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How to do a Vulnerability Assessment for Storage and Distribution

From the desk of Karen Constable, our Principal Consultant

The other day, a frustrated food safety manager wrote to me, wanting help to figure out how to do a food fraud vulnerability assessment for storage and distribution (BRCGS Issue 4).

It’s such a tricky one, because storage and distribution (S & D) facilities have so little direct control over product choices.  And the BRC standard is so wordy!

The good news is that when BRC first added product fraud to their storage and distribution standard in 2018 (Issue 3), they wrote a position paper that attempted to provide some guidance.

Even though Issue 4 is a bit different to Issue 3, the guidance in the position paper is still useful.

Here’s just a small portion of guidance from BRC Position Paper:

“The Standard does not define the exact process that the company must follow when completing the vulnerability assessment;however, it is likely to incorporate the following steps:

  • draw up a list of products and services and the controls that are already in operation (e.g. approval of suppliers by customers, pre-packaged products purchased)
  • consider any relevant information regarding potential fraud for each product and service
  • complete a risk assessment on the vulnerability of the products.

The output of the vulnerability assessment is usually a ranking or scoring of the materials to identify those which need additional controls. The ranking and actions required could, for example, be as follows:

  • Very high – a high-profile product with recent reports of adulteration or substitution published by regulatory authorities. Action or monitoring is required to ensure that only genuine materials are purchased.
  • High – a high-profile product that provides an attractive target for potential substitution or adulteration. Some action and/or monitoring is required to ensure that only genuine materials are purchased.
  • Low – this product is unlikely to be a target for substitution or adulteration. However, a re-assessment may be necessary if new information becomes available.
  • Negligible – no further action is required as the product is extremely unlikely to be a target for fraud.”

 

There’s more in the position paper, which you can read or download from the BRC Website: https://www.brcgs.com/media/1055426/sd308-position-statement-accommodating-the-requirements-of-gfsi-benchmark-72-into-issue-3-v2-12082019.pdf

If you are completely new to vulnerability assessments, we have step-by-step instructions on our website, which might help a little if you haven’t seen it yet.  Plus, our on-demand, online food fraud training might also help.  Although both of these resources were created primarily for food manufacturers the concepts of vulnerability assessments also apply to S & D facilities.

I can also assist with custom one-on-one consulting, guidance/feedback or custom templates if you need.   Just get in touch and we can hop on a phone call to discuss.

Regards,

Karen Constable

Food Fraud Advisors

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Food Safety Standards Compared (2022)

 

Image credit: Robert Anasch

 

Different food safety standards have different food fraud requirements. For example:

  • Some standards require food businesses to include counterfeiting in their vulnerability assessments, while others don’t.
  • Some standards specify that vulnerability assessments must be performed on ingredients, while others state they should be done on finished products.

Confused? We are here to help.  Read on to find out which standards have what requirements, and get recommendations for creating a great food fraud prevention (VACCP) program.

Background

Food safety standards are standards that describe requirements for food and related businesses.  The requirements aim to ensure that food and food-related goods are safe for consumers and customers.  The correct term for such standards is food safety management systems standards (FSMS).

There are food safety standards for all types of operations within the food supply chain, including:

  • growing and packing fresh produce,
  • manufacture of food and food ingredients,
  • buying and selling food (“brokers”),
  • storage and transport of food,
  • manufacture or converting of packaging materials
  • manufacture of animal feed or pet food,
  • services such as cleaning, laundry, or pest control for food businesses.

While the over-arching aim of all food safety standards is to keep consumers safe, many standards also serve secondary purposes. Some of the most popular food safety standards were developed by food retailers, with the aim of protecting their brands as well as keeping consumers safe. Other standards were developed to help food businesses understand best practices and gain a way to demonstrate their excellence through independent certifications.  Some standards include quality parameters, while others only address food safety issues.

There are dozens of internationally accepted food safety management system standards, each with slightly different requirements.  This can make it difficult to know which standards are ‘better’ or more suitable for your food company.

To solve this problem, a standard for food safety standards was created by the GFSI (Global Food Safety Initiative).  The GFSI assesses and approves food safety standards using a process called benchmarking. The aim of GFSI benchmarking is to define best practice in food safety standards and provide a way to compare and align different food safety standards.

Among the dozens of food safety standards, some are benchmarked by the GFSI (Global Food Safety Initiative), while others are not.  Benchmarked standards usually have more requirements and more rigorous expectations than non-benchmarked standards.  The auditing and certification processes for benchmarked standards are typically more expensive than for non-benchmarked standards.

Food Fraud in Food Safety Standards

Food fraud prevention activities are an important part of all food safety management systems because food fraud can pose a risk to food safety.  Some food safety standards have separate, stand alone requirements for food fraud prevention activities, while others do not.  Standards that are GFSI-benchmarked all include explicit, separate food-fraud-related requirements. Other standards rely on the hazard analysis elements of the food safety system to identify and control hazards from food fraud.

