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seamie

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Posted 08 April 2016 - 12:57 PM

Hi all,

 

I'm in need of some help here.  We have a BRC audit in the middle of May and I haven't even started our TACCP risk assessment.  I've checked out a few different forums, websites and documents and there doesn't seem to be that much consistency between them. So I need to know the following:

 

  1. Do I just consider the treat to the raw materials when they are in our possession or all the way back the supply chain?
  2. What different categories need to be considered?
  3. Should each category have the same weighted scoring?
  4. Does packaging have to be included in TACCP also?

 

As background, we are a bakery and have about 140 ingredients from 30 different suppliers.  Any advice would be much appreciated.

 

Thanks,

 

S



Charles.C

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Posted 08 April 2016 - 01:16 PM

Hi all,

 

I'm in need of some help here.  We have a BRC audit in the middle of May and I haven't even started our TACCP risk assessment.  I've checked out a few different forums, websites and documents and there doesn't seem to be that much consistency between them. So I need to know the following:

 

  1. Do I just consider the treat to the raw materials when they are in our possession or all the way back the supply chain?
  2. What different categories need to be considered?
  3. Should each category have the same weighted scoring?
  4. Does packaging have to be included in TACCP also?

 

As background, we are a bakery and have about 140 ingredients from 30 different suppliers.  Any advice would be much appreciated.

 

Thanks,

 

S

 

Are you referring to BRC7 section 3.5.1.1 et seq ? (ie 5.4.2)

 

If so this is not TACCP. It is VA(CCP)

Pls clarify.

 

PS - Welcome to the Forum !  :welcome:


Kind Regards,

 

Charles.C


seamie

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Posted 08 April 2016 - 02:09 PM

Hi Charles,

Thanks for the reply. I suppose I was looking at clause 5.4.2 as well as what I was told at a BRC6 to BRC7 gap anaylsis course I was on about 2 months ago. We were told they were 2 stand alone risk assessments and we should check out PAS96:2014 for guidance. So do we need to consider malicious intent as per TACCP or is VACCP all we need to worry about???

Thanks,

S



Charles.C

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Posted 08 April 2016 - 02:39 PM

Hi Charles,

Thanks for the reply. I suppose I was looking at clause 5.4.2 as well as what I was told at a BRC6 to BRC7 gap anaylsis course I was on about 2 months ago. We were told they were 2 stand alone risk assessments and we should check out PAS96:2014 for guidance. So do we need to consider malicious intent as per TACCP or is VACCP all we need to worry about???

Thanks,

S

 

Hi seamie,

 

Thks for feedback.

 

I assume you are referring to 3.5.1.1 also.

 

AFAIK, 5.4.2 is only VA as per the GFSI definition (and see the BRC glosssary = fraud)

 

afaik PAS96 is more focussed on TACCP than VA, I'm unsure why it seems to be frequently recommended for 5.4.2

 

I'm not sure if yr "2 standalone..." comment refers to 3.5.1.1 or ? . (3.5.1.1 does require at least 2 risk assessments, raw material and VA.)

 

i assume the list below refers to VA of 5.4.2

  1. Do I just consider the treat to the raw materials when they are in our possession or all the way back the supply chain? Supply chain + receiving by user
  2. What different categories need to be considered? Minimally the ones stated in the 5.4.2 + others if relevant (see other threads here)
  3. Should each category have the same weighted scoring? Up to you.
  4. Does packaging have to be included in TACCP also? Not for VA.

TACCP is afaik equated to the mention of "food defence" in the BRC7 standard. (see the glossary again).

 

I recommend you have a look at the GFSI explanation of the terminologies. These are afaik followed by BRC -

 

http://foodfraud.msu...sessment-vaccp/

 

There are numerous threads here on sec. 3.5.1.1 and 5.4.2 which offer examples of the risk assessments referred above.

 

As per yr post, for clauses 3.5.1.1/.2 the difference between brc 6/7 mainly, but not totally, relates to the requirement for VA. if you have already certified to BRC6 maybe not so difficult except for the armada of ingredients. Some grouping may be possible.

 

PS - can have a look at these BRC threads (there are many more)  which have a variety of sub-links inside -

 

http://www.ifsqn.com...sment-template/

 

http://www.ifsqn.com...plier-approval/


Kind Regards,

 

Charles.C


mgourley

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Posted 08 April 2016 - 10:52 PM

For simplicity sake (if that is possible)

TACCP = Food Defense

VACCP = Food Fraud/Adulteration for Economic Means

 

Marshall



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Posted 09 April 2016 - 12:04 PM

Treat is as you would your hazard analysis for HACCP Seamie,

 

On your Supplier risk assessment add in a section for substitution or fraud and rate accordingly ( this goes long with the micro, chemical, foreign body, allergen etc... sec: 

 

Then Do a risk assessment on each of  your raw materials:

what are the chances of fraud or substitution?

Is there an economic incentive to substitute?

How easy would it be to substitute in your supply chain?

