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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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Acronym Decoder

BRC: British Retail Consortium.  A group of British companies that publish guidance and standards for food manufacturers, including a food safety standard that is also commonly referred to as BRC.

CoOL or COOL: Country of Origin Labelling.

EMA: Economically motivated adulteration or substitution. EMA is a subset of food fraud and is defined as the fraudulent, intentional substitution or addition of a substance, or dilution of a substance for the purposes of economic gain.  Non-EMA food fraud includes black market importation and trading of food and alcoholic beverages for the purposes of avoiding duty and taxes.

DEFRA: The Department for Environment, Food and Rural Affairs, a United Kingdom government department responsible for food production and standards as well as environmental and agricultural responsibilities.

FDA:  Food and Drugs Administration.  The FDA is the name of a regulatory body in a number of countries, including USA, Philippines and India.

FSA: Food Standards Agency, a United Kingdom government regulatory body.

FSMA: Sometimes pronounced ‘Fizzmah’.  Stands for Food Safety Modernisation Act (United States of America).

FSSC 22000: A food safety management system standard similar to ISO 22000 but with extra requirements incorporated to meet the requirements of a GFSI standard.

GFSI: Global Food Safety Initiative.  The GFSI is a group of food companies whose mission is to harmonize, strengthen, and improve food safety management systems around the globe.  The GFSI provides direction and approval to organizations that create food safety management systems, so a GFSI-approved food safety standard is one that represents international best practice.  Well known GFSI standards include BRC, FSSC 22000 and SQF.

GMO: Genetically Modified Organism.

HACCP:  HACCP is a set of principles designed to control and prevent food safety risks during food production.  The principles of HACCP are codified (written down) by the Food and Agriculture Organization of the United Nations (FAO).  Download the 2020 revision of the HACCP Code here.

HARCP: Hazard Analysis Risk-based Preventive Control.  HARCP = food safety as legislated by the United States.  This acronymn being used by some in the USA when talking about the requirements of the recently enacted Food Safety Modernisation Act (FSMA) in that country.  HARCP is claimed to differ from HACCP by including requirements for preventive controls.  Read more about HARCP here.

IA: Intentional Adulteration.  Within the US Food Safety Modernisation Act (FSMA), Intentional Adulteration specifically refers to malicious adulteration that is intended to cause widescale harm.  Learn more about intentional adulteration here.

ISO 22000:  ISO is the International Organization for Standardization.  They have thousands of standards across many different businesses, products and systems.  ISO 22000 is the ISO standard for food safety management systems.  Like other major food safety management systems it is based on the principles of HACCP.

NSF:  a pseudo-government organization head-quartered in the United States that is active in the area of food safety and sanitation.

SQF:  Safe Quality Food Institute.  The Safe Quality Food Institute owns and publishes a group of food safety standards also known as SQF that is a GFSI – approved standard.

USP: United States Pharmacopeial Convention.  USP is a non-profit organization that creates identity and purity standards for food ingredients and food chemicals, as well as for medical drugs.

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.

Learn about Vulnerability Assessments, what they are and how to do them, here.

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Food Fraud Online Training Course

Food fraud requirements of BRC, SQF, FSSC and other food safety standards

How to meet the food fraud prevention requirements of major food safety standards

This course will make audit preparation a breeze.  It contains step-by-step instructions, worked examples and downloadable templates to help you meet the food fraud requirements of all major food safety standards.

sqf edition 8 food fraud

 

  • Learn about food fraud and how it can put your brand and your consumers at risk
  • Hear food fraud stories that will surprise you and learn ways to protect your business
  • Get step-by-step instructions for food fraud vulnerability assessments and food fraud mitigation plans, using real life examples
  • Download templates for vulnerability assessments, mitigation plans and food fraud prevention procedures
  • Proceed at your own pace; skip forward and back through the lessons, start and stop at your convenience*

The content is a mix of written words and short video clips, plus downloadable worked examples.

Ask the trainer a question at any time.

What’s included?

  • Food Fraud Commonly Affected Foods Ebook
  • Food Fraud Vulnerability Assessment template
  • Food Fraud Prevention Procedure template
  • Food Fraud Mitigation Plan template
  • Vulnerability assessment document – worked example
  • Raw Material Specification template
  • Food Fraud Team Job Descriptions
  • Top tips for audit preparation
  • Special 40% discount code for use on www.foodfraudadvisors.com
  • Optional exam and Certificate of Competency

Duration: 3.5 hours

Visit our training academy today

* course is available for 6 months after commencement

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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.

Want more stories?  Like us on Facebook to receive news items like these straight to your news feed. Food Fraud Advisors on Facebook

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Oregano Fraud; six things every food professional needs to know

1. What happened?

Testing was conducted by the Australian consumer group Choice, mirroring tests conducted in the UK and published by the UK Consumer Group Which? in 2015.  A selection of packs of dried oregano were purchased from supermarkets (grocery stores), delis (specialty food stores) and grocers (produce stores) in three cities in Australia and a single sample of each was tested.  Seven of the twelve samples, over fifty percent, were found to be inauthentic, with the inauthentic samples containing between 10% and 90% of ingredients other than oregano, including olive leaves and sumac leaves.

