3 replies to this topic

[mohamed ahmed yusuf]

Dears,

 

I have an inquiry about HACCP requirement mentioned in clause 2.7.1, Hazards including Microbiological, chemical, physical and allergen plus Fraud and malicious contamination , my inquiry is about what is the difference between Fraud and malicious contamination mentioned into this clause and the VACCP and TACCP , if i did the TACCP and VACCP plans then that's mean that i covered these requirements? 

 

Thanks for your help, 

[Marloes]

Hi Mohammed,

 

Generally Food Fraud (VACCP) are unlawfull food practices for financial gain. 
Food Defense (TACCP) is about (preventing) unlawfull food practices with malicious intent. 

 

So yes, if you have your VACCP and TACCP you are covered for these requirements.

[Charles.C]

Dears,

 

I have an inquiry about HACCP requirement mentioned in clause 2.7.1, Hazards including Microbiological, chemical, physical and allergen plus Fraud and malicious contamination , my inquiry is about what is the difference between Fraud and malicious contamination mentioned into this clause and the VACCP and TACCP , if i did the TACCP and VACCP plans then that's mean that i covered these requirements? 

 

Thanks for your help, 

Hi M.Yusuf,

 

Also see this BRC-related thread and particularly Post 2 -

 

https://www.ifsqn.co...on/#entry184060

[Tony-C]

Hi mohamed ahmed yusuf,

 

I agree that the duplication can be somewhat confusing. I find it simpler to carry them out separately but also cross-reference in HACCP documentation so:

• fraud (e.g. substitution or deliberate/intentional adulteration) – see VACCP plans and documentation including assessment

• malicious contamination of products – see TACCP plans and documentation including assessment

 

As to the requirements of the BRCGS Global Standard Food Safety:

Section 2.7 List all Potential Hazards Associated with each Process Step, Conduct a Hazard Analysis and Consider any Measures to Control Identified Hazards (Equivalent to Codex Alimentarius Step 6, Principle 1)

2.7.1 The HACCP food safety team shall identify and record all the potential hazards that are reasonably expected to occur at each step in relation to product, process and facilities. This shall include hazards present in raw materials, those introduced during the process or surviving the process steps, and consideration of the following types of hazard:

• microbiological

• physical contamination

• chemical and radiological contamination

• fraud (e.g. substitution or deliberate/intentional adulteration)

• malicious contamination of products

• allergen risks (see section 5.3).

It shall also take account of the preceding and following steps in the process chain.

 

In fact the draft, Issue 9 of the BRCGS Global Standard Food Safety it actually now refers to relevant sections of the standard:

• fraud (e.g. substitution or deliberate/intentional adulteration) (see section 4.2)

• malicious contamination of products (see section 5.4)

 

As per the links posted by Charles there is duplication in the BRCGS Global Standard Food Safety, perhaps to emphasise exactly what is required rather than it being a grey area:

 

3.5 Supplier and Raw Material Approval and Performance Monitoring

3.5.1 Management of Suppliers of Raw Materials and Packaging

3.5.1.1 The company shall undertake a documented risk assessment of each raw material or group of raw materials including primary packaging to identify potential risks to product safety, legality and quality. This shall take into account the potential for:

• allergen contamination

• foreign-body risks

• microbiological contamination

• chemical contamination

• variety or species cross-contamination

• substitution or fraud (see clause 5.4.2)

• any risks associated with raw materials which are subject to legislative control.

Interpretation: Raw material risk assessment

All proposed ingredients and packaging must be subjected to a documented assessment of their inherent risk. This may form part of the HACCP or food safety plan; however, as this is an important starting point for the production of safe food, it needs to be detailed and will be specifically assessed by the auditor.

When considering the risk of non-compliance with legal requirements specific to the product line (e.g. banned substances), it is important to remember that legislative requirements in the country of raw material production may be different from those of the country where the site is located. This is particularly important when importing ingredients.

For example, the company should consider:

• the potential for fraudulent activity in the supply chain; for example, undeclared additions, dilution or substitution of the raw material or a component of it. (This part of the risk assessment may be completed as part of the vulnerability assessment in clause 5.4.2.)

 

4.2 Site Security and Food Defence

4.2.1 The company shall undertake a documented risk assessment (threat assessment) of the potential risks to products from any deliberate attempt to inflict contamination or damage. This threat assessment shall include both internal and external threats.

4.2.2 Where raw materials or products are identified as being at particular risk, the threat assessment plan shall include controls to mitigate these risks.

 

4.9 Chemical and Physical Product Contamination Control

Statement of Intent: Appropriate facilities and procedures shall be in place to control the risk of chemical or physical contamination of product.

Interpretation: The risk of foreign-body and chemical contamination must be minimised through the consideration of potential sources and the implementation of control procedures within the HACCP or food safety plan.

 

4.10 Foreign-Body Detection and Removal Equipment

4.10.1 Selection and Operation of Foreign-Body Detection and Removal Equipment

4.10.1.1 A documented assessment in association with the HACCP study shall be carried out on each production process to identify the potential use of equipment to detect or remove foreign-body contamination.

Interpretation: Documented assessment

The HACCP analysis should be the starting point for implementing an effective foreign-body control programme. Potential hazards and their sources must be identified so that appropriate control procedures can be put in place to minimise the likelihood of product contamination.

 

5.4 Product Authenticity, Claims and Chain Of Custody

Statement of Intent: Systems shall be in place to minimise the risk of purchasing fraudulent or adulterated food raw materials and to ensure that all product descriptions and claims are legal, accurate and verified.

5.4.2 A documented vulnerability assessment shall be carried out on all food raw materials or groups of raw materials to assess the potential risk of adulteration or substitution. This shall take into account:

• historical evidence of substitution or adulteration

• economic factors which may make adulteration or substitution more attractive

• ease of access to raw materials through the supply chain

• sophistication of routine testing to identify adulterants

• the nature of the raw material.

The output from this assessment shall be a documented vulnerability assessment plan.

 

Kind regards,

Tony