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Section 5.4 - Vulnerability

TACCP VACCP Threat

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#1 GMO

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Posted 03 July 2017 - 11:33 AM

Hi All,

 

I've lost a member of staff who used to do this stuff and could do with getting some (cheap) TACCP / vulnerability training.  We all get the idea of what we're doing as the retailers have been more useful than BRC if we're honest but we need something ideally to "tick the box".  My team member went on the Campden BRI TACCP course and said it was useless.  If I'm going to pay to listen about the Elliott report and Carver and Shock then I'd rather it's a cheaper online course.

 

Has anyone done one they recommend?

 

Ta.

 


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#2 Jo Deakin

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Posted 03 July 2017 - 01:04 PM

Hi All,

 

I've lost a member of staff who used to do this stuff and could do with getting some (cheap) TACCP / vulnerability training.  We all get the idea of what we're doing as the retailers have been more useful than BRC if we're honest but we need something ideally to "tick the box".  My team member went on the Campden BRI TACCP course and said it was useless.  If I'm going to pay to listen about the Elliott report and Carver and Shock then I'd rather it's a cheaper online course.

 

Has anyone done one they recommend?

 

Ta.

 

AIB On-Line. Worth a look.


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#3 Jo Deakin

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Posted 03 July 2017 - 01:05 PM

AIB On-Line. Worth a look.


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#4 GMO

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Posted 03 July 2017 - 01:22 PM

Thanks but this is in dollars and still costs $199.  Any UK based schemes at all anyone knows about?  The cheapest I've seen is £125 but this is only for a 90 minute online course so my "economically motivated swindle" detector ™ is going off like billy-o! 


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#5 Nikki R

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Posted 12 July 2017 - 10:04 AM

Hi, when my company looked into this all we found were unhelpful courses for a lot of money so we decided not to have "Official" training which the BRC auditors seem quite happy with. A lot of these courses take the VACCP/TACCP route which to us were messy and overly complicated and we never understood the process as you end up with control points which need controlling but lets face it food fraud is not controllable you need to be prepared for when it happens to you.

 

I found a fantastic company called Techni-K who produced a book called Assessing threats & vulnerabilities for food defence by Adele Adams and Kassy Marsh. This book talks you through creating a fool proof risk assessment which ticks all the BRC boxes for issue 7 and we have been told it will hold up in Issue 8 as well. The book was £75 at the time and for around £300 you can buy the pack which has all the procedures and documents in it for you just have to adapt it to your company. This took the stress out completely and I would highly recommend it.


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#6 Scotty

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Posted 12 July 2017 - 01:26 PM

Free Food Fraud excel spreadsheet/ Assessment available from http://www.ssafe-foo...g/our-projects/ with further info via http://www.pwc.com/foodfraud.


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#7 Charles.C

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Posted 12 July 2017 - 02:25 PM

Free Food Fraud excel spreadsheet/ Assessment available from http://www.ssafe-foo...g/our-projects/ with further info via http://www.pwc.com/foodfraud.

 

Hi Scotty,

 

Thks above.

Was previously (~1 year +) reviewed here as being distinctly buggy (in an output sense IIRC), sufficiently  to render it of limited value. Hopefully now less so. Presumably still oriented to Spider diagrams.

 

@ Nikki - Indeed some of their haccp stuff has beeen useful to myself. I recall seeing their "individual" BRC VA approach/layout illustrated some time ago and it looked (to my simple mind) conceptually rather complicated. Maybe has changed since then though.

(I also wonder if the UK/BRC E.Fraud fascination may have diminished recently with, afaik, a  lack of Horsegate headlines ?.)

 

Regardless, thanks for the suggestions. I suspect GMO is attempting a tricky quest if simplicity is a major objective, but always depending on available resources.

 

PS - @ GMO, JFI there is a VA component in the BRC Package available on this site also.


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Kind Regards,

 

Charles.C


#8 GMO

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Posted 12 July 2017 - 09:16 PM

 

(I also wonder if the UK/BRC E.Fraud fascination may have diminished recently with, afaik, a  lack of Horsegate headlines ?.)