Is there a way to check for adulterants in your raw materials, is this hard or easy to do?

what is the nature of the raw material?

 

Personally I started with the nature of the raw materials and worked through from there.

 

You'll have to do a search on the interwebnet looking for evidence of substitution or fraud historically for each of your raw materials and then record this evidence.

 

 

 

I'm attaching the document I am using, I got this from someone else ( she knows who she is :-)) and I found it self explanitory

 

I'll be more/ less confident about my approach after the BRC audit in May......

 

which reminds me I need to do salt....

Attached Files


I'm entitled to my opinion, even a stopped clock is right twice a day

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Posted 09 April 2016 - 02:33 PM

Hi All,

 

A major minefield/confusion has developed over the varying interpretation / usage of terms like VACCP, TACCP, Vulnerability, Threat, etc .

For some examples can see these links -

 

http://vwa.co.uk/blo...the-difference/

http://www.foodengin...ity-assessments

http://www.ifsqn.com...demystified-r49

 

afaik, BRC are primarily (but not necessarily exclusively) following GFSI's approach as in the link in Post 4. My suggestion of VA(CCP) was based on this and the BRC Interpretation Guideline (bracket implied that no CCPs are explicitly required).

 

Perhaps, in the context of BRC7 standard,  it is logical to stick  with the terms which are  used/defined  by BRC, eg Vulnerability Assessment (VA), eg as in clause 5.4.2 / BRC Interpretation Guideline and food defense eg as in 1.1.3.

 

VA is defined in the BRC Interpretation Guideline as -

A documented risk assessment designed to identify potential sources of food fraud within the supply chain and to prioritise suitable control measures to minimise the chances of receiving fraudulent or adulterated raw materials

(i.e. to  prevent the adulteration or substitution of raw materials before they arrive at the site),

(“food fraud” is defined in the BRC7 glossary)


Kind Regards,

 

Charles.C


seamie

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Posted 11 April 2016 - 07:56 AM

All,

Thanks for your replies and assistance.

From what I can gather so is that we don't have to do a TACCP as it's not specifically requested for in BRC7. Saves me a bit of work! We have our HUGE spreadsheets already done for supplier and raw material risk assessments so we decided to build a new one for VACCP. I'm happy enough with our VACCP. We just have to get it finished within 4 weeks... It's just a drag trying to get information from some of our suppliers...the usual...

On another note, I'm very disappointed Safefood360 never published a whitepaper on VACCP and TACCP. It would have been helpful and saved a lot of time trolling for info on the net... Anyone here uses it? What's their opinion of the platform and support services?

Thanks,

Seamie.


PS I don't be on forums much so not too familiar with some of the shorthand but, what does AFAIK mean???



mgourley

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Posted 11 April 2016 - 09:38 AM

AFAIK = As Far As I Know

 

Marshall



seamie

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Posted 11 April 2016 - 09:47 AM

Oh! Would never have guessed it.... Thanks!



Charles.C

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Posted 12 April 2016 - 07:04 AM

Hi seamie,

 

In respect to TA(CCP),  i guess some possible "elements" are in Security, sec. 4.2 /  food defence 1.1.3


Kind Regards,

 

Charles.C


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GMO

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Posted 13 April 2016 - 07:51 AM

Do you have access to BRC participate?  There are some good examples of what they're looking for in the guidance document.  If you don't have it, I recommend it because although we got into a right ding dong with our BRC auditor about one clause where the interpretation guideline basically indicated she was wrong, we did manage to avoid a non con because of it and the guidance on the vulnerability assessment stuff was good.

 

Interestingly, one BRC auditor I spoke to (not ours) said they'd been told that "having a go" was the main thing for the first year.  Remember as well that TACCP / VACCP are just proposed tools for the job, they are not BRC requirements per se but just one method you could use.  Remember how long it took for HACCP to be more standardised across industry?  And that was when we had a clear Codex Alimentarius standard!  No-one has decided yet what the standard should be.

 

We found the hardest part was starting but we split ours into two; assessing our raw materials then assessing our process.  We also had two members of staff trained in TACCP at Camden BRI but if I'm honest the feedback was they spent massive amounts of time on site security (important but not the only thing surely) and barely any time on supplier controls which is where most of us have struggled.  I heard of one site who boasted they'd found about 40 potential adulteration risks with milk.  I mean come on... In my view there has to be a sense of pragmatism.  Just like HACCP, on your first draft you will miss stuff.  Don't worry about it and concentrate on getting started.  RASFF website is a good resource for finding historical adulteration risks and you can sign up to their alerts (as well as FSA and FDA).  Pull together a "horizon scanning" log and stick anything on that you see which might be an emerging risk.

 

Honestly the hardest part in much of this is just starting.  Take a deep breath, pull a team together and dive in!



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Charles.C

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Posted 13 April 2016 - 08:48 AM

Hi GMO,

 

I agree, the BRC Guideline document is a remarkable piece of work on VA. As is also USP's  trailblazing document/examples. The latter so far lacks practical implementation guidelines though.

