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14th September 2021 by Karen Constable

How To Do a Vulnerability Assessment for Food Fraud

Updated 30th December 2022

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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Filed Under: Food Fraud, Learn, VACCP, Vulnerability Assessments Tagged With: 2.7.2, 5.4.2, audit, BRC, checklist, economically motivated adulteration, EMA, food fraud, FSSC 22000, FSSC version 5, risk assessment, SQF, SQF Edition 9, template, VACCP

24th July 2021 by foodfraudadvisors

HACCP, VACCP and TACCP

  1. HACCP (Hazard Analysis Critical Control Point)  Pronounced ‘hassup’.  HACCP = keeping food safe from accidental and natural risks to food safety.
  2. VACCP (Vulnerability Assessment Critical Control Point) Pronounced ‘vassup’.  VACCP = prevention of economically motivated food fraud.
  3. TACCP (Threat Assessment Critical Control Point) Pronounced ‘tassup’.  TACCP = prevention of malicious threats to food, such as sabotage, extortion or terrorism.  This type of malicious threat is also referred to as Intentional Adulteration within the US Food Safety Modernization Act.  Outside of the US, TACCP is more often called ‘food defense’.

HACCP

  • HACCP is a set of principles designed to control and prevent food safety risks during food production.
  • HACCP is not enforced or regulated by any single organization.
  • The ideas of HACCP form the basis of every food safety management system standard that is in use today, including GFSI food safety standards.
  • The principles of HACCP are codified (written down) by the Food and Agriculture Organization of the United Nations (FAO), in a set of documents called the Codex Alimentarius , a latin phrase which translates to “Book of Food”.
  • FAO’s General Principles of Food Hygiene CXC 1-1969 contains the HACCP principles (sometimes called HACCP Codex).  Download the 2020 revision of the HACCP Code here: http://www.fao.org/fao-who-codexalimentarius/codex-texts/codes-of-practice/ (click the green check/tick mark on the right side of the page to download).

VACCP and TACCP

  • VACCP and TACCP are terms that emerged during the 2010s as standards agencies, government regulators and industry groups started considering methods to prevent food fraud and malicious tampering.
  • VACCP is for food fraud.
  • TACCP is for food defense.
  • The acronymns VACCP and TACCP are designed to leverage the food industry’s familiarity with HACCP.  However, the critical control ‘points’ in a VACCP and TACCP plan are nothing like the ‘critical control points’ in a HACCP plan.
  • The control points in a HACCP plan are operational steps in a food manufacturing process.  The points are connected to processes over which the food manufacturer can exercise direct control.
  • For deliberate tampering (food fraud and food defense) the controls do not fit onto a linear set of processes, they do not fit the definition of ‘critical control points’ in HACCP.
  • The terms VACCP and TACCP are falling out of favor within the food safety industry.  They are not referenced specifically within any of the GFSI food safety standards, nor within the USA’s FSMA.
  • Instead of ‘”VACCP” and “TACCP”, it is much better to say “Vulnerabilities to food fraud” or “threats of malicious tampering (=food defense)”.

More acronyms demystified here.

Take a free short course on food fraud here.

food safety food fraud

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Filed Under: Learn, TACCP, VACCP Tagged With: audit, auditing, CCP, critical control points, food defense, food safety, intentional adulteration, TACCP, threat assessment, VACCP, vulnerability assessment

31st January 2021 by foodfraudadvisors

Preventing food fraud: testing is not the answer

Fraudulently adulterated food is receiving a lot of attention at the moment. While it is widely acknowledged that food fraud is a large and expensive problem requiring urgent action there is not a lot of practical advice available about exactly what actions food businesses should take to prevent, deter and detect food fraud. And, although published advice about direct action is rare, there is plenty of commentary that discusses the issue in general terms, including one very common refrain: food testing is not the answer.

Food safety hang-ups

One of the reasons we so often hear that testing is not the answer is that many food fraud commentators come from a food safety and quality assurance background. As such, our unwillingness to rely on testing for food fraud can be explained in part by our familiarity with food safety systems. Within the realms of food safety, testing can achieve nothing on its own; the prevention of risks and control of hazards is much more effective and efficient, with testing used simply to verify that the system is working.

For those who are less familiar with food safety systems, let’s take a closer look. For the sake of simplicity, imagine a hypothetical food safety system that is designed solely to prevent the growth of a pathogenic microorganism in salami. If the system relied solely on testing, one would have to take a sample from every pack of salami, test for pathogens and then discard packs which were found to be contaminated. A missed test could have deadly consequences. Worse still, the sampling itself could lead to contamination. A better way is to use preventive control methods to stop hazards before they arise and carefully monitor critical operations in the production process so that the finished product is safe. This combination of prevention and monitoring is the basis for every modern food safety system. Within those systems the food must still be tested to verify that the system is working but in fact every piece of salami that is consumed without causing illness is a form of ongoing verification.

