs (liquid, in shell, dried etc) it almost 100% comes from Canadian sources, VERY rarely are imports of these commodities allowed due to the quota system (and the free trade agreement)
Fingers crossed your auditor is Canadian so they will / should already know how this works here
Thank you Everyone for the response . I agree with you. Also we do have strong supplier program so it cover as preventive controls
Hold the phone
You said you're in Canada correct? If you are buying eggs and milk that are only product of Canada AND you're not buying organic or products with added nutrients, you're risk is very very very slim
Both of these commodities are supply controlled, meaning a federal body is ultimately responsible for not only the amount sold/produced but also quality--- I would be including that in my PCP and/or risk assessment
https://dairyfarmersofcanada.ca/en
when it comes to eggs (liquid, in shell, dried etc) it almost 100% comes from Canadian sources, VERY rarely are imports of these commodities allowed due to the quota system (and the free trade agreement)
Fingers crossed your auditor is Canadian so they will / should already know how this works here