We know HACCP, but what on earth is TACCP and VACCP?
Most of us are familiar with HACCP based food safety management systems and know that it means Hazard Analysis Critical Control Points. We are used to the process of looking for potential hazards to our food, determining the risks and controls and identifying those that are critical for food safety. These are then controlled with our safe methods and continuously monitored to ensure that we are producing safe food.
Now there are two new concepts and two new acronyms to understand……..
TACCP – Threat Assessment and Critical Control Points: This is all about food defence and the focus is on food tampering, intentional adulteration or contamination of food.
VACCP – Vulnerability Assessment and Critical Control Points: Here the focus is more on adulteration for financial gain in the supply chain. For example, product substitution or bulking out with a cheaper ingredient, the sale of counterfeit or stolen goods. The horse meat scandal is an example of this type of intentional substitution.
VACCP has recently appeared within the requirements of a number of accreditation standards such as BRC Version 7 and Salsa Version 5. These have been included in the form of raw material vulnerability assessments for food fraud or adulteration. Businesses are required to review the supply chain and raw materials, carry out a risk assessment, identify ‘at risk’ suppliers or products and have appropriate controls in place.
Carrying out a TACCP or VACCP assessment can be approached in a similar way to HACCP, it’s really all about the questions that you ask.
A typical HACCP question might be ‘what could go wrong here that will affect food safety?’. However, a TACCP focussed question might be ‘why would someone interfere with my product’ or ‘how could someone interfere with my product’. Most of the possible issues here will be intentional and are more likely to be more about managing people whether internal or external to your business. Disgruntled employees or an unhappy former employee could be particularly motivated to affect your business.
A VACCP focussed question might be ‘could someone gain financially from interfering with this ingredient/product?’, ‘which of my ingredients are really expensive and could be adulterated?’ These are far more specific questions that lead you to view your business in a different light. Do I really know enough about my suppliers? Is one of my ingredients really expensive and could be adulterated, have I got a specification for it?
Examples of Threats or Vulnerabilities to consider (not an exhaustive list):
- Intentional contamination with chemicals, physical objects such as glass or needles, microbiological agents or allergenic ingredients.
- Counterfeiting foodstuffs, diluting liquid ingredients, mislabelling
- Adulterating raw materials with cheaper ingredients
- Stealing commercially sensitive information such as recipe or process details
- Cybercrime, hacking of IT systems.
Key Controls in TACCP and VACCP plans:
- Supplier Assurance Systems
- Supply chain traceability
- Product specifications and checks
- Personnel Recruitment and Management
- Non-compliance, withdrawal and recall or crisis management systems
- Site security controls
- IT security strategies
The best way to approach either of these assessments is to think like a criminal or a disgruntled employee and ask the kind of questions outlined above. This will enable you identify potential areas of vulnerability or threat. These should then be risk assessed, looking at likelihood and severity or impact. For the highest risk areas either establish controls to reduce the risk of these happening or have contingency plans in place should such an event take place.
The important things to remember is not to panic! It’s just another acronym!