8 replies to this topic

[Martinblue]

Hi all,

 

As per BRC V8 for HACCP apart from Microbiological, Physical, Chemical and Allergen;  hazards related to Fraud and Malicious Contamination must be considered.

 

I am planning to cover Fraud and Malicious Contamination under TACCP . In other words don't want to touch our HACCP plan/Hazard Analysis.

 

Would it be acceptable by BRC auditor or above must be incorporated in HACCP?

 

Please share your expertise.

 

Thanks

 

Martin

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Edited by Martinblue, 10 April 2019 - 07:01 PM.

[Charles.C]

Fraud is VACCP, not TACCP.

 

These requirements originated in BRC7 already ? Many examples of responses exist on the Forum.

[The Food Scientist]

Fraud is one thing (VACCP) & Malicious contamination or Food Defense & Secuirty is another (TACCP). And I believe you may separate them from your HACCP. 

[Jpainter]

I recently completed a combined TACCP and VACCP plan. I originally planned on trying to work these into my HACCP plan, but I found it was much easier when the two were separated. From my experience, you should be fine keeping the two separate. Most auditing bodies don't care too much about format, as long as everything required is covered in an understandable manner. 

[mgourley]

Keep them separate.

Under FSMA here in the US I am required to have Food Safety Plans and a Food Defense Plan that includes intentional adulteration.

There is no requirement for a process flow diagram for the Food Safety Plan, but there is for the Food Defense Plan, which I find strange. 

In practicality, the two things serve different purposes, so combining the two, IMO, weakens both.

 

Marshall



 

[pHruit]

It is a bit irritating that BRC has decided to add direct references to both fraud and malicious contamination into clause 2.7.1, in addition to the specific TACCP/food defence requirement already covered in detail in 4.2 and the VACCP/fraud ones in 5.4.

It's more annoying still that they've done so without providing any comment in the guide to changes ("typical types of hazard have been added for clarity" is, ironically, not especially clear...) or in the interpretation guide.

We've taken the same approach that you're considering - the hazard analysis will be expanded to note the potential for e.g. receipt of material that's been tampered with, and simply referencing that this is covered in the prerequisite program via the TACCP plan. Obviously this is an existing risk that has already been considered in the TACCP plan that we've had in place for several years, but I think there is perhaps some merit to making it absolutely clear, as audits are often that much easier if you can spoon-feed the information to the auditor in the exact form that they're expecting it

[Charles.C]

It is  equally ridiculous that the section heading still claims an equivalence to Codex Haccp !

[Charles.C]

It is a bit irritating that BRC has decided to add direct references to both fraud and malicious contamination into clause 2.7.1, in addition to the specific TACCP/food defence requirement already covered in detail in 4.2 and the VACCP/fraud ones in 5.4.

It's more annoying still that they've done so without providing any comment in the guide to changes ("typical types of hazard have been added for clarity" is, ironically, not especially clear...) or in the interpretation guide.

We've taken the same approach that you're considering - the hazard analysis will be expanded to note the potential for e.g. receipt of material that's been tampered with, and simply referencing that this is covered in the prerequisite program via the TACCP plan. Obviously this is an existing risk that has already been considered in the TACCP plan that we've had in place for several years, but I think there is perhaps some merit to making it absolutely clear, as audits are often that much easier if you can spoon-feed the information to the auditor in the exact form that they're expecting it

 

Not to forget the "fraud" in 3.5.1.1.

 

It is  IMO also equally ridiculous that the section heading still claims an equivalence to Codex Haccp !

[pHruit]

Indeed, Charles.

Really feels like they need to start afresh for Issue 9 - gradual staged evolution is all very well, but all of these newer requirements are stuck incongruously in various parts of the standard. A nice clear re-write would improve intelligibility quite considerably. I'll start holding my breath...