This document summarizes a webinar presentation on 10 ways to protect an organization from food fraud. The webinar was presented by Brian Neal from SAI Global and covered topics like defining food fraud and safety, conducting vulnerability assessments, developing a food fraud prevention plan, and using certification to support mitigation. It provided examples of food fraud incidents and outlined 10 steps organizations can take including understanding food safety concepts, assessing supply chain risks, documenting prevention plans, and continually evaluating policies and processes.

1. 10 Ways to Protect your Organisation
from Food Fraud
Brian Neal, SAI Global Technical Manager

2. Welcome
• Participants will be on mute during the webinar
• Q&A session at the end – please use the ‘Question’
button on the right hand side of your screen, click ‘Ask’ to
submit.
• There will be an audience poll during the presentation
• The webinar will be recorded and the link sent out after
the webinar with the slides.

3. Our Presenter
Brian Neal - Technical Manager, SAI Global
• 15 years experience in the food industry
• Member of the Certification Body Committee for
SQF
• Current auditor with SQF as well as other food
safety standards
• Technical Manager over multiple GFSI schemes,
along with second party audit schemes

4. Agenda
• Food fraud – definition and understanding
• Impacts of food fraud
• High risk areas
• Tips for risk mitigation
• Using certification to support mitigating food fraud
risks

5. 10 Ways to Protect against Food Fraud
1. Understand the difference between HACCP, VACCP and TACCP
2. Identify the requirements to address food fraud
3. Ensure commitment from senior management
4. Use HACCP Concepts to conduct food fraud risk analysis
5. Conduct a vulnerability assessment to identify supply chain risks
6. Document your food fraud mitigation plan
7. Implement control measures support this plan and mitigate the
risks
8. Maintain records documentation
9. Conduct regular audits to ensure compliance
10. Continue to evaluate your policies, processes and plans

6. Food Fraud
Food Fraud costs the global food industry between 7-11
billion pounds annually and affects approximately 10% of
all commercially sold food products*
*Grocery Manufacturers Association

7. Food Safety, Food Defense, and Food
Fraud
• Food safety, food defense, and food fraud risk
assessments consider different criteria in order to
determine the degree of situational risk for each
criteria and the measures that need to be
implemented to mitigate that risk.

8. Food Safety, Food Defense, and Food
Fraud
Food Safety Food FraudFood Defense
Food safety refers to the
conditions and practices
that preserve the quality
of food to prevent
contamination and food-
borne illnesses.
Food Defense is the effort
to protect food from acts
of intentional adulteration.
Food fraud refers to the
deliberate and intentional
substitution, addition,
tampering, or
misrepresentation of food,
ingredients, or packaging; or
false/misleading statements
made about a product for
economic gain.
TACCP
Threats
VACCP
Vulnerabilities
HACCP
Hazards
What is Food Fraud Prevention?
FOOD SAFETY MANAGEMENT SYSTEM

9. GFSI’s definition of Food Fraud
“A collective, tampering or term encompassing the
deliberate and intentional substitution, addition,
misrepresentation of food, food ingredients or food
packaging, labelling, product information or false or
misleading statements made about a product for
economic gain that could impact consumer health.”

10. Other definitions of Food Fraud
• Collective term used to encompass the deliberate and
intentional substitution, addition (or dilution), tampering, or
misrepresentation of food, food ingredients, or food
packaging; or false or misleading statements made about
a product, for economic gain.
• Intentional deception using food for economic gain
Economic Gain

11. Where does Food Fraud appear?
FDA “Economically
Motivated Adulteration”
All Fraud
UK, EU, GFSI, ISO…
Food
Fraud
Dilution
Substitution
Contaminant
Grey
market/theft
/diversion
TamperingMislabeling
Unapproved
enhancements
Over-runs
Counterfeiting

12. Food Fraud Requirements according to
GFSI
A Food Fraud Vulnerability Assessment and Strategy
should include:
― Written Procedure
― Annual Assessment
― Address all types of risks
― Address all products

13. Putting the requirements to the test
A Food Fraud incident occurs (product is sold as something
it is not). What’s next?
― Investigation
― Did it pass your inspection process?
― Did you identify a countermeasure? (if needed)
― How did you justify not identifying as needing a
preventive control?

