From the desk of Karen Constable, our Principal Consultant
The other day, a frustrated food safety manager wrote to me, wanting help to figure out how to do a food fraud vulnerability assessment for storage and distribution (BRCGS Issue 4).
It’s such a tricky one, because storage and distribution (S & D) facilities have so little direct control over product choices. And the BRC standard is so wordy!
The good news is that when BRC first added product fraud to their storage and distribution standard in 2018 (Issue 3), they wrote a position paper that attempted to provide some guidance.
Even though Issue 4 is a bit different to Issue 3, the guidance in the position paper is still useful.
Here’s just a small portion of guidance from BRC Position Paper:
“The Standard does not define the exact process that the company must follow when completing the vulnerability assessment;however, it is likely to incorporate the following steps:
- draw up a list of products and services and the controls that are already in operation (e.g. approval of suppliers by customers, pre-packaged products purchased)
- consider any relevant information regarding potential fraud for each product and service
- complete a risk assessment on the vulnerability of the products.
The output of the vulnerability assessment is usually a ranking or scoring of the materials to identify those which need additional controls. The ranking and actions required could, for example, be as follows:
- Very high – a high-profile product with recent reports of adulteration or substitution published by regulatory authorities. Action or monitoring is required to ensure that only genuine materials are purchased.
- High – a high-profile product that provides an attractive target for potential substitution or adulteration. Some action and/or monitoring is required to ensure that only genuine materials are purchased.
- Low – this product is unlikely to be a target for substitution or adulteration. However, a re-assessment may be necessary if new information becomes available.
- Negligible – no further action is required as the product is extremely unlikely to be a target for fraud.”
There’s more in the position paper, which you can read or download from the BRC Website: https://www.brcgs.com/media/1055426/sd308-position-statement-accommodating-the-requirements-of-gfsi-benchmark-72-into-issue-3-v2-12082019.pdf
If you are completely new to vulnerability assessments, we have step-by-step instructions on our website, which might help a little if you haven’t seen it yet. Plus, our on-demand, online food fraud training might also help. Although both of these resources were created primarily for food manufacturers the concepts of vulnerability assessments also apply to S & D facilities.
I can also assist with custom one-on-one consulting, guidance/feedback or custom templates if you need. Just get in touch and we can hop on a phone call to discuss.
Regards,
Karen Constable
Food Fraud Advisors