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This information can be used to develop food safety and quality programs that meet the requirements of modern Regulatory, Customer and Industry Standards:
When considering the development, documentation and implementation of Food Fraud Risk Management within food safety and quality management systems, the following information should be considered to ensure effective outcomes:
Food Fraud Risk Management is by no means a new concept – It has been applied in many different incarnations over time. The term ‘Food Fraud Risk Management’ is used to describe the various methodologies implemented to ensure the food provided to consumers is wholesome, genuine and not unnecessarily tampered with.
Economically Motivated Adulteration is a Food Fraud Risk generally facilitated from within the Food Sector itself, with the intent of increasing profits or lowering cost. This can be done either by intentionally manipulating monetary outcomes of which an otherwise inexpensive material is sold for a higher price or perhaps was an instance where an inexpensive ingredient is used to extend or replace the more expensive one. The primary goal of EMA is to gain financial advantage from selling food products in a way which deceives both customers and consumers, but sometimes it may cause human harm or even death.
Vulnerability Assessment Critical Control Point or VACCP is the systemic management of risk through evaluation of different kinds of vulnerabilities throughout the food supply chain. A vulnerability is a status or scenario that can lead to a food fraud incident. The following steps are often applied as part of the VACCP Methodology (as based upon the HACCP methodology):
The application of VACCP into food production requires that pre-requisite programs for its implementation be documented and applied before the introduction of VACCP plans into the process. VACCP support plans are those that control the status and application of related business activities, often including Procurement, Approved Supplier Management and Production Operations. When implementing a VACCP as part of a Food Safety and Quality Program, the primary step is to assess pre-existing programs as to their adequacy and conformance to requirements, and their documented monitoring effectiveness. These support programs form the basis on which VACCP is integrated, and their adequacy will provide success to the system. If the support programs are not controlled as required, the VACCP Control Measures may not be effective. The importance of such programs cannot be overlooked in the scheme of VACCP planning and implementation, as they provide intrinsic support to all facets of the food safety management system.
A documented Scope and Purpose for the VACCP Plan is necessary to ensure all required products, processes are covered by the associated documentation and management systems:
The HACCP Scope and Purpose Statement is often used to cover VACCP related risk to avoid unnecessary duplication.
The first step in the integration of VACCP into a Food Safety and Quality system is to nominate the team that will oversee the implementation. It is of great importance to include as much knowledge and skill as possible in the team, while also including senior management. The size and scope of the VACCP team will depend on the specific food industry sectors involved and classes of hazards to be addressed of the food business to which the VACCP system is being applied. As well as internal members, external sources, such as those with relevant experience and / or specialist training can be of great benefit to providing relevance in VACCP implementation. Overall, the team should be efficient, appropriate, and well informed in its addressing of all the relevant aspects of VACCP.
The composition of the VACCP requirements that will be addressed by the VACCP team will need to be suitable and appropriate to include operational aspects of the food business, and display confidence in accounting for technologies, equipment and expertise used in processing. The specific knowledge and skills of the individuals in the VACCP team should allow this, providing the composition of the team is adequate. Senior Management should assure that the appropriate product-specific knowledge and expertise is available for the development of an effective VACCP plan. Optimally, this may be accomplished by assembling a multidisciplinary team. Where such expertise is not available on site, expert advice should be obtained from other sources. The scope of the VACCP plan should be identified. The scope should describe which segment of the food chain is involved and the general classes of Vulnerabilities to be addressed.
Teamwork will be the foundation on which any successful Food Safety and Quality Program is based. A designated VACCP Team which is made up of both management and other staff are required to ensure the food safety program policies and procedures are continuously improved. Whilst the program must be managed in its entirety, special emphasis must be put on the assurance that the nominated Vulnerability Control Points are monitored and maintained as per the specifications of the program.
The HACCP Team is often used as the VACCP Team to avoid unnecessary duplication.
The second step in VACCP implementation involves consideration of the food products that are being produced or handled by the food business. Where a service is being provided rather than a product, a similar method can be applied. The information gathered will assist in the identification of vulnerabilities that may be present in either ingredients or materials used in the processing of food. This step should also include references to appropriate legislative and industry guidelines, or scientific validations regarding the documented Product Description and Intended Use. Generic Product Descriptions may be developed for product groups rather than each individual line where applicable.
The HACCP Product Description documentation is often used to avoid unnecessary duplication.
This step allows us to assess whether the product is to be served and consumed immediately, stored or further processed; the expected use of the product by the end consumer. The intended product usage will provide an abundance of information regarding potential vulnerabilities throughout the process flow. Information on intended use is often documented in tabular format with the Product Description.
The HACCP Intended Usage documentation is often used to avoid unnecessary duplication.
