Integrity Risk Assessment
In light of the horse meat scandal; over the past year, one of the retailer standards has been significantly updated. There is now a requirement for sites to have an integrity risk assessment and the audit system has been adapted to align with this.
Once you ‘get’ integrity, it makes perfect sense, but it requires a very different mind-set to what we’re used to. In this week’s post, I’m going to try to explain what needs to be included in your integrity risk assessment.
INTEGRITY IS SPLIT INTO TWO MAIN PARTS…
A THREAT IS SOMETHING THAT IS CARRIED OUT INTENTIONALLY BY SOMEONE TO CAUSE LOSS OR HARM.
AN ERROR IS SOMETHING THAT IS DONE BY MISTAKE AND IS UNINTENTIONAL.
WHERE DO THEY OCCUR?
It’s really important that you understand where threats and errors occur, as it will reduce the confusion when doing your integrity risk assessment.
Threats happen to the raw materials BEFORE they get to your site. Threats are carried out by others, mainly due to food fraud. Threats may compromise the claims on your finished product pack, or they may cause contamination.
Errors happen inside the factory box, they are things that your site does to the product by mistake, which compromises the claims on pack.
WHAT’S IN AND WHAT’S OUT?
There are a set of rules about what needs to be considered in your integrity risk assessment, with regard to threats and errors. Making sure you only include what’s necessary is key to ensuring that your assessment doesn’t become overbearing and stays focused on the real risks.
Spending time scoping out what threats and errors to include is an important part of your assessment.
WHAT TO ASSESS?
- You need to assess your raw materials one by one for threats and errors.
- You then need to assess each finished product, by claim, for threats and errors.
This may seem like a lot of work and it may seem repetitive at times, but it’s the only way to make sure you don’t miss anything.
ASSESSING RAW MATERIALS – FOR THREATS
List all of your raw materials (including packaging) that are used in the customer’s product. Then assess if there are any known threats or plausible threats associated with each raw material. Where there are, these threats need adding to your list of threats to assess in your threat assessment later. You must also complete supply chain mapping for each raw material with a known threat. (Unless you can’t assure the claim at the back door – see my previous post on supply chain mapping for more information on this.)
ASSESSING RAW MATERIALS – FOR ERRORS
There are a number of things that you need to assess at this stage:
Is the raw material ‘A list’?
Does the GM COP apply to this raw material?
Are there any other similar raw materials on site?
Where any of these answers are ‘yes’, then these are possible errors. There are a number of factors that need to be considered if you answer yes, as this doesn’t necessarily mean that the raw material is instantly ‘at risk’. But basically you need to think about whether there is a risk of the raw material getting mixed up with another similar raw material, which would result in the claim on pack or the retailer brand values not being met.
ASSESSING THE PRODUCT – FOR THREATS
List each product and then, list each claim on pack. Where a claim on pack is assured due to a raw material, there is threat – this threat needs adding to your threat assessment and supply chain mapping will need to be carried out.
ASSESSING THE PRODUCT – FOR ERRORS
Go through the claims for each product again; looking for claims or brand values that could be compromised by errors in the factory box.
Could the process cause an error?
Could mixing up the raw materials cause an error?
Remember it’s not just the claim on pack being compromised that you need to consider, mixing up ‘A list’ ingredients or GM assured ingredients, or other brand values need to be included too.
ONCE YOU’VE DONE THIS, YOU SHOULD HAVE A LIST OF:
- What threats need supply chain mapping.
- What threats need to be included in your assessment (more will be added once you’ve completed your supply chain mapping).
- What errors need to be included in your assessment.