Week 14 - Raw Material Risk Assessment, Substitution & Adulteration - We've Got SALSA Sussed

Week 14 - RAW MATERIAL RISK ASSESSMENT, SUBSTITUTION AND ADULTERATION

Hi Everyone!

Raw Material Risk Assessment, Substitution & Adulteration

This section, I find, people struggle with. Or don’t know quite where to start with it. I am going to show you how to tackle a simple version of a Raw Material Risk Assessment for Adulteration & Substitution.

SALSA’s definitions of Adulteration & Substitution are:

Adulteration - Reducing the quality of food by including a foreign substance, in order to lower costs or fake a higher quality.

Substitution - Replacing a food or ingredient with another substance that is similar but inferior.

The reason we have to carry out this risk assessment originates from the horse meat scandal. When this incident happened in the food industry, you might remember that it was highly publicised by the media. The food industry responded to this by ensuring food safety standards such as BRC and SALSA incorporated ways to tackle the issue. This was done by incorporating raw material risk assessments for the threats and vulnerabilities of food being adulterated or substituted.

Since the horsemeat scandal, it has become apparent that there are lots of ingredients and products which are at risk from adulteration. Therefore, we need to ensure we have researched all of the raw materials that we are handling, to make sure we have got ours covered.

We will look at how to find information if the raw materials have had a risk of adulteration and substitution associated with them historically. We will look to see if they have any claims associated with them which could make them vulnerable to adulteration and substitution. We will look at the Countries of Origin risks and supply chains for the raw materials to see how lengthy they are, and how many times the ingredient changes hands in transit from the point of manufacture, prior to it arriving with you.

Let’s get started!

What’s coming next…

Supplier & Raw Material Controls

Week 15 – WATER TESTING

Raw Material Risk Assessment – what do you need to show your SALSA auditor?

Supplier & Raw Material Approval Procedure

Raw Material Risk Assessment

 

Supplier & Raw Material Approval Procedure

In the SALSA Standard, there are many elements to Section 1.6 Control of Raw Materials. In the last 2 blogs, we have spoken about the Supplier & Raw Materials Approval Criteria and the Goods Intake Procedure. This week, we need to add the Raw Material Risk Assessment to the procedure. Of course, you can split the procedures out if you wish. However, I always keep the sections and referencing of procedures the same as the SALSA standard. This keeps it simple to follow.

 

Raw Materials Risk Assessment Procedure

For the Raw Material Risk Assessment Procedure, you need to detail how you carry out the risk assessment.

 

Base the procedure on:

1.       How you research – the information sources you use

2.       What you base the criteria on for the research - historical information, claims, supply chain and country of origin.

3.       Where you record the information - the Raw Material Risk Assessment

4.       What you do about controlling the risks - documenting the risks, the control measures and evidence that the control measures have been carried out.

 

Research

There are some preparation stages in the raw material risk assessment. Some research is required for the categories of products and ingredients you use.

 

You can ask your suppliers for information, using your supplier questionnaire, when gathering information initially. However, always carry out research of your own to support this.

 

Claims & History of Adulteration & Substitution

The first things to research are Claims and History of adulteration and substitution.

 

When considering claims, you need to think about the claims which come from the raw materials and which you are stating on your Finished Product pack. If you do not make a claim on the Finished Product pack, then the raw material is not putting your product at risk.

 

1.       Is there a CLAIM on the raw material, which you state on the finished product packaging? Such as:

a.       Free range eggs

b.       Organic

c.       Provenance claims

d.       Made from UK strawberries

e.       Vegan

f.        There are many more claims you may use, but for the purposes of the raw material risk assessment, the claims must come from the raw materials.

 

When researching historical risks associated with your raw materials, there are many portals you can look up. However, I have listed the ones I use the most below. These are the ones I find most useful.

2.       Is there a HISTORY of adulteration or substitution of any of the raw materials? You can research on the following, however there are food fraud portals which you can pay for as well if you wish.

a.       RASFF (Rapid Alert System for Food and Feed)

https://webgate.ec.europa.eu/rasff-window/portal/?event=searchForm#

b.       FSA (Food Standards Agency) food alerts

https://www.food.gov.uk/news-alerts

c.       European Commission Food Fraud Summary. This one has to be my favourite. It provides monthly updates; all of the information is very up to date and relevant.

https://ec.europa.eu/knowledge4policy/food-fraud-quality/food-fraud-summary-june-2020_en

 

If the ingredient does not have either of these risks, then you do not have to consider the supply chain or country of origin, as you have established there are no risk of it being adulterated or substituted.

 

You can also ask for information from your supplier as previously mentioned, but it is important to do your own research, and to continue to keep receiving alerts. This will ensure you always have the knowledge of what is happening in the industry.

