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Vulnerability Assessments Could Affect Food Product Claims

The current challenge of the entire UK food supply chain implementing the new vulnerability assessments and supplier approval management is currently dominating my thoughts, and with good reasons.

There is one potential downside to the implementation of this process that could have a huge impact on our current food supply chain. It may force companies to reduce the claims made on their packaging, in an attempt to reduce supply chain risk, resulting in less diversity and a reduction in the availability of exciting, unusual and exclusive product ranges. Let me explain…

I am a foodie, a farmer’s son who has worked in the food industry all of my career. I am passionate about my food and its provenance claims such as: Aberdeen Angus Steak burgers, Cakes containing Sicilian lemon oil, Muffins containing Belgian chocolate, anything containing British Farm Assured produce and everything containing Irish products.

Yes, as you can see I can be a little conflicted, but the overriding driving force, is to consume products with exclusive provenance wherever possible.

Increased burden of proof to support claims

With BRC 7 and retailer standards, it is now a requirement that wherever you make claims on packaging you also need to implement a full chain of custody and consider verification such as; full traceability and mass balance audits. Failure to do this exposes your business to brand protection risks.

VisionWhoWhatWhyWhen

Onerous implementation of ‘full chain of custody’

In some supply chains, full chain of custody is difficult to implement. Using the examples above; Aberdeen Angus should be easy enough to implement a full chain of custody, but what about the Sicilian lemon oil, and don’t get me going on black pepper…

Mass Balance virtually impossible

A long time ago while working in food manufacturing, I undertook a vast amount of mass balance work in food factories. This was not because I was far ahead of the industry having already predicted today’s challenges. It was simply that the business I worked for were very professional about raw material yields and invested heavily in tracking all raw material usage and wastage, for yield management.

Nevertheless, it took years to get the systems up and running; entailing a massive investment in IT hardware and software; with veritable teams of people completing manual reconciliations. How I wonder, will an auditor who visits a supplier within their supply chain, be able to complete this task in just one or two days?

AuditorinFactory

Caution must prevail

I fear that the above challenges could force suppliers to remove some claims, due to the cost and risk of retaining them being too high. Is this where we should be going as an industry?

Thresholds are essential

Going back to the Aberdeen Angus example above, let’s assume that these burgers are made on the same line as burgers containing Irish beef, for the Irish market containing an Irish Beef claim.

  • Blocks of frozen beef are difficult to differentiate
  • The cost of full line clean downs on all pre-breakers, mincers, mixers, pattie formers etc. is prohibitive.
  • Mass balance exercises indicate that controls are in place but cannot account for every Kg due to process gains and losses

This would lead to an over cautious approach resulting in both claims being removed. I hope this is not the case, but the risk is certainly apparent.

Agreed thresholds for  adventitious cross contamination could be the answer.
What do you think?

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