Applying HACCP to food manufacture

Recent years have seen a growth in popularity of a party game called ‘Chocolate Russian Roulette’ where you could be the unfortunate recipient of the one chocolate bullet in the pack that has enough hot chilli to set your mouth on fire.  Or there is the latest craze of the bizarrely flavoured jelly beans where you could be eating jelly beans tasting like dead fish or stinky socks.  Of course, this is all great fun when the items are safe to eat and, despite the deliberate tampering with what is usually a tasty sweet, it’s all a good joke.

It’s no joke however, when fun and safety is taken out of the equation and food is deliberately tampered with and potentially contaminated for malicious reasons or financial gain.  TACCP (Threat Assessment and Critical Control Points) and VACCP (Vulnerability Assessment and Critical Control Points) are acronyms that are becoming increasingly important in the food industry.

Both TACCP and VACCP are concerned with intentional tampering and potential adulteration of food but with TACCP, threats are considered behaviourally or ideologically motivated and so the emphasis is on food defence and with VACCP, it is considered economically motivated and the focus is therefore food fraud.

As a rule, we can be confident our food is safe but there are some horror stories about behaviourally motivated adulteration of food.  An employee at a store in Grand Rapids, Michigan, was found guilty of mixing insecticide into minced beef because he had a grudge against his supervisor and wanted to get him/her into trouble.  There were over 40 people who suffered ill effects as a result and 1700 pounds of minced beef had to be recalled.  The employee himself suffered nine years in prison and a $12,000 fine.  Aside from individual vendettas, other threats on the increase include terrorism, espionage and even cybercrime.

Similarly, there are just as many stories about economically motivated food tampering.  It was only in 2013 when the horsemeat scandal hit the headlines.  Burgers being sold in Tesco, Asda, Lidl, Aldi and Iceland were found to contain quite high levels of horsemeat and, in some cases, pork and other meats too.  The suppliers were committing food fraud by substituting beef with cheaper meat for economic gain.  Aside from substitution, other vulnerabilities include practices such as dilution, unapproved enhancements and mislabelling.

If you are a food manufacturer or producer, it is imperative that you have in place procedures which will identify potential threats and vulnerabilities and specify methods to counteract them.

The Food Standards Agency suggests four critical questions to ask when considering how to protect and defend food from deliberate and malicious attack:

  1. a) Who might want to attack us?
  2. b) How might they do it?
  3. c) Where are we vulnerable?
  4. d) How can we stop them?

PAS 96:2017 is the Publicly Available Specification which gives comprehensive guidance on TACCP mitigation measures and can be found on the FSA website.

With VACCP, there are any number of factors to consider when protecting your business from food fraud, including things such as how easily accessible materials are, location of business and access to it, country of origin of goods and supply chain to mention a few.  A free tool from SSAFE which was developed with PwC is available to food businesses and will help you assess how robust your company’s current strategy is for prevention of, and protection against, food fraud.

 

Although these threats and vulnerabilities are small at present, it would be wise to assess whether your current policies and procedures are resilient enough to foil any potential attacks on your business.  CaterSafe can assist you in developing TACCP and VACCP mitigation measures so get in touch and we can help!