Food Fraud Advisors

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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 deter detect

  • 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:

  1. Update your raw material specifications to include authenticity requirements.  Guidance for raw material specifications.
  2. Review your vendor approvals systems and revise questionnaires and requirements if required.  Consider implementing more stringent requirements for suppliers that provide vulnerable materials.
  3. (Re)assess vendors’ backgrounds: the financial stability of the vendor’s company, the legal status of the company (licensed? bankrupt?)
  4. Check vendors for previous prosecutions, fines and warnings from food authorities.
  5. 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.
  6. Incoming goods inspections.  Make sure they include: checking seals for evidence of tampering; verifying batch IDs on delivery documents; verifying relevant certificates.
  7. Begin analytical testing of vulnerable materials.
  8. Investigate the costs and benefits of supply chain audits, including whether ad-hoc, one-off visits to certain suppliers might be worthwhile.
  9. Request tamper-evident packaging and bulk container tamper seals for vulnerable raw materials.
  10. Ask suppliers of vulnerable materials to undertake a mass balance exercise at their facility or further upstream in the supply chain.
  11. Make a business case for switching suppliers of materials that prove to be consistently problematic and present it to your purchasing department.
  12. Make sure that senior staff in the business understand the risks posed by food fraud, by providing Food Fraud Awareness Training.
  13. 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.

Check out our low-cost, self-paced, on-demand training courses

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Materials and Supplier Reports

The Raw Material Report page and the Supplier Report page each contain a special excel feature called a pivot table. The pivot table allows results to be filtered, organised and printed. The pivot tables on these pages are designed to produce a list of information about individual materials and suppliers. The pivot tables draw data from an inaccessible area of the spreadsheet file.

Users have full editing rights to the pivot tables on these pages. The pivot table features, filters and criteria can be customised to suit your needs.

If you want to learn more about pivot tables and how to use them, there are hundreds of free resources on the internet to help you learn pivot tables, including this one.

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Food authenticity is my passion… death from inauthentic coconut drink

Why am I passionate about authenticity in our food supply? Because when we get things wrong horrible tragedies can happen; in December 2013 an allergic child died from anaphylaxis because of undeclared dairy ingredient/s in his coconut drink.   His parents knew of his dairy allergy and checked the label to make sure that the ‘natural coconut drink’ did not contain cow’s milk before they gave it to him. Unfortunately the label was wrong.

Tragedies like this are preventable.  It has taken almost two years and the near death of another child under similar circumstances for widespread action to be taken by the local food regulatory authorities here in Australia.

The importer of the drink has pleaded guilty to charges of labelling in a way that falsely describes food and will be sentenced later this month.

Coconut beverages are being tested and recalled right now, but I’m sad that it has taken such a long time for this to become a high priority for food law enforcement.

For a full report  on this incident click here.

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Supplier Assessment Information

Help with the Supplier Assessment section of the Vulnerability Assessment Helper.

Supplier name

There is no need to enter information about a supplier more than once.

  1. If you are using the spreadsheet as a starting point for a complete supply chain map you should add supplier names for every raw material or ingredient.  You only need to add the name a second and subsequent time, there is no need to enter all the information more than once.
  2. If you do not intend to create a complete supply chain map then just enter the name and details of each supplier once.

The summary sheet will tabulate the results for each supplier in a sortable and printable format.

Likelihood

This column is populated with the results of the raw material assessment.  If a raw material is very unlikely to be affected by adulteration or substitution you may wish to give the suppliers of that material a lower priority and assess  suppliers of more vulnerable ingredients first.

Supplier Risk Profile

The supplier risk profile is calculated from the information added to this table and from the user estimate of risk.  The results are presented on the left hand side of the table to make it easy to find later.   The result returned here is either the calculated risk profile or the manually entered risk profile if one has been entered.  The user estimate always overrides the automatic calculation.

When it comes to supplier risk, no matter what answer the Helper calculates, you should seek advice from other experts within the business and together you should carefully consider the vulnerabilities and strengths of each supplier, and make your own estimate of risk.

Broker or Trader

A broker or trader is a person or business who purchases large lots of materials on the open market and sells them to many purchasers.  Brokers and traders often do not handle the actual materials at all.  Prices of good purchased from brokers and traders typically experience larger and more frequent variations than those from other supplier types.

Transport and Storage

Answer ‘yes’ to these questions if the supplier is using transport and storage facilities that contain only their products and are not used to transport or store products that belong to other businesses.

Food Safety Management Systems

Does the supplier have a certified food safety program? And does the scope include all relevant ingredients?

  1. Answer ‘yes’ if your business has a copy of the supplier’s food safety management system certificate and it is current and has been verified as valid.  The facility address on the certificate should match the site from which your materials are shipped.

Does the supplier’s food safety program include vulnerability assessments and fraud/tampering prevention?

  1. Answer ‘yes’ if the food standard to which the supplier conforms includes requirements to assess vulnerabilities and to take action to prevent and mitigate risks associated with deliberate tampering, adulteration, substitution and dilution, whether economically motivated or otherwise.
  2. Answer ‘no’ if the supplier is operating a food safety management system that does not include vulnerability assessments and fraud/tampering prevention.
  3. Answer ‘not applicable’ if there is no food safety management system or if the scope of such does not include the material being purchased or if the system is not currently certified.