Dairy Processing

Fraudulently adulterated food is very different from accidentally contaminated food. It usually doesn’t make people sick and can rarely be identified as fraudulent by the consumer. People who adulterate food for financial gain aim to avoid detection and for that reason adulterated food rarely causes acute illness. In fact, the Chinese government is currently assuring its citizens that the large volumes of counterfeit baby formula within that market are safe to consume. There have been instances of fraudulent food that caused illness and death, including the melamine milk scandal in China and toxic mineral oil passed off as olive oil in Spain. In another famous case, a carcinogenic industrial dye was used to make paprika powder appear fresher. In each of these cases it was some time before the link between illness and adulterated food was found.

Criminals are smarter than Salmonella.

The prevention of microbial contamination and growth in food can be achieved in a few simple steps using well-understood methods; Salmonella hasn’t figured out how to outsmart a thermal kill step yet. But people who seek to make money from adulterating food have much more imagination than your average bacterium. While there are only about 120 food borne pathogens known to man, there are almost unlimited ways to tamper with food, meaning many different types of controls are required. Unfortunately, any effective control method can be discovered and then outsmarted by a clever fraudster, making reliance on prevention a risky proposition. And the worst part is that no matter how effective a fraud prevention system is, at the end of the day it is indistinguishable from an ineffective fraud prevention system to the naked eye; without very frequent testing there is no way to know the system is working.

More testing?

Testing is a key element of effective fraud prevention. I envisage a day when every food manufacturer tests vulnerable raw materials before they are used in production, where every supermarket has the technology to verify that their food is authentic before they place it on their shelves and where even local restaurants will have access to cheap and fast authenticity testing. Testing holds the answers to many of our current food fraud challenges.  However, testing can be expensive, time consuming and much less effective than we would like.

Pesticide residue in food

A key challenge to the efficacy of testing is that when it comes to food fraud we can never be sure of the adulterant that might be present. Many currently available test methods are targeted for a particular adulterant, and are not designed to detect adulterants that are unexpected. Non-targetted tests are rapidly being developed but there are still relatively few that have been properly validated, a process that requires expensive cross-testing against other methods such as botanical testing, DNA-based methods and classical chemistry.

In less than five years, claim the makers of new rapid testing technology, we will be able to hold a scanner in our hand that can tell us the entire molecular makeup of our food. I think we will have to wait a little longer than that; food is complex and a huge amount of research will be required before we can properly interpret the results of complex molecular ‘scans’ of every food on the planet. But testing is an important tool in our fight to ensure an authentic food supply, and that’s a goal worth striving for.

Read about the latest food fraud analytical technologies here.

Are you ready to start testing for food fraud? Use our testing checklist to find out.

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Filed Under: Food Fraud, VACCP Tagged With: authentic food, authenticity, detection, economically motivated adulteration, EMA, food fraud, food safety

10th August 2019 by foodfraudadvisors

Learn the lingo; food fraud terms explained

Food fraud occurs when food or drink is sold in a way that deliberately misleads or deceives consumers or customers for financial gain (Food Fraud Advisors, 2015)

(other definitions)

Food fraud occurs in two different forms:

1. Fraudulent activity that does not involve tampering with the food itself:

This includes activity such as avoidance of taxes, duties and quota restrictions (fishing), fraudulent paperwork such as forged importation documents, misrepresentation of origin, changing best-before dates and counterfeiting of popular brands.

2. Adulteration of food for economic gain:

This is sometimes referred to as economically motivated adulteration or EMA.  In this phrase, the word ‘adulteration’ is used to encompass many types of tampering, such as adding unauthorised substances, substituting undeclared substances for genuine components of a food or diluting a food product with cheaper substances.

Food fraud is a type of food crime, with food crime including food fraud and other activities such as the use of food shipments to mask drug trafficking and money-laundering through the trading of food and food commodities.

food fraud,defense,safety,security

Food fraud and the risks it presents to the food industry is a separate subject to food safety, although fraud-affected food can be unsafe.  Food safety relates to unintentional contamination of food and the presence of naturally occurring contaminants.

Food defence (food defense) is a term that has come to be defined as the effort to prevent acts of adulteration that are intended to cause harm to a food business or to consumers, such as acts of terrorism or attempted extortion.

Food security, as defined by the World Health Organisation exists “when all people at all times have access to sufficient, safe, nutritious food to maintain a healthy and active life”.

Risk or vulnerability?  In the language of food fraud, the term risk is usually replaced with the term ‘vulnerability’, so food standards bodies are increasingly talking about vulnerability assessments rather than risk assessments.  ‘Vulnerability’ is used because food fraud ‘risks’ do not exactly fit with the accepted definition of risk as something that has occurred frequently, will occur again and for which there is enough data to make quantitative assessments.  Vulnerability is a better term for food fraud, due to the fact that the ‘risk’ of a specific fraudulent activity occurring cannot be quantitatively assessed.

