Top tips for your product integrity risk assessments
It’s now over 2½ years since Kassy and I wrote our book “Assessing Error Vulnerability for Food Integrity’ and almost 2 years since we began delivering integrity training courses for M&S, along side our own raw material vulnerability (VACCP & TACCP) courses for a wider audience (and yes it does make me feel old!!)
What learnings can we pass on to help you?
Well, I think the industry has made a significant amount of progress and we shouldn’t lose sight of that, even though at times audit results may not reflect the effort invested. Are we pushing in the right direction and are the efforts invested adding value? I certainly think so. Have we ever looked in as much detail at our supply chains or understood all the touch points our raw materials are exposed to before they reach our intake bay and enter our products?
Struggling to obtain information to map your supply chain?
This is still one of the greatest challenges, obtaining the information required to map the supply chain and document the chain of custody – much easier said than done! However, this increased dialogue and understanding is hopefully setting the scene for more joined up thinking and communication along our supply chains, which has to be a positive step.
Can you robustly prove your claims on-pack?
From an on-site ‘factory box’ point of view, the increasing requirement to understand, protect and be able to robustly prove the claims we make on pack is encouraging teams to look at their existing systems through a ‘new lens.’ The aim is to challenge how robust our existing systems are in achieving integrity and segregation, not to reinvent the wheel or introduce knee-jerk controls that aren’t firmly based on risk. The aim of the segregation risk assessment is to identify integrity risks that will not be controlled by existing systems; issues such as allergen claims, often score lower due to the amount of established monitoring around these. Its often the provenance issues, where its harder to detect errors and easier for them to slip through the net, where the risk assessments points our focus to.
Integrity controls will continue to grow
There’s little doubt that the requirement for integrity controls throughout the end-to-end supply chain will continue to grow and become part of the norm as they become increasingly enshrined into retailer and 3rd party standards. There’s still work to be done on establishing sensible and universal terminology, with inaccurate acronyms such as VACCP and TACCP not helping much. Although BRC v8 does not propose changes to section 5.4 Product authenticity, claims and chain of custody, we are seeing increased requirements around the risk assessment for site security and deliberate contamination. The introduction of the term ‘food defence’ has increased this focus.
How can we help with your Integrity Risk Assessments
The 2nd edition of our threat risk assessment, which is hot off the press, explains practical and simplistic risk assessment methodology for both on-site and raw material supply chain threat assessments. We have now reviewed our existing Raw Material Vulnerability course to now cover both raw material and on-site threats, this course is now ‘Food defence: Assessing raw material & on-site threats (VACCP & TACCP)’. We can also deliver this for you in-house. If you’ve already completed your raw material vulnerability assessment and are just looking for help with your food defence site security risk assessment we also offer a one-day in-house course.
Here’s the top tips I’ve learnt on my integrity journey, I hope you find them useful:
1. Tell your story
There is a range of methodologies that can be used for assessing threats, both in the supply chain and on-site, therefore its vital to explain what methodology you have utilised and why. Remember, there’s no widely accepted international methodology like we have with Codex for HACCP so you need to explain your approach. When writing your integrity / VACCP / TACCP procedure imagine you are sitting in front of the auditor – how would you explain your decisions? The more of this you get down on paper the more robust and future proofed your system will be.
2. Be clear about your claims
Decide, within your product range, what is and isn’t a claim. There won’t ever be a definitive list (even though we’ve been asked for one many times!) so spell out in your procedure what is and isn’t a claim for you and why.
3. Chains of custody
Put the effort into understanding and mapping your raw material supply chains. Work with your suppliers to do this and be persistent – we are driving a lot of change in to supply chains and it won’t happen overnight but it’s a really valuable direction of travel.
4. Keep it risk based
For on-site segregation you already know where your more vulnerable points are, such as WIP or rework. Go out and look at the process, where are the risk points, how robust are your existing systems and what evidence do you have for this?
5. Team approach
Don’t let this be just a technical thing, it’s too big and requires buy in from many departments. The input of procurement, development and goods-in teams is vital for assessing and detecting threats in the supply chain. Controlling on-site segregation requires a factory-based team with a significant input from goods-in, operations, engineering, development and more.
6. Effective verification
You will already be doing many routine verification activities, such as internal hygiene and GMP audits, that already contribute to verifying integrity so use this information rather than repeating it. Traceability and mass balance exercises are now well established but not always successful! Practice makes perfect here, and again involving others so they understand the consequences of missing batch codes or inaccurate weights is key.