The next step is to construct a production process flow diagram using the information gathered above, in conjunction with operational knowledge of the process systems. The production process flow diagram must identify every step that is used to produce the product through the process, from receipt of materials and ingredients to service of the consumer. The diagram need not be complex in its compilation but must involve all processing steps from beginning to end. To assess the validity of the flow diagram it is advantageous to closely follow the process from start to finish by physically following the process. Products may be grouped in the process flow diagram if they are nominated as being suitable to include.
The HACCP Production Process Flow Diagram is often used to avoid unnecessary duplication.
The production process flow diagram must be validated against on-site observation of production during all stages and hours of operation. The pre-conceived flow diagram must be altered if required for its validation into the food safety system. Reconfirmation of the Process Flow Diagram must be undertaken annually as a minimum or at any time where processes, products or inputs change.
The HACCP Production Process Flow Diagram Confirmation is often used to avoid unnecessary duplication.
All Food Fraud Vulnerabilities that may reasonably be expected to occur at each step from primary production, processing, and distribution until the point of consumption. Identified Vulnerabilities must then be analysed as to their potential and significance. This process should also include emerging issues, which may not be historically evident within a particular process or product, but which may be of concern, regarding the Product Description and Intended Use.
The Vulnerability Assessment should consider the following where applicable:
When the hazard analysis has been completed, the VACCP team must then consider what control measures, if any, are applicable for each identified vulnerability. It is acceptable that there may be more than one control measure nominated for a specific vulnerability, and that more than one vulnerability may be controlled by a specified control measure.
The HACCP Hazard Analysis format is often used to capture and ratify Food Fraud Vulnerability risks to avoid unnecessary duplication.
The nomination of a significant Food Fraud Vulnerability should be given consideration for nomination as a Critical Control Point within the VACCP system. This can be determined through application of a CCP Decision tree, commonly based on the Codex CCP Decision Tree. The use of the decision tree should be flexible, allowing for differences in the operational specifics of different production areas. It should be used for guidance while also relying on the intimate operational knowledge available from the VACCP team. Decision tree structures may need to be altered for certain applications where the appropriateness of the critical control point determination is not suitable for verification. Specified training in the use of the decision tree is recommended for appropriate recognition of critical control points. If a hazard has been identified at a step where a control measure is needed, and there is no existing control measure at that step, or any other, the product or process must be modified at that step, or an earlier or later stage to incorporate a control step.
The HACCP methodologies and formats for the determination of Control Points are often used to avoid un-necessary duplication.
Critical limits for each Critical Control Point must be specified and validated. It may occur that more than one critical limit is nominated at a particular step.
It is important with the determination and nomination of Critical Limits, that only measurable parameters are chosen. This is to ensure that the Critical Limits chosen can be documented as part of monitoring procedures, and that they can be measured at the Critical Control Point, against the nominated Critical Limit, which in turn verifies control of the identified significant hazard. Where non-measurable parameters are chosen, it is difficult to establish whether or not a Critical Control Point is actually under control.
When using numerical values to define limits of acceptability at a CCP, it is important to define the critical limits with an acceptability variant. This may include using symbols of wording which define limits of acceptability, for example:
This will ensure that the intended Critical Limits have a clear distinction between being acceptable and unacceptable.
A key part of the Food Fraud Reduction plan is to form appropriate controls or levels of action entirely based on the outcome of the vulnerability assessment. In the case of raw materials, it is important to request for certificates of analysis from suppliers to confirm the genuine and un-adulterated status of the materials being received. The tests or assessments involved must demonstrate the authenticity of the material. The receiving business may also conduct their own raw material testing to see whether the test results provided by the supplier match their own results. Supply chain audits, mass balance exercises, and enhanced supplier approval and risk assessment may also be scheduled and completed to ensure raw material authenticity as well as ensuring the quality of each delivered sample conforms to relevant specifications.
The HACCP methodologies and formats for the establishment of Critical Control Limits for Control Points are often used to avoid unnecessary duplication.
Monitoring is the scheduled observation or measurement of a CCP in relation to its critical limits. What, How, Where, When and Who should all be considered when developing the monitoring systems for CCP’s. The nominated monitoring procedures must be relevant in their ability to detect the loss of control at the CCP. Monitoring should ideally provide information that allows process control to prevent the violation of critical limits. Process adjustments must be made when monitoring indicates a potential loss of control at a CCP before a deviation occurs. All data collected through monitoring must be evaluated by a person who is adequately qualified knowledge and authority to initiate corrective actions when needed. The monitoring frequency, amount and continuity of monitoring must be sufficient to guarantee the CCP is under control. The monitoring of CCP’s will need to be done rapidly in most cases, as they most often relate to on-line processing, and don’t allow time for diagnostic testing. Physical and chemical measurements are often preferred to biological testing because they can be done quickly and can be indicative of microbiological control of the product. All documentation and records associated with monitoring must be signed by the person doing the monitoring, and then by those reviewing the system as elements of the verification process.