 

 

 

Ha ha ha ha ha ha ha ha.... No.  I've had a couple of communications this week from retailers which have increased mapping requirements in my supply chain.  Retailers are (now) acutely aware that their supply chains are vulnerable and it's still high on the agenda in the UK.  The next Horsegate will happen (and already is happening).  It barely made the headlines due to lack of "yuk factor" but fish speciation is a minefield for example.  There is stuff cropping up which applies in some way to us every fortnight or so on my horizon scanning.  People would be naive to think this is going away and should pay far more attention than the lip service the BRC standard gives it.  I am shocked how little knowledge there is out there of just how demanding the retailers are on this stuff in the rest of the supply chain.  We've also been trying to push down the UK legal requirements on Modern Slavery but even in the UK the knowledge and understanding of this is very low.  It will take some people to be properly dealt with by the courts before it's taken seriously enough and there are some companies developing tools which will make systems like Sedex or Valid-IT look like they only scratched the surface.  It's coming people and in detail.  I'd be shocked if the next version of BRC didn't delve more deeply on this because the length and complexity of supply chains and the information people are willing to share is still very poor.  That in itself is enough to create the opportunity and we've already seen recent adulteration of spices (again).  I would not be sitting on my laurels at all.

 

Sorry to go on a rant but what really gets me is when the Horsegate scandal hit, despite it not being the fault of these people, it was the Technical Managers of the manufacturers and retailers who ended up accidentally using the horse meat (because they'd been defrauded in their supply chains) that ended up appearing in front of the parliamentary select committees.  I don't want to be the person sat there thinking "I wish I'd gone into more detail".

 

To be honest, I think I'll stick to the retailer course.  It might not be ideal to be telling other retailers that it's the one I've gone on but it's better than nothing and with the lack of consistency on approach of how you need to achieve the aims of authenticity, threat and vulnerability, I think I'm better waiting.


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#9 Charles.C

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Posted 13 July 2017 - 06:17 AM

Hi GMO,

 

Yes fish species "manipulation" has been well known/discussed by officials  for at least 5 decades. And accelerated with more sophisticated scanning techniques.

 

IIRC, one location until fairly recently only required the ingredient in a seafood mix to be labelled as "White Fish".

 

I deduce you are not very enthusiastic regarding any of the several approaches for BRC-VA Presentations proposed on this Forum. Any particular reason ?

 

I don't know what you are referring  to by "retailer course" ?


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Charles.C


#10 GMO

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Posted 13 July 2017 - 06:42 AM

Hi GMO,

 

Yes fish species "manipulation" has been well known/discussed by officials  for at least 5 decades. And accelerated with more sophisticated scanning techniques.

 

IIRC, one location until fairly recently only required the ingredient in a seafood mix to be labelled as "White Fish".

 

I deduce you are not very enthusiastic regarding any of the several approaches for BRC-VA Presentations proposed on this Forum. Any particular reason ?

 

I don't know what you are referring  to by "retailer course" ?

 

Apologies it was a tough night, my son was ill.

 

Do you mean BRC proposals for v8?  I've not seen any yet but I have to admit to frustration on v7 when the BRC had spent years considering horsegate, then came out with something very vague and wishy washy.  This ended up with no-one having a clue how to implement it as it was possible to comply in so many ways.  As a result, each UK retailer apart from one has now come out with their own ways of doing it.  Each business to business customer has now come out with their own ways of doing it.  The lack of consistency has created a massive workload in the supply chain with us all trying to do something "standard" that we can send to everyone but then those standard documents being rejected because of the different approaches.  There was a chance for BRC to lead in this and they missed it.  It's probably too late now.

What I was meaning by my comment is that unlike in other areas, the BRC are massively behind the curve at least with UK retailers and if you don't supply out of the UK you may not realise this.  UK retailers (with the exception of one who seem quiet) see this as being a very serious problem which could massively impact their reputation and some are extending the requirements to authenticity to account for accidental substitution.

 

My point was, there is no way this is going away whatever the BRC does and if it doesn't lead in this area, it's only going to cause more cost and pain in the supply chain.  I've also found many of the courses which sprung up to help comply with this requirement have been a waste of time but I've not tried any IFSQN have done.  As a result, again, UK retailers have then felt like they need to fill the gap but even then there are weaknesses.  I personally feel the M&S course is brilliant from what I've seen but it is weaker on food defence and security but how can you support your claim of being trained in vulnerability, authenticity and threat assessments when you're being audited by Asda if the course was delivered by M&S?  The alternative is I go on every retailer course of every customer I supply.  So that's about £5k down the drain.

