Product Authenticity Vulnerability Assessment

Purpose: COMPANY will have processes in place to mitigate the possibility that raw materials
are adulterated or substituted for.

Scope: This policy covers all raw materials used by COMPANY.

Responsibilities: QA Manager is responsible for the development of this policy. Purchasing

Manager and QA Manager are responsible for completing a vulnerability assessment of all raw
materials and for monitoring information that may suggest a threat of adulteration or
substitution to raw materials used by COMPANY.

Procedure:

A. The Purchasing Manager and QA Manager will utilize resources that provide
information about historical and new risks to authenticity of raw materials. These
resources include:
1. USPC Food Fraud Database
2. Food Standards Agency Food Fraud Database

B. The Purchasing Manager and the QA Manager will conduct a vulnerability

assessment of all raw materials purchased by COMPANY.
1. The resources listed above will be utilized to determine:
a. Historical evidence of adulteration or substitution.

2. The Purchasing Manager and the QA Manager will then consider the following
points to determine the Likelihood of Occurrence of adulteration or substitution.
a. Economic factors that may make adulteration or substitution more attractive
b. Country of origin that may contribute to the likelihood of adulteration or
substitution.
c. Complexity of supply chain that may contribute to the likelihood of
adulteration or substitution.
d. Ease of access to materials in the supply chain.
e. The nature of the material.
f. The cost of materials.

3. The Purchasing Manager and the QA Manager will then consider the following
points to determine the Likelihood of Detection of adulteration or substitution:
a. Supply Chain Confidence
b. Supplier Relationship
c. Supplier History
d. Availability of replacement ingredients
e. Current ingredient testing methods
f. Existing controls within the supply chain and at the facility level

4. The resulting vulnerability assessment will calculate an Overall Ingredient Risk for
adulteration or substitution.

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 a. An Overall Ingredient Risk under 50 will require no additional assurance or
testing processes
b. An Overall Ingredient Risk of 50 or above will require additional checks or
testing procedures be put in place to reduce the risk of adulteration or
substitution.

5. The Purchasing Manager and the QA Manager will review the vulnerability
assessment on a regular basis, taking into account developing threats. The
vulnerability assessment will be formally reviewed annually.

Program Verification:

A. Consumer/Customer Complaints
B. Third party audit

Management Review:

A. This program/policy and all controlled documents that are part of the Food Safety and
Quality Management system will be reviewed at least annually as part of the Internal
Audit Program.

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