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Vulnerability assessment methods
There are two general approaches to performing a vulnerability assessment for food fraud.
But first…. for the purposes of this page, a vulnerability assessment is a risk-assessment-style evaluation of a food product or ingredient’s vulnerability to food fraud. For information about food defense vulnerability assessments (intentional adulteration vulnerabilities), click here.
The two approaches are (1) a conventional risk assessment model or (2) based on the recommendations of the British Retail Consortium (BRC) in their guidance document Understanding Vulnerability Assessment (2015)
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The conventional method is a combination of the likelihood of something occurring versus consequences if that thing occurs. This method is recommended for all types of food businesses. It allows businesses to identify their most vulnerable ingredients, products and brands and provides an excellent framework to prioritise mitigation strategies.
The second method is recommended for businesses wishing to meet the requirements of British Retail Consortium (BRC) Food Safety Standard Issue 7 and Issue 8 (clause 5.4.2). The BRC method does not address the risks from all types of food fraud; it only addresses the risk from adulteration and substitution of raw materials and ingredients. Therefore it is not recommended for businesses that need to meet the requirements of other GFSI food safety standards such as FSSC 22000 Version 4 (clause 2.1.4.6) or SQF Edition 8. What are these acronymns?
For more information about how to conduct a vulnerability assessment, take a look at Vulnerability Assessments; What? Why? How?
The future is purple; five fun food facts
Purple is my favourite colour so I was happy to see purple foods feature in food industry news this week. Here is the lowdown on purple foods and four other fun food facts that have caught my eye recently:
- Pasta made from crickets has hit the mainstream (or maybe the fringe of the mainstream…) and is available to buy commercially. The pasta is made with farmed crickets that have been roasted, ground and combined with rice and tapioca to make gluten-free pasta. It is reported to have a nutty flavour and be high in protein. Buy your insect pasta here. Or for the scientifically minded, read the European Food Safety Authority’s report on the risk profile of insects as food and feed.
- At Stockholm’s Arlanda airport there is a ‘hotel’ for sourdough starters, the fermented mixtures used for making sourdough bread. Sourdough starters contain flour, wild yeasts and bacteria and can be maintained for generations, fermenting away between batches of bread. Individual starters develop their own unique flavours and the older the starter, the tangier the loaf, but a starter needs to be ‘fed’ and watered regularly. At the sourdough hotel you can leave your starter in the care of an expert baker while you travel.
- Prison kitchens put aside a portion from each meal they serve and freeze it in case of a food poisoning outbreak. The sample is known as a ‘dead man’s tray’.
- The experts in food trend predictions are reporting that purple foods are the next big thing. Purple carrots, berry-based breakfasts, purple yams, purple cauliflower, berry-flavoured dairy products and porridge plus berry drinkable yoghurt are all on the menu for the coming year.
- Lobster rolls are also predicted to be huge this year and the good news is you can cook them in your dishwasher while washing your dishes! Shape Magazine thoughtfully shares the recipe: put a halved, deveined, de-shelled lobster tail in a mason jar with a stick of unsalted butter and run it through your wash cycle. Serve in a roll.
What next?
Updated 30th April 2022
Now you have a food fraud vulnerability assessment, what comes next?
First, make a home for the vulnerability assessment documents so that they can easily be found for reviews and audits. They should be incorporated into an existing quality manual or food safety manual, with correct document reference numbers and with review dates scheduled in the same way as other sections of the system. If the business operates a risk register or an enterprise risk management system, talk to the owner of that register about whether it is appropriate to reference the documents in that system also.
Second: communicate!