Have you reviewed the food safety program and/or the audit report and is the program robust and implemented properly with respect to the supplied ingredient/s?

  1. Answer ‘yes’ if someone from your business has reviewed the supplier’s food safety management system or a recent audit report from the food safety management system certification body.  Also answer ‘yes’ if your business has conducted a supplier audit.  Choose ‘yes reviewed and robust’ if the program is satisfactory, seems to be implemented well and includes good materials traceability and measures to prevent and mitigate fraud and malicious tampering.  Choose ‘yes reviewed but not completely satisfactory’ if the program and its implementation require improvements or the program does not include robust traceability of materials and measures to prevent and mitigate fraud and malicious tampering.
  2. Answer ‘no not reviewed’ if the supplier has a certified food safety management system but your business has not reviewed the system or a recent audit report.
  3. Answer ‘not applicable no program’ if the supplier does not have a certified food safety program.

Other certifications

Answer ‘yes’ here if there are special criteria for this raw material or ingredient such as halal, organic, non-GMO, grass-fed, free-range and if the supplier has provided valid certifications for such.  Answer ‘no’ if the supplier is providing a material that has a special criteria but no certification for such.  Answer ‘not applicable’ if this material does not have any special criteria.

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Likely to be vulnerable?

Likelihood Rating – Raw Material or Ingredient (Calculated)

A result is calculated by the Vulnerability Assessment Helper using the answers that you provide in the raw materials and ingredients table. The result returned is an indicator of how likely it is that the raw material or ingredient will be affected by economically motivated adulteration, substitution or dilution.

This calculated result does not consider the characteristics of the supplier(s) of this raw material or ingredient.  After you have completed the supplier assessment for all the suppliers of this material you can add your own estimate of likelihood based on the Vulnerability Assessment Helper’s calculated result plus the results of the supplier assessment(s).   If every supplier of that material is low risk you may wish to downgrade the likelihood rating for the material.

Likelihood Rating – Raw Material or Ingredient (User Rating)

No matter what likelihood the Helper calculates, you should seek advice from other experts within the business and together you should carefully consider the information and make your own estimate of vulnerability for each material.  Add your estimate to the ‘User rating’ column.  The results table on the Results (printable) page is populated with the user rating of likelihood if one has been entered.

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Raw Materials Assessment Information

Direct Sourcing

Answer ‘yes’ in the Vulnerability Assessment Helper if this raw material or ingredient is purchased by your company directly from the manufacturer or grower.  Answer ‘no’ if it is purchased from a distributor or importer, wholesaler or retailer.

Form of Ingredient

Answer ‘yes’ in the Vulnerability Assessment Helper if this raw material or ingredient is purchased by your company in individual pieces which can be visually identified as such.  Examples include chickpeas, whole peppers, chicken wings, bananas, frozen berries, rolled oats, coffee beans, whole cloves.  If this ingredient is purchased as a powder, liquid, mince, paste, pre-mix, slurry or blend then answer ‘no’.

Purchasing Specification

Answer ‘yes’ in the Vulnerability Assessment Helper if there is a formal specification for the raw material or ingredient.  This should be separate from any supplier invoice, certificate of analysis or purchasing contract.  Although it is common to base a purchasing specification on information provided by a supplier, a proper purchasing specification should be created ‘in-house’ and should work as a stand-alone description of the raw material or ingredient that could be used when purchasing it from any source.  Click here to read more about purchasing specifications.

Inspection and testing

Inspection means: does a designated person formally receive the shipment of this raw material or ingredient into your facility by

  1. checking that it is in good condition, undamaged and complete,
  2. checking that it is accompanied by proper paperwork, such as a certificate of analysis and
  3. does that person record the details of the incoming material including the batch number and
  4. is there a documented process for what to do if the shipment does not meet expectations?

Testing means: does a designated person take a sample of the shipment when it is received and perform physical, chemical and/or sensory tests to check that it meets criteria defined in the raw material specification?  If you do not have a raw material specification answer ‘no’ for testing.

Trading properties

Raw materials traded on specific properties are those for which the price paid for this raw material is based upon the content of water, dairy fat, nitrogen (protein), cocoa solids or some other key component. Answer ‘yes’ here if

  • the price your business pays is dependent on a specific property of this raw material or
  • if any of your suppliers’ suppliers price this material according to a specific property, even if your business pays a flat rate.

If you are unsure, speak to your purchasing officer.

Special criteria

Answer ‘yes’ here if there are special criteria for this raw material or ingredient such as halal, organic,non-GMO, grass-fed, free-range or if there is a specific country of origin or grade of produce required for this material.

Micro Ingredient

Answer ‘yes’ here if this ingredient is used in very small quantities and/or is present in the finished product at very small quantities.  If the limit of 1% is not useful for your product type, then choose more appropriate limit and amend the column heading.

The answer you provide for “Micro Ingredient” does not affect the calculated likelihood of adulteration or substitution for an individual ingredient or raw material; any ingredient can be vulnerable, no matter how small the amount used in a food product.  The answer to the Micro Ingredient question is used when combining the results from all ingredients to calculate the overall vulnerability of the finished product.