detecting food fraud - abcfoodlaw.co.uk
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Detecting Food Fraud
A webinar presented by:
Dr Andy Bowles
Attendee Notes
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Detecting Food Fraud
Dr Andy Bowles
Introduction
Four webinars Introduction to food fraud Preventing food fraud Detecting food fraud Investigating food fraud
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This webinar will consider
Introduction
Scope of audit
Audit techniques
Food sampling
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Detecting food fraud
Introduction
Scope of audit
Audit techniques
Food sampling
Detecting food fraud Detection measures by:
Food businesses Food authorities Government agencies
Main detection tools Audit
Forensic/data audit Physical audit
Sampling Analysis Labelling
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Examples of food fraudKnowledge Centre for Food Fraud and Quality
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Whistleblowing
Public Interest Disclosure Act 1998 Protects whistleblowers Act applies in England, Wales and Scotland
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Reporting
Food Standards Agency Serious/Non-localised incident
National Crime Unit Dishonest activity relating to food, drink or animal
feed
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National Crime Unit
Established December 2014 Elliott Review
“to give greater focus to enforcement against food fraud ingovernment by analysing intelligence, initiatinginvestigations and liaising with other criminal and regulatoryenforcement agencies”
Investigative and prevention functions 2018 Full operating capability by April 2020,
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Example of food fraud “ABC Ltd” buys meat for pet food production
from approved supplier “XYZ Ltd” Purchase decision made by production manager No instruction or supervision Trained butcher Examined meat on arrival, Some declared fit for human consumption Used as ingredient in meat pies
Residual used in pet food
Driver for decision – reduction in waste/rework
Example of food fraud “DEF Ltd” is a manufacturer of enrobed fish
products and purchases frozen fish from “GHILtd” a food broker. Purchase decisions made by DEF Ltd Provided with specification Buys in good faith from range of suppliers
Frozen fish delivered directly to GHI Ltd from port Imported from Vietnam No evidence of lawful import DEF Ltd not aware what’s required
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Example of food fraud
“F Ltd” has agreed to supply “G Ltd” withpremium product at below market cost. Deal negotiated by sales director Needed to boost monthly sales figures
Purchasing manager Tasked with purchase of raw materials forced to buy from unapproved suppliers
Production manager Required to keep waste costs down Forced to use rework
Detecting food fraud
Introduction
Scope of audit
Audit techniques
Food sampling
Examples of food fraudKnowledge Centre for Food Fraud and Quality
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Food chain analysis
Application of risk assessment principles
Useful to focus scope of audit. target resources
5 step process
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Food chain analysis
Step 1: Identification of vulnerabilities Step 2: Identification of steps in supply/production Step 3: Analysis of supply chain Step 4: Devise monitoring/surveillance strategy Step 5: Implement strategy
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Food chain analysisStep 1: Identification of vulnerabilities Intelligence Databases Sampling Complaints Food alerts
Risk assessment Likelihood/severity Risk/reward
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Step 2: Identification of steps in supply chain
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ARetail
CRetail
GImporter
DManufacturer
BRetail
EColdstore
FCash’n;carry H
Distributor
Step 2: Identification of steps in production
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Goods in
Despatch
StoreStore
store
Process
Production Rework
WastePurchase
Sales
Step 3: Analyse flow charts
Consider What anti-fraud measures exist Verification audit Risk assessment of raw materials Training/supervision Sampling Marking
Identify vulnerabilities Risk assess vulnerabilities Likelihood/severity Consider drivers
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Identification of vulnerabilities
Formalities: Supplier contracts, Specifications, Purchase & delivery, Accounting arrangements etc
Identification of vulnerabilities
Responsibilities Clearly stated? Clearly understood? Evidence of activities outside of responsibilities? Delegated to third parties Use of brokers Substitutions
Identification of vulnerabilities
Own checks: HACCP Threat Assessment Critical Control Point (TACCP) Quality systems Raw material risk assessments
Third party audits Scope Limitations Credibility
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Identification of vulnerabilities
Certainty: of supply chain Use of brokers and other intermediaries
goods received Adequacy of documentation Authenticity of documentation
goods supplied
Identification of vulnerabilities
Rework and waste control Rework and waste Risk assessed Managed Evidenced
Step 4: Monitoring/surveillance
Consider targeted Forensic audits Sampling
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Step 5: Implement strategy
Consider Joint working Reporting
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Detecting food fraud
Introduction
Scope of audit
Audit techniques
Food sampling
Forensic audit
Process audit follows process documents
Forensic audit follows Commercial documents Money People Decision making Responsibilities
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Commercial documents
Documents Contracts Supply/supplier contracts Employment
Human resources Recruitment/disciplinary/training
Process documents Financial transactions
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Money
How are financial transactions managed? How are they evidenced?
Decision making
Who selects suppliers? Who makes purchase decisions? Who makes recipe and specification decisions? Who decides: Purchase cost Sales price
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Responsibilities
Who audits/approves suppliers? Who orders food/materials? Who receives goods? Who is responsible for sales? Who is responsible for despatch?
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Procurement Who decides to buy what from whom? Who decides to supply what to whom? How are negotiations handled? Purchases Sales
How are orders placed, by whom? How are goods delivered/received, by whom? How are contingencies managed?
Mass Balance
Mass balance reconciliation of the amount of incoming raw
material against the amount used in the resultingfinished products.
Takes account of: Waste Rework
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Source: BRC
Detecting food fraud
Introduction
Scope of audit
Audit techniques
Food sampling
Examples of food fraudKnowledge Centre for Food Fraud and Quality
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Applicability of analytical testingSource IFST
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Application of analytical techniquesRef: IFST
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Summary
Introduction
Scope of audit
Audit techniques
Food sampling
Dr Andy Bowles
andy.bowles@abcfoodlaw.co.uk
www.abcfoodlaw.co.uk@abcfoodlaw
01603 319863
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