If food fraud vulnerabilities have been identified the business will need to make a plan to
- Prevent the purchase of fraudulent ingredients or products
- Deter fraudsters from adulterating materials that your business is going to purchase
- Deter counterfeiters from copying or ‘faking’ your products
- Detect fraudulent materials before they are used to make food
- Detect fakes in the marketplace so enforcement action can be taken
This is a job for the whole business, not just food safety or food quality personnel. Communicating what has been found in the vulnerability assessment is the first step in engaging people from other parts of the food business. Ideally the top levels of management of the food business are committed to preventing, deterring and detecting fraud and will be willing to implement changes to protect the business. It may be necessary to make changes to purchasing policies, supply chain strategies and supplier contracts to help prevent fraudulent materials from reaching the doors of your factory. Changes to sales agreements, sales channels and packaging might be needed to prevent food fraud from affecting your products after they have left your facility. Personnel from purchasing, finance, marketing, sales and legal departments will need to be involved to implement changes within these business areas. If the business has a Risk Officer or an Enterprise Risk Manager that person should also be involved in the prevention and mitigation planning process. The result should be a cross-functional team with upper management support and a commitment to prevent food fraud, plus the resources to implement changes to policies, practices and programs.
That is the theory anyway; without support from upper management and a cross-functional team, any fight against food fraud is going to be tough. However there are some things that can be done by food safety personnel that are relatively quick to implement and do not require a lot of investment from other parts of the business. These are listed below.
Third: action!
Create and implement a food fraud prevention and detection plan (‘control plan’).
Here are some actions that can reduce your exposure to food fraud:
- Update your raw material specifications to include authenticity requirements. Guidance for raw material specifications.
- Review your vendor approvals systems and revise questionnaires and requirements if required. Consider implementing more stringent requirements for suppliers that provide vulnerable materials.
- (Re)assess vendors’ backgrounds: the financial stability of the vendor’s company, the legal status of the company (licensed? bankrupt?)
- Check vendors for previous prosecutions, fines and warnings from food authorities.
- Request certificates of analysis (CofA) from suppliers of vulnerable materials and make sure they include analyses that reflect authenticity attributes as described in your purchasing specifications. This won’t actually prevent fraud but will help your business to enforce penalties if problems are found later.
- Incoming goods inspections. Make sure they include: checking seals for evidence of tampering; verifying batch IDs on delivery documents; verifying relevant certificates.
- Begin analytical testing of vulnerable materials.
- Investigate the costs and benefits of supply chain audits, including whether ad-hoc, one-off visits to certain suppliers might be worthwhile.
- Request tamper-evident packaging and bulk container tamper seals for vulnerable raw materials.
- Ask suppliers of vulnerable materials to undertake a mass balance exercise at their facility or further upstream in the supply chain.
- Make a business case for switching suppliers of materials that prove to be consistently problematic and present it to your purchasing department.
- Make sure that senior staff in the business understand the risks posed by food fraud, by providing Food Fraud Awareness Training.
- Stay up to date with changes to commodity prices and supply issues (‘horizon scanning’).
Need help with your food fraud control plans? Get easy instructions and downloadable templates from our online training course.
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Food fraud only affects expensive food, right?
Wrong! While it’s pretty obvious that you could make an economic gain by bulking out an expensive food like caviar with something less expensive, it’s also possible to make economic gains by making tiny alterations to big-volume commodities. Even switching just one or two percent of a bulk item like beef mince or rice with something cheaper can create a huge economic gain when sales are counted in the thousands or tens of thousands of tonnes.
Ground meat is one commodity that has been frequently affected by this kind of food fraud. The adulterants are typically lower grade meat or offal from the same species or meat from a cheaper species. This kind of adulteration is difficult, if not impossible for consumers to detect.
Rice is another commodity that, despite being relatively cheap, is also affected by economically motivated adulteration. The adulterants are reported to be plastic pieces, including thermal insulation materials, potato starch mixed with polymer resins and even pieces of paper rolled to look like grains. This type of fraud relies on transient and poorly documented supply chains; the person who ultimately tries to eat the rice will detect the fraud in most cases – although there are reports of people suffering digestive problems after consumption – however the source of the adulteration usually proves impossible to trace.
If rice adulteration was occurring on a big scale in Europe I suspect that increasing the requirements for paperwork and trying to improve supply chain transparency would be the chosen strategy for those tackling the issue. In the Philippines they have taken a more direct and – for now at least – more feasible approach. They have developed a hand-held scanner that uses Raman spectroscopy to detect ‘fake’ rice by distinguishing between starch and styrene acrylonitrile copolymer. Fast, cheap, easy and no paperwork needed.