Weak Fence: Vulnerability Assessment

Weak Fence: Vulnerability Assessment


Thursday, October 22, 2020

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Food fraud can either be due to negligence or due to economic gain. Either way, it is on the rise and consumers and food business operators must be aware and take steps to protect themselves and/or their businesses. According to Gary Smith (January 2020) survey statistics for 2019, 36% of USA and Canada and 33% of international processors said that food fraud is a significant issue they face. Fifteen per cent responded that they have detected it in their supply chain. To reiterate, when food fraud is motivated by economic gain it is referred to as “economically motivated adulteration (EMA)”.

In the global perspective of food fraud generated from a World Health Organization (WHO) survey (John Spink et al, July 2019), it was stated that food fraud can be understood in the risk category that deals with quality, safety and defence. The risk that food fraud poses can also be broken down into the categories of direct food risk, indirect food risk, and technical food risk. Whichever category it falls in, the reality is, food fraud is a risk. What then should a food business operator do about it?

In considering how to address food fraud, the Global Food Safety Initiative (GFSI) Think Tank states that since there are socio-economic issues linked to the history of food fraud, it takes a different perspective than for food safety and food defence. The following are recommendations that food business operators must incorporate into their system:

1. Food fraud vulnerability assessment - assess points along the supply chain to determine and prioritise vulnerability.

2. Implement appropriate control measures to reduce the risk of the vulnerabilities found.

The FSSC 22000 guidance on the mitigation of food fraud gives the following pointers for conducting the vulnerability assessment:

1. Economic vulnerability (how economically attractive is fraud?)

2. Historical data (has it happened?)

3. Detectability (eg, how easy to detect, routine screening present?)

4. Access to raw materials, packaging materials and finished products in the supply chain

5. Relationship with supplier (eg, long relationship or spot-buying)

6. Certification through an independent sector specific control system for fraud and authenticity

7. Complexity of the supply chain (eg, length, origins and where the product is substantially changed/processed)

Therefore, when conducting the vulnerability assessment one must consider suppliers, ingredients and industry pressures and influence. It is important to note that, if you are operating a franchise, or exporting or participating in a food safety certification scheme, there is an increasing request for food fraud vulnerability assessment. Below are some questions that one such certification scheme, FSSC 22000, auditors seek to answer when they are evaluating the risk of food fraud:

1. Is there a team with the correct competencies/knowledge?

2. Has a vulnerability assessment been performed and documented?

3. Are all types of vulnerabilities covered (substitution, unapproved enhancements, misbranding, counterfeiting, stolen goods or others)?

4. Depth of the vulnerability assessment (historical data, economic motivations, detectability etc)?

5. Breadth of the vulnerability assessment (all materials covered)?

6. Is there a methodology to determine the significance of vulnerabilities?

7. When significant vulnerabilities are identified, is there a written mitigation plan?

As part of their internal monitoring programme, it is advisable that food business operators evaluate their system by seeking to answer these questions. After all, who wants to be using, say, recycled oil to fry their dumplings because the oil was “mislabelled”?

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