Can TACCP be counterproductive?

Dear All,

I would like to hear your thoughts and experiences on TACCP.

I recently started work for a small family company who import, process and pack liquids (wines, spirits, beers, oils, vinegars), meats and cheeses. 

We do not produce direct for retail and are therefore FSSC not BRC accredited. Our customers however are BRC accredited and do work directly for retailers so they therefore have customer demands regarding the new BRC V7 standard, particularly TACCP and the new section 5.4. This was identified and included as part of my new role in the company and I have completed a TACCP risk assessment.

Anyway... The issue I am having is related to the lack of commercial realism involved in TACCP. We were challenged to go back to source on an item of small volume (the product is extra virgin olive oil, which is higher risk) from a small continental supplier. Due to the low volumes involved the supplier was not identified as being high risk on the TACCP risk assessment.

Previously the requirements have been to show country of origin on the specification to prove provenance and to risk assess your suppliers through supplier approval process, they were small volume so did not get highlighted as being high risk. The supplier has failed to produce the required traceability back to the source and this has caused massive uproar with our customer. . 

This small supplier is now being asked by our customer to conform to a new level of expectation and agree to be audited against it. We must now test ever batch that comes into us (at £300 per go) as the customer requires "confidence" in the product after an unannounced audit last week to our site (£2K per go) and all off the back of the fact that the supplier could not trace the product to source. 

This all adds cost to the business and increases the risk of economic motivated adulteration. Is this not counterproductive to what we are all trying to achieve?

Now I understand the concept that the TACCP is a risk assessment that identifies the highest risk products and that volume is an parameter that should be taken into account, however this has not stopped our customer demanding that we test every batch of incoming goods, audit the site and ask them to provide traceability on this product back to source... In this case the olive. All this for less than 20 ltrs per week!

Not a rant honest, just interested if anyone else sees this as being counterproductive if taken outside of the commercial realism?

Any suggestions on how to manage my customers expectation would also be appreciated (I have tried to explain this to them but they insist that it must be done so that they can regain confidence in the product they are taking)? 

Am I wrong and is TACCP not liked to commercial realism? Is it a fundamental and absolute requirement like food safety? 

Your thoughts please ladies and gents :)

Regards

Duke

Hi

My suggestion would be to change supplier for one that can effect traceability if origin is that important to your customer.

Alternatively, find out who your customer is supplying, Tesco, JS etc and by the small amount you need from that retailer where it states origin on the bottle.  Hard for your customer to deny traceability in that instance if their own customer is making the traceability claim

Regards,

The Director

I would agree with The Director. If a supplier cannot show traceability then they are high risk. Without spending large amounts of money for authenticity analyses, the only way to mitigate the risk is to change suppliers.

When we audit our suppliers, the first thing we ask for is traceability. Anything else is secondary.

Hi,

Is this a vulnerability risk assessment or TACCP? I think people are confusing the two. I've been told by an experienced BRC auditor and trainer that TACCP lies more with the security section of BRC and looks at the risk of  malicious attack to try to damage the business; i.e. the person doing it isn't doing it for financial gain. Where as vulnerability risk assessment looks at the risk of each individual raw material to be adulterated for financial gain i.e. an opportunist businessman looking to make money, not harm anyone.

How are you risk assessing each raw material? I would include risk factors (e.g. economic, history etc.), mitigating factors (e.g. COA, supply chain approval etc) and also the impact to the business (e.g. no impact, loss of business etc.). You can take the mitigating factor score from the risk factor score and multiply by the impact score to achieve the overall score for that raw material. This then shows accurately whether the raw material is low, medium or high risk. You can then have an action plan e.g. to audit suppliers, to introduce COA to prove authenticity which would lower the score.

You shouldn't just score a raw material low risk because it's low volume. You should take into account lots of factors like I've mentioned. I think olive oil would score high for risk factors because there's history of adulteration (apparently there aren't even enough olive trees to produce the amount of olive oil that's sold!), it's a liquid, there's an economic incentive, the adulteration is not likely to be detected. For mitigating factors, if the supply chain has robust approval to a GFSI recognised scheme, you carry out routine testing and you have certificate of analysis showing authenticity for every batch then this would score high and would reduce the overall risk rating.

As for the traceability, version 7 of BRC states that if a supplier has been approved on the basis of a questionnaire only, not an audit, then the traceability system should be tested on first approval and every 3 years. If the traceability is unsuccessful, this can form part of the raw material risk assessment and could lead to an audit of the supplier. I would recommend that you work with the supplier and raise non-conformances and give them a timescale to work towards. If the supplier is being difficult, then audit them. If there are concerns during the audit, raise them with the supplier. If the supplier does not improve then consider another supplier. If you have an action plan in place, I'm sure your customers would be happy that you are working towards a solution.