lynn patterson - · pdf filerisk assessment tools for food defence lynn patterson lp...
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Reduce likelihood of attack
Protect brand/ reputations
Reassure customers and consumers
Reduce impact of an attack
Due diligence defence
Create an anti-fraud culture Will assist in acting as a deterrent
Meet BRC / GFSI requirements
Source: GFSI
1.1 Senior Management Commitment and Review
1.1.6 The Company’s senior management shall have a system in place to ensure that the site is kept informed of and reviews
Scientific and technical developments
Industry codes of practice
New Risks to authenticity of raw materials
All relevant legislation applicable to the country of raw material supply, production, and, where known, the country where the product will be sold.
3.5.1.1 The Company shall undertake a documented risk assessment of each raw material or group of raw materials including packaging to identify potential risks to product safety, legality and quality. This takes into account the potential for
Allergen contamination
Foreign body risks
Microbiological contamination
Chemical contamination
Substitution or fraud (see clause 5.4.2)
Consideration shall also be given to the significance of a raw material to the quality of the final product.
The risk assessment shall from the basis for the raw material acceptance and testing procedure and for the processes adopted for supplier approval and monitoring. The risk assessments shall be reviewed at least annually
Statement of Intent :
Systems shall be in place to minimise the risk of purchasing fraudulent or adulterated raw materials and ensure that all product descriptions and claims are legal accurate and verified
5.4.1: The company shall have processes in place to access information on historical and developing threats to the supply chain which may present a risk of adulteration or substitution of raw materials
Such information may come from
Trade associations
Government sources
Private resource centres
A documented vulnerability assessment shall be carried out of all food raw materials or groups of raw materials to assess the potential risk of adulteration or substitution. This shall take into account
Historical evidence of substitution or adulteration
Economic factors which may make adulteration or substitution more attractive
Ease of access to raw materials through the supply chain
Sophistication of routine testing to identify adulterants
Nature of the raw material
The Vulnerability assessment shall be kept under review to reflect changing economic circumstances and market intelligence which may alter the potential risk. It shall be formally reviewed annually.
Where raw materials are identified as being at particular risk of adulteration or substitution appropriate assurance and/or testing processes shall be in place to reduce the risk
Documented risk assessment designed to identify potential sources of food fraud within the supply chain and to prioritise control measures to minimise the chances of receiving fraudulent or adulterated raw materials
Vulnerability Assessment
£
Espionage
Economically motivated
adulteration
(EMA)
Malicious contamination
Extortion
Cyber crime
Counterfeiting
1 • The Extortionist
2 • The Opportunist
3 • The extremist
4 • The irrational individual
5 • The disgruntled individual
6 • The professional criminal
7 • The hacktivist / cyber criminal
1. Map your supply chain
2. Identify Impacts, risks and opportunities
3. Assess and prioritise your findings
4. Create a plan of action
5. Implement, Track, review and communicate
Food & Drink Federation Food Authenticity:
Identify Team
Draw up list of raw materials (groups)
Identify potential adulteration issues
Evaluate level of risk (agree on risk criteria)
Review existing controls, identify additional controls
Record justifications
Implement
Verify
Review
QA / Technical
Production
HR
Purchasing
Site security
Engineering
Logistics
IT
Raw material supply chain
Groups of raw materials
Packaging
Handling raw materials / production
Threats to site brand
This is not a Process flow diagram
Take into account the complexity of the chain
• Agents
• Direct supply
• Logistics:
• who handles your product
• Pallet networks
• Cross docking
• Where is the raw material vulnerable to the threat of attack ?
What is the specification
Form of product
Supply issues
Country of origin
Supply base
How easily could it be substituted
Would anyone want to substitute it
Are we claiming provenance, special claims
1. Likelihood of occurrence (O)
2. Likelihood of detection (D)
3. Profitability (P)
1. Priority Risk number(PRN)
2. PRN= OxDxP
Historical incidents
Emerging concerns
Economic factors/ price fluctuations
Geographic origin/ complexity of supply chain
Ease of access to raw materials(for fraudster)
Nature of raw material
Physical form
Availability (seasonality/ harvest variability)
Availability of adulterants / substitutes
Complexity and cost of committing fraud
Geographic origin
Ease of access to raw materials
Length and complexity of supply chain
Physical form
Existing controls
Routine product testing
Relevant audits
Economic factors/ price fluctuations
Nature of raw material: value of raw material, size of market
Availability / seasonality
Complexity and cost of committing fraud
Availability of cheaper adulterants or substitutes
Volumes involved
Likelihood of occurrence
Lik
elihood o
f dete
cti
on
1. very
likely/certain
4. unlikely
3. Fairly likely
2. likely
5.very
unlikely
2. unlikely1. Very
unlikely3. Fairly
likely 4. likely
5. very
likely/certain
Certificates of analysis : per batch
Raw material testing
Supply chain audits
Mass balance exercise with suppliers
Tamper evident seals
Changes to purchasing policies
Premises, services, utilities
people
Product
Site security
•Vehicle access
•Perimeter fences
•Sign in and out procedures (contractors/ visitors)
•Temporary workers
Restricted access
•Key production areas, including control rooms, plant rooms
Security of storage tanks, silos, chemical stores
( particularly outside)
•Tamper evident
•CCTV
Mail security
Utilities
• Electricity, water
Drainage
• Are they secure
Logistics
• Third party haulage or storage
Cleaning systems
• Security, access
TACCP Controls (pre requisites)
• Site security, key pad access, access by vehicles, visitor access, CCTV
• Traceability
• Staff training
• Tamper evident seals
Additional controls
• Barcode scanning of ingredient addition
CCP’s (TACCP) ?
Procedures
Record keeping
Staff training
communication
Audit system
•Unannounced
Keep up to date
Review
Horizon scanning
•RASFF