Food Fraud: How to Build a Vulnerability Assessment That Works
GFSI-recognised schemes require a documented food fraud vulnerability assessment and a mitigation plan. Here is what they expect and how to build one.
Key points
- Food fraud is deliberate deception for economic gain; it is different from food safety and food defence.
- BRCGS, FSSC 22000 and other GFSI-recognised schemes require a vulnerability assessment and a mitigation plan.
- The assessment must be reviewed regularly and whenever the risk changes.
What counts as food fraud?
Food fraud is the intentional substitution, dilution, addition, mislabelling or misrepresentation of food, ingredients or packaging for economic gain. The motive is profit, not harm, but the result can still be a food safety hazard, for example an undeclared allergen or a toxic adulterant.
What the standards require
A documented vulnerability assessment covering raw materials and, where the scheme requires it, the wider supply chain; a mitigation plan for the significant vulnerabilities; and a review at defined intervals and when new information appears.
Building the assessment step by step
- List materials and group them sensibly
- Gather information: history of fraud, price and availability, how easy the material is to adulterate, and the length and transparency of the supply chain
- Rate each material for likelihood of fraud and likelihood of detection
- Decide mitigation for the high-rated ones: supplier approval and audits, certificates of analysis, targeted testing, changes to specifications or sourcing
- Record the decisions and who made them
Keeping it alive
Review the assessment at least annually, and sooner after a price shock, a shortage, a new supplier or a published fraud alert. Train purchasing staff as well as the food safety team: they see the commercial signals first.