detecting food fraud - abcfoodlaw.co.uk

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


Introduction

Scope of audit

Audit techniques

Food sampling


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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


Responsibilities Clearly stated? Clearly understood? Evidence of activities outside of responsibilities? Delegated to third parties Use of brokers Substitutions


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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Certainty: of supply chain Use of brokers and other intermediaries

goods received Adequacy of documentation Authenticity of documentation

goods supplied


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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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


Introduction

Scope of audit

Audit techniques

Food sampling


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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

[email protected]

www.abcfoodlaw.co.uk@abcfoodlaw

01603 319863

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