 

My frustration is the lack of overarching body leading in this area to give everyone a clearer idea and I think BRC has a massive chance to be that body as no-one else is doing it.


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#11 Charles.C

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Posted 14 July 2017 - 02:26 AM

Apologies it was a tough night, my son was ill.

 

Do you mean BRC proposals for v8?  I've not seen any yet but I have to admit to frustration on v7 when the BRC had spent years considering horsegate, then came out with something very vague and wishy washy.  This ended up with no-one having a clue how to implement it as it was possible to comply in so many ways.  As a result, each UK retailer apart from one has now come out with their own ways of doing it.  Each business to business customer has now come out with their own ways of doing it.  The lack of consistency has created a massive workload in the supply chain with us all trying to do something "standard" that we can send to everyone but then those standard documents being rejected because of the different approaches.  There was a chance for BRC to lead in this and they missed it.  It's probably too late now.

What I was meaning by my comment is that unlike in other areas, the BRC are massively behind the curve at least with UK retailers and if you don't supply out of the UK you may not realise this.  UK retailers (with the exception of one who seem quiet) see this as being a very serious problem which could massively impact their reputation and some are extending the requirements to authenticity to account for accidental substitution.

 

My point was, there is no way this is going away whatever the BRC does and if it doesn't lead in this area, it's only going to cause more cost and pain in the supply chain.  I've also found many of the courses which sprung up to help comply with this requirement have been a waste of time but I've not tried any IFSQN have done.  As a result, again, UK retailers have then felt like they need to fill the gap but even then there are weaknesses.  I personally feel the M&S course is brilliant from what I've seen but it is weaker on food defence and security but how can you support your claim of being trained in vulnerability, authenticity and threat assessments when you're being audited by Asda if the course was delivered by M&S?  The alternative is I go on every retailer course of every customer I supply.  So that's about £5k down the drain.

 

My frustration is the lack of overarching body leading in this area to give everyone a clearer idea and I think BRC has a massive chance to be that body as no-one else is doing it.

 

Hi GMO,

 

Sorry about the illness, IMEX such events can be nerve-wracking for all parties, particularly the sufferer of course.

 

Thanks for yr very informative Post.

Of course, the Horsegate event was a painful demonstration of how  (legally?) accurate Traceability could (can?) be circumvented in order to assist Economic Fraud so it certainly makes sense to treat it seriously and implement more rigorous control measures. Nonetheless it is debatable (just like Quantity Control ?) whether (some) specifically non-safety Fraud issues should be included in a self-titled FOOD SAFETY STANDARD (IIRC the GFSI-related literature justifies all-inclusion by virtue of the occurrence of documented cases where safety issues were an additional consequence, even if not initially intentioned, eg Melamine). This scope of inclusion inevitably IMO overlaps the BRC Standard also being driven by the UK’s (legal) support for the concept of Due Diligence, plus GFSI’s recent inclusion of  their “Fraud” as (I presume) a benchmarkable characteristic. I am unaware of how common the “Due Diligence” defence is found outside UK but it never seems to be elsewhere mentioned  in this Forum (?) (not criticizing, just speculating).

 

Sadly, I cannot recall ever seeing one of  the “Retailer Courses” for VA you mention being exampled/discussed here previously or on the Net so unable to usefully comment. I would much like to see one.

 

By “proposed on the Forum” I meant the maybe 3-4 BRC-specific templates devised/posted on this forum by members for BRC7. From what I have seen, these range across a spectrum of, conceptually, very simple to the exact opposite. Based on absence of contrary reports on this Forum to any of these methodologies (and others),  BRC seem to have so far been OK with all offered responses. This may have been due to the relative newness of the subject from a BRC7 POV  plus GFSI (and others) have themselves been discussing  as to preferred ways to go forward (apparently now concluded). One obvious current bugbear is the disappearance of, afaik, the most popular database source of historical Fraud data, USP, from the freely accessible scene. IIRC most of the references mentioned in BRC’s own Vulnerability I. Guidelines were of marginal assistance when I last checked.

 

As a (maybe)  interesting difference to BRC7,  SQF have apparently excluded NON-safety related Economic Fraud In their Manufacturing 8 FS Standard. I assume that  the SQF organization are confident that the Standard remains compliant to GFSI.


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Kind Regards,

 

Charles.C






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