Lynn Patterson - Safefood

1 Risk assessment tools for food Defence lynn PattersonLP Associates (NI) Ltd 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 Source: Senior Management Commitment and 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. 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 )Consideration shall also be given to the significance of a raw material to the quality of the final product.

2 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 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 : 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 materialsSuch information may come from Trade associations Government sources Private resource centresA 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 materialThe vulnerability assessment shall be kept under review to reflect changing economic circumstances and market intelligence which may alter the potential risk.

3 It shall be formally reviewed annually. 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 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 vulnerability assessment EspionageEconomically motivated adulteration(EMA)Malicious contaminationExtortionCyber crimeCounterfeiting 1 The Extortionist 2 The Opportunist3 The extremist4 The irrational individual5 The disgruntled individual6 The professional criminal 7 The hacktivist/ cyber criminal 1. Map your supply chain2. Identify Impacts, risks and opportunities3. Assess and prioritise your findings4. Create a plan of action 5. Implement, Track, review and communicate food & Drink Federation food Authenticity: Identify Team Draw up list of raw materials (groups) Identify potential adulteration issuesEvaluate level of risk (agree on risk criteria)Review existing controls, identify additional controlsRecord justifications Implement VerifyReviewQA / Technical Production HRPurchasing Site securityEngineering LogisticsITRaw material supply chainGroups of raw materials Packaging Handling raw materials / productionThreats to sitebrandThis 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 ?

4 What is the specification Form of product Supply issuesCountry of origin Supply baseHow easily could it be substitutedWould anyone want to substitute it Are we claiming provenance, special of occurrence (O) of detection (D) (P) Risk number(PRN) OxDxP Historical incidentsEmerging concernsEconomic factors/ price fluctuationsGeographic origin/ complexity of supply chain Ease of access to raw materials(for fraudster)Nature of raw materialPhysical formAvailability (seasonality/ harvest variability) Availability of adulterants / substitutesComplexity and cost of committing fraud Geographic origin Ease of access to raw materials Length and complexity of supply chainPhysical formExisting controlsRoutine product testing Relevant auditsEconomic factors/ price fluctuationsNature of raw material: value of raw material, size of market Availability / seasonalityComplexity and cost of committing fraudAvailability of cheaper adulterants or substitutesVolumes involvedLikelihood of occurrenceLikelihood of detection1.

5 Very likely/certain4. unlikely3. Fairly likely2. unlikely2. unlikely1. Very unlikely3. Fairly likely4. likely5. very likely/certainCertificates of analysis : per batch Raw material testing Supply chain audits Mass balance exercise with suppliersTamper evident sealsChanges to purchasing policiesPremises, services, utilitiespeopleProductSite security Vehicle access Perimeter fences Sign in and outprocedures (contractors/ visitors) Temporary workers Restricted access Key production areas, including control rooms, plant roomsSecurity of storage tanks, silos, chemical stores( particularly outside) Tamper evident CCTVMail securityUtilities Electricity, waterDrainage Are they secureLogistics Third party haulage or storageCleaning systems Security, access TACCP Controls (pre requisites) Site security, key pad access, access by vehicles, visitor access, CCTV Traceability Staff training Tamper evident sealsAdditional controls Barcode scanning of ingredient additionCCP s (TACCP) ?

6 ProceduresRecord keeping Staff training communicationAudit system Unannounced Keep up to dateReviewHorizon scanning RASFF