2. Why test oregano?  

Herbs and spices are one of the rock-stars of food fraud; their complex cross-border supply chains, high price per kilogram and the fact that they are often sold in powder or particulate forms make them prime targets for adulteration, dilution and substitution with cheaper materials.  

oregano adulteration
Source: Elliott, C. (2016) Addressing complex and critical food integrity issues using the latest analytical technologies

 

Why oregano in particular?  Professor Elliott, Director of the Institute for Global Food Security, and an international authority on food fraud conducted testing on oregano in the UK in 2015, the results of which were published by the UK Consumer group Which?.  It is possible that Prof Elliott used rapid evaporative ionization mass spectrometry (REIMS), a test method recently made available by Waters Corporation, although Which did not disclose the test method. REIMS makes use of a rapid sampling method that produces vapour which is analysed using time of flight mass spectrometry.  Sophisticated software compares molecular markers in the resulting spectrum with those in known materials in a database, allowing a sample to be quickly identified as belonging to a particular product type or not.  The method has huge potential for testing food authenticity, with one of the advantages being that unlike other tests for adulteration there is no need to specify which adulterants to seek.  A downside is that many hundreds or thousands of tests must be performed and compared to traditional analytical methods to create a database before the method can be used with confidence to determine the authenticity of any given material.

Professor Elliott recently revealed that Waters Corporation and Queens University, Belfast worked together to build a database of oregano samples (Elliott, C. (2016) Addressing complex and critical food integrity issues using the latest analytical technologies).  This means that oregano is one of the few materials that can currently benefit from accurate authenticity testing using the REIMS method. 

3.  Are the results unexpected?

Global food fraud commentators attribute the presence of significant concentrations of adulterants or diluents in dried herbs to economically motivated food fraud in most cases, as opposed to seafood mislabelling which sometimes occurs due to unintentional errors in species identification.  Food fraud is estimated to cost the United Kingdom one billion pounds each year.  It is thought to be very common among some food types, including herbs and spices.

4. Who is responsible?

It is highly unlikely that any of the brand owners named in the Choice report were aware that they were selling adulterated herbs.  Most if not all of the brands included the Australian testing would have been sourced and packed under well-controlled systems that include vendor approval processes, formal specifications for incoming materials (such as bulk herbs) as well as certificates of analysis and declarations of conformity to specification.   The fraudulent tampering probably occurred further up the supply chain during drying, bulk packing, shipping or storage.  Interestingly, all seven adulterated samples contained olive leaves and two contained sumac leaves.  It is possible that tampering occurred in two different points within the supply chain for some products; perhaps one fraudster added olive leaves to bulk lots of the herb at a location close to the oregano growing area and sumac leaves were added by someone else at a later date.

5. What are the legal and financial ramifications?

The sale of misrepresented products is a breach of Australian consumer law and ignorance cannot be used as a defense.  The incidences were investigated by the Australian Competition and Consumer Commission (ACCC), an independent authority of the Australian government.  One company was fined a substantial sum for selling product that contained only 50% oregano leaves.  It is likely that other businesses that had been supplied with inauthentic herbs sought financial redress from their suppliers, either through purchasing contract penalties or through private legal action.

When a food business chooses to voluntarily recall or withdraw their products from the marketplace they may try to claim the costs against their business insurance. Insurance companies will seek to recover their costs from further up the food supply chain and this may have an impact on premiums in coming years.

6. What should food businesses do?

No food business is immune from economically motivated food fraud and preventing food fraud from affecting a business is a multi-functional task that should involve personnel from purchasing, finance and legal departments as well as food safety and quality personnel.  In the short term however, there are some things that can be done by food safety and quality personnel to help prevent, deter and detect food fraud without a lot of investment from other parts of a food business: 

  1. Update your purchasing specifications to include authenticity requirements.
  2. Review your vendor approvals systems and revise questionnaires and requirements if required.  Consider implementing more stringent requirements for those suppliers that provide vulnerable materials.
  3. Request certificates of analysis (CofA) from suppliers of vulnerable materials
  4. Begin a testing regime for vulnerable materials
  5. Investigate the costs and benefits of supply chain audits, including whether ad-hoc, one-off visits to certain suppliers might be worthwhile
  6. Request tamper-evident packaging and bulk container tamper seals for vulnerable raw materials
  7. Ask suppliers of vulnerable materials to undertake a mass balance exercise at their facility or further upstream in the supply chain.
  8. Make a business case for switching suppliers of materials that prove to be consistently problematic and present it to your purchasing department.

Want to learn more about food fraud mitigation in the spice industry?  This article in Food Safety Magazine provides an excellent insight.