The GFSI benchmarking requirements specify that all benchmarked standards include a vulnerability assessment for food fraud and a mitigation plan for food fraud prevention.  Most GFSI-benchmarked standards also include details about which materials should be assessed and which types of food fraud need to be managed.

Non-GFSI standards vary in how they require a food company to approach food fraud.  Some specify or recommend a VACCP program, which is based on food fraud vulnerability assessment activities. Others, like AIB, require that food fraud risks be considered in the supplier approvals processes.  The regulations of the USA Food Safety Modernization Act (FSMA) require that food businesses identify hazards from economically motivated adulteration type food fraud and implement preventive controls to minimise the risks.

Among the most well-known standards there are some notable differences. For example, the SQF Food Safety Code requires food businesses to assess and manage risks from counterfeit-type food fraud, while the BRC Food Safety Standard only requires businesses to assess the risks from adulteration or substitution activities. BRC also requires horizon scanning activities, while the SQF and IFS standards explicitly mention food fraud training.

Below you will find a table that compares the current food fraud requirements of each of the major food safety standards.

Table 1.  Food fraud requirements of major food safety standards, 2022.  Click here for a pdf version. 

  AIB* BRC* FSSC* GlobalGAP* IFS* SQF*
Food types to include in food fraud prevention activities Ingredients (implied)

 

 

 Raw materials

 

 

 Products and processes

 

 

 Unclear

 

 

 Raw materials,

ingredients,

packaging,

outsourced processes

 Raw materials,

Ingredients,

finished products

 
Food fraud types

 

 

 

 Economically motivated adulteration (only)

 

 

 Adulteration,

substitution

(only)

 

 

 Any type where consumer health is at risk (in definition, Appendix A)

 

 Unclear, however counterfeit or non-foodgrade packaging or propagation materials are included as examples

 

 Substitution, mislabelling, adulteration, counterfeiting

 

 

 Substitution, mislabelling, dilution, counterfeiting

 

 
Vulnerability assessments explicitly required? Risk assessment (implied, Appendix A) Yes Yes Risk assessment Yes Implied (Edition 9)
Mitigation plan required?

 

 

 – Mitigation activities are to be included in the vulnerability assessment Yes Yes Yes Yes
Does packaging need to be included in the vulnerability assessment? Yes

(implied)

 

 Yes

(see 3.5.1.1)

 

 Yes

(as per food fraud definition, Appendix A)

 Yes

 

 

 Yes

 

 

 Implied

(primary packaging is a ‘raw material’)
Is a separate food fraud procedure explicitly required? – – Yes – Implied

(“responsibilities shall be defined”)

 Implied

(“methods and responsibilities shall be documented”)
Is training in food fraud explicitly mentioned? – – – – Yes

(Clause 3.3.4)

 Yes
Is an annual review explicitly required? – Yes – – Yes Yes
Other

 

 

 – Horizon scanning for developing threats must be done (Clause 5.4.1) – – Criteria for vulnerability assessments must be defined

(4.20.2)

 Food safety risks from food fraud must be specified (2.7.2.2)

*  The full names of the standards are as follows:

AIB International Consolidated Standards for Inspection Prerequisite and Food Safety Programs, 2017

BRCGS Food Safety, Issue 8

FSSC 22000, Version 5.1

GlobalG.A.P. Integrated Farm Assurance (IFA), Version 5.4-1

IFS Food, Version 7

SQF Food Safety Code, Edition 9

To get this table in a downloadable format, click here.

Takeaways

Among the major food safety management system standards, there are small but significant variations between food fraud prevention requirements.  Key differences include whether finished products or ingredients are to be assessed, which types of food fraud must be included and the presence/absence of requirements related to horizon scanning and training.

If that all seems confusing, don’t despair!

Recommendations for a robust and compliant food fraud prevention program (VACCP)

At Food Fraud Advisors we have been working at the intersection of food fraud and food safety since the very beginning!  Creating a robust and compliant food fraud program can take time and effort but it isn’t complicated.  Follow the steps below to get started:

  1. Carefully read the food fraud clauses of the standard you are/will be certified to.  This download has a complete list of clauses for food fraud requirements of all major standards.
  2. Pay attention to the food types and the food fraud types that are mentioned in your standard.
  3. Create a robust vulnerability assessment (here’s how) and a mitigation plan for identified vulnerabilities.
  4. Whether or not it is explicitly required in your standard, we recommend you create a food fraud prevention procedure that defines the methods, responsibilities and criteria for food fraud prevention.
  5. You should also conduct training for all relevant staff and ensure that the food fraud system is reviewed at least annually.

