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Protecting the Strained Supply Chain against Intentional Adulteration

With the supply chain disruptions that have come along with the COVID-19 pandemic, it has become both more difficult and more critical to track and manage your global and domestic supply chains. Not only are food safety and quality at risk as alternate suppliers are sought and added, but there is a compounded risk of intentional adulteration, especially that which is economically motivated. In fact, a recent article cited just such an overall warning, stating, “Government officials and researchers are warning world leaders not to lose focus on global security threats as extremist groups and terrorist organizations exploit the coronavirus pandemic to increase their operations.” To help keep your product safe in these challenging times, it is advisable that you be on the alert for red flags and signs that a particular chain of supply you use is under stress. Indications could include such situations as: The ingredient is sourced from an area where the coronavirus incidence is especially high or little managed. You’re seeing a great deal of pricing fluctuation and looseness in particular products/ingredients. A supplier is using a high number of temporary workers who have not undergone sufficient background checks. You are now having to source low-availability ingredients through third- or fourth-party suppliers. Packaging of received goods is questionable; trailers are unclean, not locked, or otherwise suspicious; etc. One of the best ways to mitigate this increased risk of intentional adulteration and manage your supply chain is by having a supplier assessment program that is easy to apply and update. The more complex your program is, the more difficult it will be to assess alternate and temporary suppliers while the pandemic challenges and shortages continue. One way to simplify it is to implement a supply chain tool that focuses on the risks. It should be able to: Be adapted to each supplier – as one size will not fit all. Capture geographic and historical information. Track risks to help keep you informed and enable you to allocate resources to areas of greatest risk. For example, with the coronavirus causing reduced or ceased production in many areas both in the U.S. and abroad, many businesses are needing to implement back-up plans. Having a tool that tracks such risks enables you to quickly react to changes; have a good understanding of a supplier’s strengths and weaknesses; and share tools with them to build their strengths. It also is important to ensure you are maintaining regular communication with all suppliers, and building relationships with new or temporary suppliers, not only to ensure continued trust and detect red flags, but to ensure they keep you informed of potential shortages, areas of risk they may see, etc. Even with temporary and last-minute suppliers, good contracts should be signed with roles and responsibilities assigned, service and food safety requirements detailed, and deliverables and expected performance defined. While we don’t see the supply chain as “broken,” as some have stated, it is strained, and that stress can cause businesses to attempt to cut corners causing ill effects on food safety and quality today or down the road. TAG continues to support all our clients with food safety and regulatory advice, so if you need help to look at new risks in your supply chain, please give us a call to discuss how TAG can provide assistance. About The Acheson Group (TAG) Led by former FDA Associate Commissioner for Foods Dr. David Acheson, TAG is a food safety and public health consulting group that provides guidance and expertise worldwide for companies throughout the food supply chain. With the advent of the COVID-19 pandemic, TAG’s public health and infectious disease expertise has been brought to the forefront to assist food businesses weather the increased challenges of employee protection, food safety, and business continuity. With in-depth industry knowledge combined with real-world experience and advanced virtual technologies, TAG’s team of experts helps companies assess their unique situation, address gaps, and deploy best practices to more effectively mitigate risks, improve operational efficiencies, and protect their brand. www.AchesonGroup.com

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