Food Fraud is on the rise, so it has never been more important to understand what it is, how it happens, and the best way to safeguard your Food Production Site.
Working within the food production industry, you are sure to be aware of the different risks to consumer safety, audit compliance, and the overall success of your business.
From foreign bodies to foodborne illnesses, there are so many factors to consider when it comes to making a safe and high quality product.
But with Food Fraud flourishing on a global scale, it needs to be given the attention it deserves – placed at the centre of your internal audits, risk assessments, HACCP plans, supplier relationships, and on-site training.
To help you achieve this goal, we have put together a guide on Food Fraud, with a specific focus on the audit expectations surrounding it. There are valuable takeaways throughout, but you can also use the links below to skip to the section most relevant to your site.
What is Food Fraud?
BRCGS defines Food Fraud as the: “Fraudulent and intentional substitution, dilution or addition to a product or raw material, or misrepresentation of the product or material, for the purpose of financial gain, by increasing the apparent value of the product or reducing the cost of its production.”
Although the motivation behind Food Fraud is rooted in economic gain, it can pose a serious health risk to your customers – exposing them to non-food items, ingredients that do not meet the expected food safety standards, and even undeclared allergens.
There is also an ethical risk, with free range eggs presented as organic, produce from overseas sold as a local product, and non-Halal food misrepresented as a Halal-friendly choice.
Another important point is that a major Food Fraud incident could undermine the reputation and success of your business, with customers unwilling to trust products from a site that is unable to control its supply chain and identify compromised ingredients.
What are the different types of Food Fraud?
In its 2018 guide to Food Fraud: Tackling Food Fraud Through Food Safety Management Systems, the GFSI highlighted seven different types of Food Fraud – drawing on examples first provided by the SSAFE Organisation in 2015.
As you work through the seven groups listed below, you will see that they all have the potential to result in customer complaints, product recalls, food-borne illnesses, allergic reactions, and even long-term health issues amongst consumers.
SUBSTITUTION
Substitution is the process of replacing at least one element of a product with another. This will typically be done with the intention of saving money, with a higher value ingredient switched out for a lower value ingredient.
CONCEALMENT
Concealment is the process of hiding the true value of the product being supplied. This could involve anything from the injection of brine to the application of an unlisted and potentially harmful food colouring.
DILUTION
This is the process of watering down or diluting a product with a liquid of lower value. This will often involve the use of untreated water that is not safe for consumption.
COUNTERFEITING
This involves copying the name, packaging, concept or production process of another brand in the hopes of confusing the consumer. The outcome can be harmful, as these copies are not compliant with the same standards of food safety.
UNAPPROVED ENHANCEMENTS
The introduction of undeclared materials to a food product in an effort to provide enhancements such as a higher protein value, a longer shelf-life, a more desirable aesthetic, and improved taste.
MISLABELLING/MISBRANDING
This is the process of including false claims on product packaging in the hopes of misleading the consumer and securing financial gain. Examples include printing an incorrect expiry date, country of provenance, or list of ingredients.
GREY MARKET PRODUCTION/THEFT/DIVERSION
Grey Market Production involves the sale of excess, unreported product that exists outside the expected standards and guidelines.
Which BRCGS expectations relate to Food Fraud and how do I comply with them?
References to Food Fraud appear throughout Version 9 of the BRCGS Global Food Safety Standard. This is unsurprising given the fact that Food Fraud is on the increase and is therefore a major point of concern throughout the food production industry.
To offer you a better understanding of the BRCGS expectations surrounding Food Fraud, we have listed the key clauses below. We have also included our recommended action points for securing audit compliance in each area.
Assessing your suppliers & product authenticity
Clause 9.3.1 outlines the expectation that food factories will have “a documented supplier approval procedure which identifies the process for initial and ongoing approval of suppliers and the manufacturer/processor of each product traded.” The Clause goes on to state that the requirements shall be based on a thorough risk assessment that will factor in a number of different points, including the “potential for adulteration or fraud”.
Clause 3.5.1.1 asks that your site “undertake[s] a documented risk assessment of each raw material or group of raw materials, including primary packaging, to identify potential risks to product safety, authenticity, legality and quality.” This risk assessment needs to take into account the potential for “substitution or fraud”.
Action points
When it comes to assessing your suppliers and the authenticity of your product, you and your team will need to be aware of the warning signs.
Common examples include an increase in customer complaints, inaccurate paperwork, missing traceability records, suspiciously low prices, a request for cash transactions, and a strange approach to labelling.
If your site carries out any testing of the ingredients you receive, this could be another area to look for trends or anomalies.
Along with the possible warning signs, you and your team also need to demonstrate an awareness of the risk levels at play. Carrying out thorough and regular risk assessments will help you to establish a strict procedure for documented supplier approval. This procedure will need to be well-known across your site, reflective of the current standards, written in direct response to the specific risks present at your site, and updated on a regular basis.
HACCP: Food Safety Management
Clause 2.7.1 details the expectation that a site’s “HACCP food safety team shall identify and record all potential hazards that are reasonably expected to occur at each step in relation to product, process and facilities.” According to BRCGS, one of the potential hazards in need of consideration is “fraud (e.g. substitution or deliberate/intentional adulteration)”.
Action points
As you may know, HACCP stands for Hazard Analysis and Critical Control Points and exists as a preventative approach to food safety management. Due to the obvious cross-over, your HACCP food safety team are perfectly positioned to address matters of Food Fraud and, more specifically, Food Fraud Prevention.