Get a complete guide to the food fraud requirements of all the major food safety standards from us, the food fraud experts, here.  Our join the waiting list for our 2022 workshops here.

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Vulnerability Assessments

What is a vulnerability assessment?

 

A vulnerability assessment is a risk-assessment-style evaluation of a food’s vulnerability to food fraud.

A food fraud vulnerability assessment is a documented assessment that identifies vulnerabilities to food fraud and explains how those vulnerabilities were identified.

Vulnerability assessments are also done to assess the threat of a malicious attack on food.  Malicious attacks include attacks conducted for extortion, ideological reasons or terrorism. We call these issues of food defense. To learn more about vulnerability assessments for food defense (intentional adulteration), click here.

Why ‘vulnerability’ and not ‘risk’? 

 

  • A risk is something that has occurred before and will occur again. A risk can be quantified using existing data.
  • A vulnerability is a weakness that can be exploited.  A vulnerability can lead to a risk.

Food fraud is difficult to estimate and quantify, so we use the word vulnerability rather than risk.

Why do a vulnerability assessment?

 

  1. To protect consumers: Food that is vulnerable to food fraud presents significant risks to consumers.  Food that is adulterated or diluted   [Read more…]

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Interpol and Food Fraud; Celebrating 10 Years of Operation Opson

Operation Opson is a joint activity of Interpol and Eurpol that targets counterfeit and sub-standard food and beverages.

This year marks the tenth iteration of Operation Opson.

Operation Opson X ran from December 2020 to June 2021 in 72 countries. Food and drinks worth €53.8 M were seized and 663 arrest warrants were issued.  Honey, beverages and horsemeat were areas of focus for this operation.  You can find the official Europol press release here.

Honey

Authorities performed 495 checks on honey samples as part of Opson X.  Samples were obtained from all along the supply chain, including from the farmgate, wholesalers, distributors and retailers. Most of the checks aimed to detect added sugars or corn syrup in the honey.  Of the 495 checks, 7% were found to be non-compliant and 51,000 kg of honey was seized.

Beverages

During Opson X, the most problematic beverages were wine and vodka.  A total of 1.7 M liters of alcoholic beverages were seized by authorities.  For wine, fraudulent bottling and labeling was a notable problem, with wine bottling operation(s) in Italy allegedly applying labels that misrepresented the geographical origin of the wine. In Spain, whisky with added colorant was found.  The colorant was said to have been added to enhance the perceived quality of the product.

Horsemeat

Horsemeat and the use of unapproved horsemeat for human food continues to be a focus for food fraud enforcement in Europe.  During Opson X, authorities uncovered sophisticated operations in which horses that were not approved for human consumption were being traded across international borders with false documents.  Investigations are continuing.

Other Meat

A survey of meat products in Germany found that 3% of samples (n = 264) were affected by species substitution, that is, the meat contained species that were not declared on the label. Source: Food Safety News

Unsafe and Fraudulent Seafood

Spanish and Portugese authorities identified illegal fishing of bivalve seafood such as clams in a wide-ranging investigation.  The seafood was harvested illegally and was not processed, handled or labeled properly, resulting in potential food safety issues.  At least 12 fishing vessels were implicated.

Food Supplements

In this iteration of Operation Opson, food supplements and additives were the second most seized food type, by quantity, after alcoholic beverages.  At the time of writing no details of such seizures are available.

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2019; the year in review

Happy New Year and welcome to 2020.  Last year included many pleasing, positive developments in food fraud prevention.  More and more people from within the international food industry are becoming aware of the prevalence of food fraud and becoming better educated about the risks it poses to consumers and businesses.  There were new developments in technology and more enforcement activities, plus awareness has continued to spread to peripheral industries and unconventional marketplaces.   Food Fraud Advisors and our sister company Authentic Food launched new products and continued to serve our growing customer community across the globe.  Thank you for your support in 2019.  I look forward to serving you in 2020.

Karen Constable, Principal Consultant, Food Fraud Advisors

Better assessments and tests

Food safety professionals are becoming more comfortable with performing food fraud vulnerability assessments and I have seen the quality of assessments improve markedly in the past year.  Food laboratories are also gaining more expertise in food authenticity testing.  Better test methods have been developed, and this is helping the labs to do their jobs more easily,  but for me I think the most important thing is that laboratory sales personnel are becoming better at understanding the needs of their food business customers when it comes to food fraud detection.

Food testing labs have better tools to meet the needs of their food industry customers

 

New food fraud prevention strategies

The past year saw significant increases in proactive prevention initiatives that extend beyond typical anti-counterfeit tools.  As an example, a famous Scottish salmon brand has recently implemented a chemical ‘fingerprint’ system to allow them to pursue suppliers of inauthentic product across their growing global supply chain.  BeefLedger is a new provenance verification product, which supports Australian beef exporters through the use of blockchain technology.