 

I use this simple scoring system to add to my Raw Material Risk Assessment

Threats & Vulnerabilities of Substitution & Adulteration
Has the raw material supplied have any history of adulteration or substitution? Y / N	Y = a score of 2 N = a score of 0
Does the raw material have a claim such as organic, free from, or provenance claim? Y / N	Y = a score of 2 N = a score of 0

 

Supply Chain & Country of Origin

If the ingredients do have claims and/or history of adulteration or substitution, then you need to look at your supply chain and country of origin to ascertain whether the place you are getting ingredients from is a high risk country. Also, is there an opportunity in the supply chain for the ingredients to be substituted or adulterated.

 

1.       What is the COUNTRY OF ORIGIN?

Where the ingredient is manufactured in a high-risk country, there is more risk. There is a Food Security Index, ranking all countries, which is very useful to use. https://foodsecurityindex.eiu.com/Index

Or alternatively, I use the simple scoring system below. I add to the previous scores for claims and historical risks on my Raw Material Risk Assessment.

2.       How long is the SUPPLY CHAIN?

A long and complicated supply chain, where the ingredient changes hands many times, provides an opportunity for the ingredients to be adulterated or substituted. It is advisable, to look how many steps from the point of manufacture, to when it arrives at your door, to check if there are any risk points such as repacking. You can ask your supplier for all of this information. Again, I add the score on for further supply chain risks and calculate the overall score for all of the risks I have found. You will see my completed example further on.

 

Threats & Vulnerabilities of Substitution & Adulteration
Detail the manufacturing site country:	UK = a score of 0	Europe= a score of 1
	USA/Canada, Singapore, Australia, New Zealand = a score of 2	Other International = a score of 3
How many steps are in the supply chain back to the place of manufacture? (Please include intermediate agents, wholesalers, storage and distribution steps in the no of steps back)	1 step = a score of 0	2-3 steps = a score of 1
	4-5 steps = a score of 2	Over 5 steps = a score of 3

 

Raw Materials Risk Assessment

When we have carried out research on the raw materials, we need to record it. We also need to define what we believe is a high-risk raw material to our business. Therefore, adding overall scoring to determine this, based upon results, is a great idea.

 

For the example I am using, the score categories I have used are:

High Risk             = a score of 4 - 10

Medium Risk     = a score of 2 - 3

Low Risk              = a score of 0 - 1

 

The risk to your business may differ. You can adjust the scores based on the what you believe the risks to your business are.

 

Below, I have put together a simple Raw Material Risk Assessment table to capture the information and have scored it accordingly.

 

If you find there are no risks, ensure you still add the raw materials to the risk assessment, to show they have also been considered, and you have not missed them.

 

Ingredient Category	Risk				Adulteration & Substitution Score	Control Measure
	Claims	History	Supply Chain	Country of Origin
Spices - Cumin	NA	Adulteration with nuts / nut shells	1. Grown & Ground in India 2. Transported to Turkey 3. Packed in Turkey 4. Transported to UK	India	7	1.     Certificate of Analysis from supplier 2.     Traceability Test once per year 3.     Request suppliers risk assessment and controls for the raw material
Meat - Beef	UK Reared Red Tractor Certified	Horsemeat found used as beef	1. UK Farms 2. UK Slaughter 3. UK Cutting Plant 4. Transported to site	UK	5	1.     Speciation Testing sent from supplier 2.     Traceability Test once per year, back to farm – completed by the supplier 3.     Red Tractor Certificate provided annually
Organic Strawberries	Organic	Non organic strawberries	1. UK Farm 2. Transported to site	UK	4	1.      Organic Certificate provided annually 2.      Product inspection for organic product delivered and paperwork confirmation of organic
Veg Oils	NA	NA	NA	NA	NA	NA
Flour	NA	NA	NA	NA	NA	NA

 

Control Measures

Once you have added all of the detail to your Risk Assessment, and calculated your overall scoring, you will have determined your high-risk raw materials.

 

It is important to add the control measures for all risks you find, those which are medium and low risks too, however the control measures may not be as specific, such as testing.

 

When we are considering the control measures to apply to the risk, we need to provide evidence that the risk has been eliminated, or prevented. This is the documented detail which will protect the business and the consumer.

 

Certificates of Analysis provide information on testing which has been carried out on the raw material to prove that it is free from the risk.

 

Speciation testing is to prove meat is what it says it is.

 

Organic certification is to prove the supplier has been through the organic audit, you need to make sure the raw material they supply you is included within the scope of the audit on the certificate.

 

Traceability Tests provide the information that the ingredient has come from the farm, or manufacturer, packing facility, storage or transport companies that it is supposed to. And that all parties involved are certified to the correct food safety standards.

 

There are many controls. Remember that, if your suppliers are covered by a food safety standard such as BRC or SALSA, they will have had to complete an assessment just like this, so should be very knowledgeable about their raw materials and controls they have put in place.

 

It is a complicated one, but if you follow the simple steps above, then you’ve got this!

 

Have a good week!

 

If you need assistance, please feel free to contact me! On that note, that is the end of this section. Please do not hesitate to ask any questions.

 

Be careful and stay safe!

Ruth

Ruthshawconsultingltd@gmail.com

07732 966 836