New GFSI (Global Food Safety Initiative) requirements now include special consideration to be given to food fraud. To address this new requirement, food safety standards, including SQF, mandate certified sites to complete a food fraud vulnerability assessment of a food manufacturer’s entire supply chain with a strong emphasis on ranking raw materials for potential vulnerability. Current retailers & legislation (Australia, USA & UK) require controls within this area, but unlike established food safety risk assessments, there have been very few published methodologies to carry out vulnerability assessments. This presentation will concentrate on methodologies to assess the risk of potential food fraud within the raw material supply chain.
Different countries have different Food Fraud regulations and even different definitions. If you are exporting you need to know not only what the requirements are, but also the meaning of the term in that region. Food fraud is economically motivated adulteration of food. It’s all about making money – not sabotage.
Food fraud is not HACCP which is the prevention of unintentional/accidental food safety adulteration i.e. science based, and food borne illness. It also not Food Defence or threats – the prevention of intentional ideologically motivated adulteration i.e. sabotage or bioterrorism.
Some legal definitions of food fraud from around the world include:
- Intentional adulteration from acts intended to cause wide-scale harm to public health, including acts of terrorism targeting the food supply.
- Hazard may be intentionally introduced for purposes of economic gain.
- Food fraud is considered to encompass the deliberate and intentional substitution, addition, tampering or misrepresentation of food, food ingredients, or food packaging, or false or misleading statements made about a product for economic gain.
- Gaining a financial advantage or causing a financial disadvantage through deception or dishonesty.
VACCP (Vulnerability Assessment Critical Control Point) is a method of risk assessing raw materials for the risk of food fraud occurrence. There are several methods that can be used – some require far more resources (staff knowledge, time and ability) that is available in the average food business. Some methods present you with a multi coloured spider-web that looks fabulous but does not give a clear result for ranking of the food fraud hazards. In addition to the regulations in the country of manufacture and sale, you also need to be aware of the requirements of the standards your company is audited against i.e. BRC, SQF or specific retailer/customer requirements. Some retailers specifically require a ranking of identified food fraud hazards.
All GFSI standards require some type of documented food fraud risk assessment and control plan requirements – but they do vary between the Standards. Some requirements are:
BRC Food Safety Global Std:
- 18.104.22.168 Documented risk assessment of each raw material that must consider substitution or fraud.
- 5.4.2 Documented assessment of the vulnerability of the raw material supply chain.
SQF Systems Elements Ed 8- Manufacturing:
- 22.214.171.124 Sites food fraud vulnerability assessment including the site’s susceptibility to raw material or ingredient substitution, mislabelling, dilution and counterfeiting … impacting food safety.
- 126.96.36.199 Food Fraud vulnerability assessment include the site’s susceptibility to product substitution, mislabelling, dilution, counterfeiting or stolen goods which effect food safety.
And the FSMA rulings (Federal US regulations): Mitigation Strategies to Protect Food Against Intentional Adulteration:
- A vulnerability assessment, to identify: Significant vulnerabilities and actionable process steps.
The VACCP (Vulnerability Assessment Critical Control Point) methodology developed by ICS is a simple but effective tool of risk ranking raw materials for potential food fraud occurrence. It uses the existing skills of the HACCP team and utilises a 3-variable matrix (Likelihood x Detectability x Profitability) with a resulting score between 1 (overall very low risk) – 125 (overall extremely high risk). This allows raw materials to be clearly ranked for risk. The result is a fully documented assessment against a specific raw material that is easily reviewed at least annually. ICS have used it to assess over 600 different raw materials with the resulting scores between 1 and 60.
ICS have public, virtual and online training courses (and technical support services) in Food Fraud awareness, Food Fraud requirements (Regulatory, GFSI and retailer standards) and VACCP Food Fraud assessment methods. http://integritycompliance.com.au/
Here is a presentation on a specific food fraud case presented by Clare Winkel at the 2018 SQF conference : http://integritycompliance.com.au/when-it-doesnt-smell-look-or-feel-right-food-fraud-detection-monitoring-and-mitigation-in-the-raw-material-supply-chain-marriot-marquis-atlanta-ga-october-23-25-2018/
By Margaret Balfour
While the concept of HACCP-based risk assessments for food safety (chemical, biological and physical) has been very well established globally, much of the food industry has yet to come to terms with the development of risk assessments focusing on vulnerability, authenticity and threats. To further complicate matters, multiple terms are used globally for these topics (oftentimes incorrectly). Despite this, all GFSI Standards (BRC, SQF, Global Gap, FSSC22000 and IFS) and most major retailer Standards require food fraud (VACCP) and food defence (TACCP) risk assessments.
What is VACCP?
VACCP (Vulnerability Assessment Critical Control Points) is a risk assessment focused on risks from the vulnerability of your raw materials, supply chain and your finished product from adulteration, substitution, mislabelling, counterfeit or any other attempt to change the products for economic gain. The VACCP risk assessment is designed to identify risks from food fraud.
The global cost of food fraud is estimated to be US$30-40 billion dollars per year. In many cases, there is no impact on consumer health, but the damage to business reputation and indirect costs can be massive.
Significant food fraud events globally have included the melamine contamination of baby formula in 2008 in China resulting in 300,000 reported illnesses and six consumer deaths. The three key staff members involved were punished: one with life imprisonment and two with the death penalty. Ironically, melamine contamination in the food chain was first identified in May 2007 when the US Department of Agriculture reported that the contaminant had been found in pet food fed to hogs and chickens destined for human consumption. Hundreds of dogs and cats either died or suffered health problems as a result of consuming the pet food.
The scare widened in the US after it was found to have entered the human food chain after pet food scrap was used as a feed supplement at a number of hog and chicken farms. The question that begs to be answered in all this is whether the wider food industry should have been aware of this event and considered it in their risk assessments?
Food Fraud is Not New
Multiple publications have been released as early as A Treatise on Adulteration of Food & Culinary Poisons was penned by Frederick Accum in 1820. There is plenty of historical data on food fraud and the risks associated with each and every ingredient and food product. Not all contamination events are purely for economic gain, however. When the contamination or damage is intentional and designed to cause harm, the term “threat” is used rather than “vulnerability.” Hence the term TACCP (Threat Assessment Critical Control Points).
What is TACCP?
TACCP is a risk assessment focused on risks from threats to your raw materials and could include intentional contamination of food products, sabotage of the supply chain, and using food or drink items for terrorism or criminal purposes.
Food is the number one product stolen when under transportation in the USA. More than USD$30 Billion is stolen annually in the USA and then resold on the black or grey markets, potentially having been contaminated first. And, while theft opens the door to the possibility of significant danger to human life and brand integrity, significant damage can also be achieved through simple malicious intent.
Recently Australia has been subject to a nationwide recall of strawberries in peak season due to malicious tampering with sewing needles. Initially an isolated event in Queensland, the incident escalated to other states and territories. Only a few instances were believed by authorities to be associated with the original event, with most other instances believed to be multiple hoax or “copycat” events.
Risk assessments are only as good as the input or information used to conduct the assessment. Horizon scanning and keeping up to date on threats, vulnerabilities and emerging risks are the only genuine defence we have in the HACCP, TACCP and VACCP risk assessment game