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.
If food fraud vulnerabilities have been identified in ingredients and raw materials, the business will need to make a plan to
- Prevent the purchase of fraudulent materials
- Deter fraudsters from adulterating materials that your business is going to purchase
- Detect fraudulent materials before they are used to make food
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 purchasing policies, supply chain strategies and supplier contracts to help prevent fraudulent materials from reaching the doors of your factory. Personnel from purchasing, finance 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 and these are listed below.
Create and implement a food fraud prevention and detection plan (‘control plan’).
Here are some actions that can reduce your exposure to economically motivated adulteration:
- Update your raw material specifications to include authenticity requirements. Guidance for raw material specifications.
- Review your vendor approvals systems and revise questionnaires and requirements if required. Consider implementing more stringent requirements for suppliers that provide vulnerable materials.
- 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.
- Begin a testing regime for vulnerable materials, rather than relying on the results of supplier tests.
- Investigate the costs and benefits of supply chain audits, including whether ad-hoc, one-off visits to certain suppliers might be worthwhile.
- Request tamper-evident packaging and bulk container tamper seals for vulnerable raw materials.
- Ask suppliers of vulnerable materials to undertake a mass balance exercise at their facility or further upstream in the supply chain.
- Make a business case for switching suppliers of materials that prove to be consistently problematic and present it to your purchasing department.
Need help with your food fraud control plans? Get easy instructions and downloadable templates from our online training course.