How To Guide VACCP TACCP K

How To Guide
VACCP
© 2016 Woolworths Ltd. Authorised External Distribution Issue Date: 06/06/2016 Version Number: 01
COMMERCIAL IN CONFIDENCE
Document : How to Guide: VACCP & TACCP
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Contents
1. Introduction & Objective
2. Terminology
3. Pre Assessment
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4. Vulnerability Assessment
5. Food Fraud Reduction
1. INTRODUCTION & OBJECTIVE
FOOD FRAUD
Customers have an expectation that our products are produced in a safe and legal manner. This has
been traditionally covered by the implementation of HACCP programmes. With the cases of Food Fraud
that have occurred around the world there is a shift away from the focus on risks to the focus on
vulnerabilities.
Food Fraud covers a wide range of incidents that are aimed at the financial gain for those involved, and
could lead to a public health threat.
These include:
● Adulteration (specifically dilution, substitution, concealment or unapproved enhancements)

● Mislabelling
● Grey Market (including diversion, parallel trade, etc.), theft
● Smuggling
● Concealment
● Dilution
● Counterfeiting
Woolworths use the definition for Food Fraud as:
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A collective term encompassing the deliberate and intentional substitution, addition, tampering or
misrepresentation of food, food ingredients or food packaging, labelling, product information or false or
misleading statements made about a product for economic gain that could impact consumer health or
adversely affect the Woolworths brand.
Vulnerability
Vulnerability Assessment and Critical Control Point System (VACCP-Prevention of intentional

adulteration and is economically motivated)
The most common and dangerous threat is from adulteration, but all types of Food Fraud include
vulnerability. Even stolen genuine goods pose a risk since sight is lost of the product as it moves through
the supply chain (e.g the product could have undergone temperature abuse or there is the potential for
fraud opportunities from other other types of action).
A Risk: is something that has occurred frequently before, will occur again and there is enough data to
conduct a statistical assessment.
A Vulnerability: is more a state of being that could lead to an incident and is defined as - Susceptibility or
exposure to a food fraud risk, which is regarded as a gap or deficiency that could place consumer health
at risk if not addressed.
VACCP is applying the HACCP type system specifically to the unique attributes of a food fraud incident.
The move from a Risk based system to Vulnerability is due to the nature of food fraud.
Economically motivated adulteration (EMA)
The motivation of EMA is financial, this may be by passing a cheaper material as a more expensive one
(Canola Oil for Extra Virgin Olive OIl) or using a less expensive ingredient to replace or extend the more
expensive one (Sumac and Olive leaves to bulk out Oregano). The intention of EMA is not to cause illness
or death but that may be the result. This was the case in 2008 when melamine was used to bulk up the
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nitrogen source to fraudulently increase the measured protein content of milk which resulted in more
than 50,000 babies being hospitalised and six deaths after having consumed contaminated baby milk.
EMA is more likely to be effective and therefore present a greater threat to a food business upstream in
the supply chain close to the manufacture of primary ingredients.
EMA may be revealed by audit, for example purchases of ingredients by a supplier which are
unexplained by investigation of recipes, Sudan dyes for example in spice manufacturing or where the
output exceeds the input of base raw material i.e. Minced Beef sold against Bovine meat purchased.
Vulnerability must not be confused with Threat where adulteration of food may be carried out for
ideological aims rather than economical
Threats
Threat Assessment and Critical Control Point System (TACCP-Prevention of intentional adulteration and
is behaviourally or ideologically motivated)
The main generic threats are malicious contamination with toxic materials, sabotage of the supply chain
and misuse of food and drink materials for terrorist or criminal purposes. A successful attack could lead
to disruption of business and undermine brands and can lead to illness and death of consumers.
There are online assessment tools that can be used as a starting point for Vulnerabi;ity assessments
examples can be found at: http://www.ssafe-food.org/ or http://www.pwc.com/foodfraud
Supporting guidance can also be found at
http://www.usp.org/sites/default/files/usp_pdf/EN/fcc/food-fraud-mitigation-guidance.pdf
http://www.food.gov.uk/sites/default/files/pas96-2014-food-drink-protection-guide.pdf
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http://www.brc.org.uk/downloads/Guidance_on_Authenticity_of_Herbs_and_Spices_June_2016.pdf
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2. TERMINOLOGY
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3. PRE ASSESSMENT
Assemble a Vulnerability Assessment Team. This should be multi-disciplinary with as a minimum roles
covering Quality/Technical, Product Development, Procurement, Sales, Security to carry out the
Vulnerability Assessment and implement a Food Fraud management system.
The lifecycle and implementation of a Food Fraud management system is a continuous process it begins
with an evaluation step to highlight food ingredient fraud vulnerabilities, followed by design of a control
strategy and implementation of this strategy. The system should be reviewed periodically or as changes
occur that may impact the vulnerabilities (e.g. a new adulterant is identified, there are changes in the
supply chain or tolerance for economic vulnerabilities change).
Decide the Scope of the assessment include whether a pre-screening exercise should be carried out
3.1 Pre-screening
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● One method is to evaluate each ingredient. Ingredients found to be the most vulnerable in this
pre-screening evaluation could then be more carefully evaluated by the supplier by carrying out
the complete assessment in the guide.
● Another approach is to group ingredients by class (e.g. oils, spices, dairy ingredients) and
evaluating them. Ingredient classes found to be the most vulnerable in this pre-screening
evaluation would then be more carefully evaluated ingredient-by-ingredient.
● A third approach is to prioritize ingredients sourced from countries or regions with histories of
food fraud activity.
● Alternatively is the use of other tools or factors as a pre-screen that are aimed at identifying
ingredients most likely to be adulterated.
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3.2 Product Flow
1. Document the Flow Diagram of the complete study, as defined in the scope.
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2. Carry out a Vulnerability assessment by assessing the Raw Materials, Direct Food Contact
Packaging and their associated supply chains for their vulnerability to food fraud activities.
3. Ensure that the appropriate, risk based controls are instigated to minimise the risk of purchasing
fraudulent or adulterated materials.
To enable a thorough assessment there are a number of areas to be considered that may influence the
risk of potential hazards. An information gathering stage is required to ensure all potential hazards or
fraudulent activity is understood.
Information that may be considered includes:
● Historical Incidents.
● Any emerging concerns
● Economic Factors/Price Fluctuations
● Country/Area of Origin
● Complexity and length of the Supply Chain
● Storage and distribution facilities and location
● Material Value and Market Size
● Physical form of the material
● Existing control measures
● Availability
● Ease of access to materials
Questions that may be asked include:
● Are low cost substitute materials available?