 

I believe a lot of BRC's auditorial difficulties have stemmed from the fact that they were themselves an (unwitting?) pioneer as far as VA is concerned. Forced to include VA in their  FS system by horsemeat, GFSI and due diligence.

 

Campden were perhaps chronologically  "unlucky" with respect to VA in (apparently) their focussing on PAS96  which has relatively little content regarding VA (or EMA) but a lot, as you say, on site security/TACCP. Not IMO an objectionable approach from a FS POV though,  in fact GFSI's interest in economically motivated food fraud is more debatable IMO  albeit defendable based on "consequences", eg Melamine.


Kind Regards,

 

Charles.C


trubertq

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Posted 13 April 2016 - 12:39 PM

The main advice I would give is not to overthink it. You could tie yourself in knots.


I'm entitled to my opinion, even a stopped clock is right twice a day

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Charles.C

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Posted 14 April 2016 - 06:07 AM

The main advice I would give is not to overthink it. You could tie yourself in knots.

 

And hopefully to BRC auditors also.


Kind Regards,

 

Charles.C


trubertq

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Posted 20 April 2016 - 05:47 PM

Like GMO , my BRC site split it in two... suppliers and Process and took it from there. I'll give you all a full run down after the audit in May!


I'm entitled to my opinion, even a stopped clock is right twice a day

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Posted 21 April 2016 - 05:45 AM

Like GMO , my BRC site split it in two... suppliers and Process and took it from there. I'll give you all a full run down after the audit in May!

 

Presumably in a BRC context -

 

"Suppliers" = VA

"Process" = Food Security / Food Defence

 

(slightly OT)

Amazingly it's 3 years since Horsegate.

 

The UK Guru, Prof. Chris Elliott, recently highlighted 6 common(?) food items of current notoriety -

Chorizo, Guacamole, Infant Formula, Oregano, Cocoa, Olive Oil.

 

http://www.theguardi...ks-supermarkets

 

From memory, at least 3 of the above were common knowledge 3 years back.

 

I wonder how much has actually changed ?

 

Or is it all  just another demonstration of -

 

http://www.theguardi...meat-rana-plaza


Kind Regards,

 

Charles.C


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Posted 21 April 2016 - 08:02 AM

Hi, Thanks all again for your replies and assistance. From the wording of BRC7, I do not think the auditor can pull us for not doing an in depth of TACCP. It's just too vaguely mentioned for it to be a requirement. Nevertheless, we have the following in place as per the attached: Raw Material RA (Live Document) Supplier RA (Live Document) VACCP RA (will be a live document) Site Security RA (Reviewed Annually) Obviously, I've only put in the headings for confidentiality purposes but I think we should be ok. The biggest pain in the a## is tryin' to keep them all up to date. If anyone has any neat ideas on how to do that, please share. Thanks, Seamie. Attached File  VACCP, Supplier, Raw Material and Site Security RA.xls   56KB   427 downloads



trubertq

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Posted 21 April 2016 - 08:08 AM

Employ a contractor to do it for you? Where in Ireland are you????? :gleam:


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seamie

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Posted 21 April 2016 - 10:17 AM

I'm afraid contractors aren't an option...budgets, budgets, budgets.... Ours is a shoe string....

I'm in the West. Can't give anymore than that for fear of being sprung!



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Posted 17 August 2020 - 08:35 PM

Hi, Thanks all again for your replies and assistance. From the wording of BRC7, I do not think the auditor can pull us for not doing an in depth of TACCP. It's just too vaguely mentioned for it to be a requirement. Nevertheless, we have the following in place as per the attached: Raw Material RA (Live Document) Supplier RA (Live Document) VACCP RA (will be a live document) Site Security RA (Reviewed Annually) Obviously, I've only put in the headings for confidentiality purposes but I think we should be ok. The biggest pain in the a## is tryin' to keep them all up to date. If anyone has any neat ideas on how to do that, please share. Thanks, Seamie. VACCP, Supplier, Raw Material and Site Security RA.xls



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Posted 17 August 2020 - 10:24 PM

Hi, Thanks all again for your replies and assistance. From the wording of BRC7, I do not think the auditor can pull us for not doing an in depth of TACCP. It's just too vaguely mentioned for it to be a requirement. Nevertheless, we have the following in place as per the attached: Raw Material RA (Live Document) Supplier RA (Live Document) VACCP RA (will be a live document) Site Security RA (Reviewed Annually) Obviously, I've only put in the headings for confidentiality purposes but I think we should be ok. The biggest pain in the a## is tryin' to keep them all up to date. If anyone has any neat ideas on how to do that, please share. Thanks, Seamie. attachicon.gif VACCP, Supplier, Raw Material and Site Security RA.xls

 

Just as a somewhat (4 years) late comment - the above is for TACCP, not VACCP.


Kind Regards,

 

Charles.C




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