What to do if an ingredient or sub-ingredient is found to have a high risk of food fraud?
what to do if an ingredient or sub-ingredient is found to have a high risk of food fraud.? Will requesting the vendor's food fraud SOP/Policy assure us there is/has been no fraud.?
Not completely. What we have done for high risk ingredients is get them tested. At a previous employer, we tested our parsley and our Parnassian cheese. they both proved to be the ingredient listed.
Hi ;)
I would challenge them with traceability and lab testing ;)
Usually you would need to see that a specific test/examination has been done, if not by your supplier then by yourself, targeting food fraud that could/likely be perpetrated, and show that it could be detected using that test/examination. I don't think the policy is enough by itself as a mitigation measure; it would need to be accompanied by the test/examination results.
I don't know what type of ingredient or sub-ingredient is in question here, but for example, for a powder, microscopic analysis could examine for added foreign matter such as bulking agents, adulterants, etc.
what to do if an ingredient or sub-ingredient is found to have a high risk of food fraud.? Will requesting the vendor's food fraud SOP/Policy assure us there is/has been no fraud.?
You might use their programs as justification for the frequency you perform verification testing, but not as a reason to take no action. The whole premise of fraud is economic motivation, and economic motivation it just as likely to lead to fraudulent claims in programs or seller testing results.
I'd agree with everyone that testing is what's needed, GM makes an excellent point:
The whole premise of fraud is economic motivation, and economic motivation it just as likely to lead to fraudulent claims in programs or seller testing results.
You should determine a testing frequency for this material based on risk, which may be reduced in frequency after a period of good test results as long as you're sticking with this same supplier. If this ingredient is at "high risk" for fraud, third party labs may already have great testing solutions developed to counter these fraud attempts since it's a known issue in the industry. I would contact laboratories you've worked with and get their input on what testing solutions there are. But the bottom line is that you'll need to do some testing.
Hi chuckzerbe,
The level of controls for high-risk ingredients would depend on the supply chain and history with the supplier.
Typical assurance controls may include:
Minimising the length of the supply chain
Certificates of analysis from ingredient suppliers
Supplier audits/enhanced supplier approval checks
Mass balance exercises at the ingredient supplier
Supply chain audits
Use of tamper evidence or seals on incoming ingredients
Ingredient testing
Monitoring of new factors that can affect the risk will mean you can adapt your assurances to reflect changes such as poor harvests, economic factors affecting the prices etc.
Where testing is useful in identifying adulterants, I would initially be testing each batch coming in to develop a level of confidence in the ingredient/supplier and review that once you have some history of supply.
Kind regards,
Tony