Friday, December 20, 2019

Developing a Food Fraud Prevention System

Over the past several years, we have had more questions on food fraud and developing a program to prevent the potential for food fraud.  An article in Food Safety News this past month, discusses a Food Fraud Management System.   Like a HACCP or even more so, a Food Defense system, it entails conducting a vulnerability assessment and identifying mitigating actions.  One of the key takeaways from the article, and it certainly makes sense, this system must constantly evolve.  It is not a system that can be developed and then be shelved for a year.  It requires continuous surveillance and probing by employees throughout the organization.

Food fraud is not a known risk, it is a risk that can emerge out of nowhere as a perpetrator finds a new way to take advantage of a vast food supply chain.  Catching this may not be an easy task, especially for one person assigned to the task.

Food Safety Magazine
https://www.foodsafetymagazine.com/magazine-archive1/december-2019january-2020/reducing-the-risk-of-fraud-in-the-spice-industry/
Reducing the Risk of Fraud in the Spice Industry
By Jill Hoffman
In the wake of several global incidents involving the adulteration of food, concerns over the adulteration of spices and many other food products have significantly increased. Recent regulatory and certification requirements have mandated addressing food fraud through vulnerability assessments and application of mitigating actions, but in many cases, companies struggle with knowing how to get started and whether they’ve done enough to be effective at addressing a vulnerability. Food fraud is not new. It has been recorded over thousands of years. Known events as far back as the Song (AD 960 to 1279) and Ming (AD 1368 to 1644) Dynasties in China mention instances of fraudulent tea substitution and liquor dilution.[1] For a complex supply chain like spices, the historical risk of food fraud and adulteration is high, which is why it is important to understand how your spice supplier manages food fraud vulnerabilities and what controls they have in place.

Spices: A Complex Global Supply Chain

The spice supply chain is a prime example of a complex global supply chain. Spices are grown all over the world, in both developed and underdeveloped regions. Spices can pass through multiple touch points, which can increase the potential introduction of a food fraud act. A traditional supply chain for spices starts with a grower and passes through collectors, processors, and brokers before it reaches the final consumer. A spice supplier must ensure they understand their total supply chain to determine where increased vulnerabilities exist. Spice suppliers must work to engage further upstream with their growers, processors, and agents to build in assurances and practices that will help reduce their vulnerability to food fraud.

Because of the history of fraud in spices coupled with a complex global supply chain, spice suppliers have had to insulate their products from food fraud through various management practices. The spice industry has implemented many of these practices to reduce instances of types of food fraud such as dilution, substitution, and unapproved enhancements. Leveraging the knowledge from this industry on how to manage food fraud is invaluable for all food companies as they work to build programs and meet requirements for addressing food fraud.

The Food Fraud Management System

Although the act of food fraud isn’t something new, the creation and development of a comprehensive food fraud management system are new for the food industry. Unlike traditional risk management of known hazards, the food fraud management system depends on a vulnerability assessment that relies on historic instances but must also anticipate and predict future occurrences as it is dealing with a human criminal element. Because of this element, the tools and resources for managing food fraud are slightly different from a traditional food safety management system and will require ongoing coordination of information from various functions within a food company to stay informed.

In recent years, regulations such as the Food Safety Modernization Act have required that types of economically motivated adulteration be evaluated to determine whether a hazard exists and must be addressed through preventive controls. In 2014, the Global Food Safety Initiative (GFSI) published a position paper on food fraud and now requires those seeking certification under a GFSI scheme to have programs to address food fraud. Specifically mentioned are the requirements to conduct a vulnerability assessment and to have control programs in place for identified vulnerabilities.[2]

The requirements under GFSI outline base expectations, but companies are left struggling with questions, such as: Where do I get information? What are the best tools to use? Am I evaluating this with the right information?

Having knowledge and guidance on how to pull together the components of a food fraud management system is what industry needs to assist with the development of an adequate and comprehensive program for both large and small companies. Challenges currently exist for the food industry in building a comprehensive food fraud management program. There continue to be gaps regarding accessing some of the information and intelligence needed to enable a comprehensive evaluation for the vulnerability assessment. Another challenge is the ability of companies to engage with suppliers at the source, as the source supplier may be a lower-tier supplier many steps removed from a company’s direct supplier.

The Vulnerability Assessment

One main requirement for addressing food fraud is to conduct a food fraud vulnerability assessment (FFVA). This singular task has a litany of considerations and questions surrounding it, such as: What assessment model do I choose? What information do I consider? There are existing FFVA models publicly available for companies to use. The U.S. Pharmacopeia offers guidance on how to conduct an FFVA with information on the types of information to include.[3] SSAFE offers an online tool to document an FFVA.[4] Companies can choose existing tools and models or can adapt and even create their own. The main thing to remember is to cover all types of food fraud when conducting the FFVA.

How Often?

Food fraud has a dynamic component in that there is an element of human behavior that results in frequent changes in risk. Conducting a vulnerability assessment once per year and then tabling it until the next review cycle a year later may leave your company at risk for a fraud incident. Incorporating activities to drive reevaluation of your process is critical to ensure the FFVA always remains updated.

Identifying Mitigating Actions

Once a food fraud vulnerability has been identified through the assessment process, the next step is to determine what actions can be taken to reduce the vulnerability of a food fraud incident for your company. In some cases, layering a variety of mitigation actions can reduce a vulnerability to an acceptable level for the organization.

Rest of article - https://www.foodsafetymagazine.com/magazine-archive1/december-2019january-2020/reducing-the-risk-of-fraud-in-the-spice-industry/

A good reference - USP Food Fraud Mitigation Guidance
https://www.usp.org/sites/default/files/usp/document/our-work/Foods/food-fraud-mitigation-guidance.pdf

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