● Have there been significant material cost increases?
● Has pressure increased on suppliers’ trading margins?
● Do you trust your supplier’ managers and their suppliers’ managers?
● Do suppliers think that you monitor their operations and analyse their products?
● Do storage containers have tamper evident seals?
● Is access to product restricted to those with a business requirement only?
● Which suppliers are not routinely audited?
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● Are food safety audits rigorous and up to date?
● Are you supplied through remote, obscure chains?
● Are major materials becoming less available (e.g. through crop failure) or alternatives plentiful
(e.g. through over production)?
● Have there been unexpected increase or decreases in demand?
● How do suppliers dispose of excessive amounts of waste material?
● Are you aware of shortcuts to the process which could affect you?
● Are accreditation records, C of A or C of C reports independant?
The following provides some explanation of the vulnerability category descriptors for the Likelihood of
Occurrence . These should be considered a general guideline for categorising vulnerabilities for this
factor and should be tailored to your business practices and re-evaluated on a regular basis. While not
explicitly stated in the descriptions, the vulnerability of the supply chain includes consideration of
whether the ingredient is a single raw material or an ingredient that is processed by more than one
entity and is composed of multiple components.
4. VULNERABILITY ASSESSMENT
4.1 Supply Chain
• Low: Firm vertically integrated—The ingredient is not sourced from third parties but is sourced directly
from another part of the food-producing firm.
❏ In the case of agricultural ingredients, this means that the firm produces the raw agricultural
product that is used as the ingredient.
❏ For example, the firm grows the peppers, and produces the paprika that is then used as the
ingredient in a product.
❏ Or, all juice is produced from fruit from company-owned farms.
❏ Assuming that policies regarding ingredient quality are uniform throughout the firm, this would
present the least vulnerability for ingredient fraud.
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❏ However, while this illustrates the scenario of least vulnerability, policies backed by internal
audits need to be in place to ensure that all parts of the organization are acting ethically.
• Medium-Low: Supplier vertically integrated—The ingredient is sourced from a known, trusted supplier
who produces the raw agricultural product that is the starting pointing for the ingredient.
❏ Using the example described above, the supplier owns the fields where the peppers are grown
and owns the facility where the peppers are transformed into paprika.
❏ The ingredient is then sourced directly from the supplier.
❏ In this scenario, the supplier does not buy either raw or processed agricultural product from
another supplier.
❏ Here the vulnerability is limited by knowledge of the supplier and trust that is verified by audits.
• Medium: Supplier manufactures—The ingredient is sourced directly from a primary supplier who
manufactures the ingredient but buys either raw or processed agricultural products from another party.
❏ Using the example above, the supplier buys peppers from independent farmers but owns the
facility that manufactures the paprika and the ingredient is sourced directly from the supplier.
❏ Here there is limited concern for possible adulteration of the raw agricultural product by parties
unknown to the supplier.
❏ However the onus is on the primary supplier to ensure that his supplier (secondary supplier) has
fraud prevention programs in place that are comparable to the primary supplier's own.
• Medium-High: Upstream supplier manufactures—The ingredient is either composed of a blend of
components each manufactured by a third party, or the ingredient is subject to processing by a third
party manufacturer before final processing by the supplier.
❏ This scenario might describe custom blends of juice concentrates where the supplier produces
the blend from concentrates from different suppliers.
❏ Similarly, it could describe a scenario in which the supplier acts as middle man and blends,
repackages, or otherwise re processes ingredients from other suppliers, for example, a supplier
might supply a spice blend that is composed of paprika along with spices and ingredients from
multiple suppliers.
❏ The degree of vulnerability increases with the number of suppliers involved in the process.
