Risk Assessment tools for Food Defence. Lynn Patterson LP Associates (NI) Ltd
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1 Risk Assessment tools for Food Defence Lynn Patterson LP Associates (NI) Ltd
2 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
3 Source: GFSI
4 1.1 Senior Management Commitment and Review 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.
5 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
6 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
7 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
8 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.
9 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
10 Vulnerability Assessment 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
11 Espionage Counterfeiting Economically motivated adulteration (EMA) Cyber crime Malicious contamination Extortion
12 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
13 Food & Drink Federation Food Authenticity: 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
14 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
15 QA / Technical Production HR Purchasing Site security Engineering Logistics IT
16 Raw material supply chain Groups of raw materials Packaging Handling raw materials / production Threats to site brand
17 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?
18 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
19 1. Likelihood of occurrence (O) 2. Likelihood of detection (D) 3. Profitability (P) 1. Priority Risk number(prn) 2. PRN= OxDxP
20 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
21 Geographic origin Ease of access to raw materials Length and complexity of supply chain Physical form Existing controls Routine product testing Relevant audits
22 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
23 Likelihood of detection Likelihood of occurrence 1. Very unlikely 2. unlikely 3. Fairly likely 4. likely 5. very likely/certain 1. very likely/certain 2. likely 3. Fairly likely 4. unlikely 5.very unlikely
24 Certificates of analysis : per batch Raw material testing Supply chain audits Mass balance exercise with suppliers Tamper evident seals Changes to purchasing policies
25 Premises, services, utilities people Product
26 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
27 Utilities Electricity, water Drainage Are they secure Logistics Third party haulage or storage Cleaning systems Security, access
28 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)?
29 Procedures Record keeping Staff training communication
30 Audit system Unannounced Keep up to date Review Horizon scanning RASFF
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