As mentioned above, the team will need to record all the potential hazards that could reasonably occur at your site. They will need to conduct a hazard analysis, identify Critical Control Points (CCPs), establish critical limits, identify monitoring procedures, establish corrective actions, identify verification procedures, and finally, establish the most effective approach to documentation.
To support your HACCP team with this task, you should consider introducing a Cloud-Based Quality Management system. This system will reduce the risk of human error, eliminate paper checklists, reduce the frequency/need for some manual checks, save your team a significant amount of time, and support your journey towards audit compliance.
Data analysis will also be made easier, with reports available across multiple locations. This should help your team to identify concerning patterns and even identify the warning signs of a Food Fraud incident before it actually occurs.
Internal Audits
Clause 3.4.1 addresses the need for “a scheduled programme of internal audits”. It also states that “food defence and food fraud prevention plans” need to be factored into the scope of a site’s internal audit programme.
Action points
Internal audits are all about verifying the processes at your site, making sure your factory is working to the relevant standards and giving your team the opportunity to identify and address any points of non-conformity before an external audit takes place, a customer complaint is issued, or a serious food safety incident occurs.
As referenced in the clause above, internal audits also provide the perfect opportunity to assess your site’s Food Fraud Prevention Plan and whether or not it is being followed correctly by your team.
To ensure your internal audits sufficiently address the issue of Food Fraud, we would recommend working through the following points:
- Appoint an internal auditor with a passion for Food Fraud prevention and consumer safety. Ongoing training will help to keep them motivated and informed.
- Your approach to internal auditing should be determined by a series of risk assessments. By first identifying the Food Fraud Vulnerabilities at your site, you can then establish which points to check during your internal audits.
- Although BRCGS expects your internal audits to cover all of its requirements, there is no expectation that you audit everything in one go. Because of this, you could dedicate an entire auditing session to Food Fraud Prevention.
- Internal audits should be a tool for continuous improvement and a positive experience for everyone on site. It's important that you are rewarding success, rather than highlighting failure, as this will help to keep your team engaged.
Training & awareness
Clause 5.4.2 outlines the expectation that your site will 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 (e.g. fraudulent raw materials). Such information may come from, for example: trade associations, government sources, private resource centres”.
Clause 5.4.1 states that “where personnel are engaged in vulnerability assessments, the individual or team responsible shall understand potential food fraud risks. This shall include knowledge of raw materials used by the site and the principles of vulnerability assessment.”
Action points
The first step is to ensure your site is up-to-date with the latest information and guidelines relating to Food Fraud. Resources from “trade associations, government sources, [and] private resource centres” should be circulated amongst the team leaders and key decision-makers at your factory.
Working with your team, you should also make Horizon Scanning a priority – working to detect and assess any emerging Food Fraud threats.
The most important learnings should then be shared with your general site-staff through ongoing training sessions. During these sessions, it is important to highlight the ‘why?’ behind your site’s efforts to combat food fraud. You will need to remind your operatives of the very real dangers faced by consumers and emphasise their essential role in keeping the public safe.
Finally, you should reinforce key messages with the help of Visual Management Solutions. Signs and information boards that draw attention to the dangers of Food Fraud will ensure this issue is given the attention it deserves. From reminding your team of the correct process for checking ingredients to highlighting the Top 10 Signs of Food Fraud, there are plenty of opportunities to educate your operatives, enhance your food safety culture, and impress external auditors.
What is a Food Fraud Vulnerability Assessment?
In the section above, you may have noticed that Clause 5.4.1 highlights the importance of essential personnel understanding “the principles of vulnerability assessment”.
But, what is meant by a Food Fraud Vulnerability Assessment?
Put simply, it is the process of identifying potential weaknesses in your supply chain, along with any opportunities to mitigate the risks associated with raw materials.
The 2018 GFSI Position Paper outlines the expectation that:
“[every] organization has a documented food fraud vulnerability assessment procedure in place to identify potential vulnerability and prioritise food fraud mitigation measures.”
To ensure your site is taking the correct approach, you should address the following points:
- Consider a wide range of hazards - addressing the seven threats listed earlier in this article, along with any other risks to the food and ingredients at your site.
- Address all aspects of your operation and involve key representatives from each department.
- Acknowledge the distinction between: a hazard (potential sources of harm), a risk (possible consequence of the hazard occurring), and a vulnerability (how susceptible your site is to risk).
- Use the findings of your assessment to establish a Food Fraud Mitigation Plan.
If you are unsure about carrying out a Food Fraud Vulnerability Assessment at your site, BRCGS now offers a course in this area – launched with the intention of providing manufacturers with an in-depth and practical understanding of how these assessments work and how they can be applied to your operation.
That brings us to the end of our overview of Food Fraud in the Food Production Industry. You should now have a clear idea of what Food Fraud is, the different threats to be aware of, the impact that Food Fraud could have on your site securing audit compliance, and the importance of Food Fraud Vulnerability Assessments.
If you have any questions about any of the information shared throughout this article, you can contact us directly on 01473461800 or sales@klipspringer.com. Alternatively, you can fill out the contact form below and one of our friendly team members will be in touch.
Plus, if you would benefit from further resources relating to food safety and audit compliance, you are welcome to check out the articles linked below:
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