Food Fraud

Are you struggling  with defining the requirements of Food Fraud? When it comes to Food Fraud there are two main categories you need to consider: intentional adulteration and economically motivated adulteration. Intentional adulteration is defined as individuals that intentionally adulterate your products (e.g. insert poison, viruses or bacteria in your products or find another way to change the properties of your product and make it potentially harmful for others). Economically motivated adulteration happens when individuals or companies have an economical incentive to adulterate products, e.g. when prices rise or fall sharply in a short period of time. Another time to be suspicious of economically motivated adulteration is when buying, handling or selling expensive or exclusive products (e.g. Manuka honey).

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Food fraud comes in wide range of varieties and is often quite difficult to detect. When food fraud is detected while the product is still inside the company the product must be blocked and most likely will be scrapped. When the product is already in the market, the issue will quite easily escalate to a recall situation.  The USA, Canada and China have put new legislation into place since 2016, which mandates the authorities to blacklist any company from exporting goods to these countries if there is a suspicion of food fraud. The same legislation requires you to take appropriate action and perform a risk assessment in your business to investigate whether or not you are prone to food fraud (see http://www.fda.gov/Food/GuidanceRegulation/FSMA/ and http://eng.sfda.gov.cn/WS03/CL0768/98109.html ) .

Good prevention starts with profound insight and the best place to start here is the FDA website. The FDA has developed a checklist which can be used for food defence and next to this the FDA has developed a comprehensive risk assessment tool (see http://www.fda.gov/food/fooddefense/toolseducationalmaterials/ucm349888.htm ). Alternatively you can have a look at the SSAFE toolset, which has been developed by PWC in collaboration with large players in the food industry (see http://www.ssafe-food.org ) . Still the basics need to be in place such as temper evidence – not only on your finished goods, but more and more also for your raw materials and intermediates. Best in class is to use your own logo included in the temper evidence solution (e.g. have a cap for piles which has your logo on it – of course this requires an additional investment for your cap supplier to make new inserts for the injection moulds to make this happen).  Another strong tool is to continuously scan for changes in pricing of your raw materials and finished goods, as these might give rise to economically motivated adulteration. If prices shown big changes either up or down it is wise to perform additional tests on your raw materials in terms of composition or activity / dilution levels. Finally you want to make sure to limit options for intentional adulteration by keeping open product behind closed (and preferably locked) doors. This involves things like access control (only allowing designated staff to handle open product), locking inlets and manholes of all tanks (protecting your raw materials / intermediates and finished good stored in tanks).  Another useful item is to hand our staff batches with photos on it and make them wear visibly, this way you make sure only your employees and allowed visitors / contractors are present in your factory.

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