Food Fraud
This entire requirement seems i bit much from my end. We have letters of guarantee from all companies that we receive supplies from. We also have certificates of analysis for all products we receive. If we don't have COA's, we can request them at any time. Would this not be enough for a manufacturing plant? What else could we do? We are a very small plant so we don't have a huge budget like all these big companies.
I see where you are coming from, but COAs do not defend food. Once it is in your facility, what are you doing to ensure it is safe? Also, we don't know what you order from suppliers and what you manufacture.
We make over 300 products so the list is extensive. Being a very small company we don't have the resources to put together a 10 person team of people to work on this. I am doing this alone. Once its in our facility our Food Defense program covers this. Shouldn't food fraud and food defense be together and not separate. Makes no sense to me to have these requirements as a separate code.
Food fraud is usually for economic gain, whereas food defense is to cause harm to consumers, economy etc. What measures are you taking to protect food, like access restriction, employees verification, security cameras etc?
In my 20 or so years of consulting I have seen way too many small companies (we always specialized in family owned companies) knocked out of business because of food fraud caused by external suppliers where the only thing the company asked for was some documents and left it at that.
Do I think the requirements are over the top, yes I do - I would pick out what works best for you and go with that.
Most food fraud is economic in nature, however when it comes to big vs small it leans much more to malicious - if a supplier is supplying you but also supplying a much larger company what are the odds of potential pitfalls?, you would hope they treat all their customers the same - but many would be surprized this is just not the case.
Have you tried to reach out locally to your land grant university. They can provide free resources and expertise.
Food Fraud Prevention Think Tank has free classes (you have to pay if you want a certificate) if it will help. It helped me be able to focus on fraud and defense as separate topics. There are a lot of similarities, but different motivation, so they do need to be addressed separately.
We make over 300 products so the list is extensive. Being a very small company we don't have the resources to put together a 10 person team of people to work on this. I am doing this alone. Once its in our facility our Food Defense program covers this. Shouldn't food fraud and food defense be together and not separate. Makes no sense to me to have these requirements as a separate code.
There may be similar vulnerabilities in some cases, but the people perpetrating the actions have different motives. Food Fraud is about gaining economic advantage at the expense of your company; Food Defense is about using what you produce as a conduit to harm people consuming it.
This entire requirement seems i bit much from my end. We have letters of guarantee from all companies that we receive supplies from. We also have certificates of analysis for all products we receive. If we don't have COA's, we can request them at any time. Would this not be enough for a manufacturing plant? What else could we do? We are a very small plant so we don't have a huge budget like all these big companies.
That's like expecting the criminal to turn himself in with a confession. The company selling you materials is the same one saying it meets spec., they have economic incentive not to tell you they're adulterating it to scam you.
.... if I had a dollar for every time I heard a food business say "But we get letters of guarantee" I'd be a millionaire!
Food fraud affects 10 percent of all food, so I guarantee your business has purchased ingredients that are fraud affected. If you're buying spices, seafood, honey, oil, fruit juices/concentrates or organic ingredients you are almost certainly receiving fraud-affected ingredients quite regularly.
It might not be your suppliers who are perpetrating the fraud, they might be unknowingly selling fraud-affected food to you.
Did you hear about the massive recall of cinnamon applesauce pouches in the US last November? They had so much lead in them that kids were getting lead poisoning. The problem was discovered by public health experts who were trying to figure out why kids had such high levels of lead in their blood. The lead turned out to be in the cinnamon used to make the applesauce. It was put in the cinnamon in the form of lead chromate, an industrial colorant, to make the cinnamon appear to be of a higher quality. This is food fraud.
The retailer (Dollar Tree) did not know the applesauce they purchased was fraud-affected. The wholesaler/importer that sold the pouches to Dollar Tree did not know either. The applesauce manufacturer did not know the cinnamon was adulterated with lead chromate. The company that sold the cinnamon to the manufacturer (a broker/trader) probably did not know about the adulteration either. Only the company that ground up the cinnamon bark, and added the lead chromate to it knew about the adulteration.
I bet the applesauce manufacturer has a letter of guarantee for that dodgy cinnamon in their files. Not worth the paper it's written on. Hundreds of people were poisoned because the fraud wasn't identified until tens of thousands of units had been sold. Millions of units were recalled.
Don't rely on letters of guarantee! Take the time to learn about food fraud and then start asking yourself which ingredients are the riskiest for your brand and your consumers. ... The Think Tank courses are fine but this (free) course is more succinct and practical. Good luck!