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• High: Open market—This scenario describes the situation where an ingredient is sourced in the open
market and none of the other scenarios described above can be verified as being applicable.
❏ While it is possible that an ingredient could be sourced in the open market from a supplier with
an integrated supply chain, this scenario assumes that a purchase on the open market limits the
buyer's ability to verify that the supply chain is 1) integrated, and 2) that appropriate controls
are in place to prevent fraud.
❏ This does not mean that all ingredients purchased in the open market are vulnerable to fraud; it
means that the buyer has less ability to verify that procedures to prevent fraud are in place.
❏ In summary, the amount of vulnerability presented by the supply chain is related to both the
amount of control over the sourcing of the ingredient by the end user and the amount of
transparency that the end user has with regard to the sourcing practices of suppliers of the
ingredient.
❏ Actual control and oversight are more important than organizational or legal descriptions that
may describe purchasing agreements, but which, do not in practice, reduce vulnerability.
4.2 Audit Strategy
• Low: Robust, onsite, with numerous anti-fraud measures
❏ This category describes a case where a robust and mature onsite audit strategy is in place that
includes numerous anti-fraud measures.
• Medium-Low: Robust, onsite, with limited anti-fraud measures
❏ This category describes a case where a robust and developing onsite audit strategy is in place
that includes a limited number of anti-fraud measures.
• Medium: Immature, onsite, with limited anti-fraud measures
❏ This category describes a case where an onsite audit strategy has been implemented, but is
currently immature and contains limited anti-fraud measures.
• Medium-High: Immature onsite audit strategy with no anti-fraud measures, or strategy with limited
anti-fraud measures in development
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❏ This category describes two potential scenarios; one where an onsite audit strategy with no
anti-fraud has been implemented but is immature; or another scenario where an onsite audit
strategy with limited anti-fraud measures is in development [supplier(s) have been notified and
details regarding relevant audit factors are being assembled].
• High: No onsite audits being used
❏ This category describes a case where no onsite audit strategy is being used nor is one being
developed.
4.3 Supplier Relationship
• Low: Trusted Supplier—This supplier is one with whom the buyer has established a partnership-type
arrangement.
❏ The supplier and ingredient were on-boarded many years ago, and a high degree of confidence
has been established through a long positive business relationship history, high degree of
transparency and/or through testing programs.
❏ There is sharing of key information and expectations, including an understanding of key needs
and controls in the both buyer and supplier processes.
❏ There is an open and responsive sharing of market intelligence and open communication on
what each company is doing to protect its products.
❏ For example, if information is presented to the supplier suggesting that someone may be
adulterating an ingredient from a specific country, the supplier responds that they are aware of
the problem and are not sourcing from that region; that they have a vertically integrated
process which avoids these issues; or that specific testing is occurring to identify any threats.
❏ This helps to assure that issues which arise are inconsequential and can be quickly resolved.
• Medium-Low: Trusted supplier, new ingredient—This category of supplier fulfills all the requirements
of a "Trusted Supplier," with the exception that the buyer only recently began purchasing this particular
ingredient from the supplier.
❏ A high degree of confidence in the supplier has already been established through purchases of
other ingredients but not the one under consideration.
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❏ You have on-boarded the new ingredient and implemented a testing program if required.
• Medium: Established supplier, some relationship—A short history of business with the supplier exists,
the supplier is well respected in their market with a solid reputation, and no significant issues have been
identified through discussions with other customers or public information.
❏ See History of supplier regulatory, quality or safety issues).