Monitoring is the on-going collection of information on a control measure at the step the control measure is applied. The information establishes that the measure is meeting or functioning within established limits. Monitoring activities are typically focused on real-time measurements and are generally focused on the performance of a specific control measure.
The HACCP methodologies and formats for the establishment of Monitoring requirements for Control Points are often used to avoid un-necessary duplication.
Corrective actions must be nominated for each CCP in the VACCP system to confront deviations when they occur. The corrective actions must ensure that the CCP has been controlled or brought back into controlled critical limits. All deviation and product character related procedures must be documented as part of VACCP record keeping.
Common motivators for Corrective Action applied within a food business at any given time include:
The HACCP methodologies and formats for Corrective Actions are often used to avoid unnecessary duplication.
Verification includes auditing and assessment, procedures and testing, sampling and analysis. Such techniques are important in determining whether or not the VACCP system is working correctly. The frequency of verification must be sufficient to validate that the HACCP system is working effectively. The verification process is commonly linked to the Continuous Improvement processes nominated within the food safety and quality management systems. Often a Verification Schedule format is developed and documented to define all the verification activities, including frequencies and the responsibilities.
Verification activities may include:
Verification procedures may include:
Verification should be conducted:
Verification record formats may include information on the presence and adequacy of:
The HACCP methodologies and formats for Verification and Validation Activities are often used to avoid unnecessary duplication.
Accurate and efficient record keeping is critical to the validity of any VACCP system. All VACCP documentation and record-keeping should be appropriate in its format, content, control and application to the nature of the food business for which it is constructed.
VACCP Documentation may include:
VACCP Records may include:
The HACCP methodologies and formats for Documentation and Record Keeping are often used to avoid unnecessary duplication.
If your food business supplies foodstuffs manufactured to a customer’s specifications, it is important to consider any specific Food Fraud Risk Management Development requirements in relation to their items.
Document: A document provides guidance and/or direction for performing work, making decisions, or rendering judgments which affect the safety or quality of the products or services that customers receive.
Documented policies, procedures, work instructions and schedules form the basis of any food safety and quality management system. The following documentation formats may be considered to ensure ongoing compliance with specified requirements for Food Fraud Risk Management:
If your food business supplies foodstuffs manufactured to a customer’s specifications, it is important to consider any specific Food Fraud Risk Management Documentation requirements in relation to their items.
You may wish to visit the Food Fraud Risk Management Templates section of haccp.com for examples of Food Fraud Risk Management documentation, record and resource formats commonly applied within food safety and quality systems.
Implementation: Implementation is the application of documented food safety and quality system elements into the actual business operation.
The implementation of Food Fraud Risk Management within any food business requires genuine commitment from senior management, staff and visitors to ensure the nominated goals of implementation are achievable on an ongoing basis. It is a step which requires significant planning and consideration of general and specific food business circumstances to ensure the outcomes of Food Fraud Risk Management do not negatively impact upon the safety and quality of the food items dispatched from the business.
Implementation of Food Fraud Risk Management must include the clear definition of responsibilities and authorities for all levels of participation by senior management, staff and visitors to the site.
When implementing Food Fraud Risk Management within a food safety and quality system, you may wish to consider the following requirements prior to completion:
If your food business supplies foodstuffs manufactured to a customer’s specifications, it is important to consider any specific Food Fraud Risk Management Implementation requirements in relation to their items.
Monitoring: Monitoring is the act of reviewing and confirming measurable parameters of a defined process or product status.
Monitoring requirements within food industry sectors are generally identified against limits of acceptability defined within Food Fraud Risk Management plans, implementation procedures and work instructions. Monitoring usually includes some element of record-keeping, which may be maintained manually or through digital systems. It is important to consider that advancements of technology have spawned many systems and processes which are self-monitored and or self-adjusted when variances are identified. Regardless of the system used; The goal of any monitoring activity is to provide sufficient evidence that any limit of acceptability has been met.
Food Fraud Risk Management monitoring requirements include manual recording and the application of corrective actions when the results of monitoring are found to be outside acceptable limits. Corrective Actions should also generally be strongly linked to the monitoring process where applied to ensure full traceability of the applied actions.
If your food business supplies foodstuffs manufactured to a customer’s specifications, it is important to consider any specific Food Fraud Risk Management Monitoring requirements in relation to their items.