International enforcement

In India, there has been an ongoing effort by the media to publicise food adulteration problems in that country.  In response, government authorities are tackling the problem head on, with the aim of increasing trust in the food supply.  Indian news outlets feature stories of seizures and shutdowns of illegal food outlets on an almost daily basis.  Tea, spices, ghee, jaggery, cooking oil and milk are often affected.  The Food Safety and Standards Authority of India has promised to reimburse the cost of food fraud testing for consumer samples tested by credible consumer organisations.

The food crime unit in the UK benefitted from more funding last year, which increased its investigative capacity and its ability to train people in other agencies on food fraud awareness and intelligence handling.

In Europe there appears to be a growing acceptance that some organised crime groups are actively choosing to include food fraud operations within their money-making portfolios.  Although this type of operation may not be the norm, it does occur and acknowledgement of the problem is an important step in the fight to intercept and control such crimes.

Operation Opson, a joint operation between Interpol, Europol and national law enforcement agencies was run again in 2019, for the eighth year.  Operation Opson sees fraudulent food, drink and supplements investigated, located and seized by authorities across the globe, from sub-Saharan Africa to South America.  The categories of items seized most often in 2019 were illicit alcohol, cereals (grains) and condiments.  This year also included targeted actions that focussed on organic foods, coffee and 2,4-Dinitrophenol (DNP), an illegal fat-burning supplement that has caused multiple fatalities in recently years.

Grain was the second most-seized food type in Operation Opson VIII

 

In the USA, enforcement activities are also on the rise.  In 2019 there were a number of high profile prosecutions of business owners in the seafood, beef and pet-food industries.  The implementation of the Food Safety Modernisation Act (FSMA) has improved the standard of knowledge about food safety hazards and controls across the food industry in that country.  Also in 2019, many USA food companies were required to meet the International Adulteration (IA) rule of FSMA for the first time.  The rule is designed to prevent malicious threats to public health from food adulteration.  While the IA rule is not technically related to food fraud, it has made an important contribution to the concept of food safety.  As the new decade unfolds, I predict we will continue to expand our understanding of food safety; from our historical focus on natural and accidental contaminants to wider awareness of the risks posed by deliberate, human-mediated hazards.

Marketplace improvements

The good news continues, with 2019 witnessing a small but subtle shift in the willingness of online marketplace owners to talk about the problem of counterfeit goods in general, and counterfeit foods, drinks and supplements in particular.  There has been a change in the discourse around counterfeit products which increasingly addresses safety issues in addition to financial costs.  While many consumers and retailers continue to tolerate, or even seek out, counterfeit fashion items, more businesses are becoming aware of the prevalence of unsafe counterfeit supplements, foods and electronic components in online marketplaces.  And as awareness grows, I expect enforcement and preventive activities to follow; resulting in gradual improvements to the way we source and supply goods online.

Beyond food and drink

The food industry’s anti-fraud crusade has spilled over into related industries, including agricultural chemicals and packaging materials.  These two global heavy-weights are benefitting from the food industry’s food fraud awareness and prevention strategies of recent years.  As an example, the British Retail Consortium (BRC) included raw material fraud prevention activities in its most recent Packaging Materials Standard.   In pesticides, Operation Silver Axe resulted in the seizure of 550 tonnes of illegal or counterfeit pesticides across Europe.

The packaging materials industry has benefitted from lessons learned in food fraud prevention

Our year in review

Last year Food Fraud Advisors passed the 2000 downloads milestone for our tools and templates.  We continue to receive wonderful feedback and rave reviews for  our tools, templates and downloads.

We have customers in 48 countries, from large multinational food conglomerates to small start-ups, and everything in between.  While most are food manufacturers, this year we have had more customers from businesses peripheral to food production, such as brokers, logistics businesses and packaging manufacturers.  Students and consultants continue to make up a small but significant proportion of our online learning community.

 

New products

With our sister company, Authentic Food, we developed and launched the Intentional Adulteration Vulnerability Assessment Tool in June.  It filled an important gap for businesses in the USA, as there are few resources to help meet the requirements of the new FSMA IA rules and regulations.

Our vulnerability assessment tool for packaging materials was launched in November.  This tool is designed specifically to meet the requirements of BRC Packaging Materials Issue 6 which, for the first time, includes requirements to address food-fraud-like issues within the supply chain of packaging materials.  Purchasers of the packaging vulnerability assessment tool also receive a free threat assessment tool that generates a product defense plan for site security and product safety.

Our free Food Fraud Risk Information Database continues to grow.  It currently contains more than sixty five thousand words.

My favourite thing about 2019 was having the opportunity to interact with so many intelligent and resourceful food safety professionals from all over the world, as we work together to make our food supply safer for everyone.   I look forward to more of the same this year.