All Global Food Safety Initiative
(GFSI) food safety standards
now require a food fraud
vulnerability assessment across a food
manufacturer’s entire supply chain,
with a major emphasis on ranking raw
materials for potential vulnerability.
If any potential fraud is identified by
the investigation, it is expected that
appropriate mitigation strategies and
control measures will be implemented.
Using a risk assessment and ranking
method I developed in 2016, I recently
re-assessed the raw materials for a
company that had originally been
assessed in 2018.1
The original 34
raw material rankings ranged from
the highest score of 60 to the lowest
score of 3, out of a possible highest
score of 125.
The next lowest score was 32, and
the next was 24. In 2020 the 23 raw
material rankings ranged from a high
score of 18 to the lowest score of 3,
yet many of the ingredients were the
same. What else had changed?
The reason the score improved
so much was that the company had
spent time examining its suppliers
and assessing what they really
knew (or did not know) about their
ingredient supply chain. As a result,
they changed not just their suppliers,
but also their supply chains, so they
knew the country of origin and could
identify each major step in the supply
chain, combined with the controls
already in place.
Changing suppliers can
decrease uncertainty
For example, the ingredient that
scored 60 in 2018, was supplied by
a broker who gave two different
countries of origin, no source
manufacturer, no certifications and
no certificate of assurance or batch
specific lab results.
Not only did
the supplier fail to undertake any
control measures, the company
purchasing the product took no
samples and didn’t carry out any
testing or conduct even basic sensory
assessment.
In 2020, that same ingredient is
now supplied by a wholesaler who
supplied the following information
and documentation:
• Country of origin
• Name of the source manufacturer
• Current GFSI certificate of the
source manufacturer
• Current GFSI certificate of the
wholesaler
• Certificate of assurance from the
source manufacturer.
The company then undertook sensory
evaluation (appearance, aroma and
taste) of received products and also
conducted a detailed review of the
product information form (PIF).2
This closer analysis found that the
raw material was not sourced from
a species at high risk from fraud (as
had been assumed), but was instead
sourced from a different species
which had a much lower risk of fraud.
The PIF contains useful information
when you are starting your food
fraud assessments - if it is completed
correctly and completely - including
information on product description
(often listing species Latin
name), country of origin, source
manufacturer, ingredient declarations,
allergens, product description, legal
description, allergen management and
controls in place, suitability for claims,
physical, organoleptic, chemical and
micro specifications, that can all be
matched to information from your
supplier.
The general history of fraud for each
ingredient was identified using the
Horizon Scan database. This database
lists all daily recalls from almost every country in the world, along with many
national border rejections, covering
food safety and food fraud issues
for thousands of raw materials and
packaging.
This analysis enables you to easily
and correctly quantify the risk for
that raw material, and the risk for the
specific country of origin, and search
for specific suppliers. Horizon Scan can
also identify what type of adulterants
you should be looking to test for.3
Public databases can help
detect inconsistencies
Many supplied audit certificates can
be matched to the standards public
access database to confirm that it is
indeed legitimate. Any discrepancy
between stated information in the PIF,
audit certificates and certificate of
assurance needs to be investigated.
If you suspect the certificate of
assurance you are receiving may be
fraudulent, line up 12 months of records
to see if the results are identical, as
almost no product sourced from
plants or animals will be identical all
year round.
The next step is to take
a product sample and get it tested
independently.
Even taking a sample of the product
at each delivery and smelling it, feeling
it, and assessing the colour against
a known master sample, can help
identify batch to batch discrepancies.
If a sample is identified as ‘different’
to a known sample, then a ‘presence/
absence’ test for starch or gluten can
often identify additional components
that may indicate fraud.
There are also a wide range of
sophisticated lab tests that can be
undertaken to identify food fraud,
but start with some consistent and
complete supply chain information,
and product sampling, to minimise
your risk to food fraud in your raw
materials.
Know and understand your supply
chains, use sensory evaluation,
review the detail on the PIF, read the
information printed on the actual
ingredient cartons, research the history
of fraud for each ingredient, identify
what type of adulterants you should
be looking for, obtain valid certificate
of assurances, and then get it tested
independently.
References
1. https://www.integritycompliance.com.au/
course?courseid=20-raw-materials-assessment
2. https://www.afgc.org.au/industry-resources/
product-information-form-version-6
3. https://www.integritycompliance.com.au/pages/
global-food-integrity-and-risk-system
4. “What does a Food Fraud Vulnerability
Assessment Look Like?” at the BRC Global
Standards, Food Safety Americas. 2019, San
Diego USA. https://vimeo.com/351518036
5. “When it doesn’t smell, look or feel right: Food
Fraud Detection & Mitigation in the raw material
supply chain. A case study of food fraud.” SQF
International Conference, Atlanta Georgia USA.
https://vimeo.com/301102480
Clare Winkel is executive manager,
technical solutions, at Integrity
Compliance Solutions. She
has presented on food fraud
internationally, including the SQF &
BRC conferences in the US.4,5 f