❏ The supplier has been on-boarded and a tiered testing program has been implemented.
• Medium-High: Established supplier, no relationship—The supplier is respected in the marketplace, has
a solid reputation, and has been on-boarded; however, a business relationship and history has not yet
been established.
• High: Unestablished supplier, No relationship—This is often a new supplier, with whom the buyer does
not have any history or general industry knowledge of the supplier.
❏ The supplier may be new to a given industry or a startup firm.

❏ Relationship time frames and issue ratings should be developed based on purchaser business
practices and re-evaluated on a regular basis.
❏ On-boarding is a formal protocol for new suppliers and ingredients that typically includes a
thorough background review, risk assessment, and a pre-purchase testing of the ingredient.
❏ This typically extends into a verification testing program for the supplier/product combination.
❏ Testing is often an element in establishing the relationship and confidence in a supplier.
❏ Employment of a tiered testing regime may be warranted. Each lot (batch) would be tested for a
specified period, followed by skip-lot testing with an eventual move to audit testing.
❏ Criteria for moving from individual lot testing to audit testing is directly aligned with "no issue"
findings.
4.4 History of Supplier Regulatory, Quality or Safety Issues
• Low: No known issues
❏ The buyer has no direct knowledge of quality or safety issues on the part of the supplier, and a
review of public records did not identify any.
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❏ Audits indicate very robust food safety and quality control systems that meet or exceed peer
company systems.
• Medium-Low: Few minor issues which were quickly resolved
❏ Very few and/or minor issues that were adequately resolved by the supplier within a reasonable
time frame.
❏ Food safety and quality issues are either relatively infrequent but rapidly and sufficiently
addressed or are very infrequent and aggressively addressed, especially if they pose real public
health or product performance risks.
• Medium: Recurrent issues or issues which were not resolved quickly or adequately
❏ Persistent quality or safety issues or those which were not resolved adequately.
❏ Firms that respond to food safety or quality issues but fail to do so consistently without
additional failures would indicate a basic capability problem that could make the supplier more
susceptible to EMA even if it does not suggest that they would knowingly do so.
• Medium-High: Multiple persistent issues indicating lack of responsiveness to concerns or some
evidence that adequate controls are not in place.
❏ This could include examples where the time to report or correct food safety or quality concerns
compares poorly with the purchasing company's expectations or supplier peer group
performance.
❏ Evidence of not notifying the purchaser when an enforcement action has been taken by a
regulatory authority would also indicate a lack of responsiveness.
• High: Numerous uncorrected/continuing issues or undeniable evidence that the extent of quality or
safety concerns is unacceptable
❏ This would be evidenced by repeated citations for the same basic failure food safety or quality
standards in audits, regulatory agency enforcement actions or repeated rejections for the same
problem.
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❏ A consistent pattern of not notifying the purchaser when an enforcement action has been taken
by a regulatory authority would also indicate an unacceptable lack of control or awareness of its
importance.
❏ This factor has very close ties to the Supplier relationship.
❏ Care should be taken to determine under which factor issues should be classified.
❏ As with the Supplier relationship, issue ratings should be developed based on current business
practices and re-evaluated on a regular basis.
❏ If issues do arise, testing would revert to the lower level and full root cause and resolution
protocols would be required.
❏ The testing plan would include suspect adulterants as well as key standard indicator attributes.
❏ Variance from the norm, as stated in testing frequency, can be a key indicator in helping
substantiate a supplier's status.
4.5 Potential Impacts Assessments
All food ingredients have some potential to be targeted for food fraud, not all represent foods or
ingredients that have a potential to have a substantial impact on public health, an economic impact or
an impact on the regulatory authorities. An assessment of the range of potential impacts is necessary
part of an overall food fraud vulnerability matrix.
• Minor: Low Economic Impact,
❏ Food grade which is known to be safe.

• Some: Moderate Economic Impact.
❏ Food grade with no known risks.