14. • Develop a team
• Design Food Fraud Policy Statement
• Conduct Food Fraud Vulnerability Assessment
• Review Food Fraud Vulnerabilities
• Consider countermeasures/Preventive Controls for
higher risk vulnerabilities
• Training
• Implement Strategy
• Annual Assessment, or for each incident
Prevention Strategy

15. What is your greatest challenge in
addressing food fraud?
15
• Developing a robust Food Fraud Plan
• Confidence in our Supplier Compliance Program
• Traceability within our Supply Chain

16. Food Fraud Examples
During the middle ages (18th to 19th century)
• Spices – When the price of spices increased, merchants
began to substitute spices with seeds, stones or dust.
• Milk – Commonly diluted with water (sometimes dirty
water) and coloured with chalk or plaster.

17. Food Fraud Examples – 2013 Horsemeat
In 2013, consumers in Europe unknowingly purchased
meatballs and burgers containing meat other than beef.
The investigation determined the fraudulent products were
produced by two meat processing facilities in the Irish
Republic and the UK. The analysis concluded:
• One sample of meat contained 29% horsemeat
• Of 27 beef burger products tested, 10 tested positive for horse
DNA and 23 for pig DNA
• Of 31 beef meal products tested, 21 tested positive for pig DNA

18. Food Fraud Examples
– 2008 Melamine in Infant Formula
In 2008 scandal in China involved milk and infant formula.
Melamine was being used to dilute milk in order to elevate
nitrogen levels to get higher protein results. This lead to the
poisoning of many infants and children through contamination
of milk formula and other products.
The result was a boost in the demand for foreign products and
after 2009, more than 100 foreign brands flooded into the
Chinese market.*
*Source: https://www.forbes.com/sites/yanzhonghuang/2014/07/16/the-2008-milk-scandal-
revisited/#7ecd7eeb4105

19. Food Fraud Examples
– 2015 Peanut tainted Cumin
In one of the largest recalls the US has seen, more than half a
million pounds of food products were recalled due to
undeclared peanut in Cumin.
Spice supply chains are long and complex, making traceability
a significant challenge. From one supplier alone there were 38
different companies associated, nearly 600K pounds of beef,
pork and chicken contaminated as well as some vegetarian
products affected. *
*Source: www.allergicliving.com

20. Food Fraud Prevention
• Conduct a Documented Food Fraud Vulnerability
Assessment
• Target all types of Food Fraud
• Implement a Documented Food Fraud Prevention
Strategy
• Conduct an annual Food Fraud Incident Review
• Confirm coverage for the scope and all products;
including both incoming goods (e.g., ingredients) and
outgoing goods (e.g., finished goods) to the
consumer.
• Conduct a challenge of your system, to ensure it
works.

21. Conducting Vulnerability Assessments
• Key terms and elements
• Methodologies are available across the industry
• References

22. Traceability Challenges
Food Fraud Vulnerability
• Susceptibility or exposure to a gap or deficiency that could place
consumer health at risk and/or have an economic or reputational
impact on a food company’s operations if not addressed.
Food Fraud Assessment
• The process of collection and evaluation of information on
potential food fraud risk factors as well as mitigation measures
which, when combined, determine the actual fraud vulnerability
Food Fraud Mitigation Measures
• Hard and soft actions that are taken to combat against identified
food fraud vulnerabilities.

23. Methodologies – Vulnerability Assessment
Methodologies available across the industry:
1. VACCP – Vulnerability Assessment Critical Control
Point
2. Vulnerability Assessment – BRC Method
3. Vulnerability Assessment PWC

24. Methodology – Risk Analysis
• A risk matrix assesses and rates the likelihood and
impact of risks

25. Tools for Self-Assessment
Examples of Vulnerability Assessment Sources/Tools:
― US Pharmacopia
― SSAFE
― BRC
― FDA

26. Vulnerability Assessment Methods -
References
Topic/Search term Source
Vulnerability Assessment Methods
Vulnerability Assessment Tools
www.foodfraudadvisors.com
SSAFE and PwC tool helps assess
vulnerability to food fraud
www.foodqualitynews.com
FDA food fraud vulnerability
assessment
www.docscrewbanks.com
VACCP: HACCP for vulnerability
assessments
www.foodengineeringmag.com/articl
es
Vulnerability Assessment Tools www.foodfraudadvisors.com
Vulnerability Assessment Software www.fda.gov/Food/FoodDefense/To
olsEducationalMaterials/default.htm

27. Tools – Self Assessment Tools - SSAFE
Who is SSAFE?
• SSAFE is a non-profit organisation that SSAFE is a non-profit
membership driven organisation.
― Foster the continuous improvement and global
acceptance of internationally recognised food
protection systems and standards
― In 2015 SSAFE launched a free Food Fraud
Vulnerability Assessment Tool. It is available in excel,
on the web and as an app.

