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Help with GFSI vulnerability assessments; Detection

Use the information on this page when performing an assessment with Food Fraud Advisors’ Vulnerability Assessment Tools:

Supply chain audits

Answer ‘yes all suppliers are audited’ in the Vulnerability Assessment Tool if you know that all the suppliers from whom you purchase this material and their suppliers are audited by your business or by third parties.  Suppliers that have been successfully audited by third parties will have current certificates of conformance to food safety standards; for example they will be ‘BRC certified’ or ‘SQF certified’.

Routine Testing

A routine authenticity test is a test carried out on a regular, defined basis by your business, a trusted supplier or a third party to determine whether the material is ‘authentic’.  An authentic food or food ingredient is one that is what it is claimed to be.  That is, if the material is claimed to be olive oil, an authenticity test would confirm that the oil has been made from olives; if the material is claimed to be Spanish olive oil, authenticity testing would check that the chemical profile of the oil matches those of Spanish olives; if the material is claimed to be virgin Spanish olive oil, the testing would check for the origin, the species and whether the oil is virgin.  If testing has occurred but it is occasional, ad-hoc or one-off then it is not considered routine and you should answer ‘no’ at this question.

Frequency of testing

Is the authenticity testing of an appropriate frequency?  If routine authenticity testing does not occur, answer ‘not applicable’.  If routine testing does occur, it is difficult to know whether the frequency is appropriate, even if fraudulent material has previously been detected during routine testing.  Materials that are very susceptible to food fraud – that is the likelihood of occurrence is ‘very likely’ or ‘likely’ – should have a very high testing frequency; testing per batch of incoming goods is best practice.  An appropriate frequency of testing for a less vulnerable material could be based on testing one in five incoming batches.

Relevant audits

Is the supplier of this material subject to relevant audits?  Relevant audits are those which consider adulteration, traceability, mass balance, supplier approvals and authenticity testing.  Audits to GFSI food safety standards are ‘relevant’.  Most other food safety management standards adequately address traceability requirements, and some also consider adulteration and mass balance.  You will need to check the applicable standards or audit reports to determine if the supplier audits are considered ‘relevant’ according to this question.

Special criteria

If there are special criteria are they tested for and/or properly certified?  Special criteria include organic status, halal, vegetarian, gluten-free, non-GMO and origin claims such as ‘Spanish olives’.  If there are no special criteria for this material answer ‘not applicable’.  Otherwise, answer according to whether or not those criteria are verified with testing and/or certifications.

Score

The score is included for interest only.  It is a numerical score out of 100 with a lower score being desirable.  The default score is 100 and remains 100 until all questions have been answered.  This is to ensure that an incomplete assessment produces a high vulnerability rating.

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Excel compatibility; Vulnerability Assessment Tool

Got compatibility issues?

We’ve got you covered: the Vulnerability Assessment Tool (BRC Method) is compatible with Microsoft Excel versions 2004 onwards (file extension .xlsx) and Microsoft Excel for Mac, from 2011 and onwards.  There are no macros in the spreadsheet.

Still want to try it now?  Download a free trial

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How much does a recall cost part 2

Earlier this year I reported on the huge losses faced by Patties Foods after their hepatitis A problems in frozen berries. Patties have now sold off their frozen berry business.  That part of the business generated 13% of their sales in past years.

More on the sale

pics 019

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Traceability myth #1: Consumers want transparency

Consumers want transparency.  It’s a phrase I hear all the time in supply chain and food safety circles.  Ask consumers if they want transparency and the answer is overwhelmingly ‘yes’.  It seems obvious; transparency equals knowledge, knowledge equals informed decisions, informed decisions result in good purchasing practices and good purchasing practices are a win for both consumers and suppliers.  But is that how food purchasing really works?

If consumers say they want transparency, and in a study by BBMG, GlobeScan and SustainAbility  a total 82% of consumers reported that “ingredient transparency is a very important or important factor” when shopping for food and beverages, why is it that ingredient transparency remains relatively unusual for most food products?

As a young food technologist working for a large snack food manufacturer, I learnt a valuable lesson in understanding consumer behaviour; those of us in marketing and product development jobs were very good at imagining the wants and preferences of our core consumers.  We were almost always wrong.  I was lucky enough to work for an organisation that was willing to spend money on focussed, in-depth and product-specific market research and we used that research to refine our product offerings and strengthen our brands.  What we learnt was that our own white-collar preferences were quite unlike the preferences of our core consumers and that self-reported attitudes to products almost never aligned with actual purchasing behaviour.  When it was time for consumers to select a bag of snacks from a retail store shelf, the qualities that we had been focussing on in our product development laboratory contributed very little to the decisions that were made.

I see the same thing in the current commentary of food safety and integrity professionals.  Traceability and transparency are important to food professionals and this is likely to be reflected in our food purchasing habits.    But for most people, food purchasing decisions are dominated by availability, cost, quality and sensory preferences.  Transparency is nice to have, but if it comes with a higher price tag it is unlikely to result in increased sales of a food product.  I don’t doubt that this is something most large food processors already understand.  We will continue to hear calls for supply chain transparency but we won’t be seeing it on an ordinary big-brand box of cookies any time soon.

Traceability myth #2; traceability is expensive

Traceability myth #3; traceability equals authenticity

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The Food Scientists’ Diet

When I tell people I am a food scientist they often ask me for dietary advice. Here’s my favourite advice. It comes from author Michael Pollan:

michaelpollanquote

More from Michael

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Vulnerability assessments are a waste of time according to this investigator

Vulnerability assessments are a hot topic in food safety at the moment, with Global Food Safety Initiative (GFSI) food safety standards set to include requirements for documented food fraud vulnerability assessments in the near future.  Most food safety and food integrity experts believe that vulnerability assessments are an important first step towards preventing fraudulent foods from reaching consumers.   However, in an interview with Food Safety News, Mitchell Weinberg, food fraud investigator and CEO of Inscatech describes food fraud vulnerability assessments as “frankly… a little bit of a waste of time.”  Mr Weinberg says that a food fraud vulnerability assessment is essentially about recording what you already know.  He explains that if a business is sourcing a food ingredient from a developing country, they should already know that it is more likely to be affected by fraud than if sourced locally.  Likewise, high value and high volume materials are more attractive to fraudsters.  Weinberg tells the interviewer:

“Just use common sense, figure out where the problem is, check it out… trust but verify.“

Weinberg is right; creating documented risk assessments of any kind is simply an exercise in writing down what we already know.  And common sense should be at the core of any risk assessment.  So is there any value in a documented vulnerability assessment?  

Absolutely!

  • A documented assessment is a record of who thought of what and when they thought of it.  It is evidence that fraud has been considered; it can be used to check that common sense was used in that consideration.  It can be audited, reviewed and updated.  It can be shared.
  • The process of creating a documented assessment can serve as a prompt to identify gaps in knowledge and provide an incentive to ‘fill in the gaps’.
  • A documented vulnerability assessment can be used to transfer knowledge.  Weinberg says creating a written assessment is making a record of what you already know; that is exactly what is needed when the person who made the assessment changes jobs or has to explain supply chain risks to a stubborn Purchasing Manager.
  • Most food businesses manufacture hundreds of food products and many more hundreds of ingredients; comparing the vulnerability assessments of different products and materials is an effective way to prioritise fraud prevention actions.  While the ultimate aim is for no product to be compromised ever, we all have to start somewhere.

Read more about Vulnerability Assessments here.

To view the interview with Mitchell Weinberg, click here.