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.
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.
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.