Assessing Risk And Preventing Food Fraud With A PRN System

By Sam Lewis

Food fraud is an easy term to define and understand: The fraudulent and intentional substitution, dilution, or addition to a product or raw material, or misrepresentation of the product or material, for the purpose of financial gain by either increasing the apparent value of the product or by reducing the cost of its production. While the idea is very easy to understand, it’s not so easy of an obstacle to overcome.

At the 12^th Annual North American Summit on Food Safety, Gordon Hayburn, vice president of food safety and quality at Trophy Foods, discussed his company’s experience in assessing vulnerability to food fraud and the company’s efforts to combat it. Hayburn believes that no food is safe from fraud, but some are more vulnerable than others. Hayburn’s list of vulnerable foods includes: olive oil, fish, milk, grains, honey, maple syrup, coffee, tea, spics, wine, and some fruit juices. “More maple syrup is sold each year than is made each year,” says Hayburn. “The numbers are incapable of lying; people are. So, some of it is not maple syrup. If someone says, I can get you a container of maple syrup for $2.99, they cannot. If something seems too good to be true, it is. That's fake maple syrup.” Hayburn expands on that same idea with olive oil as an example. “Olive oil; the amount of first press, cold, extra-virgin olive oil that's sold completely beats the amount of olives grown,” says Hayburn. “Please don’t be fooled. Use the sum, the entire harvest’s numbers, if it seems too good to be true, it more than likely is.”

To combat food fraud, Hayburn advises collecting good, reliable data about the potential adulteration, mislabeling, and substitutions in your supply chain — not your production site — to conduct your vulnerability assessment. “You need the best information that's available because with correct information, you will make the best decisions.” Hayburn continues, “If your information is flawed, you will only be making the best decision you are capable of. It might be your best decision, but it will still be wrong because your input was inappropriate. Spend time acquiring good data; this is step one of your vulnerability assessment.”

Once you know which ingredients and products are at risk, you can begin grouping similar products, such as types of grain or flour, together as long as they carry the same risks. “There is no single, prescribed method to determine risk,” says Hayburn. “It's completely a personal preference which methods you apply to evaluate your risks. Ultimately, what’s important is that you are addressing genuine reasonably foreseen risks.”

One of these methods of determining risks, of course, is HACCP. However, Trophy Foods took a different approach after seeing a sudden explosion in a trendy food. “Do you remember three or four years ago when pomegranate was the next big thing?” asks Hayburn. “It was ‘the next big thing’ in a matter of weeks or months, so where did all these pomegranates come from? Anyone who knows anything about agriculture knows pomegranate bushes take four to five years before the bush will produce harvestable fruit. I can’t believe these products all contained 100 percent pomegranate because the history of seasonability and harvest availability questions it… as did we at Trophy Foods.” So, Trophy Foods decided to put some values on the likelihood of pomegranates, and other raw materials, of being fraudulent. And with that, Trophy Foods’ Priority Risk Number (PRN) system was born.

The PRN system Hayburn describes categorizes collected risk data into three categories and scores them one through five:

Likelihood Of Occurrence:

1. Very unlikely or none (No evidence of historical or T/R occurrence)
2. Minor (No more than five historical or T/R occurrence)
3. Moderate (More than five, but less than ten historical or T/R occurrence)
4. High (More than 10, but less than 20 historical of T/R occurrence)
5. Very High (More than 20 historical or T/R occurrence)

Detectability:

1. Certain (Very easily detectable, even by visual examination)
2. High (Easily Detectable by sensory evaluation)
3. Possible (Can be detected by simple, inexpensive, laboratory evaluation)
4. Unlikely (Can be detected at most external food testing laboratory, but testing is complex and expensive)
5. Undetectable (While some analysis may exist, the extreme complexity and knowledge required to undertake an examination makes finding the fraud practically impossible)

Profitability:

1. Very Low (No significant profit)
2. Low (Very low margin of profit)
3. Moderate (Moderate margin of profit)
4. High (High margin of profit)
5. Very High (Very high margin of profit

Each of these categories has several subcategories that receive a one through five score. Subcategories include availability of adulterants in likelihood of occurrence, existing supply chain controls in likelihood of detection, and availability/seasonality of an ingredient or product in profitability.

If you were to use this technique, it would be best for you to determine and create your own unique subcategories based on your company’s products and needs. Based on how many subcategories you have, you can then make a scoring system for your vulnerability. Trophy Foods’ PRN has an Overall Risk Rating Scoring of 1-125:

1. 1 – 25 (Very-Low Risk)
2. 26 – 50 (Low Risk)
3. 51 – 75 (Moderate Risk)
4. 76 – 100 (High Risk)
5. 101 – 125 (Very-High Risk)

According to Hayburn, Trophy Foods undertakes a vulnerability assessment of all groups of the company’s raw materials on an annual basis and adjusts its controls accordingly with the updated scores. Depending on PRN scores, implemented controls can include: certificates of analysis from suppliers, testing programs, supply chain audits, tamper evidence seals, and enhanced supplier approval and risk assessment checks.

However, Hayburn understands the need to stay educated on new risks and updating your company’s information and efforts to control them. “New risks happen all the time,” says Hayburn. “I'm, sadly, one of these people who are old enough to remember when we didn't actually know about listeria. New risks and more information are coming out all the time. These changes will stimulate you to do different things. If you have a problem controlling your supply chain, work closer with your suppliers. Rather than having four or five suppliers, go to one that you trust, agree on a price, agree on deliveries, and work together.”

About Gordon Hayburn

Gordon is the vice president of food safety and quality at Trophy Foods. Gordon has worked in the food industry for over thirty years in a range of roles and sectors including: industry, enforcement and academia.

In his current role as Director of Food Safety for Trophy Foods, he is responsible for all of the food safety and quality standards within their manufacturing sites. Gordon is also an experienced auditor for most GFSI Standards, is one of the six worldwide Principal Trainers for the BRC Food Standard (Issue 7), and he is responsible for training many of the BRC’s Approved Trainers in this new version of the Global Standard for Food Safety.

Gordon was also the 2012 recipient of the International Association for Food Protection (IAFP) Harold Barnum Industry Award. This award is “presented to an individual for outstanding service to the public, IAFP and the food industry.” Gordon is also one of the tutors on the University of Lancashire Master’s program in Food Safety Management. He is passionate about food safety and enjoys working with people at all levels and in all sectors of this industry.