Since the horse meat food fraud scandal in 2013, GFSI standards have developed several requirements to encourage processing plants to improve fraud mitigation measures within their supply base and own processes.
It is well known that beef substitution is one of the top 10 food products with the highest risk of food fraud according to the available literature.
The BRCGS standard, in its V7 version (soon to be in V9), created new requirements (point 5.4) and a Food Fraud Compliance Guide. SQF has recently updated to V9 code and has made Food Fraud a mandatory element, which further supports the importance of this program.
Since the GFSI standards have started to required Food Fraud, we now have a better understanding on how to development, implement, and monitor foo fraud. We also learn from the non-conformities that are given during these audits. The following are the top 3 non-conformities that have arose.
Individual ranking of each of the elements of the vulnerability assessment:
The standards require raw materials and process to undergo a Vulnerability Assessment where the information is categorized and risk assessed to determine the likelihood of occurrence, severity, and ability to detect food fraud. The evaluation and ranking should consider the following:
- historical incidents of fraud
- geographic origin
- emerging concerns
- supply chain length and complexity
- economic factors / price fluctuations,
- physical form (for e.g. minced, powdered or liquid products)
- existing controls (e.g. CofA’s, audits) and frequency of testing
- ease of access to raw materials (e.g. tamper-evident seals)
- availability (season/weather events)
Advise: The considerations must be assessed with data, scientific literature, and understand the impact to determine a mitigation plan for those areas that are deemed a high risk for food fraud. This activity takes resources and experience and is an area where many companies need to continue to improve.
Select a traditional risk assessment tool, such as simple quadratic methods or a quadrant chart, which provides a structured and standardized approach, or a method like TACCP, or VACCP. Another option is to multiply three ratings to obtain a PRN score, (Priority Risk Number) = Occurrence (O) × Detection (D) × Profitability (P). In all cases, ALL items will be evaluated to obtain a final ranking. This range can be used for individual raw materials from different suppliers or to group raw materials from the same supplier. The goal is to ensure the approach used is sufficient to understand potential food fraud risk.
Do not consider the overall rating value of the vulnerability assessment as an input to the provider’s risk assessment
When raw materials are identified as posing a significant risk of tampering or substitution due to fraud, appropriate mitigation and control measures should be put in place to ensure that only genuine materials are purchased. In this way, the potential for fraudulent activity in the supply chain must also be evaluated based on who the supplier is and the history of incident or potential for issues to occur.
Advise: The overall potential food fraud rating will be an additional input in the vendor/supplier approval and tracking system. Vendor management and food fraud assessment are not independent of each other for one food processing plant, but rather feedback to the other. Ensure to consider food fraud in your initial approval process and annual reapproval.
Not developing specific mitigation measures
Not only does a site have to assess the risk and potential for food fraud but they have to develop mitigation strategies. Remember accepting of a GFSI audit from your supplier is not the only mitigation plan that should be in place. So exploring additional mitigation plans such as requiring an independent testing(CoA) provided by the supplier or sampling upon arrival at your facility for certain risks that can be determined through analytical tests. Although a certificate alone is not a sufficient mitigation measure, this must work in combination with visual inspections, seals on trucks, only purchasing from approved suppliers, and other plans. The facility must take ownership to ensure labs are accredited independent and that they are using trusted vendors. “Trust but Verify”, Ronald Regan.
Advise: These are valid examples of specific detection and identification techniques that should be performed by accredited external laboratories contracted by food processors:
- Stable Isotope Ratio Analysis (SIRA)
- TLC and HPLC for saffron artificial color
- Microscopic identification for non-compliant herbs, such as thyme or marjoram in oregano
- UV absorbance to detect the possible adulteration of extra virgin olive oil with refined oils
- PCR method for meat
- Melamine testing in Animal food/treats/infant formula
During the COVID 19 pandemic, the risk of food fraud increased due to different problems in the supply chain that led to problems in harvesting and production. Food auditors and food producers need to be vigilant and more thorough with procedures and mitigation measures now more than ever!