You may wish to visit the Food Fraud Risk Management Templates section of haccp.com for examples of Food Fraud Risk Management documentation, record and resource formats commonly applied within food safety and quality systems.
Corrective Action: Corrective action is mandatory action to be taken when a deviation to the Quality System occurs, particularly in relation to a Critical Control Point.
Preventative Action: At any step in the process where a hazard has been identified, preventative action must be put into place to prevent re-occurrence.
Corrective Action and Preventative Action is implemented to ensure that any identified non-conformance issues are documented, investigated and rectified within appropriate time-frames. Corrective action is any action applied to regain control over a product, process, policy or procedure that has been identified as being non-conforming or outside nominated limits of acceptability. Preventative action is any action applied to prevent any identified non-conformance from reoccurring.
The outcomes of corrective and preventative actions should result in regained process control after effective application. Specified corrective actions are commonly linked to the Food Fraud Risk Management Plans and to the food business certification process.
Below are Corrective Action and Preventative Action examples which may be associated with Food Fraud Risk Management related non-conformance:
If your food business supplies foodstuffs manufactured to a customer’s specifications, it is important to consider any specific Food Fraud Risk Management Corrective Action requirements in relation to their items.
You may wish to visit the Corrective Action and Preventative Action section of haccp.com for examples of best practice applications for this food safety and quality system element.
Verification: The act of reviewing, inspecting, testing, checking, auditing, or otherwise establishing and documenting whether items, processes, services, or documents conform to specified requirements.
Verification is the detailed review of all food safety and quality system elements to confirm that they are effectively developed, documented, implemented, monitored and reviewed. It is important that all food safety and quality system elements, including documented policies, procedures, training, Food Fraud Risk Management plans and their operational applications are verified on an ongoing scheduled basis. The verification process commonly includes a defined schedule for which verification activities are required, how often they are conducted, who is responsible and detailed documented procedures for each nominated verification activity.
The general goal of an established verification process is to ensure any systemic non-conformance issues are identified and rectified within an appropriate time-frame. When non-conformance issues are identified through the verification process, Corrective Actions and Preventative Actions should be implemented to ensure they do not impact upon the effectiveness of the food safety and quality system.
The following examples of verification activities may be applicable to Food Fraud Risk Management:
If your food business supplies foodstuffs manufactured to a customer’s specifications, it is important to consider any specific Food Fraud Risk Management Verification requirements in relation to their items.
You may wish to visit the Verification Activities section of haccp.com for examples of best practice applications for this food safety and quality system element.
Validation: The process of gathering evidence to provide a scientific basis for the documented act of demonstrating that a procedure, process and activity will consistently lead to the expected results. It often includes the qualification of systems and equipment.
Validation is the provision of evidence to support the limits of control or acceptability for food safety or quality parameters nominated within systemic elements. Limits of control or acceptability are commonly included within documented food safety and quality system elements such as procedures, Food Fraud Risk Management plans and specifications.
Common sources of validation include regulatory and legislative standards, finished product specifications and customer requirements, industry codes of practice and guidelines, verified and validated research, historical product and process control outcomes and analytical testing.
The general goal of an established validation process is to ensure any systemic non-conformance issues are identified and rectified within an appropriate time-frame. When non-conformance issues are identified through the verification process, Corrective Actions and Preventative Actions should be implemented to ensure they do not impact upon the effectiveness of the food safety and quality system.
Validation activities are commonly defined within the verification schedules and procedures of established food safety and quality management systems.
The following examples may be applicable to validation of the limits of control or acceptability for Food Fraud Risk Management:
If your food business supplies foodstuffs manufactured to a customer’s specifications, it is important to consider any specific Food Fraud Risk Management Validation requirements in relation to their items.
You may wish to visit the Validation Activities section of haccp.com for examples of best practice applications for this food safety and quality system element.
Skills and Knowledge: Skills and knowledge are attributes of human interactions commonly linked to competency within any specified job related task.
Training and competency requirements for Food Fraud Risk Management must be ongoing, including regular scheduled reviews to ensure the effectiveness of training and competency outcomes.
Team members who have defined responsibilities regarding Food Fraud Risk Management should have knowledge including:
Team members who have defined responsibilities regarding Food Fraud Risk Management should have skills including:
Team members who have defined responsibilities regarding Food Fraud Risk Management should have access to resources including:
If your food business supplies foodstuffs manufactured to a customer’s specifications, it is important to consider any specific Food Fraud Risk Management Training, Competency and Resources requirements in relation to their items.
You may wish to visit the Training, Competency and Resources section of haccp.com for examples of best practice applications for this food safety and quality system element.
haccp.com was created to support food businesses and food industry professionals in achieving and maintaining the stringent requirements of food industry compliance.