28. • Systematic process of assessing the vulnerabilities to food fraud
• Used by business across the food supply chain
• Supports implementation of GFSI requirements for food fraud
mitigation.
• Provides a profile of the company potential food fraud vulnerability
– basis for developing specific interventions to mitigate identified
vulnerabilities.
• Used to assess vulnerability to fraud – ingredient, product, brand,
facility, country or company wide level, major direct suppliers and
customers. Decision tree is used a filter to help determine where to
apply the tool.
• Note: Food fraud vulnerabilities are dynamic and change over time
– a ‘living tool’ requires regular usage.
Tools – Self Assessment Tools - SSAFE
What is the scope of SSAFE?

29. Tools – Self Assessment Tools - SSAFE
Scope of the Assessment Tool
Who?
Any food business
From farm to fork
Irrespective of
company size
Anywhere in the
world
Where?
Ingredient
Product
Brand
Site
Country
Entire company
How?
Series of
questions
Motivations,
opportunities and
controls
Provides general
and detailed
spider webs
Rapid
interpretation and
analysis
What?
Identifies areas of
vulnerability
Links to external
information
sources & tools
Structured
assessment on a
regular basis
Produces a report
that forms part of
a FSMS

30. Decision Tree 50 Questions
Series of
Spider Webs
Preparation
of Control
Plan
Tools – Self Assessment Tools – SSAFE
Food Fraud Vulnerability Assessment Tool

31. Tools – Self Assessment Tools – SSAFE
Components of a Typical Mitigation Plan
MitigationPlan
Investigate methods for improving the company’s traceability system
Prepare a Code of Ethics and guidelines for all employees
Develop a whistleblowing system
Review future contracts with suppliers and include additional
requirements that strengthen food safety and fraud controls
Request suppliers to complete the Food Fraud Vulnerability
Assessment
Prepare a fraud contingency plan, business continuity plan and provide
managers with crisis management training

32. Tools – Self Assessment Tools – SSAFE
Vulnerabilities identified
Adulteration
Simple technologies and
methods are available, no
specialist facilities are
required, to adulterate raw
materials
Product Monitoring Controls
No methods for fraud
detection, no fraud
monitoring systems, and no
sampling for authenticity
Employee Screening
No integrity screening of
employees
Whistleblowing
No whistleblowing system
exists
Direct Suppliers Fraud
Control Systems
Suppliers don’t have a FSMS
or is not audited externally;
FSMS contains no fraud
measures

33. • U.S. Pharmacopeia Appendix xvii : Food fraud mitigation guidance
http://www.usp.org/sites/default/files/usp_pdf/
EN/fcc/food-fraud-mitigation-guidance.pdf
• BRC Global Standard for Food Safety Issue 7 Understanding
Vulnerability Assessment
http://www.brcbookshop.com/p/1782/brc-global-standard-for-food-safety-issue-7-understanding-
vulnerability-assessment-ukunlocked-pdf-version
• UK Food and Drink Federation (FDF)
http://www.fdf.org.uk/corporate_pubs/Food- Authenticity-guide-2014.pdf
• TACCP (Threat Assessment and Critical Control Point): a practical
guide 2014 (Campden BRI)
http://www.campdenbri.co.uk/publications/pubDetails.php?pubsID=4640
Guidance Documents

34. 10 Ways to Protect against Food Fraud
1. Understand the difference between HACCP, VACCP and TACCP
2. Identify the requirements to address food fraud
3. Ensure commitment from senior management
4. Use HACCP Concepts to conduct food fraud risk analysis
5. Conduct a vulnerability assessment to identify supply chain risks
6. Document your food fraud mitigation plan
7. Implement control measures support this plan and mitigate the
risks
8. Maintain records documentation
9. Conduct regular audits to ensure compliance
10. Continue to evaluate your policies, processes and plans

35. How can SAI Global help?
• Global Reach
• Holistic approach to managing risk across your
business
• Auditing & Certification
• Training Solutions – in house / public / online
• Supply Chain Management
• Food Safety Management Systems
• Advisory & technical support services
To discuss your requirements, email information@saiglobal.com
Or add in a comment to the post-webinar questionnaire

36. Training Courses
Online / public / Inhouse:
• FSPCA Preventive Controls for Human Food
• Food Safety Internal Auditor
• HACCP L2, L3 & L4
• RSPH Allergen Awareness
• Root Cause Analysis (Food industry)
• Supply Chain Traceability
• TACCP, Food Defence, Bio-vigilance and Bio-Terrorism PAS 96)
• Internal Food Safety Auditor Training
• HACCP Validation and Verification - Online
• Root Cause Analysis - Online

37. Standards – Training - Certification
Email: information@saiglobal.com
www.saiglobal.com