The difference between the food protection plan from fraud and the food protection plan from deliberate threats and sabotage according to the Saudi Food and Drug Authority regulations

Starting on March 31, 2023, the executive regulations for protecting food from deliberate risks in the Kingdom of Saudi Arabia will come into force.

But sometimes we hear about food fraud and the so-called food fraud protection plan. Is it different from defending food? In this article, we will learn about the food protection plan from food fraud and the difference between it and the food protection plan from deliberate threats and sabotage.

Many companies and countries worldwide have recently suffered from problems with food availability, which has led to an increase in inflation indicators for most commodities in the world. What we must pay attention to here is that the lack of availability of products and fluctuations in their prices affect the possibility of their exposure to fraud, one of the most important topics that food safety and quality management systems have recently become interested in. Food fraud means the fraudulent and deliberate substitution, dilution, or addition to a food substance to achieve financial gains, and operations Fraud poses risks to the health of the consumer, such as the use of toxic or unlicensed materials in this process.

Food fraud, on the one hand, and the threat and deliberate sabotage of food, on the other hand, share the fact that both are intentional processes, but the main difference between them is the purpose of the process. Food fraud aims to gain financial gains, but the threat and deliberate sabotage expose harm to the consumer or the company’s brand.

Analysis of the weaknesses of fraud:

Food fraud protection systems are created and implemented through a vulnerability assessment, the same tool used to create a protection system against threats and deliberate sabotage. The difference here is that the analysis of weaknesses is done using different factors and focuses more on the supplied materials (not limited to raw materials only, but also includes food additives, packaging materials, and everything that can affect the safety and authenticity of the product). These factors are summarized in the following:

• Historical incidents: Here we must consider the incidents in the industry and similar products.

• Economic factors: Fluctuations in product prices and the availability of raw materials may incentivize the fraud process.

• Availability of raw materials: Poor harvests and short seasons (seasonal raw materials) can affect the likelihood of fraud.

• Length and complexity of the supply chain:  the more companies and countries that materials pass through before arriving, the higher the risk of fraud.

• Ease of access to materials: Using locks on trucks or locks and tamper-evident tape on raw material packaging can prevent fraud.

• Nature of raw materials: Luxury products or products that make certain claims (such as organic) are more likely to be fraudulent.

• Physical form: Physical form affects the likelihood of fraud, as fraud is easier to identify in whole materials that have not been cut, chopped, or ground.

• Availability of materials used in fraud: The availability and low cost of these materials can increase the likelihood of fraud, and knowing these materials helps against fraud.

• Emerging events: The potential effects of different news stories should be considered. For example, war news in some areas may not seem directly related to food fraud. However, war can lead to a decrease in the availability of products produced by this country, especially if it is a major producer, which affects their global availability and increases their prices.

Sources of information collection:

A lot of information needs to be collected that may take a lot of time, but we can obtain this information through many free databases on food fraud, such as:

• The European Commission (EC) Rapid Alert System for Food and Feed

• The Trello database – food fraud risk information

• The European Commission’s monthly report on food fraud cases

• News and data from the (European Law Enforcement Agency – Europol) website on food fraud and fraud

Control and control measures:

After collecting and analyzing the previous information, if the assessment indicates that the substance is very vulnerable to fraud, we must take one of the appropriate measures as follows:

1. If we can exclude the substance or find any alternative, then we have completely removed the risk from us.

2. If excluding or replacing the substance is not possible, we need one of the other means, which include:

• Ensuring that traders, warehouses, agents, and brokers are officially registered as operators in the food sector with the official and regulatory authorities in Saudi Arabia.

• Raw material testing: Here we focus on tests that make us sure of the authenticity of the product and can include: Species confirmation testing (such as ELISA or DNA testing) – Radioisotope testing to distinguish geographical or botanical origin – Product characteristics testing – Composition analysis (such as olive oil or honey composition analysis) using HPLC devices or others

• Certificates of Analysis (COAs) from raw material suppliers, but we do not prefer to use them because these certificates may sometimes be forged. If they are used, they must be verified by conducting random analyses to confirm their results. If the supplier does it, the point at which the test is done must be considered (whether the supplier does it directly or after the specified risk point)

• Auditing and reviewing suppliers’ processes including the supplier’s fraud protection system, tracking, and mass balance testing. Including manufacturers, traders, agents, brokers, storage facilities, and distribution services.

• Seals that indicate tampering with incoming raw materials using.

• Moving to a shorter supply chain, such as sourcing local materials instead of imported ones (the longer and more complex the supply chain, the more points of weakness that can allow for fraudulent materials to enter, and the more difficult it is to detect fraud)

• Developing closer relationships with suppliers, such as having companies that work with them for long periods, which increases mutual trust so that potential concerns are reported effectively and managed proactively before they occur

• Changing the country of origin to a lower-risk country

• Changing purchasing policy (such as avoiding auctions where traceability of components is difficult to determine).

Therefore, we note a big difference between the food protection plan from fraud and the food protection plan from threats and deliberate sabotage.

Remember that the Saudi Food Protection Regulations require that each food facility have an individual who supervises and follows up on the activities included in the regulation and holds the following certificates and qualifications:

• Receive the following training (Food Safety Principles – Food Protection Management – Risk Management) from one of the entities accredited by the Saudi Food and Drug Authority
• Hold a scientific degree in one of the following specializations (Food Science, Food Manufacturing, Manufacturing Technology, Production Engineering, Veterinary Medicine, Agricultural Sciences…etc.)

We at Guidance Consulting and Training Company provide training services accredited by the Saudi Food and Drug Authority and consulting services to establish and develop a food protection plan according to the regulation requirements, with step-by-step follow-up of implementation and control procedures.