Horizon scanning is another term that has been co-opted to the language of food fraud.  Horizon scanning is the act of looking for and analysing threats and opportunities that will emerge in the medium to long term.  It is used across many industries, including the financial and health care industries.  Within the food industry, horizon scanning refers to the act of collecting information about current trends in food production and predicted incidences that could increase the likelihood of food fraud for a particular food material.  For example, climate change is likely to affect coffee production which could drive up prices and increase fraudulent activity in that sector.  Click here for the complete low-down on horizon scanning.

TACCP: Threat Assessment Critical Control Point.  TACCP = prevention of malicious threats to food.

VACCP: Vulnerability Assessment Critical Control Point.  VACCP = food fraud prevention.  Learn more about TACCP and VACCP here.

Intentional Adulteration:  Although food fraud activities often involve the intentional adulteration of food with unauthorised substances, within the food safety industry, Intentional Adulteration has recently been given a more specific meaning.  And it is not related to food fraud at all.  It is related to food defense, and more specifically to activities intended to cause wide scale harm to consumers.  There is a rule within the USA’s Food Safety Modernization Act (FSMA), that addresses these activities.  It is known as the Intentional Adulteration rule.  According to the US FDA (2019), Intentional Adulteration is the deliberate contamination of food with a biological, chemical, radiological, or physical agent by an individual or group of individuals with the intent to cause wide scale public health harm.  How to protect against intentional adulteration. 

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Filed Under: Learn, TACCP, VACCP Tagged With: EMA, food defense, food fraud, food safety, horizon scanning, intentional adulteration

19th October 2018 by foodfraudadvisors

Raw Material Specifications

Raw material specifications are an important defence against food fraud for all food businesses.  Whether you are a restaurant, a specialty grocer, delicatessen, central kitchen, hotel or manufacturer, you are susceptible to food fraud.  Robust specifications can help to protect your food business from inadvertently purchasing, using or serving fraudulent ingredients and raw materials.  They can also help to protect your business from the financial fall-out if things go wrong.

Fraudulent materials include:

  • adulterated food ingredients, such as melamine added to milk powder to increase the apparent protein content
  • diluted food, such as dried oregano leaves diluted with cheaper leaves
  • substituted food, such as a cheaper grade of olive oil being substituted for virgin
  • counterfeit food, such as ‘fake’ premium vodkas and brandies
  • misrepresented food, such as conventionally grown vegetables that are sold as organic
  • packaging materials made with unauthorised additives, such as banned phthalates

Modern Dairy food-processing industry Worker On A Milk Factory

Specifications for raw materials and ingredients should contain the following information:

  1. Name of the material
  2. A description of the material, including biological, chemical and physical characteristics
  3. Composition of the material, including additives and processing aids
  4. Country of origin
  5. Method of production
  6. Packaging format/s or unit of measure
  7. Delivery method/s
  8. A description of the labelling, lot ID and coding for traceability
  9. Storage conditions and shelf life
  10. Preparation and/or handling before use
  11. Acceptance and rejection criteria
  12. Requirements for certificates of analysis for high risk materials or vulnerable materials
  13. Special requirements such as allergen information, organic status, GMO status, fair-trade and ethical sourcing policies
  14. Information about compliance with statutory and regulatory requirements, where relevant
  15. A requirement for suppliers to notify of any authenticity issues with the product
  16. A requirement for suppliers to notify of any changes to the product
  17. Formal agreement between the supplier and purchaser
  18. Document control features, such as author, date and page numbers.

Download our excellent template today

How to develop a raw material specification:

  • Create a template that suits the needs of your business.  A tabular format is easy to work with.  Include all of the sections above, even if you don’t think you will use them now, or if they are not relevant to some of your materials.  You can always leave them blank.
  • You should create a separate specification for every unique material, do not create category-level specifications.
  • Obtain product specifications from your suppliers and use them to add key criteria to your specifications.
  • Add any extra criteria that will help you to control the quality, safety and authenticity of your products.  It is useful to imagine that you are receiving the material at your door or loading dock; what would you like to know about the material before you accept it? For example: Is it at the correct temperature?  Is it properly labelled?  Is the packaging undamaged with no evidence of tampering?  Is the material free of undeclared allergens?  Does it have the fat content you expect?  Has it been aged (meat) for as long as you expect?  Is it free from salmonella?  Use these questions to check that you have included all important criteria in your specification.
  • Don’t forget to include requirements for suppliers to have a food safety certificate, licence, approval or registration, where relevant.
  • If you are purchasing materials under fixed supplier contracts (as would be the case for  food manufacturers), the draft specifications will need to be approved by your purchasing department and by the suppliers themselves before they can be formally issued and implemented.
  • Review each specification at least annually and update the issue/review date.

Need help?

Contact Us Today

Our food safety and authenticity experts can develop your purchasing specifications. Click here for a free introductory consultation.

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Filed Under: Learn, VACCP Tagged With: audit, authentic food, BRC, critical control points, detection, EMA, food fraud consultant, food safety standard, FSMA, GFSI, specification, SQF, supply chain, template

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