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FSMS FFVA and Mitigation Plan SOP

Doc #: Title: Date Issued:


Food Fraud Vulnerability Assessment
and Mitigation Plan Example
Version #: Prepared By: Date Revised:
0.0 YOUR NAME HERE

PLEASE READ THROUGH THE DOCUMENT CAREFULLY, THEN GO BACK AND EDIT THE
DOCUMENT TO MEET YOUR OPERATION’S SPECIFIC SITUATION.

Do not forget to edit the header and footer texts.

This document is for guidance purposes only and in no way seeks to replace any national or
local legislation or be viewed as giving legal advice. Primus Group, Inc. and its subsidiaries
accepts no liability for the contents of this document, nor how an individual chooses to apply this
document.

Food Fraud Vulnerability Assessment and Mitigation Plan Example

Purpose: All types of food fraud can have serious implications for food safety and the health of
consumers. The prevention of food fraud is critical to protect the trust of our consumers and to
maintain fair, sustainable business practices. This plan provides an overview of YOUR
COMPANY food fraud and vulnerability assessment and protection plan based on a food fraud
vulnerability assessment, and mitigation strategies.

Scope: The scope of the plan and activities to mitigate, prevent or understand the risks
associated with food fraud consider the entire company’s activities including incoming materials,
production, outgoing materials, technology transfer and contract activities.

Responsibility: The Food Fraud Mitigation Team is responsible for the vulnerability
assessment process, control plan and its implementation. The Food Fraud Mitigation Team is
supported by the Food Safety Management Team.

Definitions: Vulnerability Assessment: is similar to a conventional risk assessment in that it


considers the likelihood that food fraud will occur, and the consequences should it occur. Using
a Vulnerability/Risk Matrix one determines the overall risk.

TK-SOP-002 R0 Page 1 of 3 Primus Group, Inc. Toolkit


Please edit & personalize texts. FSMS FFVA and Mitigation Plan SOP

Vulnerability/Risk Matrix: A tool used to assess the likelihood of occurrence and


consequences.

High
LIKELIHOOD Medium
Low
Low Medium High
CONSEQUENCES
Key:
High (Significant) Risk, regular
monitoring required
Moderate Risk, occasional
monitoring required
Low Risk

Materials: Food Fraud Vulnerability Assessment Form, historical data, supplier program, etc.

Procedure:
1.0 General
1.1 Establish a Food Fraud Mitigation Team. The Team is composed of people with a wide
range of expertise (e.g. legal, purchasing, production, quality, R&D). External expertise
may be required. The team should be appropriately trained, and training documented.
1.2 Conduct a Food Fraud Vulnerability Assessment (FFVA) using Food Fraud Vulnerability
Assessment Form.
1.3 When conducting the FFVA it is acceptable to group like-materials, i.e. similar
commodities, similar products, similar raw materials/ingredients that have similar supply
chain characteristics. If significant vulnerabilities are identified within a group, a more
detailed analysis may be required. In this case, describe the products that contain the
ingredient or raw material. Address all products, both incoming (raw
materials/ingredients) and finished goods through to the consumer.
1.4 Enter the required information at the top of the form.
1.5 Create a new Food Fraud Vulnerability Assessment Form for each group. List the
materials (commodities, products, raw materials/ingredients). If you need to split a group,
use another form.
1.6 Collect information about the material group and use it to answer the questions on the
form. Know your materials and risks (historical, economic, geographic, emerging issues),
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Please edit & personalize texts. FSMS FFVA and Mitigation Plan SOP

suppliers (grower, packer, broker, etc.), supply chain length and complexity, existing
control measures.
1.7 Food Fraud Vulnerability Assessment Form is intended to be customized to each
operation. Depending on the operation, some questions may not be applicable, and in
some cases questions specific to your operation and materials may need to be added.
Every operation is different.
1.8 Explanations of questions have been given in red under Likelihood of Occurrence. It is
intended that you customize the information in each column based on your specific
operation and materials.
1.9 Begin the assessment by reading each question. Each question is designed to help
identify and describe any risks or vulnerabilities in the supply chain. The best way to
assess vulnerabilities is to “think like a criminal”. Answer each question as Yes, No or Not
Applicable in column 3. Either Yes or No may indicate a potential issue, depending on
how the question is phrased.
1.10 If any vulnerabilities are identified by the response to the question, use column 4
“Likelihood of Occurrence” to identify the potential vulnerabilities or risks, and whether
they are considered to be of “High”, “Medium” or “Low” likelihood. Probability is an
important factor of likelihood of occurrence.
1.11 Indicate the consequences of the identified vulnerability or risk (high, medium or low), in
column 5.
1.12 For example, for Q. 10, “Is the supply chain audited? (1st, 2nd, or 3rd party)?” You would
consider your relationships with suppliers and supplier program. Do you have a supplier
program? How robust is it? What are your supplier agreements? Do you conduct 1st or 2nd
party audits/visits? Do you contract 3rd party audits? Examples in red on the form have
been given as an aid only and are not exhaustive.
1.13 Use column 6 “Comments, Mitigations” to detail what measures are in place to mitigate or
control the identified food fraud vulnerability/risk. Use of N/A (used in column 3) must also
be explained in column 6 “Comments, Mitigations”.
1.14 When defining mitigation measures the potential vulnerabilities identified should be
assessed for their significance using the Vulnerability Matrix (see above). Note, every
vulnerability identified will not automatically be determined to be significant and will not
automatically be required to be addressed by a mitigation measure. It is important to
identify as many vulnerabilities as possible, so they can be assessed.
1.15 Where significant vulnerabilities/risks are identified, develop and document mitigation
strategies. Use the Corrective Action Form to detail actions taken and validation of
effectiveness of measures taken.
1.16 Review the Food Fraud Vulnerability Assessment Form annually, and when any new
information (e.g. emerging issues) requires reviewing the fraud management system.

TK-SOP-002 R0 Page 3 of 3 Primus Group, Inc. Toolkit

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