Code of Practice VACCP

Transcription

1 Code of Practice VACCP

2 Contents Page No. 1. Introduction & Objective 2 2. Food Fraud Vulnerability Assessment 4 Page 2 of 8

3 1. INTRODUCTION & OBJECTIVE VACCP refers to Vulnerability, which is how exposed a company is to a particular risk. A vulnerability assessment is undertaken to identify potential weaknesses in the supply chain, it is aimed at assessing the supply chain for potential weaknesses and identifying high risk materials; VACCP specifically targets Food Fraud which is defined as:- The fraudulent and intentional substitution, dilution or addition to a product or raw material, or misrepresentation of a product or material, for the purpose of financial gain, by either increasing the value of the product or reducing the cost of its production. The key Food Fraud Hazards to be assessed are: Substitution Concealment Mislabelling Theft/Grey Market/Diversion Unapproved enhancements Counterfeiting Dilution Replacement of an ingredient with another, usually at a price advantage e.g. melamine in milk, horse meat. Not disclosing all information regarding a material such as country of origin, leading to an economic advantage e.g. cashews from India vs USA Labelling in a manner leading to an economic advantage e.g. Nutritional information incorrect, shelf life extended without verification. Unauthorised company selling into the food sector e.g. Unauthorised imports, selling/diverting waste streams into main stream production. Replacement of an ingredient with an unapproved material e.g. Sudan Red, GM Declaring a material as something it s not, leading to an economic advantage e.g. Organic products, Manuka honey. Reducing the percentage of an ingredient to gain an economic advantage e.g. % meat, % fruit juice E.G. Horsemeat in Beef example: Horsemeat is being delivered to your site instead of beef due to fraudulent activity in the supply chain: If the meat is delivered as a carcass, you are able to recognize it s not beef, so you are not vulnerable. Page 3 of 8

4 If the meat is delivered as a joint, you are less vulnerable as you can probably recognize the joint doesn t resemble a beef joint. If the meat is delivered minced or cubed, there is no easy visual identification as to what type of meat it is, so you are vulnerable. VACCP is not a food defense which is TACCP which is aimed to protect against malicious tampering to cause harm. Page 4 of 8

5 To help identify how the requirements must be met for each clause a P, R or O will be indicated under the columns headed PRO. These columns indicate whether the requirement is met through: P = Procedure. R = Record. O = Observation. - A documented procedure that has been fully implemented. - Documented and accurately completed records. - Compliance will be checked through observation. 2. Risk Assessment P R O Section No. Requirement Compliance (Y/N add comments) 2.1 The Supplier must carry out a Food Fraud Vulnerability Assessment: Step 1 Collect information from appropriate points along the supply chain and evaluate it to identify where there are significant vulnerabilities for food fraud. Step 2 Introduce appropriate control measures at the steps where there is vulnerability highlighted. These may include but are not limited to e.g. monitoring plans, product testing, origin verification, supplier audits and anti-counterfeit technologies. R 2.2 The Food Fraud Vulnerability assessment will be conducted by a multi disciplinary team. R 2.3 Review the Food Fraud Vulnerability assessment and improvement plans as a minimum annually. R 2.4 Review the Food Fraud Vulnerability assessment if new products, new processes or any other changes that may affect the Food Fraud Vulnerability assessment are introduced. Page 5 of 8

6 STEP 1 Collect information from appropriate points along the supply chain and evaluate it to identify where there are significant vulnerabilities for food fraud. R 2.5 Listing all Food Fraud Hazards: Information categories may include: Historic incidents Economic factors/price fluctuations Geographic origin Length & complexity of the supply chain Storage/Distribution Material value/market size Physical form of the material Emerging concerns Existing controls Availability Ease of access to materials 2.6 Conduct an assessment using the steps below Page 6 of 8

7 List of Materials Map Out Supply Chain Identify PotentialRisks Evaluate Risk Assess need for an Additional Control Record Findings Review at least Annually 2.7 From the review of the materials, material types & suppliers the Vulnerability Assessment Team need to decide the approach to be taken for the assessment e.g. by supplier, by raw material etc. starting with the highest risk areas. 2.8 Carry out the Risk Assessment taking into account the following: Likelihood of Occurrence with Supporting Evidence Likelihood of Detection with Supporting Evidence Likelihood of Profitability with Supporting Evidence For each of the relevant potential Food Fraud Hazards in section 2.5 this will then give an Individual Risk Rating with any Control Measures that are deemed necessary. Step 2 Introduce appropriate control measures at the steps where there is vulnerability highlighted. These may include but are not limited to e.g. monitoring plans, product testing, origin verification, supplier audits and anti-counterfeit technologies. 2.9 The outcome of the Food Fraud Vulnerability Assessment will identify areas of improvement which should be documented with who will carry out improvement and when the improvement is to be completed If further controls are required that will take some time, these actions should be planned, with timelines and responsibility clearly defined Page 7 of 8

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