One of the main questions I get asked at Food Defence and Product Integrity courses is “how does it all fit together?”
The terminology can be confusing at the best of times! I’m not a fan of the acronyms VACCP and TACCP for a couple of reasons. Firstly, CCPs should be exclusively used to manage food safety and we have spent many years trying to hammer that message home. Specific CCPs may help with food defence by aiding the detection of a deliberate threat such as metal in product and within product integrity, a CCP around thermal processing may help deliver a claim such as ‘slow cooked’. However, in both of these instances the CCP is primarily there food safety. CCPs should not be created to manage anything but food safety. Secondly, the reference to threats and vulnerabilities in the acronyms is also misleading as threats and vulnerabilities must be considered together not separately, the threat being a deliberate act that could cause harm or financial loss, the vulnerability being the level of exposure your business or supply chain has to the treat.
Anyway, off my soap box now and back to how it all fits together, hopefully the graphic will help. (Click to see it in higher resolution!)
Food Defence (VACCP & TACCP)
You will notice that I have used the term ‘food defence’ to span the entire end-to-end supply chain from raw material source to consumer. This makes logical sense to me as the issues we include (food fraud, food sabotage and food terrorism) are all threats i.e., deliberate acts and therefore should sit under the broader heading of food defence. Food defence can be defined as protecting food products, raw materials and processes from threats1. Particular elements may be more pertinent in specific parts of the end-to-end supply chain, such as food fraud in the raw material supply chain, or food sabotage in the factory box, however, for a robust assessment all 3 types of potential threat (food fraud, food sabotage and food terrorism) should be considered across both parts of the end-to-end supply chain.
Food integrity introduces an additional consideration of errors (non-intentional acts), such as labelling errors, which could compromise integrity. The focus of product integrity is to protect the claims made on the finished product and to ensure that what is ‘on pack ‘is also ‘in pack’. There are many segregation and manufacturing errors that could compromise product integrity, but we must also include the potential for deliberate acts too. Therefore, food integrity has a broader scope which encompasses food defence (VACCP & TACCP), in addition to errors, across both parts of the end-to-end supply chain.
How do they fit together?
Therefore, in my opinion, the easiest way to structure this is to have very clearly defined scopes in both your product integrity and food defence policies and procedures, and to document the risk assessment for each element in a separate tab/page on the same document or group of documents. This very simple approach allows for the elements to be easily cross-referenced whilst remaining distinct, which should aid clarity of thought. Even though we are now being asked by the BRC Global Food Standard to include fraud and malicious contamination in our HACCP / food safety plan, this is best done by cross-referencing to our food defence assessment, not by dumping everything into HACCP and diluting the food safety message. This change has been driven by the FDA requirements who see a food safety plan as a set of related documents, not one document as we would.
In conclusion, keep some separation between the different elements of food defence / product integrity but keep them within the same ‘bigger picture frame’ and navigate the links between them.
Do you want to find out more about Food Defence?
We have training courses and also textbooks to help you to create your own risk assessments.
Food Defence: Assessing Raw Materials and On-Site Threats training course
- Open course: £350 + VAT at regional venues or 2 for £600 + VAT – more information
- In-house course: £1,695 + VAT + trainer expenses – more information
Assessing Threat Vulnerability for Food Defence Text Book – Adams & Marsh
Please note, each delegate who attends the training course will receive the textbook during the day.
Assessing Error Vulnerability for Food Integrity Text Book – Adams & Marsh
- Assessing Threat Vulnerability for Food Defence, Adele Adams and Kassy Marsh, 2nd edition