• Significant: High Economic Impact/Low Public Health Impact.
❏ Food grade with known sub population risks, potential operational risk, potential loss of public
confidence in industry sector.
• Major: High Economic Impact/Moderate Public Health Impact.
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❏ Non-food grade with unknown risks, potential target populations affected may be a core food
for a sub-population, potential loss of public confidence industry wide.
• Catastrophic: High Economic Impact/High Public Health Impact.
❏ Non-food grade with known risks, at risk populations, primary/critical sub-population food,
potential loss of confidence in relevant authorities or industry.
The risk assessment can be carried out using a matrix, taking into account the following and taking into
account all the considerations above;
● Likelihood of occurrence - whether an attacker could have access to the product or process?
● Likelihood of detection - whether an attack would be detected before it had any impact?
● Impact/Profitability - whether an attacker would achieve their aims if successful?
4.6 Overall Vulnerability Characterisation
To prioritise the efforts in controlling the potential fraud for a food ingredient it is necessary to consider
the Likelihood of Occurrence against the potential Impact of a food fraud. A highly vulnerable food,
ingredient or item of packaging for which fraud would have no public health impact and is manageable
from an economic impact would represent a benign threat to both the public and the company,
whereas a less vulnerable component if subject to fraud could cause a grave public health and economic
impact would be far more threatening and be of a higher priority.
Whilst every company’s assessment will vary a basic matrix can be used to categorise the overall food
fraud vulnerabilities. After working through each element of the Likelihood and Impact the area of focus
should be sorted into their importance to public health, the company and any other stakeholders in
MATRIX 1 below anything falling into the red zone would be considered the the highest priority whereas
the green zone would be the lowest priority.
Simple Risk Assessment Scoring
Likelihood of Occurrence Score Impact
High Chance 5 Catastrophic

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Medium-High Chance 4 Major
Medium 3 Significant
Medium-Low 2 Some
Low 1 Minor
Likelihood of occurrence could be judged for example over a period of 5 years.

Impact could be considered through death/injury, cost, damage to reputation and/or public and media perceptions of the company due to the consequences of the
fraud.
MATRIX 1
5 Catastrophic Threat A
4 Major
Impact
3 Significant Threat B
2 Some
1 Minor Threat C
Low Medium-Low Medium Medium-High High
1 2 3 4 5
Likelihood of Occurrence
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Threat A Unacceptable risk - New controls required
Threat B Moderate risk - Further risk reduction investigation needed
Threat C Insignificant risk - New controls optional
5. Food Fraud Reduction
On completion of the assessment of the potential for Food Fraud the next step is to develop a reduction
strategy. The thought behind this is to move the vulnerability to an acceptable level with respect to both
food safety as well as economic impacts.
After reviewing the outcome of the assessments there are three possible outcomes;
1. If the result is in the green area - Insignificant risk the documentation of of the assessment may
be all that is required.
2. If the result is in the orange area - Moderate risk then the company needs to consider if the
vulnerabilities are acceptable and if they require a food fraud mitigation process to reduce the
threat to an acceptable level of vulnerability.
3. If the result is in the red are - Unacceptable risk then the company needs to determine how and
where to apply food fraud reduction resource to move the threat to orange and then green.
EXAMPLE ASSESSMENT
Ingredient S is a high value ingredient processed and grown in only one region of the world and the
market price of the of the ingredient has risen twofold during the last two years due to civil unrest and
war in the area.
Ingredient S is being sourced from a new supplier on the open market, the suppliers manufacture has
had historical issues with hygiene from their audit reports.
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Ingredient S has had reported incidents where it has been diluted with lower value components to
enable lower prices being available to specific suppliers.
The manufacturer has no history of investment into QA testing of Ingredient S and has not implemented
an onsite audit strategy for the ingredient.
STEP 1. The Vulnerability Assessment based on Likelihood of Occurrence of Fraud
Factor Low Medium-Low Medium Medium-High High
Controllable Factors Supply Chain X
Audit Strategy X
Supplier Relationship X
History of Supply X
Control Measures X
Testing Frequency X
Uncontrollable Country of Origin X

Factors
Fraud History X
Economic history X
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STEP 2. The Vulnerability Assessment based on the Impact that Fraud would cause
Impact
Minor Some Significant Major Catastrophic
Food Safety Food Grade -Known Safe Food Grade-No Known Food Grade-Known Sub Non-Food/Non-Food Non-Food/Non-Food
risks Population Risks Grade-Unknown Risks Grade-Known Risks
Economic Impact No Significant Economic Operational Cost Risk Company Risk

Impact
Consumption No Focused Consumers Temporarily Focused Low Level Potential Target At Risk Populations
populations
Nutritional Impact No Impact Important Micro-Nutrient Core Food For A Sub- Primary/critical Sub-
Food Population Population Food
Public Confidence Specific Food Specific Commodity Industry Sector Industry Wide Authority & Industry
Impact
Results of the assessments are fed into MATRIX 1 the Mitigation Strategy Plan
The results of the assessments show the potential impacts; the economic impact are potentially
Catastrophic for the company and potential food safety implications are Significant
Step 2. 4 Major
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Impact 3 Significant Threat B Unacceptable Risk
(Low Public - New Controls
Health/High Required
Economic)
2 Some
1 Minor Threat C
1 2 3 4 5
Step 1. Likelihood of Occurrence
Potential changes that could be made based on the findings are:
● The new supplier should be researched to see if there were any warning flags such as other
customer complaints regarding the quality of ingredients, as well as looking into the controls on
ingredient quality that the supplier had.
● Based on any red flags raised during the research there is the potential to return to the previous
supplier if they are trusted or look for a vertically integrated supplier.
● Testing frequency of the ingredient could be increased strategically.
● QA methodology and specifications for the ingredient can be formulated to better characterise
the ingredient.
● The audit strategy can be improved with increased audits of the supplier and the supply chain
introduced.
This can result in an improvement in the vulnerability assessment:
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Factor Low Medium-Low Medium Medium-High High
Controllable Factors Supply Chain X
Audit Strategy X
Supplier Relationship X
History of Supply X
Control Measures X
Testing Frequency X
Uncontrollable Country of Origin X

Factors
Fraud History X
Economic history X
If there is no change to the formulation of the final product, the impact assessment will not change but
the overall assessment would change:
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Step 2. 4 Major
Impact
3 Significant Moderate risk - Threat B

(Low Public Further risk
Health/High reduction
Economic) investigation
needed
2 Some
1 Minor Threat C
1 2 3 4 5
Step 1. Likelihood of Occurrence
All conclusions and actions should be documented.
An ongoing program should be initiated to ensure that no changes to the assumptions made in the
assessment have occurred e.g.:
1. Assessment of fraud history and issues within the country of origin.

2. Review of audits of supplier.
3. Supplier performance against scorecard indicators.
This process of review is a dynamic one as changes can be both beneficial as well as detrimental, the
review should not be a one time activity and the ownership of the process should be documented.
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FOOTNOTE
This is only one way of carrying out a risk assessment there are various others for example:
Priority Risk Number with 3 factors used to give an outcome score: Likelihood of Occurrence x Likelihood
of Detection x Likelihood of Profitability
The type of assessment should be researched and the best format decided by the team carrying out the
assessment.
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1. Introduction & Objective

5. Food Fraud Reduction

1. INTRODUCTION & OBJECTIVE

● Adulteration (specifically dilution, substitution, concealment or unapproved enhancements)

Woolworths use the definition for Food Fraud as:

Vulnerability Assessment and Critical Control Point System (VACCP-Prevention of intentional

Economically motivated adulteration (EMA)

Supporting guidance can also be found at

Information that may be considered includes:

● Are low cost substitute materials available?

4.1 Supply Chain

• Low: Robust, onsite, with numerous anti-fraud measures

❏ See History of supplier regulatory, quality or safety issues).

❏ The supplier may be new to a given industry or a startup firm.

• Low: No known issues

• Minor: Low Economic Impact,

❏ Food grade which is known to be safe.

❏ Food grade with no known risks.

Simple Risk Assessment Scoring

Likelihood of Occurrence Score Impact

High Chance 5 Catastrophic

Likelihood of occurrence could be judged for example over a period of 5 years.

Low Medium-Low Medium Medium-High High

Threat B Moderate risk - Further risk reduction investigation needed

Threat C Insignificant risk - New controls optional

5. Food Fraud Reduction

STEP 1. The Vulnerability Assessment based on Likelihood of Occurrence of Fraud

Factor Low Medium-Low Medium Medium-High High

Controllable Factors Supply Chain X

Uncontrollable Country of Origin X

Minor Some Significant Major Catastrophic

Economic Impact No Significant Economic Operational Cost Risk Company Risk

Low Medium-Low Medium Medium-High High

Step 1. Likelihood of Occurrence

Potential changes that could be made based on the findings are:

Factor Low Medium-Low Medium Medium-High High

Controllable Factors Supply Chain X

Uncontrollable Country of Origin X

3 Significant Moderate risk - Threat B

Low Medium-Low Medium Medium-High High

Step 1. Likelihood of Occurrence

All conclusions and actions should be documented.

1. Assessment of fraud history